Text For Citation: 01 Item/Group: 001 Hazard:

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 titanium and titanium alloy components metal dust flash fire hazards when manually removing and handling dry type media air-material separator filters associated with vacuum recirculation pumps on the weld boxes in Melt Shop #1: (a) On or about May 21, 2019 in Melt Shop #1, employees manually removed and handled dry type media air-material separator filters containing dry, combustible titanium and titanium alloy components fines from the vacuum recirculation pump housings on weld boxes such as, but not limited to, weld box #1. The manual handling of the dry filters exposed employees to burn hazards from recognized flash fire mechanisms associated with combustible titanium and titanium alloy components dust. Among other methods, one feasible means of abatement that eliminates the interaction of the operator with dry metal fines during the servicing and maintenance of the system is to utilize a wet air-material separator in accordance with the guidance in Arconics Safety Data Sheet (SDS) for Titanium Alloys with Vanadium #341 - Section 7: Handling and Storage, Subsection 7.3 Requirements for Processes which Generate Dusts or Fines: Operations producing dust should be equipped with a dust collection system discharging into a water-type dust collector (note: similar language is provided in Arconic SDS for Titanium Alloys #1164) as well as in accordance with the guidance in National Fire Protection Association (NFPA) Standard 484 Standard for Combustible Metals, 2019 ed. Section 11.2.3.6.8 of NFPA 484 (2019) states the air-material separator (AMS) selected for the system shall be designed to allow for the characteristics of the combustible dust being separated for the air gas flow. Annex A, Explanatory Material, of NFPA 484 (2019) - Section A.11.2.3.6.8 explains that a dry-type AMS often cannot be used with combustible metal dusts. This is due mainly to the inherent operation of such a device and the tendency of combustible metal material to accumulate inside the unit. A wet-type AMS unit uses a liquid to capture and separate the dust from the air or gas stream. This quenching of the dust particles (i.e. wetting) inherently reduces the risks as long as the device operates properly. Proper selection of the AMS for a dust collection system with combustible metal dusts is critical to the safe operation of the system.