Thursday, December 31, 2009

Fire in U.K. Factory-Potential Cloudburst

The fire in the manufacturing site’s main vent and piping was caused by a faulty extractor fan.

A firefighter who was at the scene called the incident a "close call" and said the blaze could have led to a "cloudburst" operation – declared after major accidents like chemical leaks.

Never heard about a “Cloudburst Operation," until now What sort of potential cloudburst situation are they referring to in the news article?

Posted via web from ComDust

School Fire causes $300k damage in Wood Shop

fire began when a spark from a circular saw being operated by a staff member ignited sawdust and set fire to the extractor system.

Globally it is a regular occurrence at educational institutions of fires occurring in the dust collector systems. NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities is an excellent resource in providing guidance of best engineering practices for minimizing the severity and reducing the consequence of future incidents. Would a spark detection and flame suppression system minimized the $300,000 of damage in this incident? News Video

Posted via web from ComDust

Explosion Hazards in Baghouses and Dust Collectors

Transport of sparks through ducts. ...This spark and the hot gas associated with the spark can travel hundreds of feet in a duct... Spark suppressors are placed in the duct to change the laminar flow to turbulent (coarse) flow. This agitation or turbulence strips the air from around the ember and cools the spark below ignition temperature.

Gary Berwick, P. Eng. at Quality Air Management shares with readers his informative article, "Explosions and Fires; Baghouses, Cartridge Dust Collectors." Fascinating video on the QUENCHER™ in-line spark arrester device for spark Cooling and air blending for dust collection systems.

Posted via web from ComDust

Resources
Quencher spark arrester Video

Combustible Dust Housekeeping with Vacuums

Vacuum Cleaning = First Defense Against Dust
In nearly all industries, the National Fire Protection Association (NFPA) recommends vacuum cleaning as the preferred first defense method of controlling fugitive dust. NFPA 654 states “vigorous sweeping or blowing down with steam or compressed air produces dust clouds.”

Informative article on housekeeping and the importance of using a vacuum in cleaning accumulations of combustible dust. Housekeeping violations were the second most cited violation according to the recent OSHA Combustible Dust NEP status report.

Posted via web from ComDust

Resources
Housekeeping Solutions
by Walter L. Frank, P.E. and Mark L. Holcomb, MS, CIH, CSP

Friday, December 25, 2009

Proposed Combustible Dust PSM Standard

Here is an idea on how a proposed OSHA Combustible Dust Process Safety Management Standard (PSM) could look like as an alternative regulatory approach. The commonality of combustible dust fire and explosion hazards in the workplace is process equipment. The most controversial aspect of a proposed ComDust PSM would be the threshold level. This is an area were valuable input from all stakeholders is needed. Many elements of PSM already are incorporated in the NFPA Combustible Dust Standards. So what do you think?

Posted via email from ComDust

Thursday, December 24, 2009

NIOSH Absent: Combustible Dust Rulemaking Agenda

Reflecting on the recent OSHA Combustible Dust ANPRM stakeholder meeting that was held in Washington, D.C on December 14, 2009 it is becoming even more apparent through researching the background of the OSHA Grain Facility Standard that many key stakeholders are not participating in the rulemaking process. Several of the potential participants that were absent would be academia, state government, insurance industry, fire protection officials, and National Institute for Occupational Safety and Health (NIOSH).

NIOSH has the most extensive background than any stakeholder in understanding the complexities of combustible dust explosions through the extensive research on the subject at it's Pittsburg Research Laboratory in addition to their participation in the development of the OSHA Grain Facility Standard.

OSH Act
Occupational Safety and Health Act of 1970 in addition to creating the Occupational Safety and Health Administration (OSHA) also created a sister agency the National Institute for Occupational Safety and Health (NIOSH) in the Department of Health and Human Services. Congress has directed through the OSH Act that the Secretary of Labor, in consultation with the Secretary of Health and Human Services, shall:

(1) provide for the establishment and supervision of programs for the education and training of employers and employees in the recognition, avoidance, and prevention of unsafe or unhealthful working conditions in employments covered by this Act, and

(2) consult with and advise employers and employees, and organizations representing employers and employees as to effective means of preventing occupational injuries and illnesses.

