Saturday, November 1, 2008

$3 million Combustible Dust Related Fire Unreported

How can a $3 million fire that destroyed a historic furniture factory in Salt Lake City, Utah four years ago be unreported in the Chemical Safety Board Combustible Dust Hazard Study? An excerpt from a news account states:

"Local fire officials suspect that the fire started in the dust collector at the 120-year-old factory owned by Jeffrey Cobabe and Associates."

Hundreds of Incidents not Reported
The troubling aspect of the incomplete CSB Dust Hazard study that was submitted to OSHA in 2006 is that public policy concerning worker health and safety was formulated in the OSHA Combustible Dust National Emphasis Program (NEP) directive. Additionally, in March 2008 the House Education and Labor Committee introduced to Congress (H.R.5522) The Worker Protection Against Combustible Dust Explosion and Fires, also utilizing the CSB Dust Hazard study as the guidance and foundation in the drafted bill.

Since the Imperial Sugar Refinery dust explosion, dozens of training classes at industry conferences hosted throughout the nation have been providing industry stakeholders with information on combustible dust hazards. Yet these training seminars also make continuing reference to the CSB dust study in addition to the OSHA Combustible NEP, which unfortunately omits hundreds of manufacturing sub-sectors (NAICS). This training is fine and much needed in the industry. A problem arises when plant owners and managers are not obtaining the complete picture of the magnitude and depth of combustible dust hazards.

The Chemical Safety Board is not to blame. This agency is the finest accident investigation agency in federal government and has provided the industry with crucial information in preventing future accidents. With a limited budget these dedicated professionals are on the front lines investigating catastrophic accidents finding the root cause. What the agency isn't, is a research organization like the Bureau of Labor Statistics

OSHA Dust NEP NAICS
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Get the Knack of the NAICS
Referring to the above destructive fire where a dust collector was involved in just one example of the hundreds of NAICS and tens of thousand of manufacturing plants not listed in the OSHA Combustible Dust NEP, where only 68 out of a 427 manufacturing NAICS are referenced in Appendix D-1 & D-2. Just because your facility is not one of the 68 NAICS listed in the NEP, don't for a second believe you have a free pass and all is fine and dandy.

If the process stream handles combustible particulate solids that generates combustible dust of any sort, then you are sitting on a bottle rocket waiting to go off when all the factors of ignition, heat, fuel, suspension, and confinement all come together in the rare moment. We all know what a vapor cloud explosion can do in the refinery sector. The same devastating overpressure effects occur with a dust explosion in the manufacturing sector. In fact, unbelievably for many combustible dusts, the deflagration index or explosion severity (Kst) is much higher.

Explosion Ventilation Panels in Action



Last weeks combustible dust explosion at a evaporated dairy product manufacturing plant in Visalia, California is an excellent example how explosion ventilation panels reduce the severity of combustible dust explosions. Fatalities, injuries, and adverse economic damage can be minimized when manufacturing process facilities initiate a thorough process hazard analysis and follow the guidelines in the NFPA combustible dust standards, which address the objectives of life safety, structural integrity, and mission continuity through preventative and mitigative control measures.

OSHA's continuing proactive efforts in ensuring that manufacturing facilities have minimized the occurrence and reduced the severity of combustible dust hazards in the workplace is best illustrated when reviewing an inspection report and General Duty Clause citation ($6,400) completed several months earlier at similar evaporated dairy product manufacturing plant (NAICS 311514) in Wisconsin.

General Duty Clause Citation
(excerpt)
1.Protein dryer were located inside a building lacked explosion venting.
2.Storage bin, located inside the building, did not have explosion venting.
3.Pneumatic Conveyor did not have spark detectors

AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS to comply with National Fire Protection Agency (NFPA) Chapter 61 Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2008 edition; NFPA 69 "Standard on Explosion Prevention Systems" 2008 edition; NFPA 654 "Standard for the Prevention of fire and Dust Explosion from the Manufacturing, Processing and Handling of Combustible Particulate Solids" 2006 edition

Industry Leader
Hopefully the Wisconsin facility has taken immediate action on the key items which the OSHA inspector cited in the report. Other manufacturing facilities can learn from the recent explosion that occurred in California, where explosion ventilation panels effectively reduced the risk to life and property. California Dairies is an industry leader in the evaporated dairy product manufacturing sector and should be commended for the preventative and mitigative control measures that management instituted in addressing combustible dust hazards.



C/S Explovent Video-must see!

There are many sources where explosion ventilation panels can be acquired after a process hazard analysis is completed. For example, Construction Specialties is a global leader in providing explosion ventilation panels with it's field testable and ATEX 95 compliant C/S Explovent® If your facility does not have explosion ventilation panels installed yet, then maybe it's time to include this important investment in the 2009 budget.

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