Friday, April 25, 2008

Controlled ComDust Explosion: Flash-Bang!

Until the horrific combustible dust explosion at Imperial Sugar Refinery over two months ago, most of the nation had no idea that seemingly harmless coffee creamer and sugar poured into a cup of coffee jump starting us with a morning java jolt could also create another type of jolt, yet devastating . Many of the same food products found on the aisles of the local grocery store have the explosive power of gunpowder when suspended and ignited in a confined space such as a manufacturing facility.

Information gathered from OSHA's National Emphasis Program on combustible dust in conjunction with the Chemical Safety Boards Combustible Dust Study provides a conservative glimpse of over 100,000 firms in the United States that utilize raw combustible particulate solids of wood, rubber, plastic, metals, food, chemicals, and pharmaceuticals, which could generate explosive atmospheres. When the manufacturing process begins, combustible dusts are generated. Military and police forces use the same physics of a dust explosion in fuel-air bombs that generate controlled dust explosions.

The United States military has been very successful with fuel-air thermobaric bombs hitting the enemy caves in Afghanistan with the Hellfire missile. Police SWAT teams also have an application for controlled combustible dust explosions with flash-bang grenades that utilize a mixture of aluminum and potassium perchlorate dust. Yes, this is the same dust thats caused many combustible dust explosions and fires in the metal and chemical process manufacturing industries over the past several decades.

Combustible dusts are commonplace occurrence in our daily lives; in the packages on the grocery store aisles, military arsenals, community police tactical equipment, in addition to the manufacturing process. Once an awareness of combustible dust is acknowledged, then the proper mitigative and preventative measure can be instituted. Just don't go hiding in any caves or get the SWAT teams upset, theres no mitigation there.

Explosion Suppression and Spark Detection

The 2008 Process Technology Expo International Conference to be held at the Donald Stephens Convention Center on the outskirts of Chicago on May 6-8 2008 is the extravaganza to attend concerning combustible dust explosion prevention and mitigation equipment. Exhibitors will be displaying new technologies that the process manufacturing industry utilizes in the prevention and mitigation of future preventable and predictable combustible dust incidents.

Since the tragic Imperial Sugar explosion there's been over 30 combustible dust fires and explosions throughout the United States. OSHA's Combustible Dust National Emphasis Program highlights nearly 70 North American Industrial Classification codes (NAICS) of over 63,000 firms that have frequent and/or high consequence combustible dust explosions/fires in addition to industries that may have potential for combustible dust explosions/fires

The Combustible Dust Policy Institute has localized an additional 47,000 (NAICS) firms that also have occurrences of combustible dust related fires and explosions. With over 110,000 firms potentially exposed to explosive atmospheres in the process manufacturing industries, its' crucial that proactive measures be instituted

Initially firms must conduct a risk analysis of their unique processes in determining if hazards exist. For a minor investment of several thousand dollars, commercial testing facilities can assist in determining the minimum ignition temperature, minimum ignition energy , minimum explosive concentration, and explosive severity of the dust generated in their process.

With the information obtained concerning the ignition sensitivity and explosion severity, plant management can plan on the technical mitigative and preventive measures to implement. Protective and mitigative equipment could include spark detection systems, spark suppression, mechanical isolation valves, explosion vent panels, in conjunction with a
multipoint monitoring system.

The PTXi show in Chicago will have a diverse spectrum of combustible dust protection manufacturers exhibiting such equipment and answering technical questions that arise concerning specific applications in the thousands of process industries throughout the nation.

Hope to see you there.

Explosion Protection Resource

(OSHA) Combustible Dust National Emphasis Program (NEP)

2008 Process Technology Expo International Conference

North American Industry Classification System (NAICS)

Thursday, April 24, 2008

Metal Combustible Dust Particle Size

Information in Material Safety Data Sheets concerning fire hazards of most combustible particulate solids and the combustible dusts generated in the manufacturing process is absent in most instances. The definition of a combustible dust as defined by NFPA 654 is:

"Any finely divided solid material that is 420 microns or smaller in diameter (material passing a U.S. No. 40 Standard Sieve) and presents a fire or explosion hazard when dispersed and ignited in air." The same definition is used for combustible metal dust in NFPA 484, Standard for Combustible Metals, Metal Powders, and Metal Dusts.

Additionally, OSHA's Safety and Health Information Bulletin (SHIB), "Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions," published in 2005 states:

"That one possible source for information on combustibility is the Material Safety Data Sheet (MSDS) for the material. In some cases, additional information such as test results will be available from chemical manufacturers."

But thats were the problem arises, MSDS's, don't have the vital fire and safety information concerning combustible dust and laboratory testing is very costly. It's highly advised to have testing conducted as soon as possible . Until the facility management completes testing there is one alternative that the Combustible Dust Policy Institute has found most helpful concerning metal combustible dusts in the fabricated metal product manufacturing industries when determining if
finely divided solid material is 420 microns or smaller in diameter .

For example, Atlantic Equipment Engineers has provided on their website a metal product technical data reference for over 120 metal powders and compounds. While browsing the numerous metal powders its quite easy in determining the product size of many many powders used in industry. Any US Sieve Series and Tyler Mesh Size higher than 40 would rank the powder as a combustible dust .

For a helpful review of micron powder particle size in relation to mesh size, here is a helpful link:
ESPICorp Inc.

Hope that helps in clarifying particle size in determining if your metal dust is a combustible dust or not. Until then, as soon as possible schedule a testing of your process dust for ignition sensitivity and explosion severity.

NFPA 484, Standard for Combustible Metals, Metal Powders, and Metal Dusts

Map Combustible Dust Explosions 2007 & 2006

Here are a few helpful links of Google Maps regarding combustible dust related explosions and fires during 2007 and 2006.The data included in the Google Maps was obtained from Chemical Safety Board incident data. The Combustible Dust Policy Institute did not start collecting incident data until after the Imperial Sugar Refinery dust explosion in February 2008.

Google Map 2007

Google Map 2006

Here at the Combustible Dust Policy Institute, we will continue to provide updated information on the extent of combustible dust incidents throughout the process manufacturing industries. With knowledge of the prevalence of such incidents, all stakeholders can take appropriate preventative measures in protecting life and property.

