Monday, December 29, 2008

Grain Facility Explosion in Arizona

Update : Reports of a welder on top of the silo, moments prior to the explosion

Just how well is the OSHA Grain Facility Standard working? Only through media accounts is it possible to ascertain the magnitude of combustible dust related fires and explosions in the grain and manufacturing sectors. Possibly someday an anonymous incident reporting system can be implemented by all stakeholders where the probability and severity of incidents can be understood in the development of process safety information for a thorough process hazard analysis.

The dust explosion at Arizona Grain brings to question the hot work permit system as outlined in the OSHA Grain Facility Standard 29 CFR 1910.272 . For instance, the employer shall issue a permit for all hot work, with the following exceptions:

1910.272(f)(1)(i) -Where the employer or the employer's representative (who would otherwise authorize the permit) is present while the hot work is being performed.

1910.272(f)(1)(iii) In hot work areas authorized by the employer which are located outside of the grain handling structure.

So is it okay to conduct hot work adjacent to an explosive atmosphere when the employer's representative is present.? What is the difference if a representative is present or not? Combustible dust will explode or deflagrate either way once an ignition source is present.

Reviewing the OSHA Welding, Cutting, and Brazing Standard, 1910 Subpart Q provides a more clearer approach to lessening the probability of fire/explosion incidents. The current OSHA Grain Facility Standard needs to be reviewed in conjunction with the OSHA Welding Standard in regards to the exception previously cited, to ensure incidents are prevented and mitigated.

In the meantime NFPA 51B: Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, should be required reading for all stakeholders that conduct hot work in the vicinity of combustible particulate solids that generate combustible dust. Click here to review standard

NFPA 68 Standard on Explosion Protection by Deflagration Venting, Annex E & F is an excellent resource in understanding how the overpressure characteristics are not to be ignored. In many instances the Pmax and Kst (deflagration index) of combustible dusts is similar to Pmax and Kg (deflagration index) of flammable gases. This alone, is proof that there should be no confusion in developing a single combustible dust regulation for the variety of combustible dusts found throughout the manufacturing, non-manufacturing, utility, and grain sectors.

Video CBS Channel 5 News
Series of Explosions
Prior Conveyor Belt Fire
Google Map Grain Facility Explosions & Fires 2008

Sunday, December 21, 2008

Milk Powder Combustible Dust Hazards

It's been nearly two months now since the California Dairies Inc facility in Visalia, Ca experienced an explosion in the milk hydrator. According to news accounts, "the explosion blew out a "blowout panel" in the five story tower but the structure itself was safe." This is an excellent example how an industry leader in the United States implements good engineering practices in reducing the severity of a combustible dust explosion where ignition sources are readily present.

Another example of proactive measures, is the dairy industry in New Zealand, which is a global leader in milk powder production. In a recent discussion with Dr. Chris Bloore, Dairy Industry Systems Consultant, in Dunedin, New Zealand highlighted that back in 1988 the dairy industry, Insurance Council, Labour Department and Fire Service got together and after 2 years of meetings and discussions arrived at the Appoved Code of Practice for the Prevention, Detection and Control of Fire and Explosion in New Zealand Dairy Industry Spray Drying Plant (1990).This is available for FREE download as a .pdf

The New Zealand Department of Labor's web page on Approved Code of Practice notes that:

An approved code does not have the same legal force as a regulation, and failure to comply with a code of practice is not, of itself, an offence. However, observance of a relevant code of practice may be considered as evidence of good practice in a court.

Dr. Bloore emphasized, "that
the NZ dairy industry earns about 25% of the country's export income, and nearly half that comes from powders. We make over 1.1 million tonnes (about 2.2 billion pounds) of milkpowder each year, so the rate of explosions per pound is not high. The cost per explosion ranges from a few thousand dollars up to US$15 million."

In addition to
whole milk powder (WMP or Full cream Milk Powder FCMP) and skim milk powder (SMP or Non Fat Dried Milk). Dr Bloore notes, that New Zealand manufactures several tens of thousands of tonnes each of :

  • Buttermilk powder (BMP)
  • Milk Protein Concentrate (MPC) powder
  • Whey Protein Concentrate (WPC)
  • nutritional powders (infant formula, growing up milks etc.)
"These bring the total tonnage to around 1.1 million tonnes per year, which New Zealand exports virtually 100% of powder production. The local consumption is restricted to calf food powders and small volumes of powders as food ingredients and some body building and health related products," says Dr. Bloore

The above example in New Zealand where the fire service and insurance sector works collectively with stakeholders in labor, business and government in seeking a potential solution in lessening the likelihood and reducing the severity of combustible dust related fires and explosions might be of interest to stakeholders here in North America.

For additional information on Case Studies and Principles, Prevention, Detection and Control of fire and explosion hazards in milk powder production, the Combustible Dust Policy Institute recommends the training pamphlets that Dr. Chris Bloore has available for purchase. Contact Dr. Bloore at who will also be a keynote speaker April 15-17, 2009 at the 4th International Symposium of Spray Dried Dairy Products in Melbourne, Australia.

Resources :

NZ Code of Practice in Spray Drying

Conventional Spray Drying Concept

World Dairy Production Trends

Top Five World Milk Powder Producers

U.S. Dairy Export Council

Milk and Milk Products: A Global Market Analysis

International Symposium on Spray Dried Products 15-17 April 2009

Tuesday, December 16, 2008

Spark Detection Systems-Podcast #4

Click Player for Podcast

Allen Wagoner, V.P. at Flamex and Bob Barnum, V.P Sales at GreCon Inc., discuss important aspects of spark detection engineering controls in lessening the probability and reducing the severity of combustible dust related fires and explosions at facilities.

