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

OSHA 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 recycled materials (i.e. plastics and metals) dust deflagration, explosion, and/or other fire hazards while working at or near two indoor dust separation and collection systems that were not adequately located, designed, and equipped to prevent or materially reduce employee exposures in the event of an internal deflagration or other fire event: a) The indoor Amtech ATPS-20 dry-type, horizontal cartridge dust collector used to collect fugitive dust from the upstream processes, including the Q140 primary shredder, lacked a means of 1) explosion protection, and 2) deflagration propagation protection (isolation). Employees working near the dust collector were exposed to explosion hazards such as exiting flame front, exiting pressure wave, and projectiles in the event of an internal deflagration resulting in an over-pressurization of the vessel. Employees working near or upstream of the dust collector were exposed to deflagration propagation hazards such as exiting flame front in the event of an internal deflagration resulting in propagation of a flame front outside of the vessel. b) The indoor Torit Downflo II DF T2-4 dry-type, horizontal cartridge dust collector used to collect fugitive dust from the upstream processes, including the size reduction process Q85 secondary shredder, lacked a means of 1) explosion protection, and 2) deflagration propagation protection (isolation). Employees working near the dust collector were exposed to explosion hazards such as exiting flame front, exiting pressure wave, and projectiles in the event of an internal deflagration resulting in an over pressurization of the vessel. Employees working near or upstream of the dust collector were exposed to deflagration propagation hazards such as exiting flame front in the event of an internal deflagration resulting in propagation of a flame front outside of the vessel. Among other methods, feasible methods to correct these hazards are outlined in National Fire Protection Association (NFPA) Standard 652, �Standard on the Fundamentals of Combustible Dust,, 2019 ed.� � Sections 9.3.4.1 (dust collector indoor locations), 9.7 (explosion prevention / protection), 9.7.3 (equipment protection), 9.7.4 (equipment isolation) and Chapter 7 �Dust Hazards Analysis�. Specifically - Perform a dust hazards analysis (DHA) within the guidelines of NFPA 652 to determine the most appropriate method of abatement based on the specific combustion properties of the dusts handled by each dust collection system. Depending on the results of the DHA, options for abatement may include, but may not be limited to, the following: (A) [1] Relocate the dust collectors to an outdoor location, provide a method of explosion protection (such as explosion venting to a safe outdoor location in accordance with NFPA 68 �Standard on Explosion Protection by Deflagration Venting� or a deflagration detection and chemical suppression system in accordance with NFPA 69 �Standard on Explosion Protection Systems�), and [2] provide methods of deflagration propagation protection for vessel outlets (such as a flow-actuate flap valve isolation device designed in accordance with NFPA 69 or a chemical isolation system in accordance with NFPA 69 to protect the upstream processes & a rotary valve isolation device designed in accordance with NFPA 69 to protect the area underneath the unit)., or (B) [1] Provide the indoor dust collectors with a method of explosion protection (such as explosion venting to a safe outdoor location in accordance with NFPA 68, explosion venting through a listed flame-arresting and dust retention device in accordance with NFPA 68, or a deflagration detection and chemical suppression system in accordance with NFPA 69) , and [2] provide methods of deflagration propagation protection for vessel outlets (such as a flow-actuate flap valve isolation device designed in accordance with NFPA 69 or a chemical isolation system in accordance with NFPA 69 to protect the upstream processes & a rotary valve isolation device designed in accordance with NFPA 69 to protect the area underneath the unit). Additional NFPA combustible dust standards may also be need to be reviewed for guidance including NFPA 484 �Standard for Combustible Metals, 2019 ed.� and NFPA 654 �Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2020 ed.