Text For Citation: 01 Item/Group: 006 Hazard:

29 CFR 1910.119(d)(3)(ii): The employer shall document that equipment complies with recognized and generally accepted good engineering practices. (a) On or about December 26, 2023, and through January 3, 2024, the employer had not documented, under required process safety information, that the equipment associated with the solvent-based inks manufacturing process within the Class I Division 1 manufacturing area producing flammable liquid inks with flash points below 100 F and in quantities over 10,000 lbs. complied with recognized and generally accepted good engineering practices (RAGAGEPs) for instances such as but not limited to those listed below: (i) The employer did not document that the ventilation system's explosion protection system installed on the dust collector servicing covered mixing vessels CT-1, KD-5, KD-2, KD-3, KD-4, and CT-6 complied with RAGAGEP. The outdoor Donaldson Torit dry-type cartridge collector was used to convey flammable vapors and combustible dusts from the process vessels. The dust collector's explosion protection design (explosion venting) was based solely on explosibility properties of combustible paint pigment particulate solids and not on hybrid mixtures, including flammable vapors. National Fire Protection Association (NFPA) Standard 91 "Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, 2020 ed." stipulates that the concentration of flammable vapors or gases shall not exceed 25 percent of the lower flammable limit (LFL) unless designed and protected in accordance with NFPA 68 "Standard on Explosion Protection by Deflagration Venting, 2018 ed.". NFPA 68 requires that the design of explosion protection venting systems handling flammable gases and/or hybrid mixtures be designed with the properties of the flammable gases and/or hybrid mixtures in mind. (ii) The employer did not document that the ventilation system's fan system installed on the dust collector servicing covered mixing vessels CT-1, KD-5, KD-2, KD-3, KD-4, and CT-6 complied with RAGAGEP. The outdoor Donaldson Torit type cartridge collector was used to convey flammable vapors and combustible dusts from the process vessels. The dust collector's fan was not designed with industry recognized spark-resistant construction principles. National Fire Protection Association (NFPA) Standard 91 "Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, 2020 ed." stipulates that air-moving devices handling flammable or combustible materials greater than or equal to 10 percent of the minimum explosible concentration (MEC) of the dust or the lower flammable limit (LFL) of the vapor be of Type A, B, or C spark-resistant construction per Air Movement & Control Association (AMCA) Standard 99-0401-86 "Classification for Spark Resistant Construction". (iii) The employer did not document that the ventilation system's dust collector servicing covered mixing vessels CT-1, KD-5, KD-2, KD-3, KD-4, and CT-6 complied with RAGAGEP. The outdoor Donaldson Torit dry-type cartridge collector was used to convey flammable vapors and combustible dusts from the process vessels. The dust collector was designed for the purpose of separating combustible particulate solids from the air stream and was not designed for handling flammable gases/vapors. National Fire Protection Association (NFPA) Standard 91 "Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, 2020 ed." stipulates that that the type of separator shall be suitable for the gas, vapor, or mist being separated from the air stream. (iv) The employer did not document that the ventilation system's dust collector servicing covered mixing vessels CT-1, KD-5, KD-2, KD-3, KD-4, and CT-6 complied with RAGAGEP. The outdoor Donaldson Torit dry-type cartridge collector was used to convey flammable vapors and combustible dusts from the process vessels. The dust collector's design basis was not documented to include the operation range of flammable vapors and combustible dusts to be maintained in the system. National Fire Protection Association (NFPA) Standard 91 "Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, 2020 ed." stipulates that the design of ventilation systems shall be documented, and the documentation shall include information such as the concentration of flammable vapors or gases in the conveyance air stream and the concentration of particulate or dust in the conveyance air stream. (v) The employer did not document that the ventilation system's cellulose cartridge filters installed in the dust collector servicing covered mixing vessels CT-1, KD-5, KD-2, KD-3, KD-4, and CT-6 complied with RAGAGEP. The outdoor Donaldson Torit dry-type cartridge collector was used to convey flammable vapors and combustible dusts from the process vessels. The dust collector's filters were constructed of cellulose and were not demonstrated to be capable of being compatible with the vapors collected in the process. National Fire Protection Association (NFPA) Standard 91 "Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, 2020 ed." stipulates that that the type of separator shall be suitable for the gas, vapor, or mist being separated from the air stream. (vi) The employer did not document that the ventilation system's branch ducts servicing covered mixing vessels CT-1, KD-5, KD-2, KD-3, KD-4, and CT-6 complied with RAGAGEP. The outdoor Donaldson Torit dry-type cartridge collector was used to convey flammable vapors and combustible dusts from the process vessels. The ventilation system's flexible, plastic ducting used as branch duct to connect the vessel to the main duct was non-conductive and not bonded and grounded. National Fire Protection Association (NFPA) Standard 91 "Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, 2020 ed." stipulates that nonconductive system components are not permitted where hybrid mixtures and/or flammable gas/vapor atmospheres are present. (vii) The employer did not document that covered mixing vessels CT-1, KD-5, KD-2, KD-3, KD-4, and CT-6 ventilation system design complied with RAGAGEP. The mixing vessels had top mounted, hinged lids through which non-liquid ingredients were added which provided for the potential escape of flammable vapors. National Fire Protection Association (NFPA) Standard 30 "Flammable and Combustible Liquids Code, 2021 ed." stipulates that equipment shall be designed and arranged to prevent the unintentional escape of flammable liquids and vapors. In addition, NFPA 30 stipulates that process vessels with flammable liquids above their flash point shall be closed to the room in which it is located and vented to the outside of the building, specifying that if the vessels need to be opened to add ingredients, the room ventilation shall ensure that concentrations of vapors within the area are at or below 25% of the lower flammable limit (LFL). (viii) The employer did not document that covered mixing vessels CT-1, KD-5, KD-2, KD-3, KD-4, and CT-6 particulate solids charging processes complied with RAGAGEP. Manual additions of particulate solids were permitted to be added through direct, open means that could cause displacement of flammable vapors. National Fire Protection Association (NFPA) Standard 654 "Standard fire the Prevention of Fire and Dust Explosions from the Manufacturing, Process, and Handling of Combustible Particulate Solids, 2020 ed." stipulates that particulate solids shall not be manually dumped directly into vessels containing flammable atmospheres or where displacement could cause a flammable atmosphere external to the vessel. Similar requirements can be found in NFPA Standard 77 "Recommended Practice on Static Electricity, 2019 ed.".