http://www.iht.com/articles/ap/2008/11/30/europe/EU-Germany-Factory-Explosion.php Note: You can easily translate from German to English if add the Google Toolbar to your browser. Click the link for free download Resources: Brewing Process-
Here in the USA we all pray for the families and emergency responders that experienced a tragic event quite similar to the Imperial Sugar Refinery dust explosion at Port Wentworth, Georgia in Feb. 2008. The German news account stated, "There was a first explosion at 07.00 AM causing the fire fighters to rush in, then at 09.00 AM there was in the midst of firefighting activities a second explosion, fatal for one fire fighter, injuring 7 others." Sounds eerily familiar, a more deadly secondary explosion.
Combustible dust related fires and explosions are a constant threat to fire-fighters responding to such events. In many instances the hazards of seemingly harmless combustible particulate solids that generate combustible dust are unknown.
The explosion severity of many combustible dusts are quite similar to flammable vapors, liquids, and gases. Currently many national manufacturing industries in the USA have not acknowledged this fact.
This catastrophic event in GLOBAL MALT GMBH & CO KG, in Germany should be a wake up call for stakeholders in the USA in following similar process safety management (PSM) programs that are required by OSHA at petrochemical refineries where a thorough process hazard analysis is conducted, which identifies, evaluates, and institutes control measures in lessening the occurrence and reducing the severity of future events.
Dave Statter's Blog: STATter 911
German News Article
Aftermath Pictures http://is.gd/9Dd6
Sunday, November 30, 2008
Malt Silo Explosion in Germany kills 1, injures 7
Friday, November 28, 2008
Combustible Dust Hazards Facility Evaluations: Podcast #2
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Identifying combustible dust hazards at a facility is the first step in in conducting a thorough risk assessment of what can go wrong in addition to the probability and consequence of combustible dust related fires and explosions. Brian Edwards a graduate of Georgia Institute of Technology with a B.S. Civil and Environmental Engineering and now Director of Engineering at Conversion Technology Inc. discusses the importance of a combustible dust hazard evaluation.
The Occupational Safety and Health Administration (OSHA) reissued the Combustible Dust National Emphasis Program following the catastrophic Imperial Sugar Refinery explosion. Subsequently, Conversion Technology, Inc. (CTI) offers combustible dust evaluations to ensure the safety of employees and the facility. Also, CTI offers site specific safety plans and training. CTI is available now to help companies ensure compliance with the OSHA Dust NEP.
Note: During the podcast I inadvertently mentioned combustible dust standards when
I should of correctly stated the OSHA Combustible Dust NEP. Currently there is no OSHA combustible dust standard.
Resources:
Conversion Technology, Inc-Combustible Dust Safety Plans
Georgia: Rules and Regulations for Loss Prevention Due to Combustible Dust Explosions and Fire
Sunday, November 23, 2008
PSM Oriented Towards Dust Hazards?
A process safety management (PSM) oriented program that addresses combustible dust hazards in the manufacturing, non-manufacturing, and utility sectors needs to be implemented as it is in the chemical and refinery sectors. The main problem, is a disconnect concerning wood, food, paper, textiles, etc. process streams as not being considered like the 136 highly hazardous chemicals (HHC) as outlined in OSHA's Process Safety Management regulation (29 CFR 1910.119).
OSHA National Emphasis Programs (NEP)
Last year, the OSHA Combustible Dust National Emphasis Program (NEP) became effective four months after the Petroleum Refinery Process Safety Management (PSM) National Emphasis Program (NEP). There is a vast difference in the two OSHA NEP's with the goal of protecting the nations workforce and outlying communities from the harmful effects of industrial fires, explosions, and toxic releases.
In reviewing the background information for the Refinery PSM NEP, its disturbing when comparing and contrasting fatalities and catastrophes(FAT/CAT) between refineries and facilities that handle combustible particulate solids that generates combustible dust. For instance, on pg. 4 the Refinery NEP states:
"According to OSHA’s IMIS database, since May 1992, 36 fatality/catastrophe (FAT/CAT) incidents related to HHC releases in the refining industry have occurred. These incidents included 52 employee deaths and 250 employee injuries, 98 of these injuries required hospitalization."