National Institute for Occupational Safety and Health (NIOSH)
Now the big question is why hasn't the Secretary of Labor sought consultation with NIOSH on combustible dust explosions? Especially when the Pittsburgh Research Laboratory, formed as the U.S. Bureau of Mines, has been conducting studies and research on dust explosions for over a 100 years. Additionally, the Department of Agriculture's Bureau of Chemistry also conducted studies on dust explosions during this period, whose work became the foundation for the NFPA Combustible Dust standards. In the past six years the only consultation that DOL, through Occupational Safety and Health Administration (OSHA) has sought has been with the Chemical Safety Board combustible dust hazard recommendations.

This is a reactive position with the utilization of CSB as the sole governmental agency provider of recommendations in the combustible dust rulemaking process following recent catastrophic dust explosions. A more proactive position would be to utilize the excellent resources of NIOSH, an agency that was actively engaged in the development of the OSHA Grain Handling Facilities Standard three decades ago.

For example, in the preamble for the Grain Handling Facilities Final Rule, NIOSH stated, "the danger of fires and explosions is "ever present in the industry because of the physical characteristics of organic dust that is generated while handling and processing grain" (52 FR 49595). Prior to the Final Rule NIOSH, OSHA, and the Department of Agriculture contracted with National Materials Advisory Board, which functions under the auspices of the National Research Council (NRC), the operational arm of the National Academies, in conducting extensive dust hazard studies following the series of catastrophic grain facility explosions in 1977.

NIOSH's Mining Safety and Health Research Division
The National Academy of Sciences completed four reports between 1980 and 1984: Investigation of Grain Elevator Explosions; Prevention of Grain Elevator and Mill Explosions; Pneumatic Dust Control in Elevators; and Guidelines for the Investigation of Grain Dust Explosions. The data on ignition sensitivity and explosion severity in these reports was compiled from the U.S. Bureau of Mines 1961 research on combustible dust explosions. Unfortunately in 1995, Congress shutdown the U.S Bureau of Mines and transferred it's activities to other Federal agencies.

Much of the background information that stakeholders utilize today in the identification, evaluation, and control of combustible dust hazards originated from the in-depth research that the
U.S. Bureau of Mines conducted at the Pittsburgh Research Center. NIOSH's Mining Safety and Health Research Division collaborative efforts with the Mine Safety Heath Administration (MSHA) has effectively eliminated mining fatalities, injuries, and illnesses through research and prevention. Since 1910, fatalities decreased from more than 3,000 per year to 34 in 2009.

Additionally, Congress in Section 20 of OSH Act has stated concerning Research and Related Activities (a) (1) The Secretary of Health and Human Services, after consultation with the Secretary and with other appropriate Federal departments or agencies, shall conduct (directly or by grants or contracts) research, experiments, and demonstrations relating to occupational safety and health, including studies of psychological factors involved, and relating to innovative methods, techniques, and approaches for dealing with occupational safety and health problems.

So where is NIOSH now and why hasn't the agency been involved in seeking methods and approaches in assisting stakeholders in developing layers of protection concerning workplace combustible dust related fire and explosion hazards? It makes no sense to reinvent the wheel when this governmental agency already has over a century of expertise on this complex topic.

NIOSH Intramural Programs
Already NIOSH has a superior infrastructure with it's intramural programs that could possibly address combustible dust hazards in the workplace. For instance, the Education and Information Division (EID) develops and transfers information and provides recommendations to foster prevention of occupational injuries, Then there is the Division of Applied Research and Technology (DART), which provides national and international leadership in research focused on the prevention of occupational illness and injury by developing and evaluating:

  • Methods and tools to identify and quantify workplace hazards (chemical, physical, organizational)
  • Strategies and technologies to control exposures to workplace hazards.

