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Wednesday, March 21, 2012

The use of modern spark detection and extinguishment systems in Tobacco Manufacturing

Risks in the bud: to explore the use of modern spark detection and extinguishment systems

From International Tobacco Online, an article on applying modern spark detection systems to the tobacco/cigarette manufacturing process.

For more detailed information on Spark Detection and Extinguishing Systems please see our website: www.IndustrialFirePrevention.com


Tobacco online tobacco "Tobacco," reported in the processing and transportation process large amount of dust, fermentation and friction so that its temperature rises to unsafe values, and generate sparks. The vast majority of tobacco processing are using modern equipment, once by its cause a fire, will cause huge losses to the enterprise.
To solve these problems, at present, some advanced tobacco factory has been installed and use the spark detection and extinguishment systems.
Dust generated by the first process of the tobacco processing flavored or feeding easier to handle, less likely to spark. Even a small spark, and is likely to be extinguished by water, will not cause great risk to the next process. Thus, only in the production equipment installed spark detectors and sprinkler nozzles. Once detected by Mars, fire fighting nozzle within 3 seconds to extinguish the burning material, the whole process does not have to stop. Meanwhile, you can set a system alarm sparks number or interval period. If the spark occurrences exceeds the set value over time, the production line will automatically stop working for manual inspection.
In the next process, the dust is very easy to stick together with other tobacco substances, when available fire ring instead of the automatic sprinkler nozzle. Once the spark is detected, the fire ring will immediately start the entire production line to stop working within 200 milliseconds. Again unconventional run in order to prevent production equipment, extinguishing after fire ring is open to re-set the alarm in order to resume production. The fire circle is airtight, to ensure completely prevent burning particles in the pipe. The more security measures is a fire ring can be attached to a carbon dioxide or argon gas fire extinguishing system. Hours of this gas fire extinguishing system installations in the amount of transmission can use the diversion valve, the combustion of particles streaming out, transported to a waste box and then turns off the production line without having to stop work. Diversion valve is restored to its original position after 5 seconds, at any time "standby".
Tobacco baking, cooling conveyor and Hong, the temperature usually over 80 degrees Celsius. The choice of the fiber probe, and install it on the low temperature region.This detector in the high temperature of 360 degrees Celsius can also provide effective detection.
In the tobacco the strapping processing or transmission process, the burning embers may be tobacco covered the install FM1/8-PM detector - the instrument has a maximum sensitivity of the burning embers.
Some of the tobacco processing process is open, such as the use of the conveyor belt transporting tobacco, which need to install related equipment on the far-infrared detectors.
Materials used in cigarette production, such as mouth-stick adhesives, ethylene glycol, such as liquorice, will lead to the exhaust pipe to the accumulation of clogging, which led to the failure of the detectors. This case, you can add air purification adapter estimated minimum compressed air throughput through a fine metering valve to avoid the accumulation of these substances.
Most of the dust extraction system does not require regular checks of dust accumulation areas is necessary to carry out regular inspections - the dust will increase the chance of fire. All filters should be equipped with thermal sensors and a clean air test. As a result, the fire can quickly be detected. Has been tested and fitted with a filtration system for clean air testing can be detected within 20 seconds the fire occurred.

Thursday, March 15, 2012

CSB to Increase Participation of Non-Management Employees – At the Expense of Employers

Another update from Epstein, Becker, Green.


The U.S. Chemical Safety and Hazard Investigation Board (CSB) announced earlier this month a new policy disguised as a nod to enhancing employee participation in CSB investigations, but which may actually represent a dramatic limitation in the investigation rights of both employees and employers.

The new policy expands the role of non-management employees in the CSB’s investigations into the causes of chemical accidents that occur at industrial facilities, but does so at the expense of employers’ involvement and employees’ rights.

By way of background, the CSB was created under the Clean Air Act, but does not report under the EPA, nor does it fall under the Department of Labor.  Rather, the CSB is an independent, non-enforcement federal agency charged with investigating industrial chemical accidents.  While the CSB investigates many of the same incidents as the Occupational Safety and Health Administration (OSHA), the CSB distinguishes itself from OSHA in key ways, and really fancies itself as a sister agency to the National Transportation Safety Board (NTSB).  Like the NTSB, which conducts investigations of transportation related incidents, and issues reports and recommendations but not citations or fines, the CSB conducts root cause investigations of chemical accidents at fixed industrial facilities, and issues reports and recommendations but no penalties.

