OSHA Inspection: RAVAGO AMERICAS LLC

Issued

Sep 5, 2018

Abate by

Oct 23, 2018

Penalty

Initial $7,068 · Current $4,948 Reduced

Hazardous substances E200

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 were causing or likely to cause death or serious physical harm to employees exposed to combustible plastic fines/dust explosion and deflagration (flame front) propagation hazards associated with an outdoor dust collection system.  The unprotected dust collector was located in an area for which there was direct employee exposure and was also connected to upstream processes without means to prevent flame front propagation back into the work area via the dirty air inlet ducting.   (a) On or about April 25, 2018, in and near the production area, the outdoor Pacific Engineering Systems dust collector located along the West side of the building in the West parking lot was used for collecting combustible fines/dust associated with the transfer of polystyrene and polyethylene pellets and granules.  The collector 1)  lacked means of explosion protection  and 2) lacked means of deflagration propagation protection (isolation) for the upstream processes and the area below the unit's material discharge hopper.     Among other methods, feasible and acceptable means of abatement include following the guidance contained in National Fire Protection Association (NFPA) Standard 654 "Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2017 ed."  Sections 7.1.4.1 (explosion protection design), 7.1.6.1 (isolation of equipment and work areas) and 7.13.1.2.2 (AMS protection).