Violation Detail
Standard Cited: 5A0001 OSH Act General Duty Paragraph
Inspection Nr: 106549199
Citation: 02001
Citation Type: Unclass
Abatement Date: 08/30/1995 X
Initial Penalty: $70,000.00
Current Penalty: $56,000.00
Issuance Date: 08/25/1995
Nr Instances: 1
Nr Exposed: 105
Related Event Code (REC): A
Gravity: 10
Report ID: 0524530
Contest Date:
Final Order:
Emphasis:
Type | Latest Event | Event Date | Penalty | Abatement Due Date | Citation Type | Failure to Abate Inspection |
---|---|---|---|---|---|---|
Penalty | I: Informal Settlement | 09/12/1995 | $56,000.00 | 08/30/1995 | Unclass | |
Penalty | Z: Issued | 08/25/1995 | $70,000.00 | 08/30/1995 | Willful |
Text For Citation: 02 Item/Group: 001 Hazard: FALLING
Section 5(a)(1) of the Occupational Safety and Health Act of 1970: 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: ........the hazards of fire and or explosion due to the unsafe methods of operating, collecting and storing of aluminum dust and the residue mixture of polish and cotton generated during the production process of aluminum alloy bicycle rims. General methods of abatement applicable in these circumstances include, but are not limited to, the following: 1) Exhaust aluminum dust to an approved dust collection system located outdoors as defined in sections 2-1.5, 2-1.6 and 2-3.1 of the 1993 version of NFPA 65. * 2-1.5; Dry-type dust collectors shall be located outside of buildings. * 2-1.6; All dust collection systems shall be installed in accordance with NFPA 91, Standards for Exhaust Systems for Air Conveying of Materials. * 2-3.1; The exhaust vent shall terminate outside the building and be securely fastened. .... 2) Design and install local exhaust systems that meet the minimum operating parameters and safety guidelines established in sections 2-2.1 through 2-2.6 in the 1993 version of NFPA 65 in areas where aluminum dust is being generated. These areas include polishing, brushing, and grinding stations. * 2-2.1; Ducts shall be designed to maintain a velocity of not less than 4500 ft/min(1372.5 m/min.) to ensure the transport of both coarse and fine particles and to ensure reentrainment if, for any reason, the particles can fall out before delivery to the collector (for example, in the event of power failure). * 2-2.2; Ducts shall be designed to handle a volumetric flow rate sufficient to maintain a dust loading safely below the lower explosive limit. * 2-2.3; Ducts shall be as short and as straight as possible. * 2-2.4; Ducts shall have as few bends and irregularities as possible so that free airflow is not interfered with. * 2-2.5; Ducts shall be of conductive material construction and shall be carefully fabricated and assembled with smooth interior surfaces and with internal lap joints facing the direction of airflow. There shall be no unused capped outlets, pockets, or other dead-end spaces that might allow accumulations of dust. Duct seams shall be oriented in a direction away from normal working personnel. * 2-2.6; Duct systems, dust collectors, and dust-producing machinery shall be bonded and grounded to minimize accumulation of static electric charge. 3) Use separate dust collection systems for grinding operations and polishing/buffing operations as described in section 2-1.3 of the 1993 version of NFPA 65. Dedicate dust collection systems for aluminum or aluminum alloy dust only as described in section 2-1.7 of the 1993 version of NFPA 65. * 2-1.3; Grinding operations shall not be served by the same dust collection system as buffing and polishing operations. * 2-1.7; Dust collection systems shall be dedicated to collection of aluminum or aluminum alloy dust only. Grinders, buffers, and associated equipment with dust collectors utilized for processing aluminum shall be provided with a placard indicating, "Warning-Aluminum Metal Only-Fire or explosion can result with other metals." 4) Once the decision is made to install either a wet-type or dry-type dust collection system, all requirements in sections 2-3 or 2-4 in the 1993 edition of NFPA 65 must be met. WET TYPE * 2-3.1; The exhaust vent shall terminate outside the building and be securely fastened. The duct shall be as short and as straight as possible, and shall be designed to withstand the same explosion pressure as the wet collector. * 2-3.2; The exhaust vent shall be inspected and cleaned frequently to prevent buildup of highly combustible deposits of metal dusts on the interior surfaces of the duct. * 2-3.3; The dust collector shall be arranged so that contact between dust particles and parts moving at high speeds is prevented. The blower for drawing the dust-laden air into the collector shall be located on the clean air side of the collector. * 2-3.4; The dust collector shall be arranged so that the dust-laden air stream shall be thoroughly scrubbed by the liquid to achieve the desired efficiency. * 2-3.5; Sludge shall be removed from the collector on a regular schedule