Tuesday, April 22, 2008

Dozens Combustible Dust Fatalities and Injuries Unaccounted

As H.R. 5522, the Combustible Dust Explosion and Fire Prevention Act bill moves to the House floor shortly, dozens of fatalities and injuries are unaccounted for. Legislators, governmental agencies, and industry trade associations only have a partial picture of the magnitude of the threat posed to the workplace by the hidden dangers of combustible dusts.

Over the past decade 14 documented fatalities and 47 injuries have occurred in two dozen combustible dust explosions and fires that were not included in the official 2006 Chemical Safety Board Combustible Dust Study. Many of the incidents were not cleared for public release due to pending court cases. With the passage of time this information now becomes available to the public through governmental databases.

Chemical Safety Board

The Chemical Safety Board has provided the public with an excellent service considering their limited annual budget of less than $10 million dollars. Most of the workplace accidents consisting of fires and explosions go uninvestigated by the CSB due to limited resources. Innovation combined with computer technology the agency provides helpful feedback to the workplace on root causes of accidents so they don’t occur again. Most helpful to the process industries are the DVD’s that are offered free of charge which are excellent safety training tools for veterans and newcomers to the industry.

As a federal independent investigative agency, the CSB is limited in breath and depth while conducting research on past incidents. Especially troublesome is the absence of central database with records of workplace accidents consisting of fires and explosions. Concerning the Combustible Dust Hazard Study, the CSB did not represent the data as complete or error-free. Especially since the combustible dust incidents were only a small sampling.

Recent Studies

Over the past two months, the Combustible Dust Policy Institute has completed cursory research on combustible dust explosions and fires and picked up were the CSB combustible dust studies ended. Over that past ten weeks since the Imperial Sugar Refinery explosion there have been over 30 combustible dusts related fires and explosions.

Hundreds of Incidents

Currently, many stakeholders both opponents and proponents of the proposed Combustible Dust Explosion and Fire Prevention Act, H.R. 5522, are under the assumption that there has been approximately 350 combustible dust fires and explosions since 1980. This is a very small sampling and a closer number would be approximately 3500 combustible dust explosions and fires over the last 28 years.

Either the earth, moon, sun, and planets were aligned in some unusual manner for the nearly three dozen combustible dust incidents to occur over the past ten weeks or now we have a better picture of the extent of the complex subject of combustible dust incidents occurring in the nation’s manufacturing process industries.


Chemical Safety Board

OSHA Integrated Management Information System database

Saturday, April 19, 2008

Failure Knowledge Database-JST

An excellent resource in studying the cause an effects of accidents can be found at the Japan Science and Technology Agency (JST website. Under the direction of Professor Yotaro Hatamura (Kogakuin Univ.), a Failure Knowledge Database was developed. Several of the incidents involve combustible dusts and it is very helpful browsing and reviewing all the incidents. This would be a fantastic tool to implement in the United States in assisting industry in the prevention of reoccurring predictable and preventable ComDustX accidents. Question is, who would enter the data and would the manufacturing industry provide such hush-hush information?

Costly Information
Currently, in order to learn about combustible dusts, one has to spend hundreds of dollars to attend out-of-state educational sessions at conferences and seminars. Many stakeholders which include millions of workers in the manufacturing industries, don't have several weeks of their paycheck to spend for such an outlay on these educational endeavors. More information needs to be available freely on the Internet, like the Japan Science and Technology Agency has provided.

Global Resources
On the other side of the globe, the Berufsgenossenschaftliches Institut für Arbeitsschutz - BGIA in Germany has a free database of combustion and explosion characteristics of dusts from more than 4000 dust samples across a wide spectrum of industries. Why doesn't the United States have such a database? Up until 1996, the U.S. Bureau of Mines was the primary organization conducting scientific research and providing information on combustible dusts. Now, after over a decade, the agency is gone with no replacement . Where is the leadership in government in providing the data that our industrial infrastructure needs?

Instead the nation has to resort to Acts of Congress, like an act of war in providing safety standards regarding workplace safety issues. Standardization in preventive and mitigative measures is only one aspect of the pyramid. Transparency and ease in availability of vital information is also required. For example, you have two manufacturing processes exactly alike. One on the East Coast, the other on the West Coast. Suppose a ComDustX incident occurs on the West Coast due too a static electricity source. Wouldn't it be prudent to share that information with the entire industry in the prevention of future electrostatic ComDustX incidents? But no, this isn't done in the U.S., it takes several years for information availability.

Global Collaboration
Japan and Germany are just two countries which are also our global trading and security partners. There are many other nations spanning the globe that governmental, industry, and academia need to collaborate with concerning the complex subject of ComDustX. Why waste time and other resources if specialized work and programs have already been successfully implemented? A global Internet revolution on combustible dust is in order.

California ComDustX Record Outstanding

How can one state that has over 13% of the nation's 333,460 manufacturing establishments, according to U.S Census Bureau 2005 data, maintain such a superb record of minimal combustible dust incidents? Across the board in the food, metal, wood, chemical, plastics/rubber, and textile industries, California has stayed off the radar with no incidents over the last two months. Either ComDust incidents are not being reported by the local press or industry must have a instituted a phenomenal preventive and mitigative combustible dust safety program.

Currently California has four times as many manufacturing facilities (44,825) than 84% of the 50 states in the union. Over the past 10 weeks since the Imperial Sugar Refinery explosion there has been over 30 combustible dust related fires and explosions occurring across a wide spectrum of industries throughout the United States from coast to coast. The revealing aspect is in over 45% of these incidents, California has the leading number of establishments in the following distinct industries were incidents have occurred in other states. Yet none in California.

How can this be? The math doesn't compute, since it seems if you have the leading number of industries, then shouldn't the state lead in ComDust incidents?