Fatalities and Catastrophes (FAT/CAT)
Over the same fifteen year period, according to the results of the Chemical Safety Board Dust Hazard Investigation, there were over 95 fatalities and hundreds of injuries as the result of over 160 combustible dust related fires and explosions in the manufacturing, non-manufacturing , and utility sectors. Basically there are three times as many fatalities and catastrophes (FAT/CAT) in sectors that generate combustible dust than in the refinery sector.
Yet Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) and administrative control measures to protect the manufacturing workplace are dismally lacking. So is the rapidly diminishing manufacturing sector that provides a base for our national economic security even worth protecting? It doesn't seem so with the obvious inattention thats been misdirected elsewhere, to supposedly more urgent aspects of workplace occupational health and safety.
Highly Hazardous Chemicals (HHC)
Combustible dusts have similar explosion severity (Pmax, Kst) effects as flammable liquids, gases, and vapors concerning destructive overpressure, thermal radiation, and ensuing projectiles. Facilities that maintain processes with over 10,000 pounds of flammable liquids and gases must consider these products as highly hazardous chemicals (HHC) as outlined in the OSHA's Process Safety Management regulation (29 CFR 1910.119). So if combustible dusts have similar devastating explosive effects causing fatalities and catastrophes (FAT/CAT) like flammable liquids and gases, why aren't they listed as a highly hazardous chemicals(HHC)?
Wood, food, textiles, paper and many other seemingly harmless materials in manufacturing process streams are not considered toxic, reactive, or corrosive like the over 130 highly hazardous chemicals (1910.119 App A) under the Process Safety Management program. It's their combustible and explosive characteristics that need to be addressed as it is for flammable liquids and gases HHC (highly hazardous chemicals) in the OSHA PSM standards.
Recognizing the hazards of combustible dust is the first step through a process hazard analysis which is the foundation in lessening the occurrence and reducing the severity of future combustible dust related fires and explosions. Once the hazards are identified and evaluated control measures can be implemented in similar fashion as outlined in the OSHA Process Safety Management program. A few of the measures in the current PSM with debatable input to a possible Combustible Dust PSM include:
Operating Procedures
For instance, the implementation written operating procedures addressing operating limits with consequences of deviation with steps to follow to correct deviations such as high operating temperatures. These operating procedures must include safety and health considerations concerning quality control for raw materials and control of dust emissions. Additionally,
Contractor Participation
A process safety management program would also require contractor participlation. Over the past year a large percentage of combustible dust related fires have involved contractors conducting hot work adjacent to process equipment. A Combustible Dust PSM would properly and proactively inform contract employers of the known potential combustible dust fire, explosion hazards related to the contractor’s work and the process. This would lessen the occurrence of future incidents.
Mechanical Integrity (MI)
Mechanical integrity (MI) issues in a Combustible Dust PSM, would address the potential ignition sources that cause combustible dust related fires and explosions at facilities. For instance duct work, dust collectors, dryers, mixers, blenders, ovens, bulk storage enclosures are reoccurring problem areas concerning combustible dust related fires and explosions.
The refinery sector Mechanical Integrity PSM program addresses pressure vessels and storage tanks, piping, relief and vent systems and devices, and emergency shutdown systems controls. In contrast the manufacturing sector has bulk storage enclosures (silos, bins), pneumatic
Implementing written procedures to maintain the integrity of the above process equipment would provide employees with an overview of the mechanical integrity process and the combustible dust hazards that have been identified in a prior process hazard analysis. Process equipment inspection, maintenance, and testing would also be a vital aspect in the MI at the facility where deficiencies can be addressed in a proactive manner.
Incident Investigation
Reoccurring incidents of combustible dust related fires and explosions have been a common theme in the manufacturing sector over the past year. This year, over 30% of incidents are repeats of prior fires and explosions at facilities. In many instance a combustible dust fire is a precursor to a a rare event, the combustible dust explosion.
Without proper incident investigation by the facility, the exact cause of the fire goes unnoticed and the combustilbe dust hazard remains present for the next preventable and predictable incident. A Combustible Dust PSM would identify the chain of events and causes where corrective measures such as Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) can be developed and appropriately implemented.
Conclusion: Do I feel lucky?
The above examples are just a few proactive measures that could be crucial aspects of a Combustible Dust PSM that is similar to the current PSM utilized for facilities which process highly hazardous chemicals (HHC). Other measures in the PSM include Hot Work Permits, Emergency Planning and Response, Management of Change, and Compliance Audits. Many of the areas are already covered in the National Fire Protections Association (NFPA) combustible dust standards.
Until combustible dusts are recognized as having similar explosive severity characteristics as flammable liquids and gases (highly hazardous chemicals) of the current OSHA PSM, preventable and predictable combustible dust related fires and explosions will continue to occur. Hopefully on a bit of borrowed time the next rare event will not be in the magnitude of the recent Imperial Sugar Refinery dust explosion. Like in the 1971 Dirty Harry movie, Detective Inspector Harry Callahan played by Clint Eastwood asks, "You've got to ask yourself one question: 'Do I feel lucky?"
Thursday, November 20, 2008
Grain Elevator Explosion-Nebraska
One person injured in elevator explosion
"The top of the head house blew up in the explosion and its skeletal remains are hanging off the top of the elevator. The headhouse is where the leg is contained that elevates grain to the top of the elevator." 11/20/08 Gothenburg Times
http://www.gothenburgtimes.com/vnews/display.v/ART/2008/11/20/49259bb9b179a
This is the third grain facility explosion in the United States, over the past two months. Luckily no fatalities. Click here for Google Map of prior grain facility combustible dust related fires and explosions.
So how well is the OSHA grain facility standard working? Maybe it's time to re-evaluate all combustible dust related fires and explosions, whether occurring in the grain sector or the manufacturing sectors. All explosions have similar effects of over pressure, thermal radiation, and ensuing projectile hazards. If the petrochemical refining sector has a process safety management program (PSM) that protects their facilities then maybe stakeholders should look into a similar program for the grain and manufacturing sectors. The question is, "just how important are these sectors for the nation's economic security?"
Tuesday, November 18, 2008
Wednesday, November 12, 2008
NAICS Awareness ComDust Hazards Alert
I'd like to thank David Osbon, Product Manager of Unifirst, a provider of flame resistant clothing (FRC's) and contributing author of the ComDust Blog in sharing the above pie chart that encompasses 60%, (over 18,0000) of the 30,000 letters that OSHA sent to establishments which were identified by OSHA as national industries (NAICS) that have imminent and inherent combustible dust hazard along with a copy of OSHA's Combustible Dust SHIB. .
In the March 2008 letter, OSHA urged employers to review the information in the Combustible Dust SHIB and reminded stakeholders of their responsibilities to minimize combustible dust hazards and lessen the severity of future incidents that are inherent in the manufacturing and non-manufacturing process. It also reminded them of the assistance OSHA's on -site Consultation Program can provide confidentially and free of charge.
There is a problem here that needs to be addressed concerning industry awareness of combustible dust hazards. Since the beginning of the year, through media accounts, theres been 14 combustible dust related fires and explosions in the Paper Manufacturing sector, yet in the above pie chart it highlights that this manufacturing subsector was not identified as having a combustible dust hazards when letters where sent out. Below you'll note another pie chart of combustible dust explosion over the past year in the various subsectors
Thats odd, especially, through media accounts, 7% of the ComDust explosions have occurred in the Paper Manufacturing sector. In no way is this meant to be derogatory to this vital national industry with over 6,000 establishments and over 400,00 dedicated and hard-working employees. The Combustible Dust Policy Institutes's goal is to provide a proactive awareness and work collectively in stategic alliances with all stakeholders in the public and private sectors.
An especially critical aspect of hazard awareness is the OSHA Combustible Dust NEP, where Paper Manufacturing sector is excluded as Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires and Industries that may have Potential for Combustible Dust Explosions/Fires.
The paper manufacturing sector which includes 16 national paper industries (NAICS), not one national industry (NAICS) is listed in the OSHA Dust NEP. It's like a snowball rolling down the hill as the plot gets bigger and bigger with four paper mill combustible dust related fires, three sanitary paper product manufacturing fires, and two combustible dust fires at corrugated solid and fiber box manufacturing plants.