Finally, the National Personal Protective Technology Laboratory would be an excellent NIOSH resource in providing useful information to OSHA concerning the donning of Flame Resistant Clothing/PPE in the workplace where combustible dust flash fire hazards are present.

National Advisory Committee on Occupational Safety and Health (NACOSH
)
It appears from what currently is occurring in contrast to what Congress intended in the OSH Act is not being fully pursued in addressing workplace fatalities, injuries, and illnesses in a comprehensive manner.. For example, in Section 7 of the Act, Advisory Committees; Administration:

(a) (1) There is hereby established a National Advisory Committee on Occupational Safety and Health consisting of twelve members appointed by the Secretary, four of whom are to be designated by the Secretary of Health and Human Services, without regard to the provisions of title 5, United States Code, governing appointments in the competitive service, and composed of representatives of management, labor, occupational safety and occupational health professions, and of the public. The Secretary shall designate one of the public members as Chairman. The members shall be selected upon the basis of their experience and competence in the field of occupational safety and health.


(2) The Committee shall advise, consult with, and make recommendations to the Secretary and the Secretary of Health and Human Services on matters relating to the administration of the Act.

Reviewing the Meeting Agendas and Minutes of previous National Advisory Committee on Occupational Safety and Health (NACOSH) meetings it is a bit unusual that there has not been any discussion on combustible dust workplace fire and explosion hazards. Combustible dust explosions was a big issue back in 2003 following the rapid succession of explosions at three different manufacturing facilities.

There were several NACOSH meetings in 2003 and several more since then yet it appears that the combustible dust hazards was not a main topic amongst stakeholders. So I guess it should not be so much of a surprise that proportionate stakeholder participation is lacking at the recent OSHA ComDust ANPRM meeting.

Status Report ComDust NEP
There is a diverse conflicting aspect between OSHA and NIOSH, where one agency believes strongly in enforcement and citation activities rather than education, research, and outreach. This aspect was most evident in the October 2009 release of the status report on the Combustible Dust National Emphasis Program. From October 2007 through June 2009 over 1,000 inspection where conducted that tallied over 2,200 combustible dust citations.

The main problem was that the majority of facilities that had been inspected previously prior to the Dust NEP had not received combustible dust citations. In contrast, after the OSHA inspectors received their recent specialized combustible dust NEP training and began inspecting facilities, the tally of citations skyrocketed catching the manufacturing sector off-guard. An educational approach for businesses prior to citation activities would of been more appropiate. This is where OSHA collaboration with NIOSH would of helped.

NIOSH activity in regards to forming working proactive alliances with business concerning workplace health and safety is in conflict with OSHA's strong enforcement activities. Many small businesses are not even aware of the assistance that NIOSH offers concerning research, surveillance, prevention/intervention, information, and training. A visit to OSHA's website main page has no mention of
the National Institute for Occupational Safety and Health (NIOSH).

National Occupational Research Agenda
An innovative concept that NIOSH is pursuing concerns their outreach to eight industrial sectors which includes manufacturing in addition to 24 cross-sector programs organized around adverse health outcomes, statutory programs and global efforts. NIOSH fulfills their mission goals through developing practical solutions, research, partnerships, and research to practice (r2p).

Just recently the comment period ended for the Manufacturing sector National Occupational Research Agenda (NORA) partnership program to stimulate innovative research and improved workplace practices. Combustible dust hazards would be an appropriate topic to add to NORA manufacturing sector content. Where in Strategic Goal #10 Catastrophic Incidents: Reduce the number of catastrophic incidents (e.g., explosions, chemical accidents, or building structural failures) in the manufacturing sector.

Strong enforcement and citation activity is a great goal to pursue in minimizing fatalities and injuries in the workplace. But if the facility owners and managers don't have the educational resources to understand the complexities of controlling combustible dust hazards, then all that will result will be just be chaos. The impact of regulatory costs for the the proposed combustible dust regulation has not even appeared yet on the national horizon.