Over the past year the Combustible Dust Policy Institute has found through media accounts over 130+ combustible dust related fires and explosions. Many of these incidents could have been prevented and mitigated with proper engineering controls as referenced in the NFPA Combustible Dust Standards. Concerning fire and explosion protection for process equipment, NFPA 654 lists several protection methods such as:

  • Oxidant Concentration Reduction
  • Deflagration venting
  • Deflagration pressure containment
  • Deflagration suppression
  • Dilution with non-combustible dust
  • Deflagration venting through a dust retention and flame-arresting device

In today’s podcast, we’ll discuss fire and explosion protection methods utilizing spark detection and extinguishment. Spark detection systems are used in dust collectors and pneumatic conveying systems to detect and extinguish sparks and embers.

Click Picture for Animation

Photo Credit: GreCon
The applications listed above are for example only. Qualified personnel must design suitable pneumatic conveying, electrical, and plumbing systems to local regulations, plant equipment and requirements. The drawings shown below may not meet the needs all facilities, but these drawings demonstrate how spark detection systems can be used in similar applications with the appropriate design


NFPA 654 Combustible Dust Standard
Flame Detection Tutorial-Sense Ware
Infrared Radiation

Combustible Dust: Threat to First Responders

BlogTalkRadio host Lieutenant Raymond E. Foster, LAPD (ret.), at the Watering Hole will feature a discussion Friday evening 9:00PM PST, December 19, 2008 with John Astad and Justin Clift, Industrial Market Specialist at Hazard Control Technologies on Combustible Dust Hazards that are unknowingly present when emergency responders respond to combustible dust related fires and explosions in the manufacturing, non-manufacturing, utility sectors.

In the past, fire-fighter fatalities and injuries have occurred when responding to these incidents. These occurrences could have been prevented if responders understood the hidden and unknown dangers of combustible dust found throughout the diverse multitude of manufacturing facilities.

Currently a situational awareness is lacking nationwide that combustible dust also poses a potential explosive atmosphere in the same light as flammable gases, vapors, and mists. Instead of vapor cloud or BLEVE explosions that occur in the refining sector there are deflagrations and dust explosions in the manufacturing sector.

Listeners can call in live Friday evening toward the end of the show by dialing the Call-in Number: (646) 378-1513.


4th Annual Industrial Fire, Safety, and Security Conference (IFSS 2009) Combustible Dust Hazard Workshop Feb. 3-4 2009 Houston, Texas at the Reliant Center (next to the Astrodome)

2. Global Malt Explosion-1 Fire-fighter fatality/7 injuries

3. Six Stockton, Ca firefighters slightly hurt in plant explosion

4. BlogTalkRadio

Thursday, December 4, 2008

House-Keeping: Combustible Dust Hazards-Podcast#3

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I like to welcome Jon Barrett a graduate from Temple University and Business Development Specialist at Interior Maintenance Company, Inc. to ComDust Podcast #3. We had the opportunity to discuss the importance of regular housekeeping at facilities that accumulate combustible dust during the manufacturing process.

Interior Maintenance Company, Inc.(IMC) located in Lansdowne, PA serving the Mid-Atlantic Region since 1973.was founded in by Chuck and Maria Mongiello, for the purpose of providing quality contract cleaning services for commercial facilities. Joined by sons Chuck in 1986 and Matt in 1990, IMC remains a family owned and operated business employing over ninety dedicated associates.

Housekeeping is an important aspect at any facility that handles combustible particulate solids that generate combustible dust. A regular cleaning program minimizing the fuel source must be implemented which lessens the likelihood and reduces the severity of potential combustible dust related fires and explosion.

Surfaces such as rafters, ceiling trusses, piping, conduit, lighting, ductwork, and other flat surfaces that accumulate combustible dust, fibers, and flings must be cleaned on a regular basis. In large facilities these hidden areas can encompass over 5% of the facility, enough to create a catastrophic dust explosion when a weaker primary explosion or deflagration creates a disturbance where these particles will float down meeting an ensuing flame front.

Good Housekeeping
View SlideShare presentation or Upload your own. (tags: combustible dust)

Utilizing high reach and high lift mechanized equipment, along with ladders and scaffolding, IMC technicians are able to safely access the above areas. Safety is IMC's main concern, and all IMC technicians are trained to perform the work in compliance with OSHA Standards requiring the proper Fall Protection and the use of safety harness' and lanyards.

Cleaning is typically performed by using HEPA-filtered vacuums with attached brushes to provide surface cleaning of loose particulate debris. Wet wiping, or wiping with a chemically treated cloth, are also methods utilized to control the dust and debris from cross contaminating into other areas.

Give IMC a call for a combustible dust hazards evaluation concerning your next cleaning schedule.

Wednesday, December 3, 2008

Fire-Fighter Combustible Dust Hazards Workshop

Unknown hidden dangers are posed on emergency responders when responding to combustible dust related fires and explosions are addressed at the Combustible Dust Hazard Workshop during the 4th Annual Industrial Fire, Safety, and Security Confere
February 3-6 2009 @ Reliant Center (next to the Astrodome) Houston,Texas.

Here is recent example of fire-fighter injuries responding to combustible dust related fires Currently, MSDS's do not have the vital fire/explosion hazard data concerning the explosive severity and ignition sensitivity of combustible dusts generated from combustible particulate solids.

Sunday, November 30, 2008

Malt Silo Explosion in Germany kills 1, injures 7

Here in the USA we all pray for the families and emergency responders that experienced a tragic event quite similar to the Imperial Sugar Refinery dust explosion at Port Wentworth, Georgia in Feb. 2008. The German news account stated, "There was a first explosion at 07.00 AM causing the fire fighters to rush in, then at 09.00 AM there was in the midst of firefighting activities a second explosion, fatal for one fire fighter, injuring 7 others." Sounds eerily familiar, a more deadly secondary explosion.

Combustible dust related fires and explosions are a constant threat to fire-fighters responding to such events. In many instances the hazards of seemingly harmless combustible particulate solids that generate combustible dust are unknown.

The explosion severity of many combustible dusts are quite similar to flammable vapors, liquids, and gases. Currently many national manufacturing industries in the USA have not acknowledged this fact.

