Combustible Dust NEP-Not All There?

Had to read it twice...maybe I initially misread it between the lines. No, No... it all there but not all there. Over half the states in the union are not required to participate in OSHA's Combustible Dust National Emphasis Program (NEP)

VI. Federal Program Change. EFFECTIVE DATE: October 18, 2007
...State plan participation in this national emphasis effort is strongly encouraged but is not required. State response/notice of intent regarding this directive is required....

Learn something new everyday. So how is the nation fully covered by the current effort that OSHA is projecting in protecting the health and safety of workers in regards to the hazards of combustible dusts? Especially when only half the nation's workplace is covered. Last time I checked, there were fifty stars in the blue union of the American Flag.

Combustible Particulate Solids vs. Dust Confusion

Hopefully the confusion in terminology regarding combustible particulate solids and combustible dusts will be cleared up prior to the House Education and Labor Committee hearing on Wednesday morning concerning the ‘‘Combustible Dust Explosion and Fire Prevention Act of 2008’’. With so many important policymakers being initially introduced to this complex acronym induced topic, it behooves the champions of the cause to get it right the first time out of the box.

First off, lets all understand and be in complete agreement that combustible dusts are a subset of combustible particulate solids (CPS). In its raw form combustible dusts did not arrive at the facility rear loading docks. Instead combustible particulate solids were trucked in. Thats where the Material Safety Data Sheets (MSDS) enter the picture, since these documents communicate the potential hazards of handling combustible particulate solids. which in their initial packaged state are mostly not hazardous at all.

For instance, after the facility receives the combustible particulate solids, the solid is then transformed into a finished product. During the production phase, which can include such activities as shipping, handling, conveying, mixing, pulverizing, etc. It's during this phase that combustible dusts are generated and a potential hazardous atmosphere can develop when minimum explosive concentrations (MEC) are partnered with a minimum ignition energy (MIE) to produce a potential explosion or fire.

Hope that clears up the confusion. Since prior to today and until reading several times over NFPA 654, I really couldn't of won the Wheel of Fortune either, if asked to compare and contrast the two.