U.S. Small Business Administration

For instance the U.S. Small Business Administration, Office of Advocacy, “Statistics of U.S. Businesses: Firm Size Data," illustrated that nearly 75% of manufacturing sector firms are small businesses, employing less than 20 workers. OSHA regulations account for 53% of the cost of all workplace regulations, according to Joseph M. Johnson (2005), "A Review and Synthesis of the Cost of Workplace Regulations," in Cross-Border Human Resources, Labor and Employment Issues. Kluwer Law International: Netherlands. So will small business be financially able to immediately implement best engineering abatement controls?

These are some tough questions to answer during the nation's worst recession in over a half a century with businesses shutting down throughout the country on a daily basis. The most economical aspect in addressing combustible dust hazards would be education and outreach. Where was the OSHA Directorate of Cooperative and State Programs (DCSP) in addtion to the Directorate of Training and Education (DTE) during the recent OSHA Combustible Dust ANPRM Stakeholder Meeting? It's troubling that there is no OSHA Outreach Training Programs for combustible dust yet OSHA inspectors receive specialized training on combustible dust so as to write more citations. Where is the balance for the business sector?

With the huge chasm of different approaches that OSHA and NIOSH currently has in addressing complex workplace combustible dust fire and explosion hazards there will be a tough hill to climb in assisting the nation's manufacturing sector in prevention and mitigation strategies. A single page on Combustible Dust that OSHA provides online with a safety alert and poster is not going to provide and reach the majority stakeholders , consisting of small businesses, with the vast amount of information that is direly needed. Maybe a visit across the Mall to E Street at Patriot Plaza would be in order so OSHA and NIOSH can marshal their resources effectively as the Congress outlined in the OSH Act?

Resources
Coal-Dust Explosion Tests-USBM 1913-1918
Prevention of Grain Elevator and Mill Explosions 1982
Conference Grain Dust Fire & Explosions-1920
Preventing Dust Explosions-Scientific American 1921
Grain Dust Explosions Investigations-1918

Here is some additional background info where the subject of NIOSH reorganization that was more in line with the Congressional mandates of the OSH Act, that was brought up in 2004-2005.

The Future of NIOSH A View from Inside

Change at CDC Draws Protest

Effective Reorganization for NIOSH-September 2004 -
ASSE
CDC Proposes Staff Cuts For NIOSH



Tuesday, December 22, 2009

Safe handling of combustible dusts: Precautions against explosions

Excellent resource from the United Kingdom's Health and Safety Executive (HSE). The HSE is responsible for the encouragement, regulation and enforcement of workplace health, safety and welfare, and for research into workplace risks in England, Wales, and Scotland.

The free 41 page .pdf document provides helpful information on the prevention and mitigation of combustible-dust-related explosions and fires, Information can be easily understood for use by employers, employees, managers, foremen and EHS professionals working in the many manufacturing and non-manufacturing sectors. Provides in an easy to read manner, terminology, the hazardous potential, and examples of layers of protection to control the risk.

In addition to the content in this document readers are also encouraged to review the Dangerous Substances and Explosive Atmospheres Regulations 2002 and Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres. This will assist stakeholders in obtaining a more in-depth view of possible alternative regulatory approach to the OSHA proposed combustible dust rulemaking.

One major aspect that was overlooked in the OSHA Combustible Dust ANPRM is that dust forms a potentially explosive atmospheres like gases, vapors, and mists. In the U.K and European Union concerning their regulations, an explosive atmosphere is defined a mixture with air, under atmospheric conditions, of flammable gases, vapors, mists or dusts in which, after ignition has occurred, combustion spreads to the entire unburned mixture.

A potentially explosive atmosphere is an atmosphere which could become explosive due to local and operational conditions. So how come OSHA or the Chemical Safety Board can't acknowledge what our international trading partners already understand? A separate OSHA combustible dust standard that deviates from the family of other explosive atmospheres is treading into some dangerous waters.