During its investigations, CSB investigators request (or subpoena) records, interview management and non-management employees, evaluate physical evidence, and review applicable regulations and industry practices.  Following its investigations, the CSB holds public meetings to review its finding, and drafts public investigation reports or case studies that include safety recommendations issued to companies, government agencies (often OSHA), trade associations, local governments, labor unions, and other entities.  Although CSB recommendations are technically non-mandatory, CSB tracks the implementation of its recommendations, and uses public shaming to compel employers and others to adopt the recommendations.
Below are the key differences between the manner in which the CSB and OSHA carry out their respective missions:
  1. Unlike OSHA, which has a six-month limitations period to complete its inspections and issue citations, the CSB has no time limit.  Indeed, it is not uncommon for CSB investigations to last more than a year;
  2. Whereas OSHA issues citations that carry monetary penalties, require mandatory abatement, and can result in criminal charges, the CSB issues “non-mandatory” recommendations following its investigations;
  3. In addition to the public shaming related to its recommendations, the CSB is also known for making public statements early and often about its on-going investigations, preliminary findings, interaction with the employer, and just about anything else, unlike OHSA, which, by policy, makes no public comments as to active matters; and
  4. While both agencies frequently make critical mistakes in their findings, OSHA citations can be contested before a body of administration law judges, but because the CSB is a non-enforcement agency, there is no venue to which employers can appeal to correct the CSB’s flawed reports and recommendations (not even by attaching formal comments to CSB’s official reports, like its “sister agency” the NTSB allows).
Another key difference between OSHA and CSB investigations is that OSHA excludes management representatives (e.g., the employer’s attorney) from non-management interviews, but the CSB has historically allowed employer’s representatives in interviews of employees.  The new policy articulated by the CSB in March 2012 includes a policy shift that strikes a major blow to employers’ and employees’ rights in CSB investigations.  The policy states:
“During CSB interviews, any non-supervisory employee may be accompanied by another non-supervisory employee, a personal attorney, or a family member as described in 40 CFR 1610.”
Under 40 CFR 1610.1(a), witnesses who are compelled to appear for interviews are entitled to have counsel present.  Based on CSB’s specific identification of a “personal attorney” or “fellow non-supervisory employee” as acceptable persons to accompany employees in interviews, however, it appears the CSB plans now to exclude company counsel from appearing with non-management witnesses, even if the witness expressly requests that specific attorney as his representative.

While the CSB Chairman stated that “effective employee participation” is the fundamental purpose of the new policy, and that information from employees is the most useful source for CSB understanding a facility’s day-to-day operations, it is troubling that the CSB intends to actually strip away employees’ rights by limiting their choice of interview representative.  It is even more troubling that just as the CSB praises the value of employee participation, they trample on the rights of participation of employers, who design and build the facilities where the accidents occurred, who manage the operations that were involved in the incidents, and who have access to valuable institutional knowledge not available to many non-management employees.

Furthermore, given that CSB findings and recommendations are publicized and used to shame allegedly bad actors, and employers have no venue to challenge errors and misstatements in CSB reports and recommendations, it is even more troubling that the employer is now going to be excluded from key aspects of the investigation process.  Employers have successfully challenged under the Administrative Procedure Act (APA), OSHA’s exclusion of management representatives from non-management interviews.  The same rationale for those challenges should apply in the CSB context as well.  Accordingly, provided the non-management employee and the employer waive any potential conflict of interest, and the employee is not pressured to select a management representative as his interview representative, this new CSB interview policy likely violates the APA, and should be challenged on behalf of employees who desire to have company counsel participate in their interviews.

Tuesday, March 13, 2012

Custom Woodworker Fought OSHA Penalty and Won

Another great blog post by Rich Christianson at the Woodworking Network.

