Flame Resistant Garments: Minimizing Combustible Dust Hazards

David Osbon here from UniFirst Corporation and just wanted to post to the blog to introduce myself to the network and talk about a few things related to Combustible Dust Explosions. Following the catastrophic events that took place in February in Port Wentworth, GA I have spent a great deal of time researching combustible dust and the hazards associated with dust. I will be the first to admit that prior to the February event I did not understand the devastating effect of these explosions. I do now - I have seen it first hand.

Minimizing the Risk
My background is technical in nature. Prior to my current employment I researched and developed flame resistant fabrics for the industrial sector (NFPA 70E Standard for Electrical Safety in the Workplace 2009 , Petrochem, Electric Utilities, etc). I have investigated many fatalities and in almost every case - the fatality was PREVENTABLE! In almost all cases EDUCATION and UTILIZATION of the appropriate Personal Protective Equipment (PPE) would have prevented or minimized the extent of the injuries associated with the accident.

Through all of the research I have conducted over the last several months, one of the main issues that I see as "lacking" in most of the CSB reports, the House of Representatives meeting (HR5522), and all of the OSHA NEP directive information is the utilization of PPE.

NFPA 2113 Flame-Resistant Garments
The OSHA directive CPL 03-00-008 Combustible Dust National Emphasis Program (Reissued) ,does make specific reference to General Duty Clause (OSHA 1910.132) citations if the hazard is present and the appropriate PPE is not utilized. The directive goes on to mention NFPA 2113 -Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire as a reference document for selection and care of FR garments. NFPA 2113 has a specific section that deals with combustible dust.

What I do not find is a specific section that requires the use of FR garments. As I have seen with the NFPA 70E market, the electric utility market, and the petrochem market - OSHA has generally left this area vague and has relied on the General Duty Clause as a "catch all" gray area to allow citations to be issued without having to write the requirement in to LAW!

After reviewing the LONG list of fines associated with the Port Wentworth event I did note approximately $249,000 in General Duty Clause violations. As information to the post - the Port Wentworth site is now outfitting ALL personnel in Flame Resistant garments to increase their overall level of protection.

Improved Technology
While flame resistant fabrics and garments will not eliminate ALL injuries associated with combustible dust hazards, I strongly believe that the use of these garments would have minimized some of the burn injuries. Fabric and garment technology has improved ten fold over the last 5 years. Garments are now lighter weight, more comfortable, more durable, and more protective than at anytime in the past.

We are in the beginning stages of working with NFPA on a new standard that would increase the awareness and use of protective garments in combustible dust situations.As well, a member of my team has just joined the ASTM committee that deals with combustible dust. I personally am active with ASTM F23 (Committee on PPE and Equipment) and F18 (electrical workers).

It is my hope that we can build a network of professionals that are experts on combustible dust that will be able to educate the public on the hazard and tools available to minimize burn injury. If we can save one life - this would all be worth it.