Gulftech Enterprises, Inc

The final rule that is effective Nov. 30, 2010, adds them to the section 313 list of toxic chemicals, as EPA proposed in April 2010.

Nov 29, 2010
EPA published a final rule Nov. 26 adding 16 chemicals to the EPCRA section 313 list of toxic chemicals, as the agency had proposed in April. Each of the 16 chemicals meets the listing criteria under EPCRA section 313(d)(2)(B) — the chronic human health effects criteria — the agency determined.

The chemicals being added individually are: 1-amino-2,4-dibromoanthraquinone; 2,2-bis(bromomethyl)-1,3-propanediol; furan; glycidol; isoprene; methyleugenol; o-nitroanisole; nitromethane; phenolphthalein; tetrafluoroethylene; tetranitromethane; and http://www.cdc.gov/niosh/npg/npgd0660.html” target=”_blank”>vinyl fluoride. These chemicals are being added to the category for polycyclic aromatic compounds: 1,6-dinitropyrene; 1,8-dinitropyrene; 6-nitrochrysene; and 4-nitropyrene. This PACs category is a category of persistent, bioaccumulative, toxic chemicals, so it has a lower reporting threshold of 100 pounds.

This final rule takes effect Nov. 30, 2010, and applies for the reporting year beginning Jan. 1, 2011 (meaning for the reports due July 1, 2012). The docket for EPA’s action at www.regulations.gov is Docket ID No. EPA-HQ-TRI-2010-0006.

All 16 chemicals have been classified “Reasonably Anticipated To Be Human Carcinogen” by the National Toxicology Program in its 11th Report on Carcinogens (RoC) document. EPA determined they are expected to be manufactured, processed, or used in quantities that will exceed the EPCRA section 313 reporting thresholds; EPCRA section 313(d)(2) says EPA may add a chemical to the list if any of the listing criteria in Section 313(d)(2) are met. The 313(d)(2) criteria are:

(A) The chemical is known to cause or can reasonably be anticipated to cause significant adverse acute human health effects at concentration levels that are reasonably likely to exist beyond facility site boundaries as a result of continuous, or frequently recurring, releases.

(B) The chemical is known to cause or can reasonably be anticipated to cause in humans: cancer or teratogenic effects, or serious or irreversible–

(I) reproductive dysfunctions,

(II) neurological disorders,

(III) heritable genetic mutations, or

(IV) other chronic health effects.

(C) The chemical is known to cause or can be reasonably anticipated to cause, because of

(i) its toxicity,

(ii) its toxicity and persistence in the environment, or

(iii) its toxicity and tendency to bioaccumulate in the environment,

a significant adverse effect on the environment of sufficient seriousness, in the judgment of the Administrator, to warrant reporting under this section.

Tax incentives for manufacturing companies just went up!

Small Business Jobs Act of 2010, H.R. 5297 was passed by the House and Senate and signed into law by the President on September 27, 2010.

1. Extends and doubles Section 179 expensing – was $250,000 now $500,000.

The extension is retroactive to January 1, 2010. Section 179: This deduction now allows a company to deduct the first $500,000 of equipment (Section 179 Property) purchased in 2010 or 2011 from their taxable income. For companies purchasing (or leasing with a $1.00 buyout lease) up to $2,000,000 of equipment in 2010 or 2011, this deduction is available in full. It then phases out on a dollar-for-dollar basis between $2,000,000 and $2,500,000 and it is not available for companies purchasing over $2,500,000 of equipment in 2010 or 2011. However, companies can finance purchases over $2,000,000 with an operating lease and may still be able to claim this deduction. Always talk to your accountant to confirm eligibility of tax benefits.

2. Extends bonus depreciation

The new law extends, through December 31, 2010, 50% first-year bonus depreciation, which had expired at the end of 2009. The extension is retroactive to January 1, 2010. The new law carries a very short window of opportunity — qualifying equipment must be purchased and placed into service on or before December 31, 2010. Always talk to your accountant to confirm eligibility of tax benefits.

Note – Smaller manufacturing companies intending to maximize tax write-offs and acquiring less than $500,000 in equipment per year in 2010 or 2011 would typically only utilize the Section 179 deduction and not the bonus depreciation. Larger companies that acquire more than $2,500,000 in equipment in 2010 would typically utilize bonus depreciation instead of Section 179 deduction. Companies that acquire more than $500,000 in equipment and less than $2,500,000 would typically use a combination of both.