Why Custom Woodworker Fought OSHA Penalty

Victory Woodworks' recent successful appeal of a serious table saw violation issued by an overzealous Occupational Safety and Health Administration (OSHA) enforcement agent, was the subject of my blog last week: Custom Woodworker Takes on OSHA and Wins.

The saga began last year when Victory Woodworks, a full-service architectural woodwork shop based in Sparks, NV, was working as a subcontractor on a building project in Las Vegas. The OSHA inspector visiting the site on a day when Victory Woodworks' employees were not present (a technicality that I failed to point out in my previous blog) was curious to learn about the contents of the company's  locked job box.

Cutting to the chase, at a meeting arranged a couple of days later with Victory Woodworks' foreman in which the job box was opened, the OSHA agent took the greatest interest in a 10-inch table saw. He questioned why the saw did not have an "anti-restart switch," a device that he believed would prevent it from suddenly starting in the event of a power failure, potentially putting the saw operator’s safety at risk.

Even though the lock box also contained a portable GFCI (ground fault circuit interrupter) that the OSHA agent would later admit would also prevent an accidental saw restart, he chose to write up a citation based on an outdated ANSI standard advising the use of an anti-restart device. The serious violation carried a proposed penalty of $2,380.

OSHA: Let’s Make a Deal
In bringing his frustration with the OSHA action to my attention last August. Jim Elliker, owner of Victory Woodworks, said OSHA initially offered him a deal to cut the proposed fine by 20 percent. But the deal came with the following stipulations:
 - Ensure all table saws used for woodworking have functioning anti-restarts;
- Retrain all employees who use the table saws to check them each day prior to use, the goal being to ensure that there is an anti-restart, and to ensure it is functioning; and
- Document the training, and ensure the documentation is maintained.
Elliker declined the offer and wisely so as OSHA’s next deal to bring the case to a close was even more generous: To help reduce its heavy caseload, OSHA proposed to reduce the violation to “other than serious” (OTS) and waive the full amount of the penalty.

Thanks but No Thanks
Even though the ultimate cost of its defense would prove to be more than double the proposed fine, Elliker on the advice of his “hired gun” John Skowronek Sr., managing member of labor consulting firm Square One Solutions based in Reno, NV, opted to proceed with an appeal to the Nevada Occupational Safety and Health Review Board.

Skowonrek noted that accepting OSHA’s deal would potentially leave Victory Woodworks open to a “repeat” violation if a follow-up OSHA inspection uncovered a similar violation. While OTS and serious violations are capped at $7,000, a repeat violation comes with a penalty upwards of $70,000.

So, with that plus the opportunity to clear its good name in mind, Victory Woodworks chose to fight its case and won.

The OSH Review Board ruled, “The table saw was protected from restart in the event of a power failure by a GFCI device; therefore even without strict compliance with the ANSI standard incorporated in the cited enforcement standard, an alternative method of protection was in place…There were no non-complying conditions at the respondent worksite under the cited standard.”

As Victory Woodworks prepares to file an application to recoup its more than $5,000 in defense costs, I remind readers to take heed. In my regular perusals of OSHA’s press release section, I have not only noticed an increase in the number of enforcement activities involving wood products companies, but also an increased number of citations lodged in each case.
Something to keep in mind if OSHA comes knocking at your door.

Recent blogs by Rich Christianson
Custom Woodworker Takes on OSHA and Wins, 3-2-12
Got an Opinion on Table Saw Safety? Tell the CPSC, 2-23-12
American-Made Furniture Gets Its Groove Back, 2-5-12
Read more of Rich Christianson's blogs.

Monday, March 12, 2012

Video: Firefighter Preparation and Response to a Grain Elevator and Feed Mill Fire or Explosion

The Minnesota Grain and Feed Association received a grant from the AgStar Fund for Rural America Grant Program, to produce videos to train volunteer firefighters and first responders on how to respond to a grain bin rescue situation and proper response to a grain elevator or feed mill fire or explosion.  Click the title above to view the videos.

Saturday, March 10, 2012

Managing an OSHA Inspection: Answers to 5 Frequently Asked Questions

From the OSHA Law Update blog of Epstein Becker Green, by Eric J. Conn, here is an article on OSHA inspections, frequently asked questions, and what you might expect when OSHA arives at your door step.

