Friday, April 18, 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.

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