OSHA Inspection: KUA CANDY LLC

Issued

2021-09-09 00:00:00

Abate by

2022-05-16 00:00:00

Penalty

Initial $12288.00 · Current $9216.00 Reduced

Hazardous substances M102

General-duty citation text

Alleged Violation Description	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 explosion, deflagration, or other fire hazards while working around unprotected dust collectors handling combustible dusts including powdered sugar, malic acid, and cornstarch.   On or about March 11, 2021, employees manufacturing candy were exposed to combustible dust explosion and deflagration propagation hazards associated with the indoor Tumbler dust collector, indoor NID Vortex dryer integrated dust collector, indoor NID Vortex cooler integrated dust collector, indoor Farr dust collector, and the outdoor Farr dust collector.   a)  The indoor Tumbler dust collector (Torit & Day) collected fugitive dust emissions from the upstream candy tumbling process. The indoor Tumbler dust collector lacked means of explosion protection and deflagration propagation (isolation), exposing employees in the Tumbler room to explosion hazards (exiting pressure wave, flame front, vessel fragmentation from vessel overpressure) and deflagration propagation hazards (exiting flame front through equipment openings/connections) in the event of an internal deflagration.  The system had part of a Fike deflagration detection and suppression system that was not functional.  In addition, the indoor Tumbler dust collector returned exhausted air back into the Tumbler room exposing employees in the Tumbler room to the hazardous byproducts of a fire (smoke, toxic gases, etc.) in the event of an internal fire.  b)  The integrated NID Vortex dryer unit dust collector collected fugitive dust emissions from the NID Vortex dryer.  The integrated NID Vortex Dryer unit dust collector contained deflagration/explosion venting that terminated indoors, exposing employees in the Vortex room and nearby building compartments to deflagration hazards (intentionally discharged flame front from the vessel) and secondary explosion hazards (building explosion due to the pressure from ignition of secondary fuel sources) in the event of an internal deflagration.  The dryer/dust collector system also lacked means of deflagration propagation (isolation) exposing employees in the Vortex and NID Mogul candy processing rooms to deflagration propagation hazards (exiting flame front through equipment openings/connections) in the event of an internal deflagration.   c)  The integrated NID Vortex cooler unit dust collector collected fugitive dust emissions from the NID Vortex cooler.  The integrated NID Vortex cooler unit dust collector contained deflagration/explosion venting that terminated indoors, exposing employees in the Vortex room and nearby building compartments to deflagration hazards (intentionally discharged flame front from the vessel) and secondary explosion hazards (building explosion due to the pressure from ignition of secondary fuel sources) in the event of an internal deflagration.  The dryer/dust collector system also lacked means of deflagration propagation (isolation) exposing employees in the Vortex and NID Mogul candy processing rooms to deflagration propagation hazards (exiting flame front through equipment openings/connections) in the event of an internal deflagration.   d)  The outdoor Farr dust collector collected fugitive dust emissions from the upstream NID Vortex dryer unit dust collector and NID Vortex cooler unit dust collector.  The outdoor Farr dust collector lacked means of explosion protection and deflagration propagation (isolation), exposing employees working near the running dust collector to explosion hazards (exiting pressure wave, flame front, vessel fragmentation from vessel overpressure) and employees working near the running dust collector and employees in the Vortex room to deflagration propagation hazards (exiting flame front through equipment openings/connections) in the event of an internal deflagration.  e) The indoor Farr dust collector collected fugitive dust from the upstream NID Mogul candy making system. The indoor Farr dust collector lacked means of explosion protection and deflagration propagation (isolation), exposing employees in the Vortex room to explosion hazards (exiting pressure wave, flame front, vessel fragmentation from vessel overpressure) and employees in the Vortex and NID Mogul candy processing rooms to deflagration propagation hazards (exiting flame front through equipment openings/connections) in the event of an internal deflagration.  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 Requirements), 9.7.4 (Equipment Isolation), 9.3.5 (Recycle of AMS Clean Air Exhaust),  9.3.1 (Risk Assessment in Equipment Design), and Chapter 7 (Dust Hazard Analysis, DHA) & NFPA 68 "Standard on Explosion Protection by Deflagration Venting, 2018 ed." - Sections 4.2.1.3, 5.2.3.3, 6.6.1, 6.6.2, 8.9 (Warnings about Venting Indoors or to Unsafe Locations): Specifically - Instance A, Indoor Tumbler dust collector: (1) Provide the unit with a means of explosion protection such as a functioning deflagration detection and chemical deflagration suppression system in accordance with NFPA 69 "Standard on Explosion Prevention Systems" or indoor deflagration venting through a listed dust retention and flame-arresting device in accordance with NFPA 68 "Standard on Explosion Protection By Deflagration Venting."  (2) Provide a means of deflagration propagation protection (isolation) to protect against deflagration propagation to the tumblers through the dirty air inlet ducting in accordance with NFPA 69.  (3) Provide a means of deflagration propagation (isolation) to protect against deflagration propagation to the room through the unit's material discharge hopper opening in accordance with NFPA 69.  (4) Provide a means of deflagration propagation protection (isolation) to protect against deflagration propagation to the room through the unit's return air exhaust ducting in accordance with NFPA 69.  An example of an active isolation device that will work in all three above locations is a deflagration detection and chemical suppression system.  (5) Provide a means of preventing the transmission of the hazardous byproducts of a fire into the room through the unit's return air exhaust ducting.  If choosing to return air into the building, an example of devices that will work in this location is a spark detection and high-speed abort gate to temporarily duct air outdoors during an upset condition or a spark detection and interlock system to detect an upset fire condition and disengage the unit's fan and upstream dust producing equipment. Instances B and C, Integrated  NID Vortex dryer/cooler dust collectors:  (1) If choosing to keep explosion venting as the method of explosion protection, provide the units with deflagration venting incorporating listed flame-arresting and particulate retention devices to allow safe indoor venting.  An alternative may include decommissioning the existing explosion vents and installing deflagration detection and chemical suppression systems for explosion protection.  (2) Provide a means of deflagration propagation protection (isolation) to protect against deflagration propagation to connected equipment/processes in accordance with NFPA 69.  An example of an active isolation device that will likely work on this equipment is a deflagration detection and chemical suppression system. Instance D, Outdoor Farr dust collector:  (1) Provide the unit with a means of explosion protection such as a deflagration detection and chemical deflagration suppression system in accordance with NFPA 69 or deflagration venting to a safe outdoor location in accordance with NFPA 68.  (2) Provide a means of deflagration propagation protection (isolation) to protect against deflagration propagation to the tumblers through the dirty air inlet ducting in accordance with NFPA 69.  An example of a passive isolation device that will work in this location on a dust collector protected by deflagration venting is a flow-actuated flap valve.  An example of an active isolation device that will work in this location is a deflagration detection and chemical suppression system. (3) Provide a means of deflagration propagation (isolation) to protect against deflagration propagation to the building through the unit's material discharge hopper opening in accordance with NFPA 69. An example of an active isolation device that will work in this location is a deflagration detection and chemical suppression system. Instance E, Indoor Farr dust collector:  (1) Provide the unit with a means of explosion protection such as a deflagration detection and chemical deflagration suppression system in accordance with NFPA 69 or deflagration venting to a safe outdoor location (or indoor deflagration venting through a listed flame-arresting and dust retention device) in accordance with NFPA 68.  (2) Provide a means of deflagration propagation protection (isolation) to protect against deflagration propagation to the NID Mogul candy processing room. An example of a passive isolation device that will work in this location on a dust collector protected by deflagration venting is a flow-actuated flap valve.  An example of an active isolation device that will work in this location is a deflagration detection and chemical suppression system. (3) Provide a means of deflagration propagation (isolation) to protect against deflagration propagation to the room through the unit's material discharge hopper opening in accordance with NFPA 69.

Issued

2021-09-09 00:00:00

Penalty

Initial $12288.00 · Current $5599.00 Reduced

Hazardous substances M102

General-duty citation text

29 CFR  1910.22(a)(1):(1) All places of employment, passageways, storerooms, service rooms, and walking-working surfaces are kept in a clean, orderly, and sanitary condition.  On or about March 11, 2021 the Vortex room high horizontals surfaces had excessive accumulations of combustible dust, such as cornstarch.

Issued

2021-09-09 00:00:00

Penalty

Initial $12288.00 · Current $5599.00 Reduced

General-duty citation text

29 CFR  1910.212(a)(1):One or more methods of machine guarding was not provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips: On or about March 11, 2021 in the Tumbler room there were two belts that were not guarded: a.  The tumbler rear feed belt b.  The tumbler front takeout metal lace belt