OSHA Inspection: ALL COLOR POWDER COATING, INC.

Issued

Feb 2, 2018

Abate by

Oct 31, 2018

Penalty

Initial $5,497 · Current $3,848 Reduced

Hazardous substances M102

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1):  The employer did not furnish employment and a place of employment which were free from recognized hazards that caused or were likely to cause death or serious physical harm in that employees were exposed to combustible dust explosion/deflagration hazards presented by two indoor dust collection systems, consisting of upstream primary cyclone filters and downstream filter media dust collectors, handling combustible powder coating paint dust that were installed and operated in a manner that exposed employees to several hazardous outcomes in the event of an internal deflagration:    On or about August 29, 2017 employees  were exposed to the following conditions:    a) Powder Paint Line 1 had an indoor cartridge media dust collector and upstream cyclone that were used to collect combustible powder coating paint dust from the associated powder paint booth.    (i) The dust collector and cyclone both contained explosion venting that terminated indoors.  This exposed employees to explosion products hazards (i.e. flame front, pressure wave, projectile building components, unburned product dust cloud, etc.) that could result in severe burns, trauma, and/or death in the event of an explosion.    (ii) The cyclone and dust collector lacked deflagration (flame front) propagation protection (isolation) for the following connections:  The dirty air inlets and the clean air outlets..  This exposed employees to propagating flame front hazards that could result in severe burns and/or death in the event of an internal deflagration propagating through unprotected vessel connections/openings.    b)  Powder Paint Line 2 had  an indoor cartridge media dust collector and a upstream cyclone that were used to collect combustible powder coating paint dust from the associated powder paint booth.    (i) The dust collector and cyclone both contained explosion venting that terminated indoors.  This exposed employees to explosion products hazards (i.e. flame front, pressure wave, projectile building components, unburned product dust cloud, etc.) that could result in severe burns, trauma, and/or death in the event of an explosion.    (ii) The cyclone and dust collector lacked deflagration (flame front) propagation protection (isolation) for the following connections:  The dirty air inlets and the clean air outlets.   This exposed employees to propagating flame front hazards that could result in severe burns and/or death in the event of an internal deflagration propagating through unprotected vessel connections/openings.    Among other methods, feasible methods to correct these hazards would be to follow the provisions found in the  following National Fire Protection Association (NFPA) standards:     NFPA 33 ?Standard for Spray Application Using Flammable or Combustible Materials, 2016 edition? - Section 15.8.3, (deflagration venting in accordance with NFPA 68).NFPA 652 ?Standard on the Fundamentals of Combustible Dust, 2016 edition? -Sections 8.9.4 (equipment isolation) and 8.9.3.2 (deflagration venting in accordance with NFPA 68).    NFPA 654 ?Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Dust Particulate Solids 2017 edition? - Sections 7.1.4.1 (deflagration venting in accordance with NFPA 68), and 7.1.6.1 (equipment and upstream work area isolation)    NFPA 68 ?Standard on Explosion Protection by Deflagration Venting, 2013 edition? ? Sections 5.2.3, 6.6.1, and 8.9 (measures to reduce risk to personnel from the effects of fireball temperature and pressure).    NFPA 69 ?Standard on Explosion Prevention Systems, 2014 edition? - Chapter 11 (deflagration control by active isolation) and Chapter 12 (deflagration control by passive isolation).    Specifically, these options include (but are not limited to) the following:     (1)   For explosion/deflagration vents on the system enclosures which vent directly indoors:  Provide deflagration venting through listed flame-arresting  and dust retention devices in accordance with NFPA 68 ? OR - consider utilizing vent ducts to direct vented material from the enclosures to safe, outdoor locations in accordance with NFPA 68.    (2)   For the lack of deflagration propagation protection (isolation) on the incoming (dirty air) inlets of the system enclosures:  Provide isolation between the cyclone and the upstream process and between the dust collector and the cyclone in accordance with NFPA 69*.      (3)   For the lack of deflagration propagation protection (isolation) on the return air exhaust (clean air) outlets of the system enclosures:  Provide isolation between the cyclone and the dust collector and between dust collector and the return air exhaust outlet in accordance with NFPA 69*.  Alternatively, for the clean air outlet of the dust collector, ensure that the exhaust air is ducted to a safe, outdoor location and away from any return air inlets.    *Examples of passive isolation devices are flow-actuated flap valves, passive float valves, and flame front diverters.  Examples example of active isolation devices include fast-acting mechanical valves, actuated pinch valves, and chemical suppression barriers.   Abatement certification and documentation are required for this item. Abatement Schedule  STEP 1 -A combination of administrative controls shall be implemented as an interim protective measure until feasible engineering and administrative controls can be permanently implemented.  STEP 2 -A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposures to the hazardous condition as referenced in this citation. This plan shall include, at a minimum, target dates for the following actions which must be consistent with the abatement dates required by this citation: (1)Evaluation of engineering/administrative control options; (2)Selection of optimum control methods and completion of design; (3)Procurement, installation and operation of selected control measures; (4)Testing and acceptance or modification/redesign of controls; All proposed control measures shall be approved for each particular use by a competent certified safety professional, professional engineer, or other technically qualified person. STEP 3 -Abatement shall have been completed by the implementation of feasible engineering and administrative controls upon verification of their effectiveness in achieving compliance. Date by Which Violation Must be Abated:  STEP 1 30 Days by Which Violation Must be Abated:  STEP 2 60 Days by Which Violation Must be Abated:  STEP 3 90Days.