OSHA Inspection: SENSORY EFFECTS POWDER SYSTEMS, INC.

Issued

Jun 11, 2021

Abate by

Dec 30, 2021

Penalty

Initial $9,753 · Current $6,827 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 were causing or were likely to cause death or serious physical harm to employees in that employees were exposed to combustible dust explosion, deflagration, or other fire hazards while working inside a building with an indoor, unprotected dust collector.  The indoor dust collector collected combustible food product dust without a means of explosion protection to prevent a hazardous overpressure from an internal deflagration and without a means of deflagration propagation protection (isolation) to prevent the spread of a flame front outside of the dust collector and to the upstream packaging process.  On or about January 7, 20201, employees packaging product and employees operating the spray dryer were exposed to combustible dust explosion and deflagration propagation hazards associated with the indoor Damrow dry-type dust collector located in a room next to the spray dryer and above the packaging area.  The indoor dust collector was used to collect combustible food product dusts from the packaging process/area and lacked means of explosion protection and deflagration propagation protection (isolation).  Among other methods, one feasible method to correct the hazards would be to follow the guidance in the National Fire Protection Association's (NFPA) Standard 61 "Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2020 ed." - Sections 9.3.4.2 (Dust Collector Location), 9.3.4.2.1 (Permitted Indoor Dust Collector Practices),  9.7.3.1 (Equipment Protection), 9.7.4 (Equipment Isolation), 9.3.21.1.5 (Screw Conveyor Safety Controls),  9.3.1 (Risk  Assessment), and  7.1 (Dust Hazard Analysis [DHA]  General Requirements) through 7.3 (Dust Hazard Analysis [DHA] - Material Evaluation).  Specifically -   (1)	Provide the indoor dust collector with a means of explosion protection such as safe deflagration venting in accordance with the requirements of NFPA Standard 68 "Standard on Explosion Protection by Deflagration Venting" or an explosion suppression system designed according to NFPA Standard 69 "Standard on Explosion Prevention Systems";  -and-  (2)	Provide a method of deflagration propagation protection (isolation) between the dust collector's dirty air inlet and the upstream packaging operation in accordance with NFPA 69.  An example of a passive isolation device that may work in this location with a vented dust collector is a flow actuated flap valve installed and maintained in accordance with NFPA 69.  An example of an active isolation device that may work in this location with a dust collector protected with a an explosion suppression system is a deflagration detection and chemical suppression device installed for purposes of equipment isolation; - and -   (3)	Provide a method of deflagration propagation protection (isolation) between the dust collector's material discharge hopper outlet and the room in accordance with NFPA 69.  An example of a passive isolation device that may work in this location with a vented dust collector is a rotary valve designed and listed as a deflagration isolation device.  An example of an active isolation device that may work in this location with a dust collector protected with a an explosion suppression system is a deflagration detection and chemical suppression device installed for purposes of equipment isolation; - and-  (4)	Provide the screw conveyors feeding the packaging process with controls allowing for the conveyors to relieve or stop if the discharge end becomes plugged.