Glass-Reinforced Plastic Production Process $90K OSHA Fine

OSHA's inspection found that combustible particulate solids, which were generated during trimming and repair operations, were not collected into an adequately designed dust collection system, were allowed to accumulate on machinery and surfaces, and were not adequately cleaned up to prevent such buildup.

via osha.gov

Housekeeping appears to be the major issue with this recent OSHA citation for combustible dust fire and explosion hazards at a Pawcatuck, Connecticut plant. Reviewing a MSDS sheet for glass-reinforced plastics (GRP) highlights that GRP is a compound based upon a mix of glass fibre in a polyester and styrene resin based mix.

The fire hazards of GRP arise when combustible dust from machining and fabrication operations of combustible particulate solids may be explosive if mixed with air in critical proportions in the presence of an ignition source. Additionally, during storage and handling the dust generated during normal manufacturing operations can represent both a health hazard and a fire hazard. Most importantly as the OSHA news release informs stakeholders to use dust control equipment at the point of generation in machining and sawing operations.

An often overlooked potential ignition source are powered industrial trucks where combustible dust mentioned in this news release was exposed to several potential ignition sources, including an LP gas-powered industrial truck. What class of forklift are you using at your facility? Is it rated for use in potentially explosive atmospheres? The recent status report on the OSHA Combustible Dust NEP emphasized that combustible dust citations for powered industrial trucks was the third most cited violation after hazardous communication and housekeeping violations.

The 5th Annual Industrial Fire, Safety, and Security Conference (IFSS) in Houston, Texas will be hosting a Full-Day Combustible Dust Workshop on February 2, 2010, which will provide information assisting stakeholders in addressing potential combustible dust ignition sources. During one segment of the workshop, guest speaker Robert Zuiderveld, General Manager of Business Development Americas from Pyroban Corp. will share with attendees specific information on the operation of powered industrial trucks in combustible dust. work environments. Information throughout the full day workshop will assist stakeholders in operating and maintaining a safe workplace in addition to achieving OSHA regulatory compliance.

Good housekeeping is a major issue at facilities with the generation of combustible dust from combustible particulate solids. Many facility managers and owners are not aware of the proper methods in cleaning up the dust. You just can't take a compressed air hose and start blowing down the area nor sweeping while unaware of the dust clouds that can be generated, which provide an explosive atmosphere similar to a flammable vapor cloud. Potential ignition sources in the process are inherent at many facilities. The safe and approved alternative is the use of an explosive-proof rated vacuum cleaner.

Guest speaker Bruce Gordon, Senior District Manager, from Nilfisk CFM will speak in the afternoon at the Combustible Dust workshop on "Proper Housekeeping and Explosion-Proof Vacuums Hazardous Locations" concerning good housekeeping that will minimize the likelihood of a combustible dust related fire or explosion in addition to achieving regulatory compliance. OSHA combustible dust citations are costly yet a catastrophic secondary dust explosion leveling the facility can be even more of problem. Do you know about the combustible dust hazards at your facility?

Resources
Glass-Reinforced Plastics (GRP)

OSHA Gloves Come Off with Questionable Press Release

• OSHA Gloves Come Off with Questionable Press Release - Annotated

  This is a very misleading OSHA Region 5 News Release]. There never was any repeat OSHA citations by the Eau Claire, WI Area OSHA Office for this newly acquired facility. The OSHA inspection took place less than 60 days after acquisition from SPF North America, a pet flavor and ingredient mfg. Additionally none of the citations resulted from many of the same safety and health hazards cited in the most recent inspections. Since there wasn't any recent inspections at the Milk Specialties Whitehall, WI facility

  tags: spray dryer, OSHA citation, press release

  • 
    • Whoa! $1.1 mil - post by comdust
  • Four repeat violations with penalties totaling $21,800
    • These repeats are not from this Whitehall, Wi facility. Milk Specialties operates five other manufacturing plants in Wisconsin and Minnesota - post by comdust
  • citations resulting from many of the same safety and health hazards cited in the most recent inspection.
    • Very misleading. There was never any repeat citations by OSHA at the Whitehall, WI facility. The facility was purchased from SPF North America in October 2008 and the OSHA inspection took place less than 60 days later. - post by comdust

Milk Specialties Scientific Advisory Committee

• Dr. Douglas Burrin, Baylor University
• Dr. James Drackley, University of Illinois
• Dr. Richard Hartel, University of Wisconsin
• Dr. Al Kertz, Andhil LLC
• Dr. Adam Lock, University of Vermont
• Dr. Jack Odle, North Carolina State University
• Dr. Mike Van Amburgh, Cornell University
• Dr. Wang Jiaqi, Institute of Animal Science, Chinese Academy of Agricultural Sciences

Update 6/24/09 The Other Half of the Story

Manufacturing facilities with multi-sites should be aware that if a facility currently receiving a citation and has received an OSHA citation at another site within three years for the same violation will be considered as a repeat citation. Here is an excerpt from Andy Purvin a member of the Online Safety Community that describes the situation

John,
I ran into this a lot at my previous employer. OSHA says since the company has a large enough communications network, relaying information between plants wouldn't be a hardship. Therefore, since they could have "learned" from the previous inspection citations, it technically IS repeat violations.

I argued similar points to yours, but lost. Companies that have multi-site designation are going to be held accountable to update all plants on Regulatory Activity. To combat this, at my current company, when OSHA "visited" one of our locations, I communicated the results to all and confirmed corrective actions had taken place at EVERY location to avoid repeat violations.

Here is additional helpful info that Bryan Haywood CEO & President, SAFTENG.net LLC shares with his comment on "repeat violations" at the LinkedIn Combustible Dust Policy Institute Group discussion:

"Although I can not speak to the question of "new ownership" I can state that a repeat citation can be issued to the facility if a different plant within the company that falls within Federal OSHA and NOT a state plan, has been cited for the same violation. The cited repeat violation does NOT have to have occurred at the same facility...just a facility within the company that falls under Federal OSHA, as I think was this case. You mentioned a MN facility and MN is a state plan, which means citations at the MN facility can NOT be used to issue repeats at a plant under Federal OSHA.

The change in ownership brings a new twist to OSHA's repeat citation policy. Basically, it is a new owner (e.g. new employer) and thus this new owner/employer can not be cited for the previous owners errors. Will be interesting to see if the business challenges these citations and if so if the OSHRC will vacate the citations.

Here is a link to OSHA's repeat citation policy for those interested in how FAR REACHING this policy can be.

[CPL 02-00-148] - Field Operations Manual (FOM)
http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-148.pdf
You will want to go to Page 4-32, Section VII for the Repeat Citation guidance.