Resources
Dangerous Substances and Explosive Atmospheres Regs 2002
Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres
Fire & Explosions-DSEAR (brochure)
FIRE SAFETY –FIRE RISK ASSESSMENT

Posted via web from ComDust

Large Machine Ignited ?

fire was contained mainly to the large machine, which is approximately 11 feet tall, four feet wide and four feet deep. The machine collects fine metal shavings

Hmm, I wonder what this could be? The fire chief, in the news account, mentions that the machine collects fine metal shavings. Information on their website mentions that the Massachusetts ISO 9001 certified facility manufactures spring loaded devices, ball plungers, leveling devices and mechanical components to all major industries since 1943.

Posted via web from ComDust

Grain Elevator Explosion in Texas-When all Heck Broke Loose (1976)

Emergency response radio transmission with phone calls & radio traffic synchronized as it occurred real time in the Houston Fire Department dispatch office when the Goodpasture Grain Elevator Exploded in Galena Park, Texas February 22 1976. This was prior to the OSHA Grain Facility Standard was implemented

Resources
Part 2 Radio Transmissions
Part 3

Posted via web from ComDust

Chadron, Nebraska Grain Elevator Catches Fire

The Chadron grain elevator is one of 19 that the company operates in five states. These facilities must adhere to the OSHA Grain Facility Standard in the prevention of fires and explosions. No matter how many layers of protection are instituted only the probability and severity can be minimized.

In the current OSHA Combustible Dust proposed rulemaking process, the agency intends to prevent all explosions and fires in the manufacturing sector. How can this be done when fuel loads and potential ignition sources are constantly present during the production process both in the grain industry and manufacturing sector?

Posted via web from ComDust

OSHA Combustible Dust Stakeholder Input-Grain Industry

The afternoon panel, which included the NGFA's Maness, consisted of a more balanced representation of NFPA and industry representatives.  Maness urged the agency not to adopt NFPA standards, in part because they are not subjected to economic impact studies before being approved.  He also noted that there are many elements in NFPA standards, such as facility design, construction and operational considerations, that are inappropriate, impractical or unachievable.

James E. Maness, president of JEM Safety Consultants, Rehoboth, Del. provided some very informative input concerning the possible OSHA regulatory approach to the proposed combustible dust rulemaking. The above excerpt is from the National Grain and Feed Association website, titled,"NGFA Participates in OSHA Combustible Dust Stakeholder Meeting (12/17/09)"

Posted via web from ComDust

Monday, December 21, 2009

It's the fires, stupid! Mfg Plant Two Fires, One Day

Bell said there was a small explosion in one of the silos in the first one of the day. It did damage to the top of the silo, he said, and the fire was contained within the silo.

Wood Window and Door Manufacturing plant in Bayport, MN has two fires and one explosion in one day. It's not unusual from the over 150+ combustible incidents that occurred in 2008 when a Fire Chief mentions to reporters that It's not uncommon to have a fire..."

OSHA does not realize that the majority of incidents in the manufacturing sector are combustible dust related fires. In these incidents workplace fatalities and injuries are rare. Instead the flurry of national press releases that OSHA posts on their site stating that all combustible dust incidents are explosions resulting in fatalities and injuries. This is an inaccurate statement of reality and does not address the heart of the problem. So how many facilities could of been proactively engaged in addressing layers of protection if an accurate depiction of probability of occurrence and severity of consequence was provided?

So what do you think? Should the OSHA proposed combustible dust rulemaking process be solely centered on secondary dust explosions that occur due to poor housekeeping. What about the combustible dust related fires that are a local and regional jurisdictional issue and not federal.



The proposed combustible dust rulemaking does not address the antiquated OSHA General Industry Standards. This fact was illuminated through the recent OSHA ComDust NEP status report where 90% of the citations were General Industry citations, (see figure 6) such as HazCom, Housekeeping, Powered Industrial Trucks, PPE, and Hazardous (Classified) Locations.

Combustible Dust NEP Status Report - October 2009
"It's the economy, stupid"

Posted via web from ComDust

Hazard Communication -MSDS-Wood Dust

Hazard Communication. I like this MSDS Sheet that Radiance Wood Products has prepared. The stakeholder communicates the hazard to the workers that this wood dust is potentially explosive. As you review the MSDS, notice that the minimum explosive concentration MEC (lower flammability limit) and minimum ignition temperature MIT (autoignition temperature) is included.