  • Breakfast Cereal Manufacturing
  • Dog and Cat Food Manufacturing
  • Dry, Condensed, and Evaporated Dairy Product Manufacturing
  • Cut Stock, Resawing Lumber, and Planing
  • Other Millwork (including Flooring
  • Institutional Furniture Manufacturing
  • Nonupholstered Wood Household Furniture Manufacturing
  • Electroplating, Plating, Polishing, Anodizing, and Coloring
  • Nonwoven Fabric Mills
  • Thread Mills
  • Dental Equipment and Supplies Manufacturing
  • Adhesive Manufacturing
  • Urethane and Other Foam Product (except Polystyrene) Manufacturing

Currently, the Combustible Dust Policy Institute is reviewing governmental historical data from various agencies in the determination of abnormal trends in specific industries and locales where combustible dust incidents occur. The results will assist in managing resources where ComDustX hot spots occur and strategically direct stakeholders in an efficient manner in conjunction with lowering operating costs.

For instance, in the wet corn milling industry (NAICS) 311221, the Chemical Safety Board Combustible Dust Hazard Study collected data on 21 ComDust incidents from the period 1980-2005 in this industry. The wet corn milling industry has 66 establishments nationwide, employing nearly 9,000 workers in this food manufacturing subsector according to governmental data from 2005.

Iowa, the leading state with 12 establishments had 5 of the 21 incidents during the above noted period. In contrast, Illinois with 4 wet corn milling facilities had 7 incidents (33%) of the 21 incidents. Why does one state with three times as many establishments as the other, have 30% less occurrences of ComDustX incidents?

States with good records of low incident rates could possibly collaborate with high incident rate states in the reduction of future ComDustX incidents. A central clearing house could be developed across a wide spectrum of industries in facilitating future administrative controls. Regulations are only a temporary fix unless communication is maintained between industry stakeholders when dealing with the complex subject of combustible dust.

Friday, April 18, 2008

Cost Estimate: ComDustx and Fire Prevention Act

Heres the latest on the Congressional Budget Office cost estimate of H.R. 5522, Combustible Dust Explosion and Fire Prevention Act of 2008. Click on the link below for the informative 2 page .pdf file that was released by the CBO, 17 April 2008.


63,000 Firms Under OSHA ComDust Program

OSHA's Combustible Dust National Emphasis Program includes over 63,000 firms across a wide spectrum of industries. If all the firms were to be inspected in a one year period then that would equate to 200 inspections daily in determining if a combustible dust hazard exists. This would be impossible with OSHA's limited resources . Additionally, the magnitude of the problem increases with the number of establishments the individual firm has. So one must take into account the number of facilities to increase by 20-30 % from the amount of establishments a firm has.

The Combustible Dust Policy Institute recently completed a study, using the data from the 300 incidents compiled from the Chemical Safety Board combustible dust study. The findings were revealing utilizing U.S. Census Bureau data that was obtained from North American Industrial Classification System records. For instance, an additional 66 manufacturing industries that have a history of combustible dust explosions and fires that OSHA has ignored and is not listed in the Combustible Dust National Emphasis Program. This would conservatively add another 50,000 firms that are exposed to potentially hazardous combustible dust.

With over 113,000 firms in process manufacturing that potentially generate combustible dust explosive atmospheres it is quite clear that voluntary compliance and waiting on the arrival of an OSHA inspector is out of the question. Since the Imperial Sugar refinery explosion in February there has been over 30 combustible dust related fires and explosions.

Either the planets, moon ,and sun had to be in perfect alignment for such a high number of incidents or all of a sudden combustible dust explosions occurred due to pure coincidence. Either way, the 281 combustible dust incidents that the Chemical Safety Board compiled is only a small sample from the period 1980-2005.

A more reasonable number of combustible dusts incidents extrapolating the current 30 incidents would be over 3,000 combustible incidents over the past three decades. During the course of future pending legislation concerning the Combustible Dust Explosion and Fire Act, the Combustible Dust Policy Institute will be completing additional studies in determining the breadth of this complex issue.

Thursday, April 17, 2008

Training Combustible Dust Webinar

Good news! The Illinois Department of Commerce and Economic Opportunity and OSHA are presenting a FREE webinar on Combustible Dust on May 14, 2008 10:00-11:00 AM

To register, send your email address to,.

OSHA Assistant Regional Administrator Mr. John Newquist, of Region 5 will be conducting the one hour training session. Participants can either participate in the seminar on their computer or visit the training site in person at the EiigerLab on 605 Fulton Avenue in Rockford, Illinois.

ATEX: ATmosphères EXplosibles

It's odd that our major global trading partners have instituted proactive controls in the protection of the workplace and personnel from the hazards of combustible dust incidents. Yet here in the United States under the direction of the current OSHA management there is a wait and see attitude with the idea that additional studies must be completed before further OSHA standards can be instituted concerning the hazards of combustible dust.

With innovative leadership, OSHA could instead develop a program similar to the ATEX standards that have been implemented since 2003 in Europe. Here is an excellent resource that will provide industry with guidance in developing a proactive combustible dust preventive and mitigative program. Browse the articles provided by Epsilon:

Web Based Articles

Thursday, April 10, 2008

Combustible Dust Training-May 5-8

Now that the word is getting out concerning the explosive atmospheres that are generated by combustible dusts in the workplace. It's time to obtain some training from professionals who work daily in the industry providing protection for all process industries.

The Process Technology for Industry International Expo (PTXi ) in Rosemont, Illinois on May 5-8 is the place to go. Also referred to as
the International Powder & Bulk Solids show. The extravaganza has been joined by Pharma Process, Chem Process, and the Process Pack shows. So there will be plenty of venues to participate in across a wide spectrum of industry. Heres a quote from the website concerning the educational sessions:

The 2008 Process Technology Expo International Conference will provide leading educational sessions structured with extensive input from process industry experts to provide practical high-value information attendees can immediately apply to their job responsibilities.

Topics covered on combustible dusts at the PTXi conference daily educational sessions:

Thats 15 hours of intensive training spread out over three full days,with some time in between the morning and afternoon sessions to view the exhibits in the Donald Stevens Convention Center. This training sessions will get you to speed so you don't end up on the Google Map of the next preventable and predictable combustible dust explosion or fire.

