OSHA Inspection: MIDOR LTD., LLC

Issued

Apr 25, 2025

Abate by

Aug 2, 2027

Penalty

Initial $4,729 · Current $3,015 Reduced

Hazardous substances E200M102

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 likely to cause death or serious physical harm to employees in that employees were exposed to combustible agricultural particulate solids dust explosion, deflagration, and fire hazards  associated within indoor dust collectors handing combustible agricultural powders:  On or about November 7, 2024, employees were exposed to combustible particulate solids explosion, deflagration, and fire hazards associated with the indoor dust collectors.  The indoor dry-type dust collectors were used to collect combustible dust from upstream filling, transfer, dumping, pulverizing, and mixing equipment.  The dust collectors were operated in a manner that presented combustible particulate solids deflagration and explosion hazards in that fuel, oxygen, suspension, containment, and ignition sources were all capable of being present at the same time within the systems.  The dust collectors were also operated in a manner that presented combustible particulate solids fire hazards in that fuel, oxygen, and ignition sources were all capable of being present at the same time within the systems.    a) The Front Production indoor dust collector (make and model unknown) collected dust from a bag filling station in the Front Production Area and a Pulverizer machine in the 21 Area. The indoor dust collector exposed employees in the area 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 and lacked means of explosion protection and deflagration propagation (isolation).  In addition, the indoor dust collector returned exhausted air indoors near the Front Production Area, exposing employees in the area to the hazardous byproducts of a fire (smoke, toxic gases, etc.) in the event of an internal fire.  b) The Mikro-D indoor dust collector (model unknown) collected dust from mixer loading operations in the 21 Area. The indoor dust collector exposed employees in the area 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 and lacked means of explosion protection and deflagration propagation (isolation). In addition, the indoor dust collector returned exhausted air back into the 21 Area exposing employees in the area to the hazardous byproducts of a fire (smoke, toxic gases, etc.) in the event of an internal fire.  c) The "Big Blue" Donaldson indoor dust collector (model 172268) collected dust from the dumping station and ribbon mixers in the 45 Area. The indoor dust collector exposed employees in the area 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 and lacked means of explosion protection and deflagration propagation (isolation). In addition, the indoor Donaldson dust collector returned exhausted air back into the 45 Area exposing employees in the area to the hazardous byproducts of a fire (smoke, toxic gases, etc.) in the event of an internal fire.  Among other methods, a 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 9.3.4.2.1 (Permitted Indoor Dust Collector Practices, Protection), 9.7.3.1 (Equipment Protection Requirements), 9.7.4 (Equipment Isolation Requirements), 9.3.5.2.1 (Dust Collector Filtered Air Requirements), 9.3.3.6 (Duct Systems), 9.3.1 (Risk Assessment in Equipment Design), and Chapter 7 (Dust Hazard Analysis, DHA).  As of December 6, 2024, NFPA 61 was absorbed into a new comprehensive NFPA combustible dust standard, NFPA 660 "Standard for Combustible Dusts and Particulate Solids".  See chapter 21 "Agricultural and Food Processing" of NFPA 660, 2025 ed.  Specifically: (1) Prioritize the location of a dust collector or dust collectors at a safe outdoor location;  (2) Provide means of explosion protection on dust collectors in accordance with NFPA 68 "Standard on Explosion Protection by Deflagration Venting." An example of a means of explosion protection is explosion venting to an outdoor restricted, safe area;  (3) Provide means of deflagration propagation protection (isolation) on dust collectors to protect against deflagration propagation to upstream equipment and work areas via the dirty air inlet ducting in accordance with NFPA 69 "Standard Explosion Prevention Systems".  An example of a e passive isolation device that works in accordance with a dust collector protected by explosion venting is a flow-actuated flap valve.;  (4) Provide means of deflagration propagation (isolation) on dust collectors 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 isolation device for this location is a rotary valve designed with criteria to provide flame quenching through close-clearance vanes.;  (5) Provide means of deflagration propagation protection (isolation) on dust collectors to protect against deflagration propagation to the interior of the building in accordance with NFPA 69.  An example of a passive isolation device. Isolation is not normally needed for dust collectors exhausting filtered air to a safe, outdoor location.;  (6) Ensure that exhaust-air ducting terminates at an outdoor location and away from return air inlets.  Alternatively, returning the dust collector's exhausted air into the building is possible provided that provisions are incorporated to prevent transmission of smoke and toxic gases back into the building through technologies such as fire detection and abort/extinguishment system.;  (7) Ensure that ductwork is constructed of metal and is bonded and grounded.  Flexible hose should only be utilized where there is justification for short connection lengths and should be made of static dissipative materials and bonded.

Issued

Apr 25, 2025

Abate by

Jun 2, 2025

Penalty

Initial $4,729 · Current $3,015 Reduced

General-duty citation text

29 CFR 1910.22(a)(1): The employer did not ensure that all places of employment, passageways, storerooms, service rooms, and walking-working surfaces are kept in a clean, orderly, and sanitary condition.  On or about November 7, 2024, the employer did not ensure that the 45 Area was kept in a clean, orderly, and sanitary condition in that there was a significant accumulation of combustible agricultural powder present, presenting fire hazards to the building occupants.

Issued

Apr 25, 2025

Abate by

Jul 1, 2025

Penalty

Initial $6,620 · Current $3,015 Reduced

Hazardous substances E200M102

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 November 7, 2024, employees across the facility were not trained on the physical, health, and combustible dust hazards of the chemicals in the work area, including but not limited to Hubercarb Q6 and combustible dust.