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Monday, March 10, 2008

State Dust Emphasis Programs Voluntary

Get er' Done

Nearly half the nation is unprotected concerning having the proper knowledge concerning the hazards of combustible particulate solids and the resulting combustible dusts. For instance, OSHA instituted a Combustible Dust National Emphasis (NEP) Program in October 2007, which provides health and safety inspectors with the background information needed in conducting facility inspections and informing industry of combustible dust hazards in 28 states. This is all fine and dandy.

Yet in the other 22 states with approved State OSHA programs, federal inspectors are not involved only state inspectors work in this area. Additionally, State plan participation in this national emphasis effort is strongly encouraged but is not required. Strongly encouraged means voluntary, which is the heart of the problem.

For example, North and South Carolina, and Kentucky have no local emphasis program for combustible dusts. Since the Dixie Crystal sugar Refinery explosion there has been two combustible dust related incidents in these states at rubber and textile facilities.



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Map State OSHA Programs

Indiana, Michigan, and Tennessee are in the process of adopting local emphasis programs for combustible dust hazards. Hopefully other states that have their own OSHA program will follow suit. For others that are under the federal National Emphasis Program, it will take additional congressional appropriations so that OSHA can hire additional inspectors to insure the nation's industrial infrastructure is secure.

OSHA Grain Facility Standard-Poor Results

Since the OSHA grain facility standard was promulgated in 1987 agricultural dust explosions, fatalities, and injuries have continued at nearly the same rate as general industry combustible dust explosions For example, utilizing data compiled by Dr. Robert W. Schoeff, Kansas State University, in cooperation with FGIS-USDA, during the period 1980-2005 there as been on the average of 15 annual agricultural dust explosions at grain elevators, corn processors, feed, flour and rice mills.

1980-2005

Grain Facility Explosions

General Industry Explosions

Number

368

281

Fatalities

63

119

Injuries

382

718

In contrast, the Chemical Safety Board completed a two year study which spanned the same period while investigating dust explosions in general industry and determined on the average 11 dust explosions occurred annually. So how is it that a multitude of agricultural dust explosions are still occurring even after an OSHA grain facility standard was implemented over two decades ago.?

In all fairness, since the grain standard was instituted in 1987, fatalities and injuries from agricultural dust explosions have been reduced by nearly 50 % , with incidents decreasing by 30 % on an annual average. But why is there still an explosion occurring nearly every month somewhere across our nations' heartland?

Grain Explosions

1979-1988

1989-1998

Number

20 /yr

14 / year

Fatalities

5 /yr

2 /year

Injuries

27 /yr

13 /year

Current OSHA health and safety regulations are clearly not preventing workplace injuries and fatalities. Most recently, from the ten year period 1996-2005, there were 106 grain facility dust explosions, resulting in 16 fatalities and 126 injuries, resulting in over $ 162 million dollars in economic damage.

So should it be up to the federal government to reduce further dust explosions in all industries; especially if current regulations are not working ? Many stakeholders believe governmental regulatory intervention is counterproductive and only raises the cost of business operations resulting in higher prices in finished products to the consumer.

An entire review and governmental audit of current OSHA grain facility standards is in order. The time has come in providing business management personnel and the workforce with updated Material Safety Data Sheets (MSDS)'s, which provide information on the explosive properties of all combustible particulate solids like corn, soybeans, wheat, etc. Information such as minimum explosive concentration (MIC), minimum ignition temperature (MIT), and KSt (normalized rate of pressure rise) included in the MSDS's would be beneficial in the hazard communication process.

United States Agricultural Dust Explosion Information

 

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