This catastrophic event in GLOBAL MALT GMBH & CO KG, in Germany should be a wake up call for stakeholders in the USA in following similar process safety management (PSM) programs that are required by OSHA at petrochemical refineries where a thorough process hazard analysis is conducted, which identifies, evaluates, and institutes control measures in lessening the occurrence and reducing the severity of future events.

Note: You can easily translate from German to English if add the Google Toolbar to your browser. Click the link for free download

Photo Credit: SWR


Brewing Process-
Dave Statter's Blog: STATter 911

German News Article
Aftermath Pictures

Friday, November 28, 2008

Combustible Dust Hazards Facility Evaluations: Podcast #2

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Identifying combustible dust hazards at a facility is the first step in in conducting a thorough risk assessment of what can go wrong in addition to the probability and consequence of combustible dust related fires and explosions. Brian Edwards a graduate of Georgia Institute of Technology with a B.S. Civil and Environmental Engineering and now Director of Engineering at Conversion Technology Inc. discusses the importance of a combustible dust hazard evaluation.

The Occupational Safety and Health Administration (OSHA) reissued the Combustible Dust National Emphasis Program following the catastrophic Imperial Sugar Refinery explosion. Subsequently, Conversion Technology, Inc. (CTI) offers combustible dust evaluations to ensure the safety of employees and the facility. Also, CTI offers site specific safety plans and training. CTI is available now to help companies ensure compliance with the OSHA Dust NEP.

Note: During the podcast I inadvertently mentioned combustible dust standards when
I should of correctly stated the OSHA Combustible Dust NEP. Currently there is no OSHA combustible dust standard.


Conversion Technology, Inc-Combustible Dust Safety Plans

Georgia: Rules and Regulations for Loss Prevention Due to Combustible Dust Explosions and Fire

Sunday, November 23, 2008

PSM Oriented Towards Dust Hazards?

A process safety management (PSM) oriented program that addresses combustible dust hazards in the manufacturing, non-manufacturing, and utility sectors needs to be implemented as it is in the chemical and refinery sectors. The main problem, is a disconnect concerning wood, food, paper, textiles, etc. process streams as not being considered like the 136 highly hazardous chemicals (HHC) as outlined in OSHA's Process Safety Management regulation (29 CFR 1910.119).

OSHA National Emphasis Programs (NEP)
Last year, the OSHA Combustible Dust National Emphasis Program (NEP) became effective four months after the Petroleum Refinery Process Safety Management (PSM) National Emphasis Program (NEP). There is a vast difference in the two OSHA NEP's with the goal of protecting the nations workforce and outlying communities from the harmful effects of industrial fires, explosions, and toxic releases.

In reviewing the background information for the Refinery PSM NEP, its disturbing when comparing and contrasting fatalities and catastrophes(FAT/CAT) between refineries and facilities that handle combustible particulate solids that generates combustible dust. For instance, on pg. 4 the Refinery NEP states:

"According to OSHA’s IMIS database, since May 1992, 36 fatality/catastrophe (FAT/CAT) incidents related to HHC releases in the refining industry have occurred. These incidents included 52 employee deaths and 250 employee injuries, 98 of these injuries required hospitalization."

Fatalities and Catastrophes (FAT/CAT)
Over the same fifteen year period, according to the results of the Chemical Safety Board Dust Hazard Investigation, there were over 95 fatalities and hundreds of injuries as the result of over 160 combustible dust related fires and explosions in the manufacturing, non-manufacturing , and utility sectors. Basically there are three times as many fatalities and catastrophes (FAT/CAT) in sectors that generate combustible dust than in the refinery sector.

Yet Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) and administrative control measures to protect the manufacturing workplace are dismally lacking. So is the rapidly diminishing manufacturing sector that provides a base for our national economic security even worth protecting? It doesn't seem so with the obvious inattention thats been misdirected elsewhere, to supposedly more urgent aspects of workplace occupational health and safety.

Highly Hazardous Chemicals (HHC)
Combustible dusts have similar explosion severity (Pmax, Kst) effects as flammable liquids, gases, and vapors concerning destructive overpressure, thermal radiation, and ensuing projectiles. Facilities that maintain processes with over 10,000 pounds of flammable liquids and gases must consider these products as highly hazardous chemicals (HHC) as outlined in the OSHA's Process Safety Management regulation (29 CFR 1910.119). So if combustible dusts have similar devastating explosive effects causing fatalities and catastrophes (FAT/CAT) like flammable liquids and gases, why aren't they listed as a highly hazardous chemicals(HHC)?

Wood, food, textiles, paper and many other seemingly harmless materials in manufacturing process streams are not considered toxic, reactive, or corrosive like the over 130 highly hazardous chemicals (1910.119 App A) under the Process Safety Management program. It's their combustible and explosive characteristics that need to be addressed as it is for flammable liquids and gases HHC (highly hazardous chemicals) in the OSHA PSM standards.

Recognizing the hazards of combustible dust is the first step through a process hazard analysis which is the foundation in lessening the occurrence and reducing the severity of future combustible dust related fires and explosions. Once the hazards are identified and evaluated control measures can be implemented in similar fashion as outlined in the OSHA Process Safety Management program. A few of the measures in the current PSM with debatable input to a possible Combustible Dust PSM include:

Operating Procedures
For instance, the implementation written operating procedures addressing operating limits with consequences of deviation with steps to follow to correct deviations such as high operating temperatures. These operating procedures must include safety and health considerations
concerning quality control for raw materials and control of dust emissions. Additionally, precautions necessary to prevent combustible dust related fires and explosions, which also includes engineering controls, administrative controls, and personal protective equipment.

Contractor Participation
A process safety management program would also require contractor participlation. Over the past year a large percentage of combustible dust related fires have involved contractors conducting hot work adjacent to process equipment. A Combustible Dust PSM would properly and proactively inform contract employers of the known potential combustible dust fire, explosion hazards related to the contractor’s work and the process. This would lessen the occurrence of future incidents.

Mechanical Integrity (MI)
Mechanical integrity (MI) issues in a Combustible Dust PSM, would address the potential ignition sources that cause combustible dust related fires and explosions at facilities. For instance duct work, dust collectors, dryers, mixers, blenders, ovens, bulk storage enclosures are reoccurring problem areas concerning combustible dust related fires and explosions.

The refinery sector Mechanical Integrity PSM program addresses pressure vessels and storage tanks, piping, relief and vent systems and devices, and emergency shutdown systems controls. In contrast the manufacturing sector has bulk storage enclosures (silos, bins), pneumatic conveying duct systems, air material separators (dust collectors), in addition to relief and venting with explosion ventilation panels in reducing the severity of dust explosions.

Implementing written procedures to maintain the integrity of the above process equipment would provide employees with an overview of the mechanical integrity process and the combustible dust hazards that have been identified in a prior process hazard analysis. Process equipment inspection, maintenance, and testing would also be a vital aspect in the MI at the facility where deficiencies can be addressed in a proactive manner.

Incident Investigation
Reoccurring incidents of combustible dust related fires and explosions have been a common theme in the manufacturing sector over the past year. This year, over 30% of incidents are repeats of prior fires and explosions at facilities. In many instance a combustible dust fire is a precursor to a a rare event, the combustible dust explosion.

Without proper incident investigation by the facility, the exact cause of the fire goes unnoticed and the combustilbe dust hazard remains present for the next preventable and predictable incident. A Combustible Dust PSM would identify the chain of events and causes where corrective measures
such as Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) can be developed and appropriately implemented.

Do I feel lucky?
The above examples are just a few proactive measures that could be crucial aspects of a Combustible Dust PSM that is similar to the current PSM utilized for facilities which process highly hazardous chemicals (HHC). Other measures in the PSM include Hot Work Permits, Emergency Planning and Response, Management of Change, and Compliance Audits. Many of the areas are already covered in the National Fire Protections Association (NFPA) combustible dust standards.

Until combustible dusts are recognized as having similar explosive severity characteristics as flammable liquids and gases (highly hazardous chemicals) of the current OSHA PSM, preventable and predictable combustible dust related fires and explosions will continue to occur. Hopefully on a bit of borrowed time the next rare event will not be in the magnitude of the recent Imperial Sugar Refinery dust explosion. Like
in the 1971 Dirty Harry movie, Detective Inspector Harry Callahan played by Clint Eastwood asks, "You've got to ask yourself one question: 'Do I feel lucky?"

Thursday, November 20, 2008

Grain Elevator Explosion-Nebraska

One person injured in elevator explosion

"The top of the head house blew up in the explosion and its skeletal remains are hanging off the top of the elevator. The headhouse is where the leg is contained that elevates grain to the top of the elevator." 11/20/08 Gothenburg Times

This is the third grain facility explosion in the United States, over the past two months. Luckily no fatalities. Click here for Google Map of prior grain facility combustible dust related fires and explosions.

So how well is the OSHA grain facility standard working? Maybe it's time to re-evaluate all combustible dust related fires and explosions, whether occurring in the grain sector or the manufacturing sectors. All explosions have similar effects of over pressure, thermal radiation, and ensuing projectile hazards. If the petrochemical refining sector has a process safety management program (PSM) that protects their facilities then maybe stakeholders should look into a similar program for the grain and manufacturing sectors. The question is, "just how important are these sectors for the nation's economic security?"

Wednesday, November 12, 2008

NAICS Awareness ComDust Hazards Alert

I'd like to thank David Osbon, Product Manager of Unifirst, a provider of flame resistant clothing (FRC's) and contributing author of the ComDust Blog in sharing the above pie chart that encompasses 60%, (over 18,0000) of the 30,000 letters that OSHA sent to establishments which were identified by OSHA as national industries (NAICS) that have imminent and inherent combustible dust hazard along with a copy of OSHA's Combustible Dust SHIB. .

In the March 2008 letter, OSHA urged employers to review the information in the Combustible Dust SHIB and reminded stakeholders of their responsibilities to minimize combustible dust hazards and lessen the severity of future incidents that are inherent in the manufacturing and non-manufacturing process. It also reminded them of the assistance OSHA's on -site Consultation Program can provide confidentially and free of charge.

There is a problem here that needs to be addressed concerning industry awareness of combustible dust hazards. Since the beginning of the year, through media accounts, theres been 14 combustible dust related fires and explosions in the Paper Manufacturing sector, yet in the above pie chart it highlights that this manufacturing subsector was not identified as having a combustible dust hazards when letters where sent out. Below you'll note another pie chart of combustible dust explosion over the past year in the various subsectors

Thats odd, especially, through media accounts, 7% of the ComDust explosions have occurred in the Paper Manufacturing sector. In no way is this meant to be derogatory to this vital national industry with over 6,000 establishments and over 400,00 dedicated and hard-working employees. The Combustible Dust Policy Institutes's goal is to provide a proactive awareness and work collectively in stategic alliances with all stakeholders in the public and private sectors.

An especially critical aspect of hazard awareness is the OSHA Combustible Dust NEP, where Paper Manufacturing sector is excluded as Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires and Industries that may have Potential for Combustible Dust Explosions/Fires.

The paper manufacturing sector which includes 16 national paper industries (NAICS), not one national industry (NAICS) is listed in the OSHA Dust NEP. It's like a snowball rolling down the hill as the plot gets bigger and bigger with four paper mill combustible dust related fires, three sanitary paper product manufacturing fires, and two combustible dust fires at corrugated solid and fiber box manufacturing plants.

It was only yesterday when a Paperboard Mill experienced a combustible dust fire when paper dust ignited on a dryer area and went into the pneumatic conveying system. The news account further stated, "in January, an overheated piece of machinery sparked a fire that spread along the ceiling." This is the problem, as over 30% of the 122+ combustible dust related fires and explosion are reoccurring repeats, which eventually end up as the rare event of a combustible dust explosion.

The paper sector is not alone as not being referenced in the Dust NEP as national industries (NAICS) in the wood, food, textile, chemical.plastic/rubber, primary metal, machinery , furniture, miscellaneous , and non-manufacturing are also not included. Maybe a potential solution is to utilize a watered-down version of OSHA's Process Safety Management (PSM) for combustible dust, which has similar characteristics in explosion severity (Kg, PMax) as do flammable liquids and gases referenced in the OSHA PSM.

Webinar-Evidence-Based Compliance (free)

This just in. A free webinar at 2:00 PM EST November 19, 2008, sponsored by MSDSpro and hosted by EHS Today magazine discussing OSHA Hazard Communication Standard. An added awareness must be projected to the industry concerning combustible dust hazard awareness. Currently MSDS's do not provide the vital ignition sensitivity and explosion severity data.

The Combustible Dust Policy Institute is developing a Co-Op combustible dust testing service between Users Groups and testing laboratories. If a multitude of stakeholders from a niche national industry (NAICS) desire testing all at once, then costs of testing can exponentially go down. Lets do it! I need feedback both negative and positive from all stakeholders to proceed further.

Join the Combustible Dust Policy Institute Group on LinkedIn for additional discussions on this topic. See you there.

Monday, November 10, 2008

Fireball Combustible Dust Deflagration

Here is an excellent example of the fireball effects when combustible wood dust finds an ignition source. Warning don't try this at home! These people have way to much time on their hands. Thanks Justin for sharing

Friday, November 7, 2008

Grain Facility ComDust Fires and Explosions

Since the Destrehan, Louisiana grain elevator explosion two weeks ago that put the ADM/Growmark's largest export terminal in Louisiana out of service, through media accounts, eight additional grain facility combustible dust related fires and explosions occurred throughout the nation. The financial damage from these events has totaled over $200,000 and luckily no injuries.

So is the OSHA grain facility standard working? It is not possible for OSHA with limited resources to inspect thousands of these grain handling facilities ensuring workplace safety compliance. Will it take a dust explosion in the magnitude of the catastrophic Imperial Sugar Refinery explosion this year to finally address the situation with additional governmental accident investigations, congressional hearings, and costly studies.

The clock is ticking and there is no time to waste. Combustible dust related fires and explosions in the grain handling facility or manufacturing, utility, and non-manufacturing sectors all have the same devastating effects.

The current combustible dust bill (H.R. 5522) awaiting a vote in the Senate needs to be reevaluated with provisions for all combustible dust related explosions and fires. Lets get our eggs all in one basket instead of the chaos that has engulfed the nation's workplace concerning combustible dust hazards.

Tuesday, November 4, 2008

Combustible Dust Explosions 2008

The recent grain elevator explosion in Louisiana last week brought back stark memories of over three decades ago, in 1977, when a series of similar dust explosions occurred in grain elevators throughout the south, which resulted in dozens of workplace fatalities. Fortunately in the recent explosion no injuries or fatalities were reported, just a lot of frayed nerves from nearby residents with electrical service briefly interrupted along the Mississippi River.

30 Combustible Dust Explosions
Over the past year, through media accounts, 30 combustible dust related explosions have occurred in the wood, food, chemical, metal, plastic, rubber, utility, and paper manufacturing sectors. On the western bank of the meandering Savannah River, workers weren't so lucky in escaping injuries or fatalities on the evening of February 7, 2008 when a catastrophic Imperial Sugar Refinery dust explosion occurred in Port Wentworth, Georgia. Subsequently, national media coverage created a much needed awareness concerning combustible dust hazards in the workplace.

Additionally, intense outrage amongst Democratic Congressional leaders responded with an emotionally drafted general industry combustible dust bill, which passed in the House, and now awaiting vote in the Senate. Results of the presidential election, with a potential shake-up of public policy concerning workplace health and safety will determine the future of the bill.

118+ Fires and Explosions
Unfortunately this year, the Imperial Sugar dust explosion was not an isolated incident. For instance over the past year, through media accounts, 118+ combustible dust related fires and explosions have occurred in the manufacturing, utility, and non-manufacturing sectors.

Trying to make sense of it all and why even dust explodes is an exercise in science combined with business and public policy across the vast ocean of the public and private sectors. The on-going tug of war between the interests of big business and labor complicates the matter even further in arriving at a cost effective solution in preventing future fatalities, injuries, and adverse economic damage.

Cursory Solution : Incomplete Data
Of major concern is how can public policy be created in Congress with ensuing OSHA health and safety regulation's if the extent of the problem is not completely evaluated? Costly governmental studies were completed, which resulted in federal directives that only provide a cursory solution to the combustible dust problem. In the meantime our nation's infrastructure in the manufacturing base is at threat from continuing preventable combustible dust related fires and explosions.

For instance the OSHA Combustible Dust National Emphasis (NEP) program is not even required in nearly half of the states with State OSHA Plans (strictly voluntary). That's only the tip of the iceberg, especially over the past year, where explosions and fires are occurring at facilities with dozens of NAICS not listed in the NEP.

Food Manufacturing
Reviewing the food sector, six out of the seven combustible dust explosions occurred in national food industries (NAICS) not listed in the NEP. With explosions occurring more than once at dehydrated food and evaporated diary product manufacturing plants. This is where a ComDust Hazard Alert goes out next, especially when these industries are not on the NEP radar. OSHA inspectors are actively inspecting these facilities as the following excerpt from a recent General Duty Clause (GDC) citation at a dehydrated food manufacturing plant in Wisconsin will illustrate:

"...The following C.O.W (cream of wheat) equipment did not have explosion/deflagration containment, suppression, inserting, or venting protection: a) Cooker room dust collector, approximately 375 cubic feet, was located inside the building lacking explosion venting. b) silo did not have explosion venting. d) pneumatic conveyor did not have spark detectors or propagation shut off devices to prevent explosion propagating forward or aft. "AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD..."

Overall, out of the 17 combustible dust related fires and explosion in the food sector, over 70% happened at facilities not listed in the OSHA Dust NEP. Are we seeing a trend here?

Paper Product Manufacturing
A glance at the paper manufacturing sector which includes 16 national paper industries (NAICS), not one is listed in the OSHA Dust NEP. So how many explosions and fires this year? How about 11 fires and explosions, which included two dust explosions. It's like a snowball rolling down the hill as the plot gets bigger and bigger with four paper mill combustible dust related fires, three sanitary paper product manufacturing fires, and two combustible dust fires at corrugated solid and fiber box manufacturing plants.

Plastics/Rubber Product Manufacturing
In all fairness the plastics and rubber manufacturing sector is well covered in the NEP. For example, seven combustible dust fires and explosions occurred this year which includes three explosions. There does need to be a reevaluation of whether these national plastic/rubber industries have a potential /D-2 or more frequent/D-1 history of combustible dust fires/explosions as outlined in appendix D-1 and D-2 of the NEP. All these explosions occurred in NAICS that were referenced in D-2 (potential for an incident). If incidents are reoccurring with explosions then wouldn't that move them from a potential/D-2 to a frequent/D-1 in the Appendix?

Other sectors in wood, chemical, textile, machinery and metal national industries have their share of explosions and fires as depicted in the chart for incidents in 2008. Stakeholders with financial interests in all these manufacturing and non-manufacturing sectors must understand that the OSHA Combustible Dust NEP is solely a directive which provides guidelines for OSHA inspectors in conducting enforcement and inspection actions at facilities.

It should not be used as guidance in preventing and mitigating future incidents, while misinterpreting that since your facility is not a listed NAICS in the NEP, you are out of danger from the hazards of combustible dust. Over 50% of the combustible dust explosions this year were at facilities with NAICS (national industries) not listed in the NEP. Don't be a statistic. As soon as possible initiate a process hazard analysis which identifies, evaluates, and controls the inherent combustible dust hazards at your facility.

For additional information if your national industry has a history of potential or high occurrence of combustible dust related fires/explosions contact John Astad at the Combustible Dust Policy Institute.

Saturday, November 1, 2008

$3 million Combustible Dust Related Fire Unreported

How can a $3 million fire that destroyed a historic furniture factory in Salt Lake City, Utah four years ago be unreported in the Chemical Safety Board Combustible Dust Hazard Study? An excerpt from a news account states:

"Local fire officials suspect that the fire started in the dust collector at the 120-year-old factory owned by Jeffrey Cobabe and Associates."

Hundreds of Incidents not Reported
The troubling aspect of the incomplete CSB Dust Hazard study that was submitted to OSHA in 2006 is that public policy concerning worker health and safety was formulated in the OSHA Combustible Dust National Emphasis Program (NEP) directive. Additionally, in March 2008 the House Education and Labor Committee introduced to Congress (H.R.5522) The Worker Protection Against Combustible Dust Explosion and Fires, also utilizing the CSB Dust Hazard study as the guidance and foundation in the drafted bill.

Since the Imperial Sugar Refinery dust explosion, dozens of training classes at industry conferences hosted throughout the nation have been providing industry stakeholders with information on combustible dust hazards. Yet these training seminars also make continuing reference to the CSB dust study in addition to the OSHA Combustible NEP, which unfortunately omits hundreds of manufacturing sub-sectors (NAICS). This training is fine and much needed in the industry. A problem arises when plant owners and managers are not obtaining the complete picture of the magnitude and depth of combustible dust hazards.

The Chemical Safety Board is not to blame. This agency is the finest accident investigation agency in federal government and has provided the industry with crucial information in preventing future accidents. With a limited budget these dedicated professionals are on the front lines investigating catastrophic accidents finding the root cause. What the agency isn't, is a research organization like the Bureau of Labor Statistics

View SlideShare presentation or Upload your own.

Get the Knack of the NAICS
Referring to the above destructive fire where a dust collector was involved in just one example of the hundreds of NAICS and tens of thousand of manufacturing plants not listed in the OSHA Combustible Dust NEP, where only 68 out of a 427 manufacturing NAICS are referenced in Appendix D-1 & D-2. Just because your facility is not one of the 68 NAICS listed in the NEP, don't for a second believe you have a free pass and all is fine and dandy.

If the process stream handles combustible particulate solids that generates combustible dust of any sort, then you are sitting on a bottle rocket waiting to go off when all the factors of ignition, heat, fuel, suspension, and confinement all come together in the rare moment. We all know what a vapor cloud explosion can do in the refinery sector. The same devastating overpressure effects occur with a dust explosion in the manufacturing sector. In fact, unbelievably for many combustible dusts, the deflagration index or explosion severity (Kst) is much higher.

Explosion Ventilation Panels in Action

Last weeks combustible dust explosion at a evaporated dairy product manufacturing plant in Visalia, California is an excellent example how explosion ventilation panels reduce the severity of combustible dust explosions. Fatalities, injuries, and adverse economic damage can be minimized when manufacturing process facilities initiate a thorough process hazard analysis and follow the guidelines in the NFPA combustible dust standards, which address the objectives of life safety, structural integrity, and mission continuity through preventative and mitigative control measures.

OSHA's continuing proactive efforts in ensuring that manufacturing facilities have minimized the occurrence and reduced the severity of combustible dust hazards in the workplace is best illustrated when reviewing an inspection report and General Duty Clause citation ($6,400) completed several months earlier at similar evaporated dairy product manufacturing plant (NAICS 311514) in Wisconsin.

General Duty Clause Citation
1.Protein dryer were located inside a building lacked explosion venting.
2.Storage bin, located inside the building, did not have explosion venting.
3.Pneumatic Conveyor did not have spark detectors

AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS to comply with National Fire Protection Agency (NFPA) Chapter 61 Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2008 edition; NFPA 69 "Standard on Explosion Prevention Systems" 2008 edition; NFPA 654 "Standard for the Prevention of fire and Dust Explosion from the Manufacturing, Processing and Handling of Combustible Particulate Solids" 2006 edition

Industry Leader
Hopefully the Wisconsin facility has taken immediate action on the key items which the OSHA inspector cited in the report. Other manufacturing facilities can learn from the recent explosion that occurred in California, where explosion ventilation panels effectively reduced the risk to life and property. California Dairies is an industry leader in the evaporated dairy product manufacturing sector and should be commended for the preventative and mitigative control measures that management instituted in addressing combustible dust hazards.

C/S Explovent Video-must see!

There are many sources where explosion ventilation panels can be acquired after a process hazard analysis is completed. For example, Construction Specialties is a global leader in providing explosion ventilation panels with it's field testable and ATEX 95 compliant C/S Explovent® If your facility does not have explosion ventilation panels installed yet, then maybe it's time to include this important investment in the 2009 budget.


Thursday, October 30, 2008

Over 155 Dust Explosions/Fires 2008

Is the OSHA grain facility standard working? Luckily workers escaped injury at the Destrehan, Louisiana grain elevator explosion early Thursday morning. Since the beginning of 2008, through media accounts, an alarming tally of 13 grain facility combustible dust related explosions have occurred throughout the United States. Dust explosions and fires have plagued a wide swath of industry whether it be in manufacturing or the grain sectors.

Grain and Manufacturing Sectors
Fast rewind, over two decades ago after a rash of 1977 grain silo explosions that caused dozens of fatalities and resulted in the OSHA Grain Facility Standard , which outlined measures in protecting the workforce from combustible grain dust explosions and fires. But still, fires and explosions continue to occur resulting in numerous fatalities and injuries.

Immediately after the February 7, 2008 catastrophic Imperial Sugar Refinery dust explosion in Port Wentworth, Georgia , congressional leaders drafted a combustible dust bill that outlined provisions in protecting the manufacturing sector workforce from the hazards of combustible dust explosions and fires. The bill currently sits very bored, and stretched out, yawning waiting for action in Senate chambers after passing in the House by a mostly Democrat roll call.

Kick Like a Mule
Why does there have to be two separate OSHA regulations concerning combustible dust explosions and fires ? One for the grain sector and one proposed for the manufacturing sector? An explosion is an explosion just like a mule is a mule. Just different colors and a different sort of swag of the tail but the same powerful kick as any muleskinner can tell you.

The effects of any explosion whether it be a physical or chemical explosion entail damaging effects of overpressure, thermal radiation, and ensuing projectiles. Dust explosions are quite similar to vapor cloud explosions (VCE) that occur when flammable gases or vapors are suspended in air combined with the essential flammable limit (LFL-UFL) and joining their buddy, an ignition source.

Amazingly, the maximum pressures (Pmax) that develop in milliseconds, with the energy release of a dust or vapor cloud explosion in general are quite similar, around 7 Bar (1 bar = 14.5 psi) or 100 psi. Around 3 psi is enough to knock many commercial buildings down such as with aluminum siding

In 2008, through media accounts, the Combustible Dust Policy Institute has noted over 155 combustible dust related explosions and fires in the combined grain and manufacturing sectors. Dust explosions that result in adverse economic impact, fatalities and injuries do not differentiate between a grain elevator or dust collector inside a manufacturing process facility.


Crowl, D. A. (2003). Gases and Vapors. In Understanding Explosions (p. 17). Wiley-AIChE.
Crowl, D. (2003). Appendix E Combustion Data For Dust Clouds. In Understanding Explosions (p.
191). New York, New York: Wiley-AIChE.

Wednesday, October 29, 2008

Flame Resistant Garments: Minimizing Combustible Dust Hazards

David Osbon here from UniFirst Corporation and just wanted to post to the blog to introduce myself to the network and talk about a few things related to Combustible Dust Explosions. Following the catastrophic events that took place in February in Port Wentworth, GA I have spent a great deal of time researching combustible dust and the hazards associated with dust. I will be the first to admit that prior to the February event I did not understand the devastating effect of these explosions. I do now - I have seen it first hand.

Minimizing the Risk
My background is technical in nature. Prior to my current employment I researched and developed flame resistant fabrics for the industrial sector (NFPA 70E Standard for Electrical Safety in the Workplace 2009 , Petrochem, Electric Utilities, etc). I have investigated many fatalities and in almost every case - the fatality was PREVENTABLE! In almost all cases EDUCATION and UTILIZATION of the appropriate Personal Protective Equipment (PPE) would have prevented or minimized the extent of the injuries associated with the accident.

Through all of the research I have conducted over the last several months, one of the main issues that I see as "lacking" in most of the CSB reports, the House of Representatives meeting (HR5522), and all of the OSHA NEP directive information is the utilization of PPE.

NFPA 2113
Flame-Resistant Garments
The OSHA directive CPL 03-00-008 Combustible Dust National Emphasis Program (Reissued) ,does make specific reference to General Duty Clause (OSHA 1910.132) citations if the hazard is present and the appropriate PPE is not utilized. The directive goes on to mention NFPA 2113 -Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire as a reference document for selection and care of FR garments. NFPA 2113 has a specific section that deals with combustible dust.

What I do not find is a specific section that requires the use of FR garments. As I have seen with the NFPA 70E market, the electric utility market, and the petrochem market - OSHA has generally left this area vague and has relied on the General Duty Clause as a "catch all" gray area to allow citations to be issued without having to write the requirement in to LAW!

After reviewing the LONG list of fines associated with the Port Wentworth event I did note approximately $249,000 in General Duty Clause violations. As information to the post - the Port Wentworth site is now outfitting ALL personnel in Flame Resistant garments to increase their overall level of protection.

Improved Technology
While flame resistant fabrics and garments will not eliminate ALL injuries associated with combustible dust hazards, I strongly believe that the use of these garments would have minimized some of the burn injuries. Fabric and garment technology has improved ten fold over the last 5 years. Garments are now lighter weight, more comfortable, more durable, and more protective than at anytime in the past.

We are in the beginning stages of working with NFPA on a new standard that would increase the awareness and use of protective garments in combustible dust situations.As well, a member of my team has just joined the ASTM committee that deals with combustible dust. I personally am active with ASTM F23 (Committee on PPE and Equipment) and F18 (electrical workers).

It is my hope that we can build a network of professionals that are experts on combustible dust that will be able to educate the public on the hazard and tools available to minimize burn injury. If we can save one life - this would all be worth it.

Sunday, October 26, 2008

Combustible Dust Hazards Training-Strategic Alliances

Stakeholders across a wide spectrum of industry through education can minimize the occurrence and reduce the severity of combustible dust hazards that are inherent aspect of the manufacturing process. Strategic alliances of user groups, safety councils, OSHA regional offices, and industry leaders are vital in developing a situational proactive awareness in reducing fatalities, injuries, and adverse economic impact caused by combustible dust related fires and explosions.

OSHA Regional Training
MNOSHA (State OSHA Plan) which is part of the Minnesota Department of Labor and Industry consists of separate enforcement and consultation services. Through the Workplace Safety Consultation Division, MNOSHA has already presented two combustible dust training seminars in St. Paul and Cloquet and will be presenting the third seminar, " Preventing Combustible Dust Explosions," seminar November 19, 2008 in St. Cloud, MN. Seating is limited, call 651-284-5060 for additional information.

Currently MNOSHA is working on adopting the Federal OSHA Dust NEP, which is voluntary for the 22 states that have their own separate State OSHA Plan. An excerpt from the Novemeber 2, 2007 Minutes of the Occupational Safety and Health Advisory Council mentions MNOSHA's "Intent to Adopt Identical" combustible dust emphasis program as outlined in the Federal NEP. Hopefully in the future other State OSHA Plan states will follow the example that is being developed in Minnesota.
In the meantime MNHA is hosting combustible dust seminars in a strategic alliance with BS&B Pressure Safety Management

User Group Training
Manufacturing and Energy Utility user groups are vital in addressing their membership concerning "best practices." The PRB Coal Users Group is actively addressing the hazards of combustible dust in coal fired energy plants. When referring to the Combustible Dust NEP in Appendix D-1, Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires. coal fired energy plants are noted as NAICS 221112, Fossil Fuel Electric Power Generation . The PRB Coal Users Group in conjunction with Power Magazine is offering a Webinar "Combustible Dust: Proactive approaches to managing combustible dust,"
on Tuesday, October 28, 2008 at 10AM Central.

Safety Council Training
The Illinois Safety Council (ISC) has hosted several combustible dust training seminars over the past several months. Working closely with John Newquist, OSHA's Region V Assistant Regional Administrator for State Cooperative Programs and Joe Howicz, CSP and Fire Protection Expert, ISC will host additional training at the University of Illinois October 30, 2008 and November 20, 2008 with the Combustible Dust Explosion Inspection Seminars.

Industry Training
Chilworth Technology, an industry leader in providing process safety services throughout the industry is offering several one-day combustible dust training courses "OSHA Dust Explosion Inspection Preparatory Training," during November and December in Georgia, New Jersey, and Illinois. Chilworth Technology offers a wide range of consulting services in preventing and mitigating combustible dust hazards.

Combustible Dust Policy Institute
It's important that all stakeholders with concerns of combustible dust hazards work together through strategic alliances in addressing the complex issue of combustible dust . The Combustible Dust Policy Institute serves as an informational gateway in providing a situational awareness throughout the manufacturing and utility sectors. Feedback and input is much appreciated and I welcome visitors to the Combustible Dust site in joining the professional combustible dust network on LinkedIn.

The mission of the Combustible Dust Policy Institute is to minimize the severity and reduce the occurrence of combustible dust related fires and explosions in the nation’s workplace. Through ongoing research of combustible dust related incidents, which identifies and evaluates risk, the Combustible Dust Policy Institute provides risk assessment information that a diverse spectrum of stakeholders utilize in effectively controlling combustible dust hazards. Assisting stakeholders in this endeavor, health and safety compliance is achieved in addition to reducing workplace fatalities, injuries, and adverse economic impact.

Wednesday, October 22, 2008

ComDust Alert #2 -Combine Harvester Combustible Dust Fires

I found an interesting article regarding combine harvester combustible dust hazards and would like to share it with everyone. It's really a combination of several stories that spans two continents, one under the equator for all you shellbacks and one above the equator here in the USA.

For instance, last week a news article from
MPNnow (10/16/08) of a combine that caught fire in Farmington, N.Y., which was a total loss of $240,000. The farmer thinks that a spark from one of the blades ignited a layer of soybean dust inside the equipment. This sounds so familiar in the manufacturing sector where a spark travels through the duct work into the dust collector causing a fire or much worse an explosion.

Anyway, fast forward to an article today originating in Australia where harvesting of grain crops has begun and the Fire and Emergency Services Authority (FESA) is providing a warning :

"The machinery itself, I mean it's all metal so it can get hot and if there's any build up of dust on the equipment that does get hot, well then it can ignite very quickly and they'll lose a fairly expensive piece of equipment..."

These are excellent examples illustrating how hot surfaces cause combustible dust fires no matter if its in the manufacturing sector or farming sector. Until reading these articles originating from both sides of the Pacific Ocean I had no idea there was a combustible dust hazard on farm equipment. I wonder if all the global farmers operating those very expensive combine harvesters know about the combustible dust hazards?

10/13/08 Combine Fire-Argos, Indiana
10/6/08 Combine Fire - Elma, Iowa
1o/2/08 Combine Fire-Wallingford, Iowa


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