OSHA Inspection: AMERICAN ROLLER COMPANY, LLC

Issued

Apr 18, 2019

Abate by

May 14, 2019

Penalty

Initial $7,104 · Current $7,104

General-duty citation text

29 CFR 1910.39(c)(1) A fire prevention plan must include a list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard.     (a)    On or about October 22, 2018,  the employer did not have a fire prevention plan, as required by the subpart, that addressed the combustible dust hazards in the Roller Stripping Room of the Wisconsin Roller Plan.  (b)    On or October 22, 2018 in the Roller Stripping Room of the Wisconsin Roller Plant at the American Roller Company, LLC. Campus, a Cincinnati dry-type two-stage dust collection system (consisting of non-conductive flexible ducting, a primary collection drum, a fan/blower, and a secondary enclosureless filter) was located indoors and used to collect combustible metal and roller coatings dusts.  The indoor dust collection system was connected to an upstream sanding process for short roll stripping that frequently produced sparks/embers.  The indoor dust collection system exposed employees to fire hazards including exposure to the hazardous byproducts of a fire (i.e. flame, smoke, toxic gases, etc.), exposure to the hazards of a deflagration (i.e. expanding flame front), and exposure to the hazards of an explosion (i.e. expanding flame front, pressure wave, vessel fragmentation, etc.).  Among other methods, feasible means of abatement include following the applicable guidance in National Fire Protection Association (NFPA) Standards 484 Standard for Combustible Metals and 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids.  Since metal dust is collected in the collector, appropriate Sections of NFPA 484 (2019) include, but are not limited to:  11.2.4.4.11.2 (explosion protection and deflagration isolation methods), 11.2.4.4.13 (clean air exhaust requirements), 11.2.4.4 (requirements for dry-type dust collectors), 11.2.4.4.17 (hot particle generation process controls), 10.6.2 (fan and blower construction), 11.2.4.3 (duct construction), and 11.2.3 (general requirements). NFPA 654 contains similar guidance and could also be consulted where appropriate.