OSHA Inspection: HUMANE MANUFACTURING COMPANY, LLC

Issued

Dec 3, 2021

Abate by

Jun 27, 2022

Penalty

Initial $9,557 · Current $6,630 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 explosion, deflagration, or other fire hazards while working around silo storage exhaust duct, unprotected dust collectors handling combustible dusts including rubber dust.  On or about June 04, 2021, employees manufacturing rubber mats were exposed to combustible dust explosion hazards, deflagration propagation hazards and hazardous byproducts while working with combustible materials in the Grind Area, the Baraboo Press Area and the 10 Press Area.  a) Employees working in the Grind Area were exposed to deflagration propagation hazards (exiting flame front through equipment openings/connections) in the event of an internal deflagration in the outdoor #3 and #4 silos.  The indoor grinding system ground shredded rubber into smaller particles. The smaller particles were blown from the final grinder into outdoor silos. The outdoor silos #3 and #4 had a duct that connected the silos together and another duct that returned into the building, exhausting air and particles from the silos into the Grind Area. The outdoor silos lacked means of deflagration propagation (isolation).   b) Employees working in the Grind Area were exposed to the hazardous byproducts of a fire (smoke, toxic gases, etc.) in the event of an internal fire in the outdoor silos. The outdoor #3 and #4 silos had a duct that connected the silos together and returned into the building, exhausting air and particles from the silos in to the Grind Area.  c) Employees onsite were exposed to explosion hazards (exiting pressure wave, flame front, vessel fragmentation from vessel overpressure) in the event of an internal deflagration in the outdoor silos.  d) Employees working in the Baraboo Press Area and Grind Area were exposed to explosion hazards (exiting pressure wave, flame front, vessel fragmentation from vessel overpressure) in the event of an internal deflagration in the Doral Corp air material separator.  The Baraboo Line is equipped with an indoor Doral Corp air material separator which was used to separate materials used to mix ground rubber to make rubber matting on the Baraboo press. The indoor Doral Corp Air Material Separator lacked means of explosion protection.  e) Employees working in the Baraboo Press Area and Grind Area were exposed to  deflagration propagation hazards (exiting flame front through equipment openings/connections), such as the mixers and material discharge hopper, in the event of an internal deflagration in the Doral Corp Air Material Separator.  The Baraboo Line is equipped with an indoor Doral Air Material Separator, which was used to separate materials used to mix ground rubber to make rubber matting on the Baraboo press. The indoor Doral Corp Air Material Separator lacked means to prevent deflagration propagation hazards.  f) The 10 Press indoor Hoffman vacuum cleaning system secondary bag separator was used to separate materials is a semi-closed loop system that was used to mix ground rubber to make rubber matting on the 10 press. The indoor Hoffman secondary bag separator lacked means of explosion protection and deflagration propagation (isolation), exposing employees in the 10 press area to explosion hazards (exiting pressure wave, flame front, vessel fragmentation from vessel overpressure) and employees in the Hoffman secondary bag separator and grind area 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) 654 "Standard Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids" 2020 edition: 9.3.2.3.3.1 where an explosion hazard exists, fixed bulk storage containers shall be protected in accordance with 9.7.1. 9.3.13.1.2.2 Where an explosion hazard exists, AMSs with a dirty-side volume of 8 ft3 (0.23 m3) or greater shall be protected in accordance with 9.7.1. 9.7.1.1 The design of explosion protection for equipment shall incorporate one or more of the following methods of protection: 9.7.2.1* Where an explosion hazard exists, isolation devices propagation connected equipment and/or work areas in accordance with NFPA 69. Chapter 7 (Dust Hazard Analysis, DHA),  NFPA 69 "Standard on Explosion Prevention Systems 2019 ed."and  NFPA 68 "Standard on Explosion Protection by Deflagration Venting, 2018 ed." a deflagration detection and chemical suppression system.  Instance a, b, c) Silo bulk storage: (1) Provide a means of deflagration propagation protection (isolation) to protect against deflagration propagation to the grind area through silo exhaust ducting in accordance with NFPA 69.   Instance d), Baraboo Line indoor Doral Corp air material separator: 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.   Instance e) Baraboo Line indoor Doral Corp air material separator: Provide a means of deflagration propagation protection (isolation) to protect against deflagration propagation to the Baraboo line mixers and cyclones. 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. An example of a passive isolative device that will work in this location is a specially designed rotary air lock. An example of an active isolation device that will work in this location is a deflagration detection and chemical suppression system.   Instance f) The 10 Press indoor Hoffman vacuum cleaning system secondary bag separator: (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 10 Press line mixers and cyclones. 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. An example of a passive isolative device that will work in this location is a specially designed rotary air lock. An example of an active isolation device that will work in this location is a deflagration detection and chemical suppression system.

Issued

Dec 3, 2021

Abate by

Feb 15, 2022

Penalty

Initial $9,557 · Current $5,735 Reduced

Hazardous substances M102

General-duty citation text

29 CFR  1910.1200(h)(3)(ii):Employee training did not include the physical and health hazards of the chemicals in the work area:  On or about June 07, 2021 employees working on the 10 Press and Baraboo line were not trained on the combustible nature of rubber dust.