Friday, August 8, 2008

Paper Mills Exempt From ComDust NEP

The recent box manufacturing plant fire Thursday evening at Longview Fibre in Yakima, Washington brings to mind a combustible dust related fire three months earlier at Lincoln Paper & Tissue in Lincoln, Maine. In the Washington incident, the facility fire sprinkler system in conjunction with a team effort from the the industrial fire brigade prevented the fire from destroying the facility.

In contrast, with the assistance from local mutual aid, Lincoln Fire Department Fire-fighters subdued the New England blaze after a three hour battle. Luckily no one was injured in both instances, only damaged egos of plant managers and owners. The Longview facility in the Pacific Northwest, sustained an estimated $100,000 in damages according to news reports from the Yakima Herald-Republic.

Inspectors Find No Dust
Less than three weeks prior to the New England paper mill fire, the Federal OSHA Augusta, Maine office cited the facility for electrical, hazardous materials, and exit route hazards. According to news reports from WABI TV, the facility experienced a similar fire months earlier in January 2008. No mention of dust hazards are noted in the online OSHA accident and citation report.

Reviewing OSHA inspection reports for the Longview Fibre paints a revealing picture. Over the past decade Washington OSHA inspectors visited Longview Fibre Washington plants over two dozen times for complaints, referrals, follow-ups, and planned visits. The last citation "serious" was in 11/02/05, for an Ammonia (NH3) infraction. No issues concerning a combustible dust hazard were noted at this facility either.

NAICS Emphasis
The current OSHA
Combustible Dust National Emphasis Program (NEP) initially became effective on October 18, 2007 and was reissued March 12, 2008, over a month after the Imperial Sugar Refinery sugar dust explosion. The only difference between the two NEPS, besides the change of the date at the top right hand corner, is that the newer directive divides the NAICS into Appendix D-1 and D-2 with two diverse classifications:

  • Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires D-1

  • Industries that may have Potential for Combustible Dust Explosions/Fires D-2
In either case, the Paper Manufacturing subsector, with Industry Groups of Pulp, Paper, and Paperboard Mills and Converted Paper Product Manufacturing are not covered in the revised OSHA Combustible Dust (NEP).

Amazingly, NAICS 322211/corrugated and solid fiber box manufacturing at Longview Fibre and NAICS: 322121/paper mills at Lincoln Paper & Tissue are not under the OSHA radar as having a combustible dust hazard present at their facilities. Yet combustible dust related incidents can still occur at hundreds of other facilities in the Paper Manufacturing sector without proactive preventative and mitigative measures being addressed in addition to not being listed in the OSHA Combustible Dust NEP.

State Dust NEP Voluntary
The most stunning aspect concerning the OSHA Combustible Dust NEP, is that for states like Washington that have there own OSHA program similar to Cal-OSHA, is that State plan participation in this national emphasis program is strongly encouraged but is not required.

Thats correct, participation is voluntary. The Combustible Dust Policy Institute recently talked with an official from Washington OSHA and it was reaffirmed that the state does not have an emphasis program for combustible dust due to financial resource considerations.

Not If, But When
Combustible dust related fires and explosions will continue throughout the year in the manufacturing sector. At the present rate, the Combustible Dust Policy Institute has projected with approximately 12 incidents/monthly, an additional 50 combustible dust related fires and explosions will occur before years end.

Don't gamble with borrowed time, even if your facility is not a listed NAICS in the OSHA Combustible Dust NEP and generates combustible dust from combustible particulate solids. Perform a process hazard analysis now and have your dust tested for ignition sensitivity and explosion severity immediately as time permits while the sands in the hour glass are dwindling.

Photo Credit: by Jan Tik

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