3. Acquire a machine in 2010 or 2011 and get a tax refund against taxes paid in the previous five years.

Allows five-year carry backs of NOL (net operating losses) resulting from Section 179 and Bonus Depreciation (Bonus 2010 only) -The new law extends the carryback period for eligible small business credits to five years. An eligible small business for purposes of the enhanced general business credit is a corporation whose stock is not publicly traded, a partnership or a sole proprietorship. Additionally, the average annual gross receipts of the corporation, partnership, or sole proprietorship for the prior three tax year periods cannot exceed $50 million. Always talk to your accountant to confirm eligibility of tax benefits.

The following are items taken from the new Standard to which I have received many questions.  The intent of this paper is to highlight the items that are most violated. This brief is not intended to replace the actual standard which has much more information on combustible metals.  By law any company who processes these metals are required to have this manual on premises. To order go to http://catalog.nfpa.org

Chapter 3 Definitions

3.3.6* Combustible Metal Dust.  Any finely divided metal 425 microns (40 mesh or 0.0165”) or smaller.

3.3.8 Deflagration.   Propagation of a combustible zone at a velocity that is less than the speed of sound in the unreacted medium.

3.3.13 Fines

3.3.13.1 Aluminum fines.  The fraction of an aluminum powder that is 45 microns (325 mesh) or smaller in nominal diameter, either as a discrete particle or as an agglomerate of discreet particles.

3.3.13.2 Magnesium fines.  The fraction of an aluminum powder that is 44 microns (320 mesh) or smaller in nominal diameter, either as a discrete particle or as an agglomerate of discreet particles.

3.3.13.3 Tantalum fines.  The fraction of an aluminum powder that is 10 microns  or smaller in nominal diameter, either as a discrete particle or as an agglomerate of discreet particles.

3.3.13.1 Titanium or Zirconium fines.  The fraction of an aluminum powder that is 44 microns (320 mesh) or smaller in nominal diameter, either as a discrete particle or as an agglomerate of discreet particles.

Chapter 6 Aluminum

6.1.9.10.1* Blades and housings of fans used to move air or inert gas in conveying ducts shall be constructed, non-sparking metal such as bronze, nonmagnetic stainless steel or aluminum.

6.3.2. Dust-producing operations

 

6.3.2.1 Machines that produce fine particles of aluminum shall be provided with hoods, capture devices, or enclosures that are connected to a dust collection system having suction and capture velocity to collect and transport all the dust produced.

6.3.2.4 Grinding operations shall not be served by the same dust collection system as buffing and polishing operations.

6.3.2.5 Dry-type dust collectors shall be located outside of buildings.

6.3.2.5.1 Individual machines with portable dust collection capability shall be permitted to be used when the object being processed or finished is incapable of being moved  to a properly arranged fixed hood or enclosure and shall incorporate the safe guards in 6.3.2.5.1 (A) through (D)

(A) The operation of portable dust collection devices shall be subject to a hazard analysis to ensure that the risk to personnel and operations from flash fire and shrapnel is minimized.

(B) Personnel protective clothing shall comply will 6.6.2

(C) The collector shall be designed to dissipate static electricity.

(D) Collector retention capacity shall be limited to 0.45 kg (1 lb.)

6.3.2.5.2 Dry type dust collectors shall be provided with barriers or other means for protection of personnel.

6.3.2.5.3 The area around the collector shall be posted with a sign that reads as follows:

CAUTION: This dust collector can contain explosive dust. 

Keep outside the marked area while equipment is running.

 

6.3.2.6 Dust collection systems shall be dedicated to the collection of aluminum and aluminum alloy dust only.

 

6.3.2.6.1 Grinders, buffers, and associated equipment with dust collectors utilized for processing aluminum shall be provided with a placard that reads as follows:

WARNING: Aluminum Metal Only – Fire or Explosion can results with other Metals

 

6.3.2.6.2  If the combustible aluminum dust collection system is to be used for other materials, the system shall be disassembled and thoroughly cleaned of all incompatible material prior to and after it use.

 

6.3.3 Dust Collection Ducts and Ductwork

 

6.3.3.1 All duct work to be installed per NFPA 91.

 

6.3.3.2 Ducts shall be designed for maintain a velocity of not less than 4500 ft/min or (1364 m/min).

 

6.3.3.6 Duct systems, dust collectors and dust producing machinery shall be bonded and grounded to minimize static electrical charge.

 

6.3.4 Wet type dust collector

 

6.3.4.1 The exhaust vent shall terminate outside the building and be securely fastened.

 

6.3.4.1.1 The duct shall be as short and straight as possible and shall be designed to withstand the same explosion pressure as the wet-type dust collector.

