Inconsistencies with OSHA General Industry Standards

Combustible dust explosions and fires continue at facilities throughout the United States in alarming regularity. Since the tragic Dixie Crystal sugar refinery explosion there has already been over a dozen combustible dust related explosions and fires with resulting fatalities, injuries and further economic impact to local communities. The current OSHA regulatory and enforcement scheme in preventing this predictable loss is currently not working.

Since 2005, the agency has published and distributed a Combustible Dust Safety and Health Information Bulletin, trained inspectors, implemented a combustible dust national emphasis program, and even most recently published a web page solely devoted to the hazards of combustible dusts.

Currently the attitude of upper management in the agency is solely energized toward self compliance through outreach programs and industry alliances. In the meantime preventable accidents like Dixie Crystal in proportion to a 7.0 earthquake in an urban area are still occurring. Minutes, hours, and days are ticking by before the next catastrophic dust explosion occurs in our nation.

Even at a recent House committee hearing of the Education and Labor, where Congressman George Miller introduced legislation, H.R. 5522, the "Combustible Dust Explosion and Fire Prevention Act of 2008. There was still an unwilling nature in the attitude of Edwin Foulke, the Director of OSHA during his testimony to move forward with a comprehensive combustible dust standard as recommended by the Chemical Safety Board.

A wait and see attitude until after the investigation of the Dixie Crystal was the most forthcoming pronouncement of Director Foulke. How many more investigations need to be completed before OSHA recognizes the hazards of combustible dust, where housekeeping alone will not put an end to future incidents? Already nearly 30 years ago, OSHA commissioned the National Academy of Sciences to conduct studies on the hazards of combustible dusts and the results where unanimous, combustible dust causes fires and explosion. From that study the 1987 OSHA Grain Facility Combustible Dust Standard was born. Why not now a general industry comprehensive combustible dust standard?

Currently the OSHA general industry standards of ventilation, housekeeping, hazardous locations, and hazardous communications are very weak and not sufficient in protecting facilities in the United States from future dust explosions and fires. Facility owners, plant managers, and workers must consult and review the numerous National Fire Protection Association codes in the prevention and mitigation of future incidents. Included in this post are major points that need to be considered. It’s highly recommended to read online NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids.

Document : Combustible Dust Protection: Inconsistencies with OSHA General Industry Standards.pdf file