Last time Americans heard of a scorched earth campaign was nearly a century and a half ago toward the end of the Civil War when Union Major General William Tecumseh Sherman conducted his “Savannah Campaign’ and “March to the Sea” from
Fast forward into the twentieth-first century and another more productive campaign is happening across the nation’s heartland to the tune of a different song and that is the prevention of future preventable and predictable combustible dust related explosions and fires. At the forefront of this complex issue is OSHA’s conflicting scorched earth campaign in staunchly opposing labor’s desire in a comprehensive combustible dust standard in its health and safety regulations. In the meantime the nation’s economic industrial infrastructure is burning to the ground due to the alarming prevalence of combustible dust explosions and fires.
In the same southern maritime port of the Savannah River where General Sherman ended his “March to the Sea,” the
So now the nation’s workforce is living under an OSHA ‘scorched earth” policy. Haunting recurrences of combustible dust explosion occurred yesterday in
Yet unfortunately several years earlier, 35 miles up the road on January 19, 2003 the West Pharmaceutical Services plant in
One Size Fits All
And that’s where the problem lays, OSHA’s position that a “one size fits all” combustible dust health and safety standard will not work due to the diversity of raw materials involved in the manufacturing process. The public should not be mislead by this position regarding a very complex subject of dust cloud formation and ignition processes in addition to flame propagation and blast waves generated by burning dust clouds.
OSHA’s upper management, in which Edwin Foulke is the leader, is still under the false assumption that combustible dusts ignite due to diverse flash points. This could be further from the truth. For example, there is no such thing as flash points like in flammable liquids and vapors when regulating combustible dusts. Instead the physical and fire properties include minimum ignition temperature (MIT), minimum explosive concentration (MEC), minimum ignition energy (MIE), and deflagration indexes (Kst)
Combustible Dust Properties
Most combustible dusts have a minimum ignition temperature (MIT) of less than 932 degree Fahrenheit (500 C), which is the temperature of a match that has been immediately extinguished. Regarding deflagration indexes (Kst) or explosive properties, which is the amount of pressure rising over a period of time there are four classes: no explosion, weak, strong and very strong. Sugar dust as in the Imperial Sugar Refinery explosion has a weak Kst index as does the polyethylene plastic dust that was involved in the West Pharmaceutical dust explosion.
National Emphasis Program
OSHA’s “scorched earth” policy in regards to combustible dust is intensified when misleading proclamations are made in leading global and national publications such as the USA Today Op/Ed column where OSHA Director Edwin Foulke states “last fall OSHA initiated a nationwide program to increase inspections in high-risk workplaces.” This could be further from the truth as there is no nationwide national emphasis program for combustible dusts.
For instance 26 states have approved state plans,
Reoccurring Dust Explosions
In the meantime over the last seven weeks since the catastrophic Imperial Sugar Refinery combustible dust explosion there have been over two dozen combustible dust related fires and explosions across the nation spanning from the Pacific to the Atlantic . These predictable and preventable events have ranged in a diverse set of industries and institutions such as food, wood, metal, textile, and rubber industries. In addition to an Xcel coal power plant in
It should not take an act of Congress like the proposed bill, “HR 5522, The Combustible Dust Fire and Explosion Prevention Act of 2008" that the House Education and Labor Committee held a hearing on March 12, 2008 to provide stimulus for OSHA to act. Instead sound and persuasive leadership is needed at the Department of Labor, where industry, labor, and governmental leaders can reach a comprehensive agreement in providing the health and safety protection that the country now desperately needs.
An excellent alternative to the conflicting points of view between the stakeholders would be to review programs that our global trading and security partners have. For example,
The European Union has instituted ATEX 95 equipment directive 94/9/EC and ATEX 137 workplace directive 99/92/EC. The unusual ATEX acronym is derived from French: Appareils destinés à être utilisés en ATmosphères EXplosibles .The
Additionally, down under,
Photo Credit: U.S. National Archives and Records Administration