Conference registration includes:
  • Lunch on registered day(s)
  • A set of PTXi proceedings for registered day(s)
  • Canvas tote bag
  • Coffee and refreshments during the session breaks
  • Complimentary admission to the expo
Conference Fees

20% discount rates (Exhibitor, Govt, Student)
Early bird discounted rates
Standard on site rates (after April 11)
1 day
Full Conference

Link to PTXi Conference

ComDust Hazardous Communication

Since OSHA has failed to proactively address hazardous communication of combustible dust hazards, the Combustible Dust Explosion and Fire Blog will be providing pertinent information to interested stakeholders who wish to prevent and mitigate future incidents.

Todays post at the Combustible Dust Policy Institute will begin with signage that is used in the European ATEX 137 Combustible Dust Program, which is part of the
explosion protection document.


The directive requires that all areas classified as hazardous be identified with a warning sign. The sign must be triangular, black on yellow with the text Ex. The signs must be displayed at points of entry into explosive atmospheres

The Combustible Dust Policy Institute (CDPI) is especially concerned regarding firefighters who respond to fires not knowing that the facility utilizes non-hazardous combustible particulate solids that generate explosive atmospheres of seemingly harmless combustible dust. Of major concern is a primary and secondary combustible dust explosions occuring while the firefighters are inside the building.

November 14, 2005 -And in Iowa, two firefighters are recovering today after two explosions at a Pella (Iowa) company. The Pella fire chief says a dust explosion ignited a fire inside the American Wood Fibers plant early Sunday afternoon.

As firefighters tried to put out the fire, another explosion took place. Two firefighters suffered hand injuries as concrete and metal flew through the air. One firefighter was treated and released from a hospital. The other had to be airlifted to a Des Moines hospital. His condition has not been released.

This isn't the first time there's been trouble at American Wood Fibers. Back in December of 2002, an explosion and fire consumed the plant. Police believe wood dust caused that explosion.

Placement of the signs at all entry points will provide the necessary initial hazardous communication to everyone in the vicinity of a potentially explosive atmosphere during normal operating hours in addition to fire emergencies. Yesterday an event in Hamilton, Ontario Canada where firefighters responded to a factory blaze that contained rat poisons, which they had no knowledge of while fighting the fire. If warning signs like to NFPA 704 signs were located on the outside of the building maybe proper warning would of been communicated and fire crews could assess the hazards accordingly

NPFA 704 signage at building entry points is just one example to illustrate the importance in communicating the hazard in a real scenario. Explosive atmosphere signage would work in the same manner as it currently is required in the European Union. Our brave and dedicated firefighters require the same amount of transparency upon arriving on the scene of a facility fire.

Firefighters injured in dust dxplosion

Wednesday, April 9, 2008

Sparks Fly Combustible Dust Bill

Already even prior to the approved mark-up of the combustible dust bill that passed the House Committee Education and Labor there has been a flurry of high level letters sent to bill's co-sponsors Congressmen George Miller(D-CA) and John Barrow (D-GA). For instance, the Chamber of Commerce and Edwin Foulke, Director of OSHA both oppose the bill in it's current form and and state bluntly in the content of their recent letters . The Department of Labor has even gone to the trouble in taking sides politically through it's recent public statement today after the bill markup success with this statement:

“H.R. 5522 would mandate a one-size-fits all standard for as many as 200,000 worksites throughout the country. Supporters of H.R. 5522 mistakenly believe there are no combustible dust workplace protections, when there are 17 existing OSHA standards. OSHA is currently inspecting facilities with the highest danger of combustible dust. If OSHA determines through these inspections that the standards are not effective in protecting employees, the agency will not hesitate to initiate a rulemaking. ”

It's still a bit of a shock to believe that OSHA's 17 existing standards are working, especially since there has been 30 combustible dust related explosions and fires in the last eight weeks since the Imperial Sugar explosion. How is it that the supporters of H.R. 5522 mistakenly believe that there are no combustible dust workplace protections when dust explosions and fire are occurring every other day?

In a bold move the Chamber of Commerce believes the provisions of the final standard would
be set by legislators rather than the safety and regulatory professionals at OSHA. Thats a far stretch, since over the last five years after the horrific loss of life in numerous combustible dust explosions in 2003, the professionals in management at OSHA stood by idly.

Safety professionals, industry experts, and even representatives from the Department of Labor were part of the committees that drafted the numerous NFPA combustible dust codes that would be instituted in the proposed combustible dust bill

James E. Maness, JEM Safety Consulting, MO [U] Rep. Grain Elevator and Processing Society

Guillermo A. Navas, Sheet Metal & Air Conditioning Contractors National Association,

Harry Verakis, U.S. Department of Labor,

David L. Oberholtzer,] Rep. The Aluminum Association

Keith Epperson, American Feed Industry Association,IA [U]

James E. Maness, JEM Safety Consulting, DE [U]Rep. Grain Elevator and Processing Society

Robert J. Moore, Tate & Lyle America, IL [U]Rep. Corn Refiners Association Inc.

Ira C. “Bud” Nation, Archer Daniels Midland Company,IL [U] Rep. National Oilseed Processors Association

Jerry S. Wodzinski, Underwriters Laboratories Inc., IL [RT]

In addition to trade association as members of the NFPA committees, Fortune 500 Companies were also part of drafting the protective combustible dust NFPA fire codes.

David G. Clark, E. I. du Pont de Nemours & Company

J. Anthony Yount, ConAgra Food Ingredients,

James L. Roberts, Fluor Enterprises, Inc., SC [SE]

Richard F. Schwab, Honeywell, Inc., NJ [U]

Allan J. Johnson, Cargill, Inc., MN [U]

Michael J. Shimer, The Boeing Company, WA [U]

William E. Janz, Swiss Re, Global Asset Protection

Employers will not become more knowledgeable about the hazard solely by the issuance of a Safety and Health Information Bulletin, and the recent re-issuance of the National Emphasis Program. Combustible dust explosions and fires are very complex and the current OSHA reactive voluntary program does not provide the proactive program that is needed.

Instead a National Dust Explosion Research Institute (NDRI) needs to be developed in conjunction with cooperation between academia, trade associations, safety professionals, and regulatory agencies. This is where the leadership at OSHA needs to be heading , instead of butting of heads between labor and industry.

A trip to Norway and Germany would be in order in collaborating with their excellent dust explosion research institutes. In the end this would also provide more jobs in the technical fields. Since we are delving into a technical subject that enters the realm of powder mechanics and computational fluid dynamics. From there industry will absorb the required knowledge of this complex subject.

It is true that the bill would require within 18 months OSHA promulgate a final standard that would carry forward all of the requirements of the interim final rule (IFR). That would be a difficult for many facilities and a compromise needs to be addressed. One answer would be looking into the ATEX Combustible Dust Programs that our global trading and security partners are already using in the European Union, United Kingdom, Australia, and New Zealand. The foundation of the overseas program is an explosion protection document that facilities adhere to. This program institutes a 3-5 year phase in , which we could do the same after the IFR.

Additionally, in regards to testing the ignition sensitvity and explosion severity of combustible dusts, cooperative programs could be implemented between trade associations spread across a wide spectrum of industries. This would cut costs tremendously with the costly analytical laboratory testing from thousands of facilities spread across the nation.

This will be a long haul just like the six years it has taken to complete the finishing touches of Homeland Security after the 2002 Homeland Security Act. But it can be done with cooperation between all stakeholders and the proper leadership at OSHA.

Dust Bill Opposition Letters

Free Viewing Online Access to NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 Edition

H.R. 5522,Combustible Dust Bill Moves to House Floor

This morning at the mark-up of "H.R. 5522, Combustible Dust Explosion and Fire Prevention Act of 2008", the Full Committee of the House Education and Labor voted and agreed that this important bill should move forward onto the House floor. Over the past eight weeks, since the catastrophic Imperial Sugar Refinery explosion there has been 31 combustible dust related explosions and fires, which included six dust explosions in March. In April alone, there's been five combustible dust fires at flooring, paper, dental, and food manufacturing facilities. Luckily no fatalities or injuries in these April incidents. Luck only goes so far at the roulette wheel..

Monday, April 7, 2008

Video: Mitigation Combustible Dust Explosion

Here is a short video simulating a combustible dust explosion in a silo or bucket elevator where the explosion panels take the brunt of the blast. The end result would be the protection of property and personnel.

1,000th Visitor Today

Thanks to all the visitors who have ended up on the Combustible Dust Explosion and Fire blog. I know now that the efforts in providing helpful information regarding combustible dusts have not gone in vain. It be sort of strange making posts and no one reading them ...sort of like talking to myself.

Since the first post on March 1, I've learned quite a bit and learning more everyday about the various manufacturing processes that handle combustible particulate solids that generate combustible dusts. Every process has it's unique characteristics in generating combustible dust and it's important that the plant manager obtain an awareness of this complex subject and share this knowledge with all the employees in the company health and safety training program.

When I see Google search terms come up, such as minimum explosive concentration of grain dust, combustible dust testing, kst index coal, combustible wood dust in shop, and corn dust msds. Then I know viewers are actively seeking to acquire information in the prevention and mitigation of future dust incidents. Hopefully this Combustible Dust and Fire Explosion blog will provide an easy pathway in obtaining the information you seek.

Thanks again for visiting the site and be sure to leave your comments following the posts. That would help in generating constructive dialog on the subject. If the music that I added to the site becomes to irritating you can just click the pause button at the top left of the page.

Being that many blue-collar workers in the manufacturing industry work the shift schedule I figured it would be appropriate to add Kenny Chesney's song "Shiftwork" to the site. That what this site is all about...protecting all workers from the consequences of combustible dust explosions and fires, whether they work shift or not. It doesn't help that unfortunately I work shift also. So when I first heard the song..I thought yeah, I can relate to that. So for others who don't work shift you are not missing anything. But now you have an idea of what it's all about while you browse the contents of the site.

Book Review: Electrostatic Ignition Combustible Dust

Over the past eight weeks since the tragic Imperial Sugar Refinery combustible dust explosion I've been busy seeking any information that is available concerning the causes and prevention of combustible dust fires and explosions. One subject that has come up is minimum ignition energy (MIE), which is the energy in millijoules from electrostatic discharges or static electricity that can ignite combustible dusts generated from combustible particulate solids in the manufacturing process.

An excellent book published by the American Institute of Chemical Engineers is "Electrostatic Ignition of Fires and Explosions" by Thomas H. Pratt . This book is an easy read and no prior background in engineering is necessary, which enables everyone in obtaining an understanding of static electrical hazards in the workplace.

The chapters start out with basic concepts then moves on to accumulation, separation, and discharge of electrical charges. Once that concept is mastered, minimum ignition energies can be grasped into how they apply in the workplace. As the book progresses, the author takes the reader into various areas in the manufacturing process dealing with liquids, mists, and finally powders.

With the idea of how static electricity originates the reader is presented with design and operating criteria in addition to electrostatic measurements, and quantification of electrostatic scenarios. Finally at the conclusion and last chapter case histories are provided where the reader is actually able to see how combustible dust explosions and fires occurred when minimum ignition energy ignited dusts.

For many including myself I had no idea what the terms propagating brush or brush discharges meant in regards to minimum ignition energy. Prior to reading the book I thought brush discharges had to do with brushes in an electircal motors but that is not so.

If you have combustible dust in the workplace in any form it's imperative that you understand what minimum ignition energy is. Especially since in the material safety data sheets (MSDS) of the explosive and fire hazard section, this property is not listed like flash points are listed for flammable liquids.

Criminal Charges Recent Explosion in Serbia

They don't mess around when it comes to plant explosions in Belgrade, Serbia. An explosion over the weekend at a pesticides storage facility put 29 people, mostly firefighters in the hospital. The Environmental Ministry is filing criminal charges against the responsible person. Is it possible that someone high in management could be sitting in a courtroom soon explaining why the incident occurred and what preventive and mitigative measures the facility had?

I wonder how far plant explosions would be reduced in the United States if criminal charges where filed by governmental entities immediately after an explosion? It's great here in the United States that criminal charges are really not considered after the majority of events, just a small fine and slap on the wrist. Fatalities and injuries in the cost benefit analysis are cheaper than voluntary administrative and technical preventive and mitigative measures. Thankfully we live in a free country of laissez faire.

Canadian Neighbor Combustible Dust Explosion

The six combustible dust explosions last month is not limited to incidents in the United States. Over the weekend a combustible dust explosion occurred at Associated Proteins, in Ste Agathe, Canada. Associated Proteins, a canola processing facility, and the largest expeller-pressed oilseed crushing plant in the world has a state-of-the art facility which has gone to great expense to ensure the most cutting edge technology is used in their manufacturing process. An educational video concerning the canola manufacturing process can be viewed on their web site.

So how can a plant that is so clean experience a dust explosion? Poor housekeeping is out of the question. OSHA's mantra concerning the prevention of future combustible dust explosions and fire is good housekeeping. True, housekeeping is important, but this is only one priority and that is where the current OSHA voluntary program fails miserably in preventing future combustible dust explosions and fires.

Complex Pathways
The pathways concerning the molecular fragments that generate a combustible dust explosion and fire are more complex that just housekeeping. In any manufacturing process electrical charges are constantly being separated, accumulated, and dissipated in the form of electrostatic discharges or static electricity. At this level it doesn't take much to ignite a cloud or layer of combustible dust generated from combustible particulate solids of metals, food products, wood or plastics. So even if good housekeeping is adhered to the potential for an incident persists as dusts are inherently part of the process where an potentially explosive atmospheres coexist.

It would turn into a terrible day at petrochemical plants if the explosive atmospheres from flammable vapors were ignored like is the case with combustible dust. Think explosive atmospheres....combustible dust and flammable vapors. It's all the same yet that is where the disconnect is here in the United States. Yet the majority of stakeholders do not believe combustible dusts can provide an explosive atmospheres on a regular basis.

MSDS Information Nonexistent
On the other end of the spectrum there are facilities that accumulate combustible dusts in the manufacturing process and are not aware of the hazards involved. Just last week, Quality Cushion and Pad in Georgia experienced a combustible dust fire that destroyed the facility where housekeeping was questionable according to the news report.

If the proper information on the fire hazards such as minimum ignition temperature, minimum explosive concentrations, and minimum ignition energy were included in the Material Safety Data Sheets (MSDS), incidents like this could be prevented. The big question is, who's responsibility is it to include this vital information in the MSDS...the raw product supplier or the company? In this case, that could be quite complex since this facility receives millions of pounds of recyled polyurethane foam by the truckload from thousands of sources.

Explosion Protection Document
Combustible dust explosions and fires are a global problem. Our global trading partners in the European Union, United Kingdom, Australia, and the New Zealand are already addressing the problem with the requirement that facilities develop an explosion protection document. The recent example of the unfortunate Canadian incident highlights that poor housekeeping is not the sole cause of combustible dust explosions and fires.

It's time that all facilities in the United States large or small review the combustible dust hazards in their workplace and prepare their own explosion protection document. If you don't know the minimum ignition temperature (MIT) or minimum ignition energy (MIE) of the combustible dust at your facility then please find out now. Until then you are on borrowed time.

Mark-up of H.R. 5522, Combustible Dust Legislation

The House Education and Labor Committee will vote Wednesday, 9 April on the Combustible Dust Explosion and Fire Prevention Act (H.R. 5522). Earlier on 12 March a hearing was held concerning pending legislation in response to the recent Imperial Sugar Refinery explosion in Georgia and OSHA's failure to act on comprehensive a combustible dust standard in general industry as recommended by the Chemical Safety Board.

Since the February 7 Imperial Sugar refinery explosion there has been 29 combustible dust fires and explosions in general industries throughout the United States, which doesn't include grain handling facilities. Facilities which handle grain must comply with the OSHA grain handling combustible dust standard that was implemented in 1988. Prior to the OSHA grain standard there were numerous combustible dust fires and explosions resulting in preventable fatalities and injuries. Over the past two months there has been nine combustible dust fires and explosions at grain facilities, which includes three explosions.

National Fire Protection Association
For nearly a century the National Fire Protection Association has formulated fire codes in the protection of property and personnel. Several of these fire codes deal with metal, food, wood, and agricultural combustible dusts. In contrast, the majority of state fire marshals have not implemented these combustible dust fire codes in their inspection protocol and thats where the main problem is concerning the continual occurrence of preventable and predictable combustible dust fires and explosions.

The Combustible Dust Explosion and Fire Prevention Act (H.R. 5522) will require that the National Fire Protection Association's Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids-2006 (NFPA 654) and Standard for Combustible Metals-2006 (NFPA 484) be adhered to by all states whether or not such protection is already incorporated in state fire codes.

National Emphasis Program

OSHA has instituted a voluntary National Emphasis Program for combustible dusts since October 2007 that has not offered the protection in the prevention of future incidents. For example, the program guidelines direct OSHA inspectors to obtain dusts samples for analysis at the OSHA Salt Lake Testing facility in the determination of the ignition sensitivity and explosion severity of dusts generated at a facility. This is a backward approach since thousands of manufacturing plants are already generating combustible dusts in their processes and waiting for a inspector to arrive is a recipe for disaster as can be seen in the Imperial Sugar refinery resulting in 13 fatalities.

Opposing Passage of Bill
Opponents of the Combustible Dust Explosion and Fire Prevention Act (H.R. 5522) feel that a congressional mandate in preventable combustible dust explosions and fires is to rapid of an approach and more input needs to be addressed between regulators, industry, state fire marshals, trade associations, and labor organizations. Additionally, opponents of the pending bill believe that a "one size fits all" covering combustible dusts across a wide spectrum of industries will lead to problems in the interpretation of an OSHA comprehensive combustible dust regulation.

The national consciousness of preventable combustible dust explosions and fires have yet to be aroused in between the presidential primaries and only a small minority of stakeholders vocally desire the passage of a combustible dust bill. With House committee members politically divided between the interests of labor and industry, movement of the bill to the house floor will be an uphill battle for the proponents.

Text of Bill

Thursday, April 3, 2008

Multitude Combustible Dust Incidents in One Day

Thursday started out as a normal day at many workplaces across the nation. After the lunchtime break, things would begin to change and heat up real quick in a span of two hours across three states. Prior to the clock striking 2:00 P.M. CST, a combustible dust fire consisting of titanium dust flared up in the dust collector at a dental equipment manufacturing facility in Pennsylvania.

In the Midwest, at approximately 2:30 P.M, as firefighters were responding to the titanium combustible dust fire at the Den-Tal-Ez Inc dental facility in Lancaster, Pa, a combustible dust explosion rocked the Farmer's Co-op Society grain elevator in Sanborn, Iowa.

An hour and a half later as events were just getting heated up, the afternoon turned into a leapfrog event as Baldwin Feed and Seed grain elevator in Baldwin, Wisconsin became engulfed in flames. This is very unusual for so many combustible dust related explosions and fires to occur with a span of two hours on the same day. Luckily there were no injuries only heavy economic damage to the businesses.

It's All the Same
Combustible dust is combustible dust. It doesn't matter if it's grain , metal, rubber, plastic, wood, coal, etc. All this dust is generated from a raw product of combustible particulate solids. The only difference in the dusts is the heat of combustion (oxidation), which is a measure of the rate of combustion. Which could range from 1200 KJ/mole O2 for magnesium all the way down to 470 KJ/mole O2 for starch. Proper preventive and costly mitigative measures needs to be instituted with all classes of organic, synthetic, coal, and metals. Until a comprehensive combustible dust standard is instituted more events will occur on a daily and weekly basis.

Since the OSHA grain facility combustible standard was instituted in 1988, occurrences of grain dust explosions have been reduced 30 %, with an average of 14 events annually. Have we reached an acceptable level now with the grain facility standard ? Or should a review of current procedures be in order?

Dust Explosion Research Institute
A Dust Explosion Research Institute (DERI) facility in the United States would be a good move. The time has arrived for all stakeholders in industry, academia, and cooperation with governmental agencies in facilitating the planning stages for a combustible dust research institute. This is not a novel idea, as Norway has done so decades ago at it's CMI facility in close collaboration with the University of Norway.

The results have led to the exciting field of combustible dust computational fluid dynamic (CFD) studies in conjunction with computer aided design. GEXCON, a leading Norwegian research and consultancy in explosion scenarios took over the work of CMI in 2000 and now provides a revolutionary
FLame ACceleration Simulator (FLACS) in modeling the dust explosion process.

Combining physical properties of minimum explosive concentrations, minimum ignition temperatures, minimum ignition energy, and deflagration index's into the computer application of CFD will provide a cross spectrum of industries the intricate nature of combustible dusts. Much more research needs to be done as this is only the tip of the iceberg. Question is, will, the industrial powers of our nation be up to the challenge?

For others who are up to the challenge be sure to stop by the GEXCOM booth
at the 2008 AIChE Spring National Meeting April 6-10, 2008 Ernest N. Morial Convention Center
New Orleans, La. . Olav Roald Hansen and
Kees van Wingerden will be there with demo programs of FLACS and the
Dust Explosion Simulation Code, which is the awesome CFD code for simulating the course of industrial dust explosions in complex geometries such as we experience here in the U.S. . Click here for brochure

Click here for FLACS video

Debut April Combustible Dust Incident

After 14 combustible related dust incidents last month which included 6 explosions, the month of April will be starting out in the same dismal form. On Tuesday, April Fool's Day, a combustible dust fire started in the silo that contained sawdust generated from the wooden flooring manufacturing process at Appalachian Wood Floors in Portsmouth, Ohio bordering Kentucky on the northern banks of the industrious Ohio river.

Ohio is no stranger to combustible dust fires and explosions. Less than two months earlier and hundred miles west, further up the Ohio River in Cincinnati, a wooden products plant vanished off the face of the earth as the owner watched nearly three decades of memories burn to the ground. Toughest part was the mentally anguishing dilemma of the nearly two dozen employees who no longer had a place to go to work the next day on Monday morning. Luckily no injuries in this incident either.

Just over three years ago, about an hours drive south from Lake Erie in Leipsic, Ohio at a pet food manufacturer, a combustible dust explosion occurred in the silo injuring one firefighter. The day before the incident, firefighters worked to clear smoldering cellulose in the silo. It is believed that an ember remained in the machinery overnight and caused the flash dust explosion the following afternoon.

Preventive and mitigative measures is very expensive for business with the installation of detection, isolation, ventilation and suppression fire equipment. Should this fire and explosion equipment be required at all business's that handle combustible particulate solids that generate combustilbe dust? Thats a tough question to answer especially with the many small companies that barely are getting by with other overhead costs.

A cost benefit analysis would best be able to determine an equitable solution. In the meantime the clock is ticking for the next combustible dust explosion in the magnitude of the tragic preventable and predictable Imperial Sugar Refinery explosion two months ago on the western banks of the Savannah River in Port Wentworth , Georgia.

Wednesday, April 2, 2008

Moonshine in them thar' hills !

Not combustible dust but quite an interesting story of an illegal moonshine still being busted up in Georgia's northwestern hills by the Walker County Special Operations Group.

Geez...what a waste of perfectly good product. This moonshine was produced by fermenting corn and barley the old fashioned way but instead of wooden barrels the moonshiners used plastic 50 gallon drums.

If we remember back awhile, Granny of the Beverly Hillbillies had her own moonshine still next the swimming pool. Of course she only drank it by thimbleful to cure here ailing rheumatism. Jed didn't hold much care for it as it made his truck run sort of funny.

Heres a photo gallery of the bust provided by the Chattanooga Times Free Press
Video How a Moonshine Still is made

Scorecard: Combustible Dust Explosions/Fires March 2008

March was a busy period for combustible dust explosions and fires at manufacturing facilities totaling 14 incidents, which included seven combustible dust explosions at wood, food, metal, power generation, and feed industries. In contrast, at grain facilities there was four combustible dust related incidents, which included one explosion. Luckily there were no fatalities and limited to one injury. The negative economic impact to the local communities has been the most damaging aspect of these preventable and predictable accidents.

Most troubling is the repeatable combustible dust related explosions and fires that have occurred in 20% of the incidents. For instance, a metal finishing facility in Michigan had combustible dust fires occur in their dust collectors twice within one week. In the second fire, employees emptied all 18 of their fire extinguishers to quench the flames.

Hazardous Communication
The majority of the workforce, management, and owners have no idea of the combustible nature of combustible particulate solids when combustible dusts are generated during the manufacturing process. Combustible dusts forming an explosive atmosphere can be equated to flammable vapors that occur in a transfer operations between petroleum barges and a refinery during a marine transfer of flammable liquids. For example, when the transfer hose is connected or disconnected from the barge, flammable vapors are present from the flammable liquids, which generates a potential explosive atmosphere.

Petroleum refinery operators have material safety data sheets which inform the workers of the flash points of the flammable liquids they are working with. In contrast, industries that handle wood, metal, feed, plastic, and other solids have no information in their material safety data sheets concerning the minimum ignition temperatures and minimum explosive concentrations of the combustible dusts that are generated from the combustible particulate solids they are handling.

Explosive Atmospheres
Explosive atmospheres are just as easily formed when working with combustible particulate solids as when handling flammable liquids. In both instances combustible dusts and flammable vapors are generated creating a hazardous environment. Preventive and mitigative measures must be instituted to protect the worker, facility, and community from catastrophic events that could occur if proper administrative and technical measures are not followed.

Currently it's safer to work in a chemical or petroleum plant as the petrochemical industry is already aware of the hazards and follows proper procedures. In contrast general industry has no comprehensive procedures in the safe handling of combustible particulate solids and the combustible dusts that are formed in the manufacturing process.

This is where the disconnect is over the last eight weeks with the nationwide 27 combustible dust related explosions and fires since the tragic Imperial Sugar Refinery combustible dust explosion in February. There would be public outrage if there were 7 refinery and chemical plant explosions over the month of March. But no outrage at all with the combustilbe dust explosions.

Trade Associations
Its time for all trade associations in general industry to create preventative and mitigative technical and administrative procedures concerning combustible dust hazards. This information can be shared collaboratively with it's association members in the prevention of future accidents.

For instance, material safety data sheets can be amended in providing fire and explosive hazards of combustible dusts. On the company level this would prove costly, whereas on the larger association level the costs can be reduced in amending material safety data sheets with a collaborative effort between its association members that handle the same raw materials in the manufacturing process.

Ignition Sensitivity
Additionally, at the trade association level, testing can be proactively instituted in determining the ignition sensitivities and explosive severity of the combustible dusts that are generated in the manufacturing process of combustible particulate solids. The current reactive measure that OSHA has in it's National Emphasis Program for combustible dusts does not provide industry with proper proactive preventive and mitigative measures.

Due to budget constraints, there are a limited number of OSHA inspectors in collecting samples and sending obtained dusts to the OSHA Salt Lake Testing Facility. Who is going to pay for these very expensive tests? What about the time in between when the facility might have an inspector arrive? Where is the protection in between ? The clock is ticking and only more preventable and predictable combustible dust related explosions and fires will occur until industry moves proactively.

Tuesday, April 1, 2008

Georgia Combustible Dust Fire Ends Shift Work

Over the weekend at Quality Carpet Cushion on the northern outskirts of Lafayette, Georgia as the evening crew were beginning their shift, a combustible dust related fire flared up adjacent to machinery that chops and shreds recycled foam in the manufacture of bonded polyurethane carpet padding. Dozens of firefighters from surrounding communities responded to the four alarm fire and finally where able to quench the billowing inferno 20 hours later the following day according to news reports.

Company officials have yet to comment concerning the incident, yet the entire shell-shocked town of Lafayette is still trying to recover from the dismal Sunday where approximately 100 workers in the community depend on the plant for their livelihood. Luckily there were no injuries only an overwhelming negative economic impact on a small town community that is already feeling the ripples of a nationwide housing slump and no hope for the future since the facility was gutted out with fire and water damage.

Combustible dusts are generated from the grinding process of the combustible particulate solids of polyurethane which has a minimum ignition temperature close to the heat of a recently extinguished wooden matchstick . Inattentive housekeeping is a leading factor in combustible dust fires and explosions such as the tragic event that claimed 13 lives and over 50 injuries in Port Wentworth, Georgia nearly two months at the Imperial Sugar Refinery. Remove the fuel from the fire triangle and the possibility of a fire is also removed.

Removing the fuel factor is easier said than done. Especially when the workspace also becomes part of the manufacturing process; compounded with a process that grinds over 4 million pounds of combustible particulate solids (polyurethane) a month in suppling consumer demand for bonded carpet padding . With over two dozen nationwide facilities similar to Quality Carpet Cushion in the manufacturing of bonded polyurethane carpet padding, industry trade associations such as the Carpet Cushion Council and Alliance for the Polyurethanes Industry need to convene as a collaborative group to reevaluate the manufacturing process in the prevention and mitigation of future combustible dust incidents.

As it stands now everyone is on borrowed time, as LaFayette Public Safety Director Tommy Freeman succinctly stated:

In any manufacturing plant they have a buildup of dust and soot that floats around in the air and settles everywhere. Over time this accumulates. A simple fire under these circumstances can cause a flash-burn or -fire, because that dust is extremely flammable.........“The plant has had other fires in the past but were small and in different proximity,” Freeman said. He said all manufacturing plants have fires from time to time." Source: Walker County Messenger/Larry Brooks

In the meantime there won't be any shift work at the Quality Carpet Cushion for awhile.

Shift work, hard work, tired body
Blue-collar shirt and a baseball cap
Union made

He's hot, sweat drops, 'round the clock
Door never locks
And the noise never stops

Night or day
Work seven to three
Three to eleven
Eleven to seven

Shiftwork Lyrics by Kenny Chesney :

Resource: News Channel 9 Video


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