to ensure proper and safe operation of the equipment. Sludge shall be disposed of in accordance with the requirements of 2-3.7. * 2-3.6; The sump of water wet-type dust collectors shall be ventilated at all times. When the dust collector is not in operation, this ventilation shall be provided by an independent blower or by an unimpeded gravity vent. Gravity vents shall be provided with means to automatically open when the dust collectoris shut down. DRY TYPE * 2-4.1; Electrostatic collectors shall not be used. * 2-4.2; Dust-collecting filter medium made from synthetic fabrics that accumulate high static charges shall not be used. * 2-4.3; Special care shall be taken to ensure the internal cleanliness of dry dustcollection systems at all times and to avoid the accumulation of material except in the discharge hoppers of the dust collectors. Accumulation or condensation of water shall be prevented. * 2-4.4; Dust shall be removed from dry collectors at least once each day and at more frequent intervals if conditions warrant. Extreme care shall be taken in removing dust from the collectors to avoid creating dust clouds. The material shall be discharged into metal containers that shall be promptly and tightly covered to avoid the creation of airborne "fugitive dust." Waste material shall be mixed with an inert material, such as dry sand, in a volume ration of 5 parts inert material to 1 part metal dust, and disposed in accordance with local, state, and federal regulations. * 2-4.5; Dry dust collectors where an explosion hazard exists shall be provided with explosion vents. Extreme care shall be taken in the selection of the type and location of vents or weak sections of the collector to minimize injury to personnel and blast damage to nearby equipment or structures. Explosion vents shall be positioned so that a potential blast shall not be directed towards any combustible or frangible structure. * 2-4.6; Where repairs on dry dust collectors are necessary, the collectors shall be emptied and residual accumulations of dust thoroughly removed. (see section 3-01.) Ductwork leading into the collector shall be disconnected and blanked off before repair work shall be permitted to be started. * 2-4.7; The interior of hoods and ducts shall be regularly cleaned wherever there is a possibility of buildup of wax, lint, aluminum fines, or other combustible material. * 2-4.8; The dust collector shall be arranged so that contact between dust particles and ¿parts moving at high speeds shall be prevented. The blower for drawing the dust -laden air into the collector shall be located on the clean air side of the collector. 5) If a wet-type dust collector is used, disposal of sludge accumulations from this type of collector shall be in accordance with all sections specified in section 2-3.7 of the 1993 version of NFPA 65. * 2-3.7.1; Sludge from water wet-type dust collectors shall be removed at least once each day or more frequently if conditions warrant. * 2-3.7.2; Covered, vented metal containers, preferably holding not more than 50 lb(22.7 kg) each, shall be used to transport the collected sludge for disposal.(see A-2-3.5.) * 2-3.7.3; Sludge shall be disposed of using the following method: * 2-3.7.4; Sludge shall be permitted to be mixed with sand in a ration of at least 5 parts sand to 1 part sludge, and then shall be discarded in accordance with local, state, and federal requirements. * 2-3.7.5; Smoking or open flames shall be prohibited in the disposal area and throughout the disposal process. 6) Establish a written housekeeping program for any and all accumulations of aluminum dust. This written program shall include at a minimum; employee training, daily visual checks by employees and management to assure that good housekeeping is being maintained, all guidelines established in section 3-1 in the 1993 version of NFPA 65. * 3-1.1; This chapter shall be applied to new and existing facilities. * 3-1.2; Good housekeeping shall be practiced in the entire work area. Dust shall not be allowed to accumulate on floors, exposed building structural members, piping, conduit, or ductwork. * 3-1.3; Cleaning shall be done with a soft brush or squee-gee and pickup shall be done with non-sparking conductive scoops. Synthetic fiber bristle brushes and plastic or other nonconductive scoops shall not be used because of their tendency to accumulate strong static electric charges. * 3-1.4; Only vacuum cleaners specifically approved for use with reactive combustible metal dusts shall be used to pick up small quantities of loose dust. Standard commercial industrial vacuum cleaners shall not be used, as they are not safe for use with combustible metals. * 3-1.4.1; All spills shall first be cleaned by scooping and mild brushing. * 3-1.5; The vacuum cleaner, its piping, suction hose, and tools shall be electrically conductive and shall be grounded to prevent static electric sparks. The vacuum cleaning tools shall be made of conductive non-sparking materials.* 3-1.6; The use of compressed air for cleaning of the structure and clothing shall not be permitted except for certain areas impractical or impossible to clean otherwise, and done under carefully controlled conditions, with all potential ignition sources prohibited in or near the area and the equipment shut down. 7) Eliminate all ignition sources in areas where Aluminum dust is present. This would include but is not limited to all sources listed in section 3-4 of the 1993 version of NFPA 65. * 3-4.1; No open flames shall be allowed in areas where aluminum dust or sludge is produced or handled. No smoking shall be allowed in such areas. * 3-4.2; Grinding wheels shall not be dressed while on a spindle connected to an aluminum-dust collection system. * 3-4.3; Propellant-actuated tools shall not be used in buildings where aluminum dust is created or handled. * 3-4.4; Electric or gas welding or cutting or maintenance operations that could produce hot particles, such as drilling, sawing, or chipping shall not be permitted in areas where an aluminum dust hazard exists unless the following precautions are taken: * 3-4.4.1; All machinery in the area where such operations are to be performed shall be shut down. * 3-4.4.2; All ductwork of dust collections systems shall be cleaned and the dust collectors shall be emptied and cleaned. * 3-4.4.3; All accumulations of aluminum dust shall be thoroughly cleaned and removed from the area. The area shall also be free of all solvents and solvent vapors. * 3-4.5; Smoking or open flames shall be prohibited in the disposal area and throughout the disposal process. 8) Installation of electrical equipment inside the polishing booths shall be in accordance with applicable sections of the National Electric Code 502 for Class 2, Group E, Division 1 locations. This electrical equipment would include but is not limited to motors, wiring, switches, lighting fixtures, receptacles and relay systems. In addition to meeting the requirements established in NEC 502, all guidelines listed in section 3-2 in the 1993 version of NFPA 65 shall also be complied with. * 3-2.1; All electrical equipment and wiring shall be in accordance with NFPA 70, National Electrical Code where Class 1 or 2 locations, as defined in Article 500-5 or 500-6 of NFPA 70, National Electrical Code exist, equipment shall be approved for such usage. Exception: Control equipment meeting therequirements of NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment, need not comply with 3-2.1 when equipment is approved for such usage. * 3-2.2; All electrical equipment shall be inspected and cleaned at regular intervals. * 3-2.3; All electrical equipment shall be adequately grounded by permanent ground wires to minimize accumulation of static electric charges. 9) Install motors and electrical control equipment designed for operating at 60 cycles. 10) Provide Class D portable fire extinguishers as required in section 5-1.1 of the 1993 version of NFPA 65. Provide portable fire extinguisher training to employee's expected to fight Class D fires. * 5-1.1; Only fire extinguishers approved for Class D fires shall be permitted in areas where aluminum dusts are present. Exception: If Class A, B, or C extinguishers are in the area, a conspicuous sign shall be posted adjacent to these extinguishers stating: "These extinguishers are not for use on aluminum dust fires." 11) Install an automatic power disconnect for the local exhaust systems which would disable their operation in the event of a fire. This is in accordance with section 5-3 of the 1993 version of NFPA 65. * 5-3; Equipment shutdown. In the event of fire, all fans and machinery, including dust collection systems, shall be shut down. Drafts shall be avoided wherever possible. 12) Employees who work around areas in the plant where they can come into contact with aluminum dust as part of their routine duties are prohibited from wearing clothes made of synthetic fabrics and trousers which have cuffs as defined in section 5-4 in the 1993 version of NFPA 65. * 5.4; Work Clothing. Work clothing shall be made of smooth, hard-finished, closely woven fabric and shall not be made of synthetic fabrics, which tend to accumulate static electric charges. Trousers shall have no cuffs where dust might accumulate. 13) Conduct an engineering study on the feasibility of lowering the high temperatures generated by brushing/polishing wheels when they make contact with aluminum alloy bicycle rims. 14) Comply with all other sections of NFPA 65 1993 version which relate to any other specific application in the manufacturing of aluminum bicycle rims at Weinmann, Inc. DISCLAIMERS: a) The employer is not limited to the abatement methods suggested by OSHA. b) The methods explained are general and may not be effective in all cases. c) The employer is responsible for selecting and carrying out an appropriate abatement method.