It was only yesterday when a Paperboard Mill experienced a combustible dust fire when paper dust ignited on a dryer area and went into the pneumatic conveying system. The news account further stated, "in January, an overheated piece of machinery sparked a fire that spread along the ceiling." This is the problem, as over 30% of the 122+ combustible dust related fires and explosion are reoccurring repeats, which eventually end up as the rare event of a combustible dust explosion.
The paper sector is not alone as not being referenced in the Dust NEP as national industries (NAICS) in the wood, food, textile, chemical.plastic/rubber, primary metal, machinery , furniture, miscellaneous , and non-manufacturing are also not included. Maybe a potential solution is to utilize a watered-down version of OSHA's Process Safety Management (PSM) for combustible dust, which has similar characteristics in explosion severity (Kg, PMax) as do flammable liquids and gases referenced in the OSHA PSM.
Webinar-Evidence-Based Compliance (free)
This just in. A free webinar at 2:00 PM EST November 19, 2008, sponsored by MSDSpro and hosted by EHS Today magazine discussing OSHA Hazard Communication Standard. An added awareness must be projected to the industry concerning combustible dust hazard awareness. Currently MSDS's do not provide the vital ignition sensitivity and explosion severity data.
The Combustible Dust Policy Institute is developing a Co-Op combustible dust testing service between Users Groups and testing laboratories. If a multitude of stakeholders from a niche national industry (NAICS) desire testing all at once, then costs of testing can exponentially go down. Lets do it! I need feedback both negative and positive from all stakeholders to proceed further.
Join the Combustible Dust Policy Institute Group on LinkedIn for additional discussions on this topic. See you there.
Monday, November 10, 2008
Fireball Combustible Dust Deflagration
Friday, November 7, 2008
Grain Facility ComDust Fires and Explosions
Since the Destrehan, Louisiana grain elevator explosion two weeks ago that put the ADM/Growmark's largest export terminal in Louisiana out of service, through media accounts, eight additional grain facility combustible dust related fires and explosions occurred throughout the nation. The financial damage from these events has totaled over $200,000 and luckily no injuries.
So is the OSHA grain facility standard working? It is not possible for OSHA with limited resources to inspect thousands of these grain handling facilities ensuring workplace safety compliance. Will it take a dust explosion in the magnitude of the catastrophic Imperial Sugar Refinery explosion this year to finally address the situation with additional governmental accident investigations, congressional hearings, and costly studies.
The clock is ticking and there is no time to waste. Combustible dust related fires and explosions in the grain handling facility or manufacturing, utility, and non-manufacturing sectors all have the same devastating effects.
The current combustible dust bill (H.R. 5522) awaiting a vote in the Senate needs to be reevaluated with provisions for all combustible dust related explosions and fires. Lets get our eggs all in one basket instead of the chaos that has engulfed the nation's workplace concerning combustible dust hazards.
Tuesday, November 4, 2008
Combustible Dust Explosions 2008
30 Combustible Dust Explosions
Over the past year, through media accounts, 30 combustible dust related explosions have occurred in the wood, food, chemical, metal, plastic, rubber, utility, and paper manufacturing sectors. On the western bank of the meandering Savannah River, workers weren't so lucky in escaping injuries or fatalities on the evening of February 7, 2008 when a catastrophic Imperial Sugar Refinery dust explosion occurred in Port Wentworth, Georgia. Subsequently, national media coverage created a much needed awareness concerning combustible dust hazards in the workplace.
Additionally, intense outrage amongst Democratic Congressional leaders responded with an emotionally drafted general industry combustible dust bill, which passed in the House, and now awaiting vote in the Senate. Results of the presidential election, with a potential shake-up of public policy concerning workplace health and safety will determine the future of the bill.
118+ Fires and Explosions
Unfortunately this year, the Imperial Sugar dust explosion was not an isolated incident. For instance over the past year, through media accounts, 118+ combustible dust related fires and explosions have occurred in the manufacturing, utility, and non-manufacturing sectors.
Trying to make sense of it all and why even dust explodes is an exercise in science combined with business and public policy across the vast ocean of the public and private sectors. The on-going tug of war between the interests of big business and labor complicates the matter even further in arriving at a cost effective solution in preventing future fatalities, injuries, and adverse economic damage.
Cursory Solution : Incomplete Data
Of major concern is how can public policy be created in Congress with ensuing OSHA health and safety regulation's if the extent of the problem is not completely evaluated? Costly governmental studies were completed, which resulted in federal directives that only provide a cursory solution to the combustible dust problem. In the meantime our nation's infrastructure in the manufacturing base is at threat from continuing preventable combustible dust related fires and explosions.
For instance the OSHA Combustible Dust National Emphasis (NEP) program is not even required in nearly half of the states with State OSHA Plans (strictly voluntary). That's only the tip of the iceberg, especially over the past year, where explosions and fires are occurring at facilities with dozens of NAICS not listed in the NEP.
Food Manufacturing
Reviewing the food sector, six out of the seven combustible dust explosions occurred in national food industries (NAICS) not listed in the NEP. With explosions occurring more than once at dehydrated food and evaporated diary product manufacturing plants. This is where a ComDust Hazard Alert goes out next, especially when these industries are not on the NEP radar. OSHA inspectors are actively inspecting these facilities as the following excerpt from a recent General Duty Clause (GDC) citation at a dehydrated food manufacturing plant in Wisconsin will illustrate:
"...The following C.O.W (cream of wheat) equipment did not have explosion/deflagration containment, suppression, inserting, or venting protection: a) Cooker room dust collector, approximately 375 cubic feet, was located inside the building lacking explosion venting. b) silo did not have explosion venting. d) pneumatic conveyor did not have spark detectors or propagation shut off devices to prevent explosion propagating forward or aft. "AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD..."
Overall, out of the 17 combustible dust related fires and explosion in the food sector, over 70% happened at facilities not listed in the OSHA Dust NEP. Are we seeing a trend here?
Paper Product Manufacturing
A glance at the paper manufacturing sector which includes 16 national paper industries (NAICS), not one is listed in the OSHA Dust NEP. So how many explosions and fires this year? How about 11 fires and explosions, which included two dust explosions. It's like a snowball rolling down the hill as the plot gets bigger and bigger with four paper mill combustible dust related fires, three sanitary paper product manufacturing fires, and two combustible dust fires at corrugated solid and fiber box manufacturing plants.
Plastics/Rubber Product Manufacturing
In all fairness the plastics and rubber manufacturing sector is well covered in the NEP. For example, seven combustible dust fires and explosions occurred this year which includes three explosions. There does need to be a reevaluation of whether these national plastic/rubber industries have a potential /D-2 or more frequent/D-1 history of combustible dust fires/explosions as outlined in appendix D-1 and D-2 of the NEP. All these explosions occurred in NAICS that were referenced in D-2 (potential for an incident). If incidents are reoccurring with explosions then wouldn't that move them from a potential/D-2 to a frequent/D-1 in the Appendix?
Conclusion
Other sectors in wood, chemical, textile, machinery and metal national industries have their share of explosions and fires as depicted in the chart for incidents in 2008. Stakeholders with financial interests in all these manufacturing and non-manufacturing sectors must understand that the OSHA Combustible Dust NEP is solely a directive which provides guidelines for OSHA inspectors in conducting enforcement and inspection actions at facilities.
It should not be used as guidance in preventing and mitigating future incidents, while misinterpreting that since your facility is not a listed NAICS in the NEP, you are out of danger from the hazards of combustible dust. Over 50% of the combustible dust explosions this year were at facilities with NAICS (national industries) not listed in the NEP. Don't be a statistic. As soon as possible initiate a process hazard analysis which identifies, evaluates, and controls the inherent combustible dust hazards at your facility.
For additional information if your national industry has a history of potential or high occurrence of combustible dust related fires/explosions contact John Astad at the Combustible Dust Policy Institute.
Saturday, November 1, 2008
$3 million Combustible Dust Related Fire Unreported
How can a $3 million fire that destroyed a historic furniture factory in Salt Lake City, Utah four years ago be unreported in the Chemical Safety Board Combustible Dust Hazard Study? An excerpt from a news account states:
"Local fire officials suspect that the fire started in the dust collector at the 120-year-old factory owned by Jeffrey Cobabe and Associates."