So what do you think? Should more fire and explosion physical properties be included?

Posted via web from ComDust

Global Scope of Explosive Atmospheres

http://www.unece.org/press/pr2009/09trade_p11e.htm
Here is an illustrative global view of potentially explosive atmospheres which includes combustible dust. This is a slide from the presentation that was made at the 5th SIEEE meeting, 2 September 2009, Melbourne, Australia. Mr. Frank Lienesch was the Coordinator, Sectoral Initiative on Equipment for Explosive Environments. The session also reviewed the work underway by the Initiative and in particular the survey of the regulatory environment in the sector of Equipment for Environments with an Explosive Atmosphere

The specific purpose of the Sector Project is to develop common regulatory objectives (CROs) for the regulation of placing Equipment and Services for Explosive Environments placed on the market. The CROs shall include area classification, verification of the equipment and its production, installation, inspection, maintenance, repair and the related conformity assessment procedures for products, services and competency of personnel. The aim is to eliminate barriers against the free trade of equipment and services. This goal is quite similar to Global Harmonization Standard concerning the Hazard Communication Standard that OSHA is seeking comments on.

In regards to the current proposed OSHA Combustible Dust Standard it would benefit all stakeholders to address combustible dust under the same framework where flammable gases, vapors, and mists also present a potentially explosive environment. It does not make sense to separate combustible dust from the other explosive atmospheres. What do you think?

Resources:
Equipment for Explosive Environments (SIEEE) .pdf
LIST OF PARTICIPANTS-
Working Party on Regulatory Cooperation and
Standardization Policies (WP.6)


Posted via email from ComDust

Thursday, December 10, 2009

Update-OSHA ComDust ANPRM Stakeholder Meeting

The OSHA Combustible Dust ANPRM stakeholder meeting will be held December 14, 2009, at the Marriott at Metro Center, 775 12th Street, N.W. ,Washington, DC. Two meeting will be held, one in the morning and the other in the afternoon. 35 participants have been selected for each meeting. Participants are only allowed to participate in the discussions in one session but are allowed to observe in the other.

Dates/Times for the stakeholder meetings are:

• December 14, 2009, at 9 a.m., in Washington, DC
• December 14, 2009, at 1 p.m., in Washington, DC
• Additional meetings are planned for early 2010, and will be announced in
one or more subsequent notices.

Agenda OSHA ComDust ANPRM Meeting

On a first come first serve basis the public is allowed to observe the stakeholder sessions. The most recent information obtained from the OSHA ANPRM contact indicates there will be seating for 120 observers in each stakeholder session. So get there early to ensure you can obtain a seat.

Breakfast Discussion

Early in the morning, prior to the OSHA ComDust ANPRM meeting there will be a Breakfast Discussion hosted by the Combustible Dust Policy Institute across the street at 1000 H Street NW in the Grand Hyatt Washington, upstairs in the Latrobe Room (Constitution Level 3B) from 7:00 A.M. -8:30 A.M. The gathering will provide an opportunity for a cross spectrum of stakeholders to briefly discuss, compare notes, and share ideas on important aspects of the OSHA Combustible Dust Advanced Notice of Proposed Rulemaking (ANPRM).

The Latrobe Meeting Room will also be open after the Breakfast Discussion for stakeholders that wish to network and discuss important topics concerning the combustible dust rulemaking process. Additionally, during the lunch break from 12:00-1:00 P.M. the Latrobe Room will also be open so stakeholders can meet prior to the afternoon 1:00 P.M. -4:00 P.M. OSHA ComDust ANPRM stakeholder meeting.

OSHA General Industry Standards
It's interesting to note that the Stakeholder Meeting Agenda has no mention in the suggested points of group discussion, topics concerning OSHA General Industry Standards. For instance, out of the over 2,200 combustible dust citations in the recent Status Report on Combustible Dust NEP, 90% of the combustible dust citations were from the OSHA General Industry Standards. By simply adding the words, "combustible dust," in the General Industry Standards of housekeeping, hazard communication, ventilation, PPE, and Subpart L Fire Protection would clear up much of the confusion concerning administrative and best engineering controls.

Hazard Mitigation
A major topic and a concern to all is hazard mitigation. Yet in the national dialogue there is no mention of personnel protection equipment such as flame resistant clothing (FRC's), which minimizes the extent of severe burn injuries from flash fires. Over 80% of combustible dust incidents in 2008 were combustible dust related fires where in several instance personnel received severe burns which could of been minimized if they had donned FRC's. Another important aspect of hazard mitigation, which should be the foundation of all other layers of protection is inherent safe design, which utilizes minimization, substitution, moderation, and simplification.

Contact Info-Breakfast Discussion
Please contact me if you desire to attend the Breakfast Discussion so as to ensure there is adequate seating. Currently, I've reserved space in the Latrobe Room for 35 participants. Please send an email to john@combustibledust.com and I'll reply promptly. Thank you.

Sponsor
s
Pyroban-Explosion Proof (EX)ForkLifts
Dantherm Filtration, Inc-Dust Extraction
Nilfisk CFM- Explosion Proof Vacuums
Ashburn Hill Corp.-Flame Resistant Clothing
Fauske Associates, LLC -Combustible Dust Testing

Resources

Federal Register Notice-OSHA ComDust ANPRM Stakeholder Meeting
Registration-ANPRM Stakeholder Meeting
OSHA Combustible Dust; Proposed Rule
Google Map Stakeholders Meetings-Washington, D.C.

Sunday, December 6, 2009

Dust explosion rocks plant

DUST EXPLOSION Dust explosion rocks North Portland Land O' Lakes plant (an explosion at the plant at about 8:30 p.m. caused about $100,000 - the explosion was on the third-floor of the plant - a machine called "corn cracker" had created a dust explosion - no employees were in the area of the blast - the "corn cracker" mixes hot and cold materials that are distributed to other parts of the plant - it overheated and created the dust explosion which sent embers into several silos - it took fire crews two hours to locate and put out hot spots in the building and the silos)

Wednesday, November 25, 2009

Antiquated OSHA General Industry Standards is the Problem

http://savannahnow.com/news/2009-11-24/osha-meeting-combustible-dust-rules-set-dec-14-dc

Several OSHA General Industry Standards already specify combustible dust such as hazardous (classified) locations, powered industrial trucks, and ventilation. The problem is that a majority of OSHA general industry standards are antiquated and do not reflect the 21st century where technology and the wealth of knowledge has exceeded the level from when a majority of OSHA standards were initially written over three decades ago.

It's easy for local elected officials to demand that a separate standard be developed for combustible dust when they have no understanding that combustible dust explosions are propagating explosions like vapor could explosions and require similar layers of protection concerning damaging overpressure effects, harmful thermal radiation, and life threatening ensuing projectiles.

A separate standard for combustible dust only further deviates from the fact that combustible dust poses a potentially explosive atmosphere like flammable gases, vapors, and mists. An excellent example of global protective and mitigative measures would be the ATEX Directives for explosive atmospheres that our international trading partners have implemented in the European Union.

The realistic urgent issue nationwide regarding propagating explosions is not dust explosions but the multitude of flammable liquid, vapor, and gas explosions that have plagued the nation's workplace. Since 2003, the Chemical Safety Board has investigated two dozen of these incidents compared to only four combustible dust incidents in nearly a decade.

In a politically and emotionally charged environment the hard and true facts are being misreported in governmental press releases that all fatalities and injuries since 1980 have occurred due to dust explosions. This totally contradicts the results of the CSB governmental 2006 Dust Hazard Study, which reported that combustible dust related fires and explosions are the culprit, not solely explosions.

Over 80% of the combustible dust incidents in 2008, according to media accounts, were fires not dust explosions. Any workplace fatality or injury is one to many. Fortunately in 2008, excluding the Imperial Sugar explosion, the human toll was minimal. The few injuries that did occur consisted of flash fire burn injuries and would not even come up on the radar as a national problem, in contrast to the rash of recent workplace flammable liquid, gas, and vapor explosions.

Jumping to incorrect conclusions that dust explosions with fatalities are prevalent and occur on a regular basis does not reflect current reality. The Imperial Sugar Refinery explosion was tragic and preventable. Something definitely needs to be done with the current OSHA regulatory scheme. But a separate dust standard is the wrong direction. If good housekeeping in removing the fuel load was adhered to as outlined in the current OSHA General Industry Standards then the secondary devastating dust explosions in the Imperial Sugar and prior catastrophic 2003 incidents would never have occurred.

To further complicate the matter is the call by legislators to supersede the OSHA combustible dust rulemaking process with a bill that would force OSHA to enact a standard four months after the bill became law. This is economically unrealistic in a time when the nation is experiencing the worst recession since the 1930’s with many facilities shutting down permanently and laying of workers.

Already through OSHA’s targeted national emphasis program through combustible dust enforcement and citation activities, businesses have began to lay-off workers so as to implement costly abatement actions. It’s just a matter of time following a proposed separate combustible dust standard or bill that many more small businesses in the manufacturing sector will be force to close down.

In conclusion, there needs to be an equitable balance between occupational safety and business economics, which reflects the reality of potential workplace fatalities and injuries due to combustible dust related fires and explosions.

Monday, November 23, 2009

Breakfast Discussion Prior to ComDust Stakeholder Meeting

Stakeholders, come join us in Washington, D.C. for a 7:00 A.M. -8:30 A.M Breakfast Discussion, December 14 2009, in the Latrobe Room (Constitution Level 3B) at the Grand Hyatt Washington prior to the 9:00 AM OSHA Combustible Dust ANPRM stakeholder meeting.

The gathering on 1000 H Street NW, across the street from the Washington Marriott at Metro Center will provide an opportunity for a cross spectrum of stakeholders to briefly discuss, compare notes, and share ideas on important aspects of the OSHA Combustible Dust Advanced Notice of Proposed Rulemaking (ANPRM).

With over 200 questions in the ComDust ANPRM that OSHA is seeking data, information, and comment that covers fifteen major topics, the morning discussion prior to the stakeholder meeting will be an interesting and lively event. Representatives from government, industry, standards developing organizations, research and testing, unions, trade associations, insurance, fire protection equipment manufacturers, consultants, and others are all invited to the early morning venue.

During the lunch break from 12:00-1:00 P.M. the Latrobe Room will also be open so stakeholders can meet and briefly discuss topics prior to the afternoon 1:00 P.M. -4:00 P.M. OSHA ComDust ANPRM stakeholder meeting.

OSHA plans on directing the stakeholder meetings to cover topics of possible regulatory approaches, scope, organization of a prospective standard, role of consensus standards, economic impacts, and additional topics as time permits. Additionally, OSHA will select approximately 35 stakeholders across a spectrum of industry sectors and affiliations for each of the sessions from the registrant pool that the Eastern Research Group (ERG) is compiling. Furthermore, members of the general public are welcome to attend the meeting, but not participate. Seating for the public is limited, so it is a first-come, first served basis.

Contact Info
Please contact me if you desire to attend the Breakfast Discussion so as to ensure there is adequate seating. Currently, I've reserved space in the Latrobe Room for 35 participants. Please send an email to john@combustibledust.com and I'll reply promptly. Thank you.

Sponsor
s
Pyroban-Explosion Proof (EX)ForkLifts
Dantherm Filtration, Inc-Dust Extraction
Nilfisk CFM- Explosion Proof Vacuums
Ashburn Hill Corp.-Flame Resistant Clothing
Fauske Associates, LLC -Combustible Dust Testing

Resources

Federal Register Notice-OSHA ComDust ANPRM Stakeholder Meeting
Registration-ANