A holistic approach delivers cost-effective remediation for manufacturer
Compliance issue threatens disruption of operations
A company manufactures garden and lawn equipment at multiple plants. Different color powders are applied for specific products and brands. During an inspection at one of the plants, an Occupational Health & Safety Administration (OSHA) official observed fugitive dust powders outside of the powder coating booth. OSHA tested the dust and categorized it as an ST 1 combustible dust—the lowest risk category—which was consistent with information provided from the powder coating manufacturer.
The inspector issued a citation under OSHA general duty clause, which broadly requires companies to provide a safe work environment. Further, the citation specified that the manufacturer needed to comply with National Fire Protection (NFPA) Standard 654, which required it to conduct a process hazard assessment on its powder coat operations. This would mandate that the manufacturer conduct a very detailed, step-by-step review of every activity in the chain of the process; identify failures and faults that could occur and corresponding mitigation measures; and perform quantitative assessment to determine the degree of risk reduction. Applying the NFPA 654 Standard for the powder coating operations would require extensive infrastructure modification to meet the classification requirements for electric service to the equipment and powder coat room.
The company turned to Haley & Aldrich to help it address the issue.
Leaving no stone unturned
The Haley & Aldrich team approached the problem in the context of a larger issue: business operations and continuity. We were looking for a solution that would minimize disruption of the company’s critical manufacturing operations and minimize cost. We conducted a thorough review of operations, controls and infrastructure to determine the scope of the issue and most effective course of action. Our extensive on-site analysis included observing operations, interviewing employees operating the equipment, reviewing operations manuals and inspecting the controls in place.
At the same time, we conducted a regulatory review to identify the most appropriate standard to address the combustible powder concern at the company’s plant.
Operations review and regulatory assessment provide the answer
Through site visits and assessment of the government regulations, we recognized that NFPA Standard 654 was not the applicable governing criteria to address the company’s dust powder issue. The type of materials, operations and processes at the company’s plants were not consistent with this standard, which was designed to monitor the risk of highly combustible solids and fine powders produced during the manufacturing process in sawmills, sugar plants, and similar operations. Instead, we identified NFPA Standard 33 as the appropriate governing criteria, since it specifically addresses powder booths. The process hazard assessment would therefore not be required under this standard and the compliance mandates not as broad. This was a significant discovery, enabling corrective actions to be simpler, faster and significantly less expensive.
As part of our strategy, we divided the work space into three zones, each complying with different aspects of the NFPA Standard. The powder booth itself was Zone 2, which was classified as class 2 division 1, requiring the proper handling of combustible vapors. Zone 1, which covered the distance outside the booth up to a three-foot radius, was designated Class 2, Division 2, requiring the proper handling of combustible dust incidental to the operation. Zone 0, which was the area outside of the three-foot radius, was unclassified, and therefore did not need any specific requirements.
Although the OSHA cited only one plant for combustible dust powder, the manufacturer wanted to make sure all of its plants were in compliance. If the combustible dust issue would be governed under the NFPA 654 ruling that OSHA had initially identified, the company would have to redesign and rebuild nine powder rooms. To do this, the engineering and construction costs alone would have been $2 to $4 million.
Armed with the information and recommendations we provided, the manufacturer presented its case to the OSHA regional director. He agreed with our recommendation to shift compliance to NFPA Standard 33 and with our three-zone approach.
We also worked with facilities engineers, operations directors and employees operating the equipment to develop a compliance plan for the company under NFPA Standard 33. In addition to identifying modifications to mitigate residual risk of the dust within a three-foot radius around the powder room, we also helped the company implement controls and develop preventive maintenance and inspection plans.
The value of a holistic approach
By looking at the issue holistically through the lens of operational risk and continuity, we identified a solution that satisfied regulators and saved the manufacturer from a disruptive and costly redesign of infrastructure. This approach enabled the company to continue its operations without a hitch, and at the same time, save millions of dollars.
For more information on this project, contact: