Monday, March 31, 2008

Grain Combustible Dust Explosions and Fires: 2008


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Combustible dust explosions and fires occurring in grain elevators and feed mills during 2008 throughout the United States. The OSHA grain facility combustible dust standard has reduced the the number of fatalities and injuries since prior to 1988 when the standard was implemented. Yet incidents still occur on a regular basis.

Also included on the Google Map are incidents in Canada and the United Kingdom.

Thursday, March 27, 2008

OSHA’s Scorched Earth Campaign-Combustible Dusts


Last time Americans heard of a scorched earth campaign was nearly a century and a half ago toward the end of the Civil War when Union Major General William Tecumseh Sherman conducted his “Savannah Campaign’ and “March to the Sea” from Atlanta to the port of Savannah. In his wake, he burned everything to the ground except courthouses, churches, and dwellings. In the background of the procession, military bands played on, while his troops sang the chilling words “John Brown's soul goes marching on!"

Conflicting Campaigns

Fast forward into the twentieth-first century and another more productive campaign is happening across the nation’s heartland to the tune of a different song and that is the prevention of future preventable and predictable combustible dust related explosions and fires. At the forefront of this complex issue is OSHA’s conflicting scorched earth campaign in staunchly opposing labor’s desire in a comprehensive combustible dust standard in its health and safety regulations. In the meantime the nation’s economic industrial infrastructure is burning to the ground due to the alarming prevalence of combustible dust explosions and fires.

In the same southern maritime port of the Savannah River where General Sherman ended his “March to the Sea,” the United States suffered a horrific loss of lives and property with the explosion of the Georgia’s Imperial Sugar Refinery caused by combustible sugar dust. Fifteen months prior to the explosion, the Chemical Safety Board, an independent federal agency charged with investigating industrial chemical accidents to protect workers, the public, and the environment, made recommendations concerning the implementation of OSHA combustible dust standard, which OSHA failed to act on.

Scorched Infrastructure

So now the nation’s workforce is living under an OSHA ‘scorched earth” policy. Haunting recurrences of combustible dust explosion occurred yesterday in Dudley, North Carolina where a Georgia-Pacific wood processing plant experienced over $ 20,000 of damages when four of its dust collectors exploded causing a small fire in the main structure. Luckily there were no injuries.

Yet unfortunately several years earlier, 35 miles up the road on January 19, 2003 the West Pharmaceutical Services plant in Kinston, North Carolina was not so lucky when it was scorched to the earth from a preventable combustible dust explosion, resulting in 6 fatalities and 38 injuries. Luck can only go so far with combustible dusts where many substances of wood, metal, plastic, food, coal, chemicals, and pharmaceuticals have minimum ignitions energies (MIE) less than gunpowder at the millijoule level.

One Size Fits All

And that’s where the problem lays, OSHA’s position that a “one size fits all” combustible dust health and safety standard will not work due to the diversity of raw materials involved in the manufacturing process. The public should not be mislead by this position regarding a very complex subject of dust cloud formation and ignition processes in addition to flame propagation and blast waves generated by burning dust clouds.

OSHA’s upper management, in which Edwin Foulke is the leader, is still under the false assumption that combustible dusts ignite due to diverse flash points. This could be further from the truth. For example, there is no such thing as flash points like in flammable liquids and vapors when regulating combustible dusts. Instead the physical and fire properties include minimum ignition temperature (MIT), minimum explosive concentration (MEC), minimum ignition energy (MIE), and deflagration indexes (Kst)

Combustible Dust Properties

Most combustible dusts have a minimum ignition temperature (MIT) of less than 932 degree Fahrenheit (500 C), which is the temperature of a match that has been immediately extinguished. Regarding deflagration indexes (Kst) or explosive properties, which is the amount of pressure rising over a period of time there are four classes: no explosion, weak, strong and very strong. Sugar dust as in the Imperial Sugar Refinery explosion has a weak Kst index as does the polyethylene plastic dust that was involved in the West Pharmaceutical dust explosion.

The subject of combustible dusts is a fascinating science wrought with new terms unfamiliar to most people in contrast to flammable liquids and vapors which are regulated in accordance with their flash points and hazardous classes. Combustible dusts can be understood at the same level if the analogy is used between flash points in vapors generated from flammable liquids in comparison to minimum ignition temperatures for combustible dusts generated from combustible particulate solids.

National Emphasis Program
OSHA’s “scorched earth” policy in regards to combustible dust is intensified when misleading proclamations are made in leading global and national publications such as the USA Today Op/Ed column where OSHA Director Edwin Foulke states “last fall OSHA initiated a nationwide program to increase inspections in high-risk workplaces.” This could be further from the truth as there is no nationwide national emphasis program for combustible dusts.

For instance 26 states have approved state plans, Connecticut, New Jersey, New York and Virgin Islands plans cover public sector (State & local government) employment only. Which translates into fine print that State plan participation in the combustible dust national emphasis effort is strongly encouraged but is not required. Additionally, State response/notice of intent regarding this directive is required. So far none of the 23 states have an emphasis program for combustible dusts. In all fairness, Michigan, Indiana, Virginia, and Tennessee are in the process of adopting at state emphasis combustible dust program.

Reoccurring Dust Explosions

In the meantime over the last seven weeks since the catastrophic Imperial Sugar Refinery combustible dust explosion there have been over two dozen combustible dust related fires and explosions across the nation spanning from the Pacific to the Atlantic . These predictable and preventable events have ranged in a diverse set of industries and institutions such as food, wood, metal, textile, and rubber industries. In addition to an Xcel coal power plant in Minnesota and Sheboygan Falls High School in Wisconsin. Even General Tecumseh Sherman’s scorched earth policy “March to the Sea,” had not ranged this far in proportion in such a short amount of time.

It should not take an act of Congress like the proposed bill, “HR 5522, The Combustible Dust Fire and Explosion Prevention Act of 2008" that the House Education and Labor Committee held a hearing on March 12, 2008 to provide stimulus for OSHA to act. Instead sound and persuasive leadership is needed at the Department of Labor, where industry, labor, and governmental leaders can reach a comprehensive agreement in providing the health and safety protection that the country now desperately needs.

Global Alternative

An excellent alternative to the conflicting points of view between the stakeholders would be to review programs that our global trading and security partners have. For example, Australia, New Zealand, Europe, and the United Kingdom already have health and safety regulations concerning explosive atmospheres like combustible dusts.

The European Union has instituted ATEX 95 equipment directive 94/9/EC and ATEX 137 workplace directive 99/92/EC. The unusual ATEX acronym is derived from French: Appareils destinés à être utilisés en ATmosphères EXplosibles .The United Kingdom with guidance from ATEX 95, has implemented the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) which require employers to control the risks to safety from fire and explosions.

Additionally, down under, Australia and New Zealand and doing the same with a phase in program spread out over the years like the United States did for the 2002 Homeland Security Act. After a period of six years and billions of dollars government and industry are completing the last aspects of homeland security with the controversial Transportation Worker Identification Credential (TWIC). Instead of protecting from a threat on the outside with the Homeland Security Act., the OSH Act with a comprehensive combustible dust standard can protect from the scorched earth occurring within.

Photo Credit:
U.S. National Archives and Records Administration

North Carolina Combustible Dust Explosions and Fires


Tuesday, March 25, 2008

Michigan Combustible Dust Fires Reoccurring


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How can there be two combustible dust fires in succession within one week like has recently occurred in Muskegon, Michigan at the metal finishing facility of Port City Industrial Finishing Inc? In last Tuesday’s incident the dust collector/silo sustained $120,000 of fire damage and yesterday courageous and heroic fast-acting employees emptied all 18 fire extinguishers in quenching another combustible dust fire in the vicinity of a dust collector/air handling unit inside the building.

Michigan Scorecard

Michigan is high on the national scorecard of a continual succession of preventable and predictable combustible dust explosions and fires. Of a 7.0 earthquake magnitude on the scale of the recent tragic Imperial Sugar Refinery explosion, the Ford Rouge plant in Dearborn, Michigan experienced a coal dust explosion nearly two decades ago on February 1, 1991, causing 6 fatalities and 30 injuries after the dust had settled.

Two short years would pass when on May 25, 2001 another fireball and combustible dust explosion would erupt in the state at a Georgia Pacific particle-board plant in Gaylord, Michigan. In this incident there were 15 injuries of which nearly half of them where from six firefighters who were extinguishing hot spots from the earlier fire when another combustible dust explosion erupted.

2001 Not a Good Year

Four months later on September 21, 2001 as investigators were still analyzing and writing their accidents reports on the Georgia-Pacific explosion another combustible dust explosion occurred at a Wayland, Michigan milk processing plant, which resulted in two injuries and minor damage to the facility.

2001 was not a good year for the nation or Michigan either concerning explosions that seemed to come out from nowhere. The New Year in 2002 fared no better and even before the dismal anniversary of the catastrophic coal dust explosion at the Ford Rouge Plant had turned its pages on the calendar another coal dust explosion raised its nasty head on January 16, 2002 on the banks of Lake Superior in Marquette, Michigan.

At an electric services plant, a coal-fired boiler was being brought on-line where the coal feeding system had not been purged properly and an excessive amount of coal dust left in the system ignited, causing an explosion and leaving a fatality in its wake. The dragon had spoken and was not to be ignored.

National Problem

The last six years have been dormant in comparison to earthquakes’ with several combustible dust fires spread out through 2003 and 2004 with no fatalities or injuries,
synoymonous to tremors and warning signs. It’s now when a facility such as Port City Industrial Finishing, where two combustible fires occur in succession within a week that notice occurs. In retrospect, Michigan only had nine combustible dust incidents from 1989-2004 leaving 7 fatalities and 59 injuries.

Michigan is not being singled out in the scheme that the dragon has planned out. Since he lashed his ugly tail upon the serene western bank of the Savannah River at the Dixie Crystal sugar refinery in Port Wentworth, Georgia over two dozen combustible dust explosions and fires have occurred throughout the nation.

So how many more fatalities and injuries must occur before the issue is addressed and a mandatory OSHA comprehensive combustible dust standard is implemented utilizing National Fire Protection Association combustible dust codes?

Monday, March 24, 2008

Quaker Oats Blows It's Top

http://www.gazetteonline.com/apps/pbcs.dll/article?AID=/20080324/NEWS/233198211/1006/news

Around sunrise as hearty Iowans were beginning their workday with the freezing and brisk morning commute in downtown Cedar Rapids, Iowa a dust explosion rocked the eight floor of the prominent Quaker Oats facility, which has been a landmark on the east bank on the Cedar River for over a century.

Luckily no injuries occurred and it only brought back a brief stark reminder of a catastrophic dust explosion that occurred in Cedar Rapids, nearly a century ago on May 19, 1919 at the Douglas Starch Works, where a dust explosion leveled the building causing 48 fatalities. Prior to 1899 George Douglas was a partner with the principles of North Star Milling, the predecessor of Quaker Oats founded in 1873.

Smiley Face

The familiar friendly face on that red, white, and blue Quaker Oats box in our cupboard has a rich history and there is nothing happier in the morning than crunching on a bowl of Cap”n Crunch (Quaker Oats product) to get the day started. The risks involved in getting the thousands of happy faces started in the morning are another story.

Handling food products in the manufacturing process produces inherent dangers with the seemingly harmless combustible dusts that are generated in the workplace. So who would have thought something as harmless as sugar, like earlier last month at Imperial Sugar in Georgia, would have the explosive power of another 9/11?

City-State Not Immune

Iowa has not been immune to these dangers as there have been over a dozen dust explosions over the last twenty years in the state according to the 2006 Chemical Safety Board’s Combustible Dust Hazard Investigation. Since 1991, in Cedar Rapids, there have been six dust explosions at wet corn milling, starch, bakery mix, cereal, and animal by-product plants. Luckily, no injuries just a lot of broken glass and rattled nerves and time to think more about prevention in the future.

Cause’s and ignition sources range from fires, spontaneous combustion, sparks, hot metal, and unknown. Over half of dust explosions never end up in a determination of causes due to the destruction that is wracked on the facility. Yet static electricity would be a good place to start. Are the workers wearing anti-static clothing in addition to anti-static floor covering as found in many hospitals in preventing potential explosions?

Voluntary OSHA Compliance

Voluntary measures of anti-static clothing only go so far in prevention as it is not required at facilities that generate combustible dusts. Additionally the operating costs for companies would be exorbitant in the investment of anti-static flooring coverings, which would fiercely eat into quarterly earnings statements.

This is only the tip of the iceberg when it comes to voluntary standards that the National Fire Protection Association lists in their numerous fire codes in handling metal, food, plastics, rubber, coal, wood, and other combustible particulate solids that generate combustible dusts. For instance, there are many more issues in contrast to explosion prevention which leads to explosion mitigation and covers ventilation, isolation, and suppression of dust explosions in milliseconds.

Myth or Dream

That’s where the real big bucks enter into the picture. Think of it as an entire industry rising from the ashes like the mythological Phoenix where a cottage industry of explosion protection devices is installed at all facilities generating combustible dusts and the idea of a future dust explosion would be decreased immensely. But that is only a dream such as a myth.

Threat From Within

Since the Homeland Security Act was passed in 2002, billions of dollars have been spent by government and industry in providing protection from outside threats. But what about protection from inside the nation where worker fatalities, injuries, and devastating economic impact occurs on a regular basis?

A major concern is that the Occupational Health and Safety Act was passed nearly four decades ago and it has yet to live up to the lofty goals of aggressively attacking the continual occurrence of fatalities and injuries in the workplace. Instead there is a patchwork of voluntary compliance and alliances with industry.

Labor or Industry

This mode of operation was reinforced during the March 12, 2008 hearing at the House Committee of Education and Labor on the HR 5522 "The Combustible Dust Fire and Explosion Prevention Act of 2008.” Where industry and business through the voice of the powerful and omnipresent U.S, Chamber of Commerce, the world's largest not-for-profit business federation, representing 3,000,000 businesses reiterated their position that a OSHA comprehensive dust standard is not a viable action.

Until an OSHA comprehensive combustible dust standard in the protection of workers and the workplace is instituted more preventable and predictable dust explosions and fires will occur. Since the catastrophic explosion at Imperial Sugar six weeks ago resulting in 13 fatalities there has been nearly two dozen additional combustible dust incidents. Maybe the dust explosion at Quaker Oats will be wake up call for immediate action as the kindred spirits Douglas Starch Works and Imperial Sugar look on.

Sunday, March 23, 2008

Timeline: Recent Combustible Dust Explosions


Click on the Picture for a Better View

The most recent combustible dust explosion occurred on the same day that the House Education and Labor Committee was having a hearing on HR 5522, "The Combustible Dust Fire and Explosion Prevention Act of 2008".

Testifying were William Wright, Acting Chair of the Chemical Safety Board: Ed Foulke, OSHA; Tammy Miser (whose brother, Shawn Boone, was killed in a combustible dust explosion); David Sarvadi, representing the US Chamber of Commerce; and Amy Spencer of the National Fire Protection Association.

Saturday, March 22, 2008

Up Close Imperial Sugar Explosion Update

Six weeks have passed now since the horrific Imperial Sugar Refinery combustible dust explosion that occurred in Port Wentworth, Georgia on the evening of February 7. Imperial Sugar CEO John Sheptor allowed reporters an up close view of the blast site while investigators took a break during the Easter weekend.

Today News Threes Alice Massimi and photojournalist Art Ottimo were able to get a close-up look at the destruction caused by this horrific incident.
Combustible dust explosions and fires are a regular occurrence at numerous manufacturing and processing facilities across the United States and the Imperial Sugar incident is not an isolated case. Already 20 combustible dust related fires and explosion have occurred since the explosion in Port Wentworth.
3/18/08 MUSKEGON COUNTY Muskegon firefighters responded at 1:52 a.m. to the plant at 1867 Huizenga, where they discovered the plant's "dust collector" had caught fire, said Fire Marshall Major Metcalf. It's unclear why the device -- located outside the plant -- malfunctioned

Combustible dust fires originating in dust collectors occur with regularity and without proper voluntary detection, isolation, ventilation, and suppression measures in conjunction with the regulatory good housekeeping requirements additional incidents, will continue.

Just abiding by current combustible dust industry standards and OSHA regulations is not enough as Imperial Sugar CEO John Sheptor suggests, with all good intentions

PORT WENTWORTH, GA (WTOC) 3/21/08 - "We will rebuild this facility to the best knowledge we have with regard to the management of combustible dust, whether that be a regulation or industrial standard and by all means we believe we were operating according to these codes and standards previously," he said.

Rebuilding the sugar plant in compliance to current OSHA combustibles dust regulations will only prolong the situation of the continual occurrence of more combustible dust explosions.Especially since abiding to National Fire Protection Association (NFPA)codes on combustible dust is only voluntary.

At a recent congressional hearing of the House Committee of Education and Labor concerning the introduction of the Combustible Dust Explosion and Fire Prevention Act (H.R. 5522), David Sarvadi a lobbyist and attorney representing United States Chamber of Commerce the world's nationwide largest not-for-profit business federation, of 3,000,000 businesses, didn't believe that a mandatory OSHA combustible dust standard, which includes NFPA combustible dust explosion preventative and mitigative measures was a good idea.

Meanwhile combustible dust explosions are still occuring

3/13/08 By TOM QUIGLEY The Express-Times HIGH BRIDGE,NJ Fire erupted Wednesday inside an enclosed dust collector in a metal-grinding room at the Custom Alloy plant on Washington Avenue, borough Fire Chief Jeffrey Smith said.

The severity of the situation is not just solely on the protection of workers in the workplace from the unknown dangers of seemingly harmless combustible particulate solids and the combustible dusts that are generated. But now our nation's firefighters are at risk when fighting a structure fires where unrecognized combustible dusts are generated and primary and secondary dust explosions can occur during the deflagration event.

And so the saga continues:

3/10/08 WCCO.com OAK PARK HEIGHTS, Minn. (AP) ― Xcel Energy is shutting down its King plant in Oak Park Heights after a fire and possible explosion in a building near the coal-fired plant.
This was the second combustible dust explosion of coal dust within three months at the same facility. Currently, Minnesota is under a voluntary state OSHA program and doesn't even have an emphasis program regarding combustible dusts. So how is it that future preventable and predictable combustible dust explosions and fires can be diminished if there is no nationwide mandatory protective standards?

Resources:

NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids

Google Map Combustible Dust Related Explosions and Fires

Thursday, March 20, 2008

Spooner Explosion-Dust or Vapor?



The catastrophic Tuesday chemical plant explosion at the Cortec aerosol can filling facility in Spooner, Wisconsin is still a mystery to local, state, and federal investigators. Luckily, most of the workers were in the break room when the mysterious explosion destroyed the facility. Yet two injuries occurred with the burn victims still in the hospital.

Cortec is a global leader in corrosion protection technology with its proprietary vapor-phase corrosion inhibitors. VCIs are environmentally friendly organic chemicals that condense on metal surfaces, creating an invisible barrier to moisture. Products that are filled in aerosol cans include rust removers, rust preventers, biodegradable cleaners, and degreasers.

With hundreds of diverse corrosion protection products manufactured at their other facilities, Cortec provides corrosion protection products for over 70 countries in conjunction 500 local distributors. For instance, NASA uses the products’ on the space shuttle and the U.S. military has a multitude of uses for the products in the adverse conditions which it operates whether land, sea, or air.

Normally aerosol can filling can be a potentially dangerous operation in the manufacturing process. Yet Cortec has alleviated that hazardous aspect with its EcoAir aerosol can product which utilizes unique technology in the form of aerosol products that are powered by compressed air which is not flammable. So how did the facility explode if it doesn’t use liquefied petroleum gas (LPG), dimethyl ether (DME), difluoroethane (DFE), or butane as a aerosol propellant?

That’s the mystery. Additionally, newspapers have stated through witness accounts, that no one can recall smelling any vapor such as a flammable gas leak. Furthermore, a business owner across the street heard a primary explosion then a larger secondary explosion followed by the huge fire.

Is it possible that the vapor corrosion inhibitor (VCI) in a dust form, prior to filling the aerosol cans, had accumulated over a period of time on overhead surfaces and ledges unbeknownst to plant management and the workers? That’s the big question even with the aisles and passageways spotless through conscientious housekeeping yet a hidden danger could be lurking above.


Wednesday, March 19, 2008

Metal Combustible Dust Fires Rage On

Combustible dust fires across the nation have been an ongoing trend over the past six weeks since the catastrophic Dixie Crystal Sugar Refinery explosion last month.

"MUSKEGON COUNTY — A fire that started early this morning at the Port City Industrial Finishing Inc. plant in Muskegon caused about $120,000 in damage, fire officials estimate."

In this incident lady luck held the high cards with no injuries nor fatalities at a facility that polished aluminum used for Harley-Davidson parts.

The last combustible dust incident occurred a week earlier at Custom Alloy Corporation in High Bridge, New Jersy when a fire ensued inside an enclosed dust collector in a metal-grinding room.

"Firefighters wearing protective breathing gear had to take apart the collector to extinguish burning metal particles inside. Smith said a small dust explosion occurred during the fire."
In that incident the small dust explosion occurred while fire teams were fighting the fire. Luckily, Fire Chief Jeffrey Smith's team of over 70 firefighters from the boroughs of Quakertown, Lebanon, Lebanon Township, Califon, Glen Gardner, Hampton, and High Bridge Rescue walked away unscathed.

The hazards of combustible particulate solids (CPS) and the combustible dusts that are generated in manufacturing processes can become deadly with the explosive power of gunpowder when suspended and in a confined space of the shop floor and exposed to an ignition source such as static electricity at the seemingly harmless millijoule level.

Tens of thousands of workers across the nation will arrive at work tomorrow morning with no idea of the dangers they are exposed to when handling metal, food, feed, grain, textile, paper, and other harmless bulk materials (combustible particulate solids) prior to initiating the manufacturing process. It's only when the materials in their raw form begin to be processed (combustible dust) that the dangers set in.

Thats when the dust begins to accumulate on the shop floor, ledges, hard to reach spots, and eventually suspension in the air. All that is missing for a combustible dust incident is ignition. In the right conditions with a worker walking across the shop floor, 10 millijoules of charge can be generated and touching the right spot 1000-2000 picofarads can jump across an ungrounded surface and hopefully lady luck is nearby.

Either way in some form or other, across all industries spread throughout the nation, approximately 15 of those workers will never make it to the time clock and eventually home alive to see there loved ones, lady luck won't be kind to them.

Google Map Combustible Dust Explosions and Fires

Sunday, March 16, 2008

Inconsistencies with OSHA General Industry Standards

Combustible dust explosions and fires continue at facilities throughout the United States in alarming regularity. Since the tragic Dixie Crystal sugar refinery explosion there has already been over a dozen combustible dust related explosions and fires with resulting fatalities, injuries and further economic impact to local communities. The current OSHA regulatory and enforcement scheme in preventing this predictable loss is currently not working.

Since 2005, the agency has published and distributed a Combustible Dust Safety and Health Information Bulletin, trained inspectors, implemented a combustible dust national emphasis program, and even most recently published a web page solely devoted to the hazards of combustible dusts.

Currently the attitude of upper management in the agency is solely energized toward self compliance through outreach programs and industry alliances. In the meantime preventable accidents like Dixie Crystal in proportion to a 7.0 earthquake in an urban area are still occurring. Minutes, hours, and days are ticking by before the next catastrophic dust explosion occurs in our nation.

Even at a recent House committee hearing of the Education and Labor, where Congressman George Miller introduced legislation, H.R. 5522, the "Combustible Dust Explosion and Fire Prevention Act of 2008. There was still an unwilling nature in the attitude of Edwin Foulke, the Director of OSHA during his testimony to move forward with a comprehensive combustible dust standard as recommended by the Chemical Safety Board.

A wait and see attitude until after the investigation of the Dixie Crystal was the most forthcoming pronouncement of Director Foulke. How many more investigations need to be completed before OSHA recognizes the hazards of combustible dust, where housekeeping alone will not put an end to future incidents? Already nearly 30 years ago, OSHA commissioned the National Academy of Sciences to conduct studies on the hazards of combustible dusts and the results where unanimous, combustible dust causes fires and explosion. From that study the 1987 OSHA Grain Facility Combustible Dust Standard was born. Why not now a general industry comprehensive combustible dust standard?

Currently the OSHA general industry standards of ventilation, housekeeping, hazardous locations, and hazardous communications are very weak and not sufficient in protecting facilities in the United States from future dust explosions and fires. Facility owners, plant managers, and workers must consult and review the numerous National Fire Protection Association codes in the prevention and mitigation of future incidents. Included in this post are major points that need to be considered. It’s highly recommended to read online NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids.

Document : Combustible Dust Protection: Inconsistencies with OSHA General Industry Standards.pdf file


Monday, March 10, 2008

State Dust Emphasis Programs Voluntary

Get er' Done

Nearly half the nation is unprotected concerning having the proper knowledge concerning the hazards of combustible particulate solids and the resulting combustible dusts. For instance, OSHA instituted a Combustible Dust National Emphasis (NEP) Program in October 2007, which provides health and safety inspectors with the background information needed in conducting facility inspections and informing industry of combustible dust hazards in 28 states. This is all fine and dandy.

Yet in the other 22 states with approved State OSHA programs, federal inspectors are not involved only state inspectors work in this area. Additionally, State plan participation in this national emphasis effort is strongly encouraged but is not required. Strongly encouraged means voluntary, which is the heart of the problem.

For example, North and South Carolina, and Kentucky have no local emphasis program for combustible dusts. Since the Dixie Crystal sugar Refinery explosion there has been two combustible dust related incidents in these states at rubber and textile facilities.



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Map State OSHA Programs

Indiana, Michigan, and Tennessee are in the process of adopting local emphasis programs for combustible dust hazards. Hopefully other states that have their own OSHA program will follow suit. For others that are under the federal National Emphasis Program, it will take additional congressional appropriations so that OSHA can hire additional inspectors to insure the nation's industrial infrastructure is secure.

OSHA Grain Facility Standard-Poor Results

Since the OSHA grain facility standard was promulgated in 1987 agricultural dust explosions, fatalities, and injuries have continued at nearly the same rate as general industry combustible dust explosions For example, utilizing data compiled by Dr. Robert W. Schoeff, Kansas State University, in cooperation with FGIS-USDA, during the period 1980-2005 there as been on the average of 15 annual agricultural dust explosions at grain elevators, corn processors, feed, flour and rice mills.

1980-2005

Grain Facility Explosions

General Industry Explosions

Number

368

281

Fatalities

63

119

Injuries

382

718

In contrast, the Chemical Safety Board completed a two year study which spanned the same period while investigating dust explosions in general industry and determined on the average 11 dust explosions occurred annually. So how is it that a multitude of agricultural dust explosions are still occurring even after an OSHA grain facility standard was implemented over two decades ago.?

In all fairness, since the grain standard was instituted in 1987, fatalities and injuries from agricultural dust explosions have been reduced by nearly 50 % , with incidents decreasing by 30 % on an annual average. But why is there still an explosion occurring nearly every month somewhere across our nations' heartland?

Grain Explosions

1979-1988

1989-1998

Number

20 /yr

14 / year

Fatalities

5 /yr

2 /year

Injuries

27 /yr

13 /year

Current OSHA health and safety regulations are clearly not preventing workplace injuries and fatalities. Most recently, from the ten year period 1996-2005, there were 106 grain facility dust explosions, resulting in 16 fatalities and 126 injuries, resulting in over $ 162 million dollars in economic damage.

So should it be up to the federal government to reduce further dust explosions in all industries; especially if current regulations are not working ? Many stakeholders believe governmental regulatory intervention is counterproductive and only raises the cost of business operations resulting in higher prices in finished products to the consumer.

An entire review and governmental audit of current OSHA grain facility standards is in order. The time has come in providing business management personnel and the workforce with updated Material Safety Data Sheets (MSDS)'s, which provide information on the explosive properties of all combustible particulate solids like corn, soybeans, wheat, etc. Information such as minimum explosive concentration (MIC), minimum ignition temperature (MIT), and KSt (normalized rate of pressure rise) included in the MSDS's would be beneficial in the hazard communication process.

United States Agricultural Dust Explosion Information

Sunday, March 9, 2008

Combustible Dust NEP-Not All There?

Had to read it twice...maybe I initially misread it between the lines. No, No... it all there but not all there. Over half the states in the union are not required to participate in OSHA's Combustible Dust National Emphasis Program (NEP)

VI. Federal Program Change. EFFECTIVE DATE: October 18, 2007
...State plan participation in this national emphasis effort is strongly encouraged but is not required. State response/notice of intent regarding this directive is required....

Learn something new everyday. So how is the nation fully covered by the current effort that OSHA is projecting in protecting the health and safety of workers in regards to the hazards of combustible dusts? Especially when only half the nation's workplace is covered. Last time I checked, there were fifty stars in the blue union of the American Flag.

Combustible Particulate Solids vs. Dust Confusion

Hopefully the confusion in terminology regarding combustible particulate solids and combustible dusts will be cleared up prior to the House Education and Labor Committee hearing on Wednesday morning concerning the ‘‘Combustible Dust Explosion and Fire Prevention Act of 2008’’. With so many important policymakers being initially introduced to this complex acronym induced topic, it behooves the champions of the cause to get it right the first time out of the box.

First off, lets all understand and be in complete agreement that combustible dusts are a subset of combustible particulate solids (CPS). In its raw form combustible dusts did not arrive at the facility rear loading docks. Instead combustible particulate solids were trucked in. Thats where the Material Safety Data Sheets (MSDS) enter the picture, since these documents communicate the potential hazards of handling combustible particulate solids. which in their initial packaged state are mostly not hazardous at all.

For instance, after the facility receives the combustible particulate solids, the solid is then transformed into a finished product. During the production phase, which can include such activities as shipping, handling, conveying, mixing, pulverizing, etc. It's during this phase that combustible dusts are generated and a potential hazardous atmosphere can develop when minimum explosive concentrations (MEC) are partnered with a minimum ignition energy (MIE) to produce a potential explosion or fire.

Hope that clears up the confusion. Since prior to today and until reading several times over NFPA 654, I really couldn't of won the Wheel of Fortune either, if asked to compare and contrast the two.

Friday, March 7, 2008

Combustible Dust Mill Fire 3/07/08


Another preventable combustible wood dust fire occurred in our nation's lumbering region in Pittsfield, Maine this morning at Hancock Lumber. Luckily no one was injured, only economic property damage and disruption to mill operations.

From the company's website, the business has a rich history which began operation in 1848 as a small logging operation in Casco, Maine. The first sawmill went into operation in the 1880s.

Today, Hancock Lumber operates three sawmills in Maine (Casco, Pittsfield and Bethel) and is the largest producer of Eastern White Pine in the United States. Hancock "Made in Maine" pine products are shipped nationwide.(1)


"...Crews from several towns used a ladder truck and other equipment to fight the fire, which appeared to be located in a system of pipes that moves byproducts of the milling process..."

Then Chemical Safety Board determined that lumber and wood product industries account for 15 percent of combustible dust incidents. Additionally, wood material accounted for the largest percentage of combustible dust incidents.

a planer striking a rock or piece of metal likely shot a spark into the wood shavings chute, a metal tube about 4 feet in diameter, while employees worked. A fan that draws the shavings up into the chute provided enough oxygen for the spark to ignite the shavings,

After the conclusion of a Combustible Dust Hazards study, the report was submitted to OSHA in 2006 with a half a dozen recommendations to prevent such incidents. The primary recommendation was to implement a comprehensive combustible dust standard which also incorporated National Fire Protection Association combustible dust codes. So far OSHA has failed to act.

On another front, combustible dust related explosions and fires occur with alarming regularity and the tragic Dixie Crystal refinery explosion is not an isolated incident . Already 12 such incidents have occurred in the United States since the sugar refinery explosion. An Act of Congress will soon bring protection to industry and the nation's workforce

Congressmen Miller and Barrow are on the right track in holding a House Education and Labor committee hearing on 12 March 2008 with the Combustible Dust Explosion and Fire Prevention Act of 2008, which they have recently drafted and are working on having the bill appear on the House Floor.

Pittsfield lumber mill hit by fire

Google Map of Combustible Dust Fires and Explosions

Down Under Combustible Dust Fire

It appears that combustible dust fires and explosions are not limited to the United States as this news release from Australia informs us here on the other side of the equator.

Fire crews are confident they have extinguished a fire in recycled milk powder at the Fonterra Milk processing plant at Darnum in West Gippsland. Fire investigators believed it was caused by spontaneous combustion in a four storey high hopper.




Example: 40 pounds of powdered milk meets up with his buddies at the fire triangle. Their partner, confinement, was not feeling well and decided to stay inside.

Since the Dixie Crystal sugar refinery explosion in Georgia last month, there has been quite a bit of dialog between a diverse group of stakeholders which includes government legislators, enforcement agencies, and labor unions concerning what preventive measures should be taken to prevent future incidents. So far there has been no word from business organizations concerning impending costly preventive legislation in preventing future catastrophic dust explosions.

Luckily in this incident the explosion prevention equipment was functioning properly and only a fire ensued. Back in February 1980, a powdered milk mill in Minneapolis, Minnesota was not so lucky when the mill was destroyed by an explosion when an employee lowered a drop cord into a bin of powdered milk to see if it was empty. A conveyor was running at the bottom of the bin. The drop cord got caught in the conveyor and caused the explosion. The explosion spread throughout the steel bins and the warehouse causing 1 fatality and 8 injuries.

Source:ABC Gippsland

Fire in a tower of milk powder

Thursday, March 6, 2008

Pre-Op Combustible Dust Legislation Hearing


It ought to be quite dicey at the House Education and Labor committee hearing next week covering the Combustible Dust Explosion and Fire Prevention Act of 2008 (H.R. 5522), which was introduced by Reps. George Miller and John Barrow (D-GA). There will definitely be an atmosphere of us against them between the Democrat and Republican committee members who represent conflicting interests of labor and business.

After viewing the web site opensecrets.org and comparing and contrasting the campaign contributors it became apparent as night and day that labor contributions represent the Democrats and business represents the Republicans of the committee. But who's representing the blue collar worker that is not part of any collective bargaining agreement?

The divisiveness is even more apparent between the House Education and Labor Committee when one sees that each party even has it's own web site for this specific committee. One for the Democrats and one for the Republicans . A striking quote on the Republicans website states:

"Under the Bush Administration, OSHA has made significant efforts to supplement traditional enforcement with cooperative partnerships,"

Cooperative partnerships
, that basically means no irksome costly regulations and instead form voluntary industry alliances . This is the same tone that Edwin Foulke, the director of OSHA is touting as a the administration political appointee, which of course would be only natural. If this wasn't his position then he wouldn't have a job anymore and would be back practicing law in the Carolinas.

Most troubling in the preemptive hours before the committee hearing is the dissension across the aisles that partisan committee members have against one another from an event nearly two months ago concerning House passage of the S-Miner Bill H.R. 2768,, which Republicans claim rolls back mine safety reforms.

"...Over the strong objections of leading Republicans, academic experts, and the mining community, the U.S. House of Representatives today narrowly passed legislation that rewrites major mine safety legislation approved less than two years ago. Republicans objected to the S-MINER Act (H.R. 2768) because it halts the progress of bipartisan ..."



For an excellent preview of what to expect at next week's hearing concerning the atmosphere that will prevail. Then check out this video where we can listen to Rep Don Young (R-AK) speak on H.R. 2768, the S-Miner Act and its negative effect on energy. Just strike out Miner Act and add the Combustible Dust Explosion Act when you listen, then you'll be on the right trail.

When one takes an overall view of this impending legislation it would be advantageous to look at the legislative history of the grassroots movement that formed for the house passage of the S-Miner Bill in January 2008. For example, a lobby composed of 325 corporations with 1.6 million dollars of spending money represented by the National Mining Association was amazingly defeated by 95,000 miners represented by the United Miner Workers of America on a $20,000
in lobbying money in the first half of 2007. Hopefully, that sort of momentum will occur with the Combustible Dust Explosion and Fire Prevention Act of 2008 (H.R. 5522) that Congressman Miller and Barrow drafted for impending legislation.

Click on the Google Map for an enlarged view, The fire logos are preventable combustible dust related fires and explosions over the past two months. The red bubbles are representative of electoral districts where current Republican committee members sit on the House Education and Labor Committee. Just figure I'd illustrate how prevalent this issue is and how close it strikes to home with Dixie Crystal not being an isolated incident.

OSHA Launches Web Page on Combustible Dusts

In a press release today, OSHA announced that it has prepared a specific web page with information on the safety regulations that the work site is required be under compliance with concerning combustible dusts. Not anything new concerning content. Only that the areas OSHA is enforcing and conducting inspections is neatly organized. Other content includes the voluntary OSHA Safety and Health Information Bulletin (SHIB) 07-31-2005 and information on the Combustible Dust National Emphasis Program.

Hot Topics

Additionally, a page is provided listing all the applicable aspects of OSHA General Industry standards that would apply to all workplaces even ones with combustible dust.

The best feature of the web page and my hats off to OSHA...thanks. Is the links to NFPA 654 and NFPA 454, where once you arrive at the NFPA site, you have the option of utilizing a reader to view the entire code book. Can't copy pages...you need to purchase for that.

There is a link to other resources, which could of expanded to include the very educational and informative CSB Combustible Dust Hazard Study that was completed in 2006. Instead the Chemical Safety Board link only goes to their news page.

Heh...you don't want to be in the news. We want to learn how to stay out of the news. Maybe if the OSHA webmaster is reading this he can fix this minor aberration.

Wednesday, March 5, 2008

Nation Moves to End Dust Explosions


A nationwide movement has galvanized in putting an end to combustible dust explosions and fires that have killed and injured countless number of workers on a continual basis. The recent highly publicized combustible dust explosion that caused death and destruction at the Dixie Crystal sugar refinery on the serene banks of the Savannah River has brought forth an awareness and social awakening not experienced since dozens of workers and federal grain inspectors were killed in grain-silo explosions back in 1977. From that point on and after a decade of numerous and seemingly unending studies, hearings, and notice of proposed rule makings the OSHA grain handling facilities standard was incorporated into the workplace health and safety regulations in 1988.

Dust Explosions Revisited

Hopefully it won't take a decade for a general industry combustible dust standard to be promulgated into OSHA workplace health and safety regulations. Especially while preventable dust explosions and fires are continuing nationwide on a weekly basis in close comparison to the daily earthquake tremors across the globe. It's only a major earthquake with resulting fatalities and injuries that gains public attention. Quite analogous to the Dixie Crystal incident, while dozens of other smaller earthquake tremors and combustible dust fires and explosions occur unnoticed on a local basis.

The National Academy of Sciences, in the early 1980's, did recommend after numerous preventable grain-silo explosions that a general industry comprehensive combustible dust standard be implemented in conjunction with the grain standard. That didn't happen since during that period of the political landscape, the Reagan administration issued Executive Order 12291, which created a Regulatory Relief program, diminishing the power of OSHA at the expense of the worker to the benefit of corporate financial management .

It's All About Attitude

This political attitude had future repercussions and from the period spanning 1980-2005, a plethora of 281 combustible dust explosions occurred across the nation killing 119 workers and injuring 781. It wasn't until 2003, when 3 catastrophic explosions occurred killing 14 workers that the government went back to the drawing board to investigate and decide whether combustible dust explosions was a hazard that needed regualtion.

Through the superb investigative efforts of an independent federal agency, the Chemical Safety Board, completed a Combustible Dust Hazard Study in November 2006 and submitted it's findings to the Department of Labor. In deja vu form just as the National Academy of Sciences had recommended nearly three decades earlier, the CSB recommended that a general industry comprehensive dust standard be implemented in the OSHA regulations in addition to five other preventive measures .

Grassroots Movement

In addition to independent governmental agency involvement in the effort to implement a general industry combustible dust standard, grassroots community movements have also developed. For instance, Tammy Miser, whose brother, Shawn Boone, died in the 2003 Hayes-Lemmers Huntington combustible dust explosion co-founded United Support & Memorial for Workplace Fatalities .


This dedicated group provides support to surviving family members, whose loved ones have died in combustible dust explosions and other workplace accidents. Fatalities in the workforce occur on the average of fifteen/day from numerous causes and most of these go unnoticed. Additionally, Tammy's blog, "Weekly Toll," provides resourceful insight into the daily worker fatalities in conjunction with bringing a human face and name to the endless black and white statistics.

A Voice of Millions

A call for change in the current structure of inadequate workplace safety and health regulation's is also heard from millions of union workers where the United Food and Commercial Workers International Union (UFCW) and the International Brotherhood of Teamsters recently filed a petition to OSHA demanding an emergency temporary standard to protect workers from combustible dust explosions. Organizations such as the Change to Win , American Rights at Work, and the International Labor Communication Association have also provided productive input through their membership and web sites in educating members on the hazards of combustible dusts in addition to there tireless lobbying efforts in Congress.

Legislative Action

But this is not enough in instituting change, especially since the union workforce is only 12 percent of the nation's total workforce of over 153 million. Unfortunately issues of workplace safety are polarized across party lines, where one group demands a comprehensive combustible dust standard and the other party desires less costly voluntary compliance. Issues of cost-benefit analysis questioning the benefits to society in the possible implementation of a comprehensive combustible dust standard are now debated.

Even more dialog arises when questions of whether measured criteria both quantitatively or qualitatively of preventing fatalities and injuries will outweigh the costs of regulation to industry. After the implementation of the grain facility standard back in 1987, no one noticed any agricultural business's shutting down. It's a moot point that many legislators across party lines suggest and invoke fear, that industry will move offshore when a dust standard is implemented.

Through the tireless efforts of Congressman George Miller (D-CA) and his congressional peers, an acting as the Chairman of the House Committee of Education and Labor, he called for a full committee hearing on March 12, 2008 concerning impending legislation to implement an OSHA comprehensive combustible standard where OSHA through the direction of the Department of Labor have failed to act.

Fractious Rebuttal

It's a shame that it takes an act of Congress like an Act of War to obtain a solution in the future prevention of combustible dust explosions, which not only causes preventable death, destruction, and injuries but adversely effects the economic vitality of the economy with lost jobs and exponential harm to the livelihood of all the vender's and service providers that support the damaged facilities.

Hopefully, Edwin Foulke, an attorney by trade and political appointee as the director of OSHA will get the message and instead of fractiously opposing a general comprehensive combustible dust standard will provide leadership and insight into instituting long sought after closure for the families who lost their loved ones over the past quarter century in combustible dust explosions. How many more preventable combustible dust fires and explosions before the next major tremor occurs?



Pet Food Factory Combustible Dust Explosion

http://www.wqad.com/Global/story.asp?S=7966727

As the tally rises to thirteen combustible dust related fires and explosions since the Dixie Crystal sugar refinery explosion, legislators, labor leaders, and governmental officials are at odds with each other whether a comprehensive combustible dust standard is needed for general industry across a wide spectrum of business's that generate combustible dust hazards.

MONMOUTH -- Grain dust is the likely fuel of an explosion at a Monmouth pet-food factory Tuesday that injured one person. The explosion happened at 4:14 p.m. at a tower that Wells Pet Food Co. uses to store grain for its products, said Monmouth Assistant Fire Chief Patrick Spears.

Just as there are dozens of earthquakes around the world on a weekly basis, only a handful of tremors gain notice when they strike populated areas. Which can be compared to the numerous unnoticed combustible fires and explosions that have occurred in the United States since the highly publicized Dixie Crystal, Port Wentworth sugar refinery incident on the serene banks of the Savannah River.

At the moment, with a heavily touted electoral process thrusted upon the national stage, which includes issues of immigration, the war in Iraq, health care, education, taxes, and such. Consequently, the importance of a productive workplace which includes health and safety standards amongst the nation's work force and electorate ranks way far below same-sex marriage.

The OSHA Act, which became law in 1970 has reduced work place fatalities and injuries tremendously but has a way to go before it's austere goals are obtained. Especially when at the end of the workday tomorrow, on an average, fifteen of your loved ones will not return home from at the end of the day.

Either a messy confrontation will ensue when legislators are polarized across party lines in debating whether a comprehensive combustible dust standard is needed. Or in contrast, the electorate can personally get involved, making phone calls , sending emails, and organizing at the grassroots level with the goal in mind that combustible dust explosions and fires in the nations workplace are no longer acceptable.




Tuesday, March 4, 2008

Combustible Dust Fire Basics


Flamable Food - Blow Huge Flames With Nothing But Food As Fuel - Watch today’s top amazing videos here

OSHA Stalling on Combustible Dust Standard

Sixteen months after OSHA received the Chemical Safety Boards recommendations on preventing combustible dust explosions, Edwin Foulke, the director of OSHA argues that the department is still in the process of looking into whether a comprehensive combustible dust standard should be implemented versus maintaining the status quo of the current inadequate OSHA general industry rules of housekeeping, ventilation, and electrical standards. This is a good point the director makes for workplaces that are not exposed to combustible dusts but invalid when general industry is generating hazardous atmospheres during the manufacturing processes.

Furthermore, Mr. Foulke, has no idea of the magnitude of the problem when he states there are approximately 10-15 combustible dusts that would be effected by a dust standard. For example, in the 2006 investigative report completed by the Chemical Safety Board, which the director is referring to, there are over 200 combustible dusts that require a dust standard. As an attorney by former training , Mr Foulke is not qualified to provide expert opinion on combustible dusts only opinion on compliance enforcement and litigation actions of OSHA.

Chemical Safety Board Recommendations For Combustible Dusts


1. Comprehensive Combustible Dust Standard
2. Revise the Hazard Communication Standard
3. Amend
the UNECE Globally Harmonized System (GHS) of Classification and Labeling of Chemicals
4. Provide Training through the OSHA Training Institute (OTI)
5. Implement a National Emphasis Program (NEP)
6.
Modify ANSI Z400.1 American National Standard for Hazardous Industrial Chemicals


Dust Regulation Threat of Losing Jobs Offshore

An interesting snapshot of Congressman Jack Kingston's view that if a comprehensive combustible dust standard for general industry is promulgated then a potential threat arises in industry moving offshore instead of compliance with health and safety issues . How many agricultural business's moved offshore after the grain combustible dust standard was implemented in 1987? In either case a cost-benefit analysis is needed to move forward in the protection of the nation's workforce.


Saturday, March 1, 2008

Combustible Dust Hazards: Alarming Trend

http://www.bismarcktribune.com/articles/2008/03/01/news/state/150068.txt

An alarming trend is occurring across the nation at processing facilities in general industry where fires and explosions are occurring repeatedly, especially where combustible dusts are generated. In many instances no injuries or fatalities occur; only damage to the facility and a negative economic impact to the community.

In less fortunate instances, such as the preventable recent tragic Dixie Crystal sugar refinery explosion located in the heart of Dixie, lives are senselessly lost in conjunction with insurmountable physical pain and suffering to workers and their loved ones.

It was only two years ago that the Chemical Safety Board submitted, at the completion of a Combustible Dust Study, a report to the Department of Labor recommending the implementation of an OSHA comprehensive dust standard to protect the health and safety of workers from the hazards of combustible dust explosions and fires. So far the OSHA has failed to act. In the meantime combustible dust explosions and fires continue across a wide spectrum of industries across the nation's heartland.

GRAND FORKS (AP)..."The fire early Thursday morning was contained in the dust collection system at the North American Foods plant..."

In the CSB study for the period of 1980-2005, investigators discovered that over 40 percent of combustible dust fires and explosions occurred in the dust collection systems and 24 percent of these incidents were sparked in food processing facilities such as the one at North American Foods in Grand Forks, North Dakota.

The CSB found that in all industries, dust collectors are the equipment most often involved in incidents;similarly, Zalosh et al. (2005) report that dust collectors account for more than 40 percent of all dust explosions.

Findings of the actual ignition source of the Grand Forks dehydrated potato plant has yet to be determined. In retrospect, all plant managers
throughout the nation , through close scrutiny of their Material Safety Data Sheets (MSDS) will have to reassess their current operating procedures to insure minimum explosive concentrations (MEC) and minimum ignition temperatures (MIT) are not breached in the vicinity of potential ignition sources such as non-compliant electrical fixtures.

Biggest challenge is...most MSDS, fail to list these important physical properties in contrast and analogous to flammable liquid flash points listed for petroleum product. Incidents of combustible fires and explosions will continue while the workforce is in the dark in regards to the combustible dusts hazards they are daily working with across the nation.

 

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