Friday, August 8, 2008

Paper Mills Exempt From ComDust NEP

The recent box manufacturing plant fire Thursday evening at Longview Fibre in Yakima, Washington brings to mind a combustible dust related fire three months earlier at Lincoln Paper & Tissue in Lincoln, Maine. In the Washington incident, the facility fire sprinkler system in conjunction with a team effort from the the industrial fire brigade prevented the fire from destroying the facility.

In contrast, with the assistance from local mutual aid, Lincoln Fire Department Fire-fighters subdued the New England blaze after a three hour battle. Luckily no one was injured in both instances, only damaged egos of plant managers and owners. The Longview facility in the Pacific Northwest, sustained an estimated $100,000 in damages according to news reports from the Yakima Herald-Republic.

Inspectors Find No Dust
Less than three weeks prior to the New England paper mill fire, the Federal OSHA Augusta, Maine office cited the facility for electrical, hazardous materials, and exit route hazards. According to news reports from WABI TV, the facility experienced a similar fire months earlier in January 2008. No mention of dust hazards are noted in the online OSHA accident and citation report.

Reviewing OSHA inspection reports for the Longview Fibre paints a revealing picture. Over the past decade Washington OSHA inspectors visited Longview Fibre Washington plants over two dozen times for complaints, referrals, follow-ups, and planned visits. The last citation "serious" was in 11/02/05, for an Ammonia (NH3) infraction. No issues concerning a combustible dust hazard were noted at this facility either.

NAICS Emphasis
The current OSHA
Combustible Dust National Emphasis Program (NEP) initially became effective on October 18, 2007 and was reissued March 12, 2008, over a month after the Imperial Sugar Refinery sugar dust explosion. The only difference between the two NEPS, besides the change of the date at the top right hand corner, is that the newer directive divides the NAICS into Appendix D-1 and D-2 with two diverse classifications:

  • Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires D-1

  • Industries that may have Potential for Combustible Dust Explosions/Fires D-2
In either case, the Paper Manufacturing subsector, with Industry Groups of Pulp, Paper, and Paperboard Mills and Converted Paper Product Manufacturing are not covered in the revised OSHA Combustible Dust (NEP).

Amazingly, NAICS 322211/corrugated and solid fiber box manufacturing at Longview Fibre and NAICS: 322121/paper mills at Lincoln Paper & Tissue are not under the OSHA radar as having a combustible dust hazard present at their facilities. Yet combustible dust related incidents can still occur at hundreds of other facilities in the Paper Manufacturing sector without proactive preventative and mitigative measures being addressed in addition to not being listed in the OSHA Combustible Dust NEP.

State Dust NEP Voluntary
The most stunning aspect concerning the OSHA Combustible Dust NEP, is that for states like Washington that have there own OSHA program similar to Cal-OSHA, is that State plan participation in this national emphasis program is strongly encouraged but is not required.

Thats correct, participation is voluntary. The Combustible Dust Policy Institute recently talked with an official from Washington OSHA and it was reaffirmed that the state does not have an emphasis program for combustible dust due to financial resource considerations.

Not If, But When
Combustible dust related fires and explosions will continue throughout the year in the manufacturing sector. At the present rate, the Combustible Dust Policy Institute has projected with approximately 12 incidents/monthly, an additional 50 combustible dust related fires and explosions will occur before years end.

Don't gamble with borrowed time, even if your facility is not a listed NAICS in the OSHA Combustible Dust NEP and generates combustible dust from combustible particulate solids. Perform a process hazard analysis now and have your dust tested for ignition sensitivity and explosion severity immediately as time permits while the sands in the hour glass are dwindling.

Photo Credit: by Jan Tik

OSHA Grain Facility Standard Not Working

If the OSHA grain facility standard is suppose to reduce the prevalence of combustible dust accidents in the grain industry here in the United States, then why has 10 grain facility explosions occurred over the past ten months? Since the tragic Imperial Sugar Refinery dust explosion, the Combustible Dust Policy Institute has recorded on the Google Grain Facility Incident Map through online news reports, 17 combustible dust fires and explosions at grain facilities with 35% of these events occurring as explosions.

In contrast, over the past six months with over 70 combustible dust explosions and fires in the manufacturing sector, 22 % have been explosions. Surprisingly, the number of injuries when comparing to combustible dust events between the two industry sectors are approximately the same.

Acceptable Explosions
Recent Senate testimony at a combustible dust hearing by governmental officials have stated that the number of grain facility combustible dust fires and explosions have been reduced since the OSHA Grain Facility Standard was introduced two decades ago. So what is an acceptable number of accidents if combustible grain dust explosions and fires are happening at the same pace as incidents in manufacturing plants?

The only difference between the two is the tragic event at Imperial Sugar, which gained the attention of congressional leaders to take preventative action. It's only a matter a time before the magnitude of the Georgia event catches up with the grain industry.

Take a fast rewind over 3o years ago, to 1977 when several grain silo facilities eerily exploded within days of each other creating a heavy death toll. It was these events that initiated legislation for the OSHA Grain Facility Standard. Earthquakes on the West Coast of high magnitude in metropolitan areas have the same effect. The events are spaced out many years apart but still result in high fatalities, injuries, and extreme economic damage.

Right Idea...Misguided Approach
It's commendable that legislators desire OSHA regulations with protective action to prevent further workplace injuries and fatalities. The problem is with the methodology in achieving this goal. For example, regarding the case with Imperial Sugar and the huge loss of life, concerned legislators were immediately outraged as was the public. Something had to get done and quickly to prevent additional occurrences of accidents of that magnitude. Quick it was, then ensuing congressional testimony began to turn into attacks on OSHA, the director of OSHA, and even the Secretary of Labor.

This is where the problem arose in drafting the Worker Protection Against Combustible Dust Explosion and Fires Act (H.R. 5522). Emotions entered into the picture instead of a reasoned approach which should of consulted all stakeholders concerning life safety, structural integrity, mission continuity, and mitigation of fire and explosions as outlined in the National Fire Protection Association (NFPA) standards.

Jurisdictional Collaboration
Congress needs to reevaluate the stark and unyielding provisions of the pending combustible dust bill, which has all the good intentions of accident prevention and worker safety. Instead the local jurisdictional aspect with collaborative partnerships must be aligned between federal, state, and local entities in the prevention and mitigation of future combustible dust incidents.

Already it is proven the federal provision in the OSHA Grain Facility Standard does not reduce the occurrences of combustible grain dust incidents. How can it? Doesn't take much higher math to figure there are not enough OSHA inspectors to inspect all the grain facilities on a regular basis. Besides it's not up to the federal government to ensure a facility will not go off like a Chinese bottle rocket to the moon at moments notice.

An excellent example of local jurisdictional cooperation with state, local, and federal alliances is Homeland Security. Billions of dollars have gone into that program and millions more too local and state jurisdictions. Is Homeland Security working? Maybe it's too early to tell. But the resources have been spent. Isn't our nations manufacturing sector just as vital or important?

Photo Credit: OSHA


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