Managing an OSHA Inspection: Answers to 5 Frequently Asked Questions | compliance safety and health officer, CSHO, inspection, inspection rights, OSHA Inspection, subpoena, warrant | OSHA Law Update

 Below is a set of important questions that we are frequently asked by clients when OSHA unexpectedly shows up at their doorsteps.  These questions and many more are also addressed in our OSHA Inspection Checklist desk reference guide.


Scenario 1:   An OSHA Compliance Safety and Health Officer (CSHO) arrives unannounced to begin an inspection, but the employer’s representative whom the employer desires to manage the OSHA inspection is not present at the workplace.  Can the employer request that the CSHO return later or wait to start the inspection until the employer’s chosen representative is available?
Answer:  Yes, the employer can request that the CSHO return at a later time or wait a reasonable amount of time until the employer’s chosen inspection representative is available.  The OSH Act grants to employers the right to be represented during an OSHA inspection and to physically accompany an OSHA CSHO during on-site inspection activities.  The employer has the right to designate whomever it wants to fill that role, and if that person is not available at the moment OSHA arrives, but can be available in a reasonable amount of time, the employer can request that the CSHO wait or return later.
OSHA’s Field Operations Manual explains that OSHA believes waiting approximately one hour is a reasonable amount of time to delay the start of an inspection to wait for the employer’s selected representative to become available.
“When neither the person in charge nor a management official is present, contact may be made with the employer to request the presence of the owner, operator or management official.  The inspection shall not be delayed unreasonably to await the arrival of the employer representative. This delay should normally not exceed one hour.”
Notwithstanding OSHA’s purported one-hour rule, unless the CSHO has a warrant or other exigent circumstances exist (i.e., imminent danger in plain view), the employer can refuse to consent to the inspection until its chosen representative arrives, so OSHA  could not proceed with the inspection without obtaining a warrant, which generally takes at least a couple of days.
 *          *          *          *          *          *          *          *
Scenario 2:  OSHA explains at the Opening Conference that the inspection is in response to an employee complaint about a machine guarding hazard in the maintenance shop, but he requests that the employer’s representative grant him a general tour of the entire workplace.  Should the employer’s representative provide the CSHO with a general tour of the entire workplace?
Answer:  No, in the absence of a related special emphasis program, a warrant, or a hazard in plain view, OSHA cannot expand the scope of a complaint-based inspection beyond the location and hazard identified in the complaint without the employer’s consent.  The employer should insist that the inspection be limited to only that location.
To minimize the risk of the CSHO expanding the scope of the inspection based on his observing hazards in plain view in other locations, the employer’s representative should follow a route to the complaint location that introduces the CSHO to the least sensitive areas of the facility, even if that means walking the CSHO around the outside of the building to a different entrance closer to the location of the complaint.
 *          *          *          *          *          *          *          *
Scenario 3:  The CSHO asks to conduct an interview of a non-management employee, but the employee explains to his supervisor that he does not feel comfortable speaking to OSHA and does not want to be interviewed.  How should the employer representative respond to the employee?
Answer:  The employer representative can advise the employee that it is the employee’s choice whether or not to agree to the CSHO’s request for an interview, but also that OSHA has subpoena authority, and may compel the employee to participate in an interview if he refuses the request for a voluntary interview.  Employees’ participation in OSHA inspections is protected from employer retaliation by Section 11(c) of the OSH Act, so the employer representative may not discourage the employee from participating in the interview or from sharing any particular information during the interview, and may not take any adverse employment action on account of the employee’s decision whether to participate in the OSHA interview.
 *          *          *          *          *          *          *          *
Scenario 4:  At the conclusion of a management representative interview, the CSHO asks the management witness to review the CSHO’s interview notes and sign the notes if they appear to be accurate or to write out and sign a witness statement.  Does the management representative witness have to and/or should he agree to sign the notes or write out his own witness statement?  What about being taped or video recorded during the interview?
Answer:  OSHA has no authority to require any witness to sign any document or to prepare a written witness statement, or any form of new written document during an inspection.  Likewise, during a “voluntary” interview, witnesses may refuse to allow an interview to be video or tape recorded.  Note that OSHA can issue a subpoena that compels a witness to submit to an audio or video recorded interview.  OSHA cannot, however, compel an employee to write or sign any document even with a subpoena.
 *          *          *          *          *          *          *          *
Scenario 5:  During an inspection, OSHA issues a subpoena to your workers’ compensation insurer seeking risk assessments, loss control surveys, and other safety audits conducted of your facility.  Is the insurance company required to provide such materials?
Answer:  They are now.  A few months ago, OSHA won a key battle against an insurance company and all employers in a case involving two teens, who became engulfed in corn.  As part of OSHA’s investigation, OSHA subpoenaed records from the employer’s workers’ compensation insurer, Grinnell Mutual Reinsurance Co., seeking documents and testimony regarding working conditions observed by the insurer.  Grinnell refused to produce any documents or information, and OSHA sued the insurer in federal court.  The insurer argued that enforcing the subpoena would cause a “chilling effect” by discouraging businesses from allowing insurers to conduct safety inspections if the material could later be used against them in litigation or OSHA enforcement proceedings.  The court disagreed, finding that “[w]ith OSHA’s authority to investigate, comes the authority to require production of evidence and to obtain court enforcement of subpoenas seeking such evidence.”  See the district court’s opinion in Solis v. Grinnell Mutual Reinsurance Co.
OSHA has made it a habit of requesting from employers and third parties during workplace inspections, copies of safety audit reports from third parties (e.g., insurance companies, consultants, etc.), and using the audit reports to the detriment of employers.  OSHA uses the findings from such safety audits as a roadmap to steer their inspections, and references uncorrected audit findings as evidence:
  1. to support citations;
  2. of the required showing of employer knowledge of violative conditions; and
  3. of willfulness.
Following the Grinnell case, we know that OSHA has authority to access such audit records unless the audit was conducted under the protection of the attorney-client privilege.  In order to properly invoke the attorney-client privilege today, employers should seek the legal opinion of counsel with regard to OSHA compliance issues, and have counsel either personally conduct the audit or direct a third party consultant to provide expert, technical assistance to the attorney.  The consultant should obtain information about the employers’ programs, procedures, and physical conditions at the plant directly from the employer, rather than gathering that information independently (i.e., any physical inspection or observations should be made in conjunction with a company representative, who points out and explains operations and equipment to the third party auditor).  The audit report should be delivered to counsel, who in turn must use the report to deliver legal advice based on the technical information provided by the consultant (i.e., a memorandum to the employer describing legal compliance issues and attaching the report).

