Wednesday, November 12, 2008

NAICS Awareness ComDust Hazards Alert

I'd like to thank David Osbon, Product Manager of Unifirst, a provider of flame resistant clothing (FRC's) and contributing author of the ComDust Blog in sharing the above pie chart that encompasses 60%, (over 18,0000) of the 30,000 letters that OSHA sent to establishments which were identified by OSHA as national industries (NAICS) that have imminent and inherent combustible dust hazard along with a copy of OSHA's Combustible Dust SHIB. .

In the March 2008 letter, OSHA urged employers to review the information in the Combustible Dust SHIB and reminded stakeholders of their responsibilities to minimize combustible dust hazards and lessen the severity of future incidents that are inherent in the manufacturing and non-manufacturing process. It also reminded them of the assistance OSHA's on -site Consultation Program can provide confidentially and free of charge.

There is a problem here that needs to be addressed concerning industry awareness of combustible dust hazards. Since the beginning of the year, through media accounts, theres been 14 combustible dust related fires and explosions in the Paper Manufacturing sector, yet in the above pie chart it highlights that this manufacturing subsector was not identified as having a combustible dust hazards when letters where sent out. Below you'll note another pie chart of combustible dust explosion over the past year in the various subsectors

Thats odd, especially, through media accounts, 7% of the ComDust explosions have occurred in the Paper Manufacturing sector. In no way is this meant to be derogatory to this vital national industry with over 6,000 establishments and over 400,00 dedicated and hard-working employees. The Combustible Dust Policy Institutes's goal is to provide a proactive awareness and work collectively in stategic alliances with all stakeholders in the public and private sectors.

An especially critical aspect of hazard awareness is the OSHA Combustible Dust NEP, where Paper Manufacturing sector is excluded as Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires and Industries that may have Potential for Combustible Dust Explosions/Fires.

The paper manufacturing sector which includes 16 national paper industries (NAICS), not one national industry (NAICS) is listed in the OSHA Dust NEP. It's like a snowball rolling down the hill as the plot gets bigger and bigger with four paper mill combustible dust related fires, three sanitary paper product manufacturing fires, and two combustible dust fires at corrugated solid and fiber box manufacturing plants.

It was only yesterday when a Paperboard Mill experienced a combustible dust fire when paper dust ignited on a dryer area and went into the pneumatic conveying system. The news account further stated, "in January, an overheated piece of machinery sparked a fire that spread along the ceiling." This is the problem, as over 30% of the 122+ combustible dust related fires and explosion are reoccurring repeats, which eventually end up as the rare event of a combustible dust explosion.

The paper sector is not alone as not being referenced in the Dust NEP as national industries (NAICS) in the wood, food, textile, chemical.plastic/rubber, primary metal, machinery , furniture, miscellaneous , and non-manufacturing are also not included. Maybe a potential solution is to utilize a watered-down version of OSHA's Process Safety Management (PSM) for combustible dust, which has similar characteristics in explosion severity (Kg, PMax) as do flammable liquids and gases referenced in the OSHA PSM.

Webinar-Evidence-Based Compliance (free)

This just in. A free webinar at 2:00 PM EST November 19, 2008, sponsored by MSDSpro and hosted by EHS Today magazine discussing OSHA Hazard Communication Standard. An added awareness must be projected to the industry concerning combustible dust hazard awareness. Currently MSDS's do not provide the vital ignition sensitivity and explosion severity data.

The Combustible Dust Policy Institute is developing a Co-Op combustible dust testing service between Users Groups and testing laboratories. If a multitude of stakeholders from a niche national industry (NAICS) desire testing all at once, then costs of testing can exponentially go down. Lets do it! I need feedback both negative and positive from all stakeholders to proceed further.

Join the Combustible Dust Policy Institute Group on LinkedIn for additional discussions on this topic. See you there.


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