 

6.3.4.1.2 The cleaned air shall be permitted to be returned to the work area where tests conducted by an approved testing organization prove that the collector’s efficiency is great enough to provide safety to both personnel and property with regards for particulate matter in the cleaned air stream and accumulations of particulate and hydrogen within the work area.

 

6.3.4.3 Location of dust collector

 

6.3.4.3.2 The blower shall be located on the clean air side of the collector

 

6.3.4.4 The dust collector shall be arranged so that the dust laden airstream is thoroughly scrubbed by the liquid to achieve the desired efficiency.  The use of additional dry filter medium either downstream or combined with the wet collector shall not be permitted.

 

6.3.4.6 Collector Sump Venting

 

6.3.4.6.1 The sump of water wet type dust collectors shall be ventilated at all times.

 

6.3.4.6.2 Vents shall remain open and unobstructed when the machine is shut down.

 

6.3.4.6.3 When the dust collector is not in operation, ventilation shall be permitted to be provided by an independent blower or by an unimpeded vent.

 

6.3.4.7 Power Supply

 

6.3.4.7.1 The power supply to the dust-producing equipment shall be interlocked with the airflow for the exhaust blower and the liquid level controller of the dust collector so that improper functioning of the dust collection system will shut down the equipment it serves.

6.3.4.7.2 A time delay switch or equivalent device shall be provided on the dust producing equipment to prevent the starting of the motor drive until the collector is in complete operation.

 

6.3.4.8 Disposal of Sludge

 

6.3.4.8.3 Sludge shall be permitted to be mixed with inert materials in a ratio of at least 5 parts inert material to one part sludge.

 

6.3.5 Dry type dust collectors

 

6.3.5.1 Electrostatic collectors shall not be used.

6.3.5.2 Dust collecting filter medium shall be designed to be conductive so as to dissipate static electrical charges.

 

6.3.5.3 Dry-dust collection systems shall be designed and maintained so that internal cleanliness is ensured. The accumulation of material inside any area of the collector other than in the discharge container designed for that purpose shall not be permitted.

 

6.3.5.5 Dust shall be removed from dry collectors at least once each day and at more frequent intervals if warranted.

 

6.3.5.5.1 Extreme care shall be taken in removing dust from the collectors, to avoid creating dust clouds.

 

6.3.5.5.3 Waste material shall me mixed with an inert material in a volume ration of five parts inert material to one part metal dust.

 

6.3.5.6 Dry collectors used for combustible aluminum dust shall be provided with deflagration vents.  The selection of the type and location of the vents or weak section of the collector shall be designed to minimize injury to personnel and to minimize blast and fire damage to nearby equipment or structures.

 

6.3.6 Recycling of exhaust air.  Recycling of air from a dry dust collector into a building shall be prohibited.

 

6.4.3 Vacuum Cleaning Systems

 

6.4.3.4 Portable vacuum cleaners shall be used only if listed and approved for use with combustible aluminum dust.

Chapter 10 Titanium

10.4 Machining, Fabrication and finishing of parts

10.4.1.2  Operations in which titanium is subjected to processing or finishing shall include and shall not be limited to grinding, buffing, polishing, sawing, and machining of solids.

10.4.4 Titanium, Dust Collection

10.4.4.1.2 The hoods or enclosures shall be connected to liquid precipitation separators (wet-type dust collectors) and the suction unit shall be installed so that the dust is converted to sludge without contact, in the dry state, with any high speed moving parts.

10.4.4.2.2. Ducts shall be fabricated and installed in accordance with NFPA 91.

10.4.4.4  If the combustible titanium dust collection system is to be used for other materials, the system shall be disassembled and thoroughly cleaned of all incompatible material prior to and after it use.

 

10.4.4.5  Grinders, buffers and associated equipment with dust collectors utilized for processing titanium shall be provided with a placard that reads as follows:

Caution

Current Use: Titanium Metal-

Fire or Explosion can result with other Metals

 

 

10.4.6.2 Ducts shall be designed to maintain a velocity of not less than 4500 ft/min or (1364 m/min).

10.4.4.6 Power Supply

 

10.4.4.6.1 The power supply to the dust-producing equipment shall be interlocked with the airflow for the exhaust blower and the liquid level controller of the dust collector so that improper functioning of the dust collection system will shut down the equipment it serves.

10.4.4.6.2 A time delay switch or equivalent device shall be provided on the dust producing equipment to prevent the starting of the motor drive until the collector is in complete operation.

