Redesigning Process Chute Air Contaminant Control of Total Particulate and Carbon Dust

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Redesigning Process Chute - Air Contaminant Control of Total Particulate and
Carbon Dust

In order to achieve compliance with MIOSHA’s Part 301. Air Contaminants for General Industry Standard, an employer shall first determine if administrative and/or engineering controls can be and implemented, whenever feasible. Engineering controls are the preferred compliance method. Administrative controls are often not sustainable based on assigned employee work activities and production demands. When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used, pursuant to Part 451 Respiratory Protection.

One Michigan employer initially had employee exposures to carbon dust that exceeded the eight-hour time weighted average (TWA) permissible exposure limit (PEL) for Particulates not otherwise regulated (Total Particulate); which is 15 mg/m3. The TWA air sampling results for the two employees sampled were 55.3 mg/m3 and 54.2 mg/m3, respectively. Employees were then required to wear respirators with particulate cartridges; until engineering controls could be implemented.

Through the employer’s diligent problem solving efforts, they were able to redesign the feeder chute on their process that dispensed the carbon material. The redesigned feeder chute reduced the amount of carbon and particulate material that was applied to the air filters they were manufacturing.

This process improvement had minimal cost associated with it and resulted in the following benefits:

  • Reduced employee TWA exposures to 5.5 mg/m3 and 4.9 mg/m3 (well below the PEL), by reducing the amount of dust generated from processing excess material.

  • Respiratory protection went from required use to voluntary use.

  • Reduced material cost by reducing the amount of carbon and particulate material that needed to be applied the product they manufacture.

  • Employee time savings associated with eliminating the need for employees to trim off the excess carbon and particulate containing filter material and subsequently, process and recycle this excess impregnated filter material.

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