Monday, March 5, 2012

SonicAire Combustible Dust Cleaning Demonstration

There are few options when it comes to combustible dust cleaning. Here is one option you may want to consider. This video, from our friends at IES, shows the power of fan cleaning technology. The first part of the video actually shows you the combustible dust problem "before" picture when the fan is first turned on, and then when an "after" shot with the rafters and walls clean after the fan has been running. As you can see in the first part of the video there is a dust cloud created (NOT recommended), because this customer had not cleaned just prior to turning the fan(s) on as recommended, but 3 weeks prior. The second part of the video shows what your plant could look like with this technology, clean, dust free, as this system actually creates a barrier of air on all surfaces the fan is aimed at, as it oscillates and rotates. We all know there is no real good and cost effective way to keep manufacturing facilities clean of combustible dust, that cleaning with low pressure air when all ignition sources are off, or vacuuming can be labor and cost intensive. These fans can create a dust clean barrier on ceilings, rafters, beams, and walls once installed. If you would like more information, please call 770-266-7223, or email info@IndustrialFirePrevention.com

Thursday, March 1, 2012

Panel & Engineered Lumber International Conference & Expo

Panel & Engineered Lumber International Conference & Expo

Come see us at the Bioenergy Conference and Expo,
and the PELICE Panel and Engineered Lumber Conference and Expo
this week at the OMNI in Atlanta!

About | Bioenergy, Fuels and Products Conference & Expo

About | Bioenergy, Fuels and Products Conference & Expo

Come see us at the Bioenergy Conference and Expo,
and the PELICE Panel and Engineered Lumber Conference and Expo
this week at the OMNI in Atlanta!