Hundreds of Incidents not Reported
The troubling aspect of the incomplete CSB Dust Hazard study that was submitted to OSHA in 2006 is that public policy concerning worker health and safety was formulated in the OSHA Combustible Dust National Emphasis Program (NEP) directive. Additionally, in March 2008 the House Education and Labor Committee introduced to Congress (H.R.5522) The Worker Protection Against Combustible Dust Explosion and Fires, also utilizing the CSB Dust Hazard study as the guidance and foundation in the drafted bill.
Since the Imperial Sugar Refinery dust explosion, dozens of training classes at industry conferences hosted throughout the nation have been providing industry stakeholders with information on combustible dust hazards. Yet these training seminars also make continuing reference to the CSB dust study in addition to the OSHA Combustible NEP, which unfortunately omits hundreds of manufacturing sub-sectors (NAICS). This training is fine and much needed in the industry. A problem arises when plant owners and managers are not obtaining the complete picture of the magnitude and depth of combustible dust hazards.
The Chemical Safety Board is not to blame. This agency is the finest accident investigation agency in federal government and has provided the industry with crucial information in preventing future accidents. With a limited budget these dedicated professionals are on the front lines investigating catastrophic accidents finding the root cause. What the agency isn't, is a research organization like the Bureau of Labor Statistics
Get the Knack of the NAICS
Referring to the above destructive fire where a dust collector was involved in just one example of the hundreds of NAICS and tens of thousand of manufacturing plants not listed in the OSHA Combustible Dust NEP, where only 68 out of a 427 manufacturing NAICS are referenced in Appendix D-1 & D-2. Just because your facility is not one of the 68 NAICS listed in the NEP, don't for a second believe you have a free pass and all is fine and dandy.
If the process stream handles combustible particulate solids that generates combustible dust of any sort, then you are sitting on a bottle rocket waiting to go off when all the factors of ignition, heat, fuel, suspension, and confinement all come together in the rare moment. We all know what a vapor cloud explosion can do in the refinery sector. The same devastating overpressure effects occur with a dust explosion in the manufacturing sector. In fact, unbelievably for many combustible dusts, the deflagration index or explosion severity (Kst) is much higher.
Explosion Ventilation Panels in Action
OSHA's continuing proactive efforts in ensuring that manufacturing facilities have minimized the occurrence and reduced the severity of combustible dust hazards in the workplace is best illustrated when reviewing an inspection report and General Duty Clause citation ($6,400) completed several months earlier at similar evaporated dairy product manufacturing plant (NAICS 311514) in Wisconsin.
General Duty Clause Citation(excerpt)
1.Protein dryer were located inside a building lacked explosion venting.
2.Storage bin, located inside the building, did not have explosion venting.
3.Pneumatic Conveyor did not have spark detectors
AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS to comply with National Fire Protection Agency (NFPA) Chapter 61 Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2008 edition; NFPA 69 "Standard on Explosion Prevention Systems" 2008 edition; NFPA 654 "Standard for the Prevention of fire and Dust Explosion from the Manufacturing, Processing and Handling of Combustible Particulate Solids" 2006 edition
Industry Leader
Hopefully the Wisconsin facility has taken immediate action on the key items which the OSHA inspector cited in the report. Other manufacturing facilities can learn from the recent explosion that occurred in California, where explosion ventilation panels effectively reduced the risk to life and property. California Dairies is an industry leader in the evaporated dairy product manufacturing sector and should be commended for the preventative and mitigative control measures that management instituted in addressing combustible dust hazards.
There are many sources where explosion ventilation panels can be acquired after a process hazard analysis is completed. For example, Construction Specialties is a global leader in providing explosion ventilation panels with it's field testable and ATEX 95 compliant C/S Explovent® If your facility does not have explosion ventilation panels installed yet, then maybe it's time to include this important investment in the 2009 budget.
Resources
Example Milk Powder Process
Lessons Learned : Explosion in a Milk Powder Processing Plant
New Zealand Dairy Industry Spray Drying Plant-Dust Explosion Control