OSHA Inspection: CLEAN AIR FILTERS, INC.

Issued

Jun 11, 2019

Abate by

Dec 1, 2019

Penalty

Initial $3,978 · Current $2,785 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  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 in that employees were exposed to combustible dust deflagration, explosion, and other fire hazards while working at or near two cartridge filter cleaning cabinets and associated downstream dust collection vessels which were not designed and installed to prevent or minimize employee exposure:      (a)        On or about January 9, 2019, the indoor Horizontal Cleaning Machine was used to clean cartridge filters containing combustible dusts in a manner that exposed employees to combustible dust deflagration and explosion hazards such as exposure to exiting flame front(s), propagating flame front(s), pressure wave(s), and/or vessel fragmentation in the event of an internal deflagration event.  The machine lacked: 1) a means of explosion protection & 2) means of deflagration propagation protection for the upstream, indoor cleaning cabinet/associated cyclone and for the downstream, outdoor dust collector.      (b)        On or about January 9, 2019, the indoor Sonic Dry Clean Machine (model SDC-5) was used to clean cartridge filters containing combustible dusts in a manner that exposed employees to combustible dust deflagration and explosion hazards such as exposure to exiting flame front(s), propagating flame front(s), pressure wave(s), and/or vessel fragmentation in the event of an internal deflagration event.  The machine lacked: 1) a means of explosion protection; 2) a means of deflagration propagation protection for the downstream, indoor cyclone; & 3) conductive or static dissipative duct construction to ensure bonding/grounding.      (c)        On or about January 9, 2019, the indoor cyclone was used to separate and collect combustible dust particulate from the upstream Sonic Dry Clean Machine in a manner that exposed employees to combustible dust deflagration and explosion hazards such as exposure to exiting flame front(s), propagating flame front(s), pressure wave(s), and/or vessel fragmentation in the event of an internal cyclone deflagration event.  The cyclone lacked: 1) a means of explosion protection; 2) means of deflagration propagation protection for the downstream, indoor cleaning cabinet and outdoor dust collector and for the upstream, cleaning cabinet; & 3) conductive or static dissipative duct construction to ensure appropriate bonding/grounding.      (d)        On or about January 9, 2019, the outdoor CP Environmental Filters dust collector was used to collect combustible dust from the upstream, indoor cartridge filter cleaning processes in a manner that exposed employees to combustible dust deflagration and explosion hazards such as exposure to exiting flame front(s), propagating flame front(s), pressure wave(s), and/or vessel fragmentation in the event of an internal dust collector deflagration event. The outdoor dust collector also exposed employees to the hazardous byproducts of a fire (i.e. smoke or toxic gases) in the event of an internal dust collector fire event. The dust collector lacked: 1) a means of explosion protection; 2) a means of deflagration propagation protection for the upstream, indoor cleaning cabinets, and for the return air ducting; & 3) means to prevent the transmission of the hazardous byproducts of a fire back into the facility through the return air ducting.      Among other means, feasible and acceptable means of abatement are outlined in the National Fire Protection Association (NFPA) standards such as, but not limited to:      NFPA Standard 652 ?Standard on the Fundamentals of Combustible Dust, 2019 ed.? ? Sections 7.1 (dust hazards analysis), 9.4.7.1.4 (flexible connectors), 9.7.3 (equipment protection and methods), 9.7.4 (equipment isolation), 9.3.4.3 (clean air exhaust), etc.      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 4.2 (dust hazards analysis), 7.1.4 (equipment protection methods), 7.1.6 (isolation of equipment and work areas), 7.6 (duct construction), 7.13.1.2 (dust collector protection), 7.13.1.4 (dust collector isolation), 7.13.1.6 (exhaust air), 9.3.2 (conductivity of components), etc.      The cartridge filter cleaning process and associated dust collection system should be redesigned in accordance with industry consensus methods to protect employees from associated combustible dust deflagration, explosion, and fire hazards.  Considerations should be made based on a detailed dust hazards analysis (DHA). DHAs are systematic reviews to identify and evaluate potential fire, flash fire, or explosion hazards associated with the presence of one or more combustible particulate solids in a process or facility. The design of protective systems should be based on the parameters of the most hazardous/reactive dust(s) processed within the system.       Outdoor dust collector protection      One common means of explosion protection for outdoor dust collectors is deflagration venting to a safe, outdoor location in accordance with NFPA 68 ?Standard on Explosion Protection by Deflagration Venting?.  One common means of deflagration propagation protection (isolation) for the dirty air ducting on a vented dust collector is a flow-actuated flap valve in accordance with NFPA 69 ?Standard on Explosion Prevention Systems?.  Prohibiting the return of clean air exhaust from the final dust collector into the building is one method of protecting internal building occupants from the hazardous byproducts of an internal dust collector fire as well as a method of protecting internal building occupants from deflagration propagation through the return air ducting from an internal dust collector deflagration.  If air must be returned into the building, other fire protection methods (i.e. spark/ember detection and abort gate) and deflagration propagation protection methods (i.e. passive or active isolation devices) should be utilized to protect building occupants.      Indoor cleaning cabinet protection      Determine the most feasible method of explosion protection system to protect the equipment from the effects of an internal deflagration such as, but not limited to, deflagration to a safe, outdoor location or in a safe manner and in accordance with NFPA 68.  Connections between the cabinets and other equipment can be isolated from deflagration propagation hazards through the use of commonly utilized active isolation devices such as deflagration detection and chemical suppression systems in accordance with NFPA 69.      Indoor cyclone protection      One common means of providing both explosion protection and deflagration propagation protection (isolation) for an indoor cyclone is through the use of a deflagration detection and chemical suppression system in accordance with NFPA 69.      Ventilation system design      All duct systems should be designed to achieve efficient particle flow and avoid material settling in the ducts.  Ventilation systems should be designed, balanced, tested, and maintained to ensure that duct velocities are suitable to prevent dust settling.  Poor design factors such as ducting dead ends, abrupt size transitions, aggressive transition angles, etc. should be eliminated.  Flexible ducting should be avoided unless where determined necessary for system operation.  Flexible ducting (where justified as necessary) should be made of conductive or static dissipative materials, bonded and grounded appropriately, and kept to the shortest length necessary.      Bonding and grounding    All system components must be bonded and grounded. Bonding controls static electric hazards when connecting two or more conductive objects by means of a conductor so they are the same electrical potential. Grounding of the conductive objects to the ground ensures that all objects are at zero electrical potential.       Alternative process considerations      Consider alternative cleaning processes that do not generate dense clouds of combustible dusts.  Water wash methods may be one alternative for consideration provided that a detailed DHA determines it to be a safe approach for the materials being processed (i.e. provided that water reactive materials are not accepted for processing and that there is a screening process in place for water reactive materials prior to processing).

Issued

May 31, 2019

Penalty

Initial $2,842 · Current $1,990 Reduced

General-duty citation text

29 CFR 1904.39(a)(2): The employer did not report within 24-hours a work-related incident resulting in in-patient hospitalization, amputation or the loss of an eye:    On or about December 7, 2018, an employee received a work-related injury which resulted in an in-patient hospitalization and the employer did not report the incident.