10.4.7 Wet type dust collector

 

10.4.7.1 The exhaust vent shall terminate outside the building and be securely fastened.

 

10.4.7.1.1 The duct shall be as short and straight as possible and shall be designed to within stand the same explosion pressure as the wet-type dust collector.

 

10.4.7.1.2 The cleaned air shall be permitted to be returned to the work area where tests conducted by an approved testing organization prove that the collector’s efficiency is great enough to provide safety to both personnel and property with regards for particulate matter in the cleaned air stream and accumulations of particulate and hydrogen within the work area.

 

10.4.7.2 The exhaust vent shall be inspected and cleaned frequently to prevent build-up of highly combustible deposits on the interior of the duct.

 

10.4.7.3 The dust collector shall be arranged so that the dust laden airstream is thoroughly scrubbed by the liquid to achieve the desired efficiency.  The use of additional dry filter medium either downstream or combined with the wet collector shall not be permitted.

10.4.7.4 The blower shall be located on the clean air side of the collector

10.4.7.5 The dust collector shall be arranged so that the dust laden airstream is thoroughly scrubbed by the liquid to achieve maximum efficiency.

 

10.4.7.6 Collector Sump Venting

 

10.4.7.6.1 The sump of water wet type dust collectors shall be ventilated at all times.

 

10.4.7.6.2 Vents shall remain open and unobstructed when the machine is shut down.

 

10.4.7.6.3 When the dust collector is not in operation, ventilation shall be permitted to be provided by an independent blower or by an unimpeded vent.

10.4.8 Dry type dust collectors

 

10.4.8.1 Electrostatic collectors shall not be used.

10.4.8.2 Dry-type cyclone shall be located outside of buildings

10.4.8.3 Dry dust collection systems shall be designed and maintained so that the internal cleanliness is assured.

10.4.8.4 The accumulation of material inside any area of the collector other than in discharge containers designed for that purpose shall not be permitted.

10.4.8.6 Dust shall be removed from dry collectors at least once each day and at more frequent intervals if warranted.

10.4.8.6.1 Extreme care shall take in removing dust from the collectors, to avoid creating dust clouds.

10.4.8.6.2 The dust shall be discharged into properly bonded and grounded metal containers that shall be covered promptly to avoid the creation of airborne fugitive dust.

10.4.8.6.3 Dry collectors shall be emptied before or when 100% of the storage capacity is attained.

10.4.8.6.4 The maximum volume of titanium fines collected before emptying shall not exceed 19 l or 5 gallons.

10.4.8.7 The cyclone dust collector shall be of conductive metal construction suitable for the service intended.

10.4.8.7.1 The cyclone dust collector shall be solid weld and with ground smooth internal seams.

10.4.8.7.2 The equipment shall be provided with a spark proof airlock on the hopper discharge and connected to a covered metal container.

10.4.9 Recycling of Exhaust Air. Recycling of air from dry dust collection into buildings shall be prohibited.

 

12.4.3 Vacuum Cleaning Systems

 

12.4.3.4 Portable vacuum cleaners shall be used only if listed and approved for use with combustible aluminum dust.

ANNEX A EXPLANATORY MATERIAL

A.3.2.2 AUTHORITY Having Jurisdiction (AHJ) The phrase “authority having jurisdiction” or its acronym AHJ is used in NFPA documents in a broad manner since jurisdiction and approval agencies as do their responsibilities. Where public safety is primary, the authority having jurisdiction may be a federal, state, local, or other regional departmental or individual such as a fire chief, fire marshal, chief of a fire prevention bureau, labor department, or health department; building official; electrical inspector; or others having statute authority.  For insurance purposes, an insurance inspection department, rating bureau, or other insurance company representative may be the authority having jurisdiction.  In many circumstances, the property owner or his or her designated agent assumes the role of the authority having jurisdiction; at government installations, the commanding officer or departmental official may be the authority having jurisdiction.

A.6.1.9.10.1 information on spark resistant fans and blowers can be found in AMCA standard no. 99-0401-86, “Classification for Spark Resistant Construction.”

A.6.1.9.10.4 Ultimately, all fans and blowers in dust collection systems accumulate sufficient powder to become a potential explosion hazard.

A.6.1.10.1 (selected excerpts)

………………………………………………..

Industry experience has clearly demonstrated that an eventual explosion can be expected where a bag or media type (cartridge) collector is used to collect aluminum fines.  Seldom if ever can the exact source of ignition be positively identified.  In those unusual instances when it becomes necessary to collect very small fines for a commercial product, it is customary for the producer to employ a bag or media (cartridge) type collector. With the knowledge that strong explosive potential is present, the producer will locate the bag or media (cartridge) type collector a safe distance from buildings and personnel.  ……………………………………………………………….This type of collector will be located at least 50 feet from any other building or operations.  …………………..Explosion venting must adhere to NFPA 68, Standard on Explosion Protection by Deflagration Venting.

A.6.5.2.4 Experience has shown that dry sodium Chloride is one of the most effective chemical for containing fires involving aluminum.

A.6.5.2.6.3 Class B extinguishing agents usually will greatly accelerate combustible aluminum dust fires and can cause burning metal to explode.

A.7.3.2.4.2 See “Industrial Ventilation: A Manual of Recommended Practice,” figure 4 14, range of particle size, Concentration, and Collector performance.  One pound is equivalent to 7000 grains. 

 

BRIEF OVERVIEW OF IMPORTANT ITEMS FROM THE NEW NFPA 68 Standard on Explosion Protection by Deflagration Venting

OSHA Issues New Combustible Dust Instruction

1. Prior to this NFPA 68 was a guideline and now it is a standard.  Therefore insurance companies and local fire codes will accept this as its legal code, unless the AHJ (AUTHORITY Having Jurisdiction) specifies another safety approach such as Factory Mutual guidelines.  OSHA will enforce the NFPA standard EN14491 as it mandatory code.

 

1. The AHJ (AUTHORITY Having Jurisdiction) is anyone where public safety is a concern.  This can be the fire marshal, labor department head, health department, safety inspector and etc. or just about anyone who has authority to make policy.  However and change from the stated conditions would require a waiver from the company stating the dust is not explosive or that they want us to comply with Factory Mutual.

 

1. Chapter 1 Administration 1.3 unless the customer can prove in writing their dust is not explosive, all dust collectors will have explosion vents.

 

1. Under Chapter 4.2.3.1 Hazard analysis will require a company keeping records of whether their dust in explosive or not.  In other words, the end user must submit his dust to an independent lab of analysis.

 

1. Chapter 5 stated if you can prove another method is acceptable to protecting the device from explosions that is acceptable to the AHJ, you can use that method.

 

1. Chapter 6 states the end user must know the Kst value for his dust.  It must be tested and certified unless it is a know substance where the Kst is a published value.

 

These are just a few of the highlights.  Please obtain the actual standard at http://www.osha.gov/OshDoc/Directive_pdf/CPL_03-00-006.pdf.

Sites to visit

http://www.osha.gov/dts/shib/shib073105.html

http://www.osha.gov

www.nfpa.org

4/5/10

Recent news of composite dust standards not being met.

OSHA has cited Fibrelite, a manufacturer of composite manhole covers, for 21 alleged violations of workplace safety standards at its plant in Pawcatuck, Conn. The company faces a total of $90,500 in proposed fines, chiefly for potential fire and explosion hazards…[...]

Read more here

Gulftech Enterprises, Inc. will be exhibiting the new “Hydroxyl” technology at the AHR 2010, Orlando, January 25 – 27 at the Orange County Convention Center. Please visit booth #4374 to learn how this technology can remove odors, kill bacteria, molds, fungus, MRSA, H1N1 with out dangerous chemicals such as ozone. This new “Green Technology” offers superior benefits over conventional cleaning and deordorizing methods.

Kyzen Corporation wins 2009 Global Technolgy Award for new product Cybersolv-141 for precision cleaning of electronic components and other metals.

From their press release;

NASHVILLE — November 2009 — Kyzen announces that it has been awarded a Global Technology Award in the category of Cleaning Materials for its CYBERSOLV® 141-R Precision Cleaner. The award was presented to the company during a Tuesday, November 10, 2009 ceremony that took place at the New Munich Trade Fair Center in Munich, Germany.

CYBERSOLV® 141-R is designed for optimum effectiveness on a wide variety of soils typically found in electronics assembly and maintenance cleaning applications including flux, paste, inks, uncured adhesives, waxes, mill markings, greases, oils, fingerprints, etc. It is the most effective bench top cleaner on the market, capable of cleaning all types of solder paste and many SMT adhesives. Better cleaning means better quality, due to lower residues and fewer failures.

Kyzen is one of Gulftech’s premier product lines due to thier excellent factory and technical support for the metal working industry.

Current aluminum, magnesium, titanium, and zircromium dust standards from OSHA.

Reference NFPA 484 for standard operating procedures.