Tuesday, March 4, 2008
Sixteen months after OSHA received the Chemical Safety Boards recommendations on preventing combustible dust explosions, Edwin Foulke, the director of OSHA argues that the department is still in the process of looking into whether a comprehensive combustible dust standard should be implemented versus maintaining the status quo of the current inadequate OSHA general industry rules of housekeeping, ventilation, and electrical standards. This is a good point the director makes for workplaces that are not exposed to combustible dusts but invalid when general industry is generating hazardous atmospheres during the manufacturing processes.
Furthermore, Mr. Foulke, has no idea of the magnitude of the problem when he states there are approximately 10-15 combustible dusts that would be effected by a dust standard. For example, in the 2006 investigative report completed by the Chemical Safety Board, which the director is referring to, there are over 200 combustible dusts that require a dust standard. As an attorney by former training , Mr Foulke is not qualified to provide expert opinion on combustible dusts only opinion on compliance enforcement and litigation actions of OSHA.
Chemical Safety Board Recommendations For Combustible Dusts
1. Comprehensive Combustible Dust Standard
2. Revise the Hazard Communication Standard
3. Amendthe UNECE Globally Harmonized System (GHS) of Classification and Labeling of Chemicals
4. Provide Training through the OSHA Training Institute (OTI)
5. Implement a National Emphasis Program (NEP)
6.Modify ANSI Z400.1 American National Standard for Hazardous Industrial Chemicals
An interesting snapshot of Congressman Jack Kingston's view that if a comprehensive combustible dust standard for general industry is promulgated then a potential threat arises in industry moving offshore instead of compliance with health and safety issues . How many agricultural business's moved offshore after the grain combustible dust standard was implemented in 1987? In either case a cost-benefit analysis is needed to move forward in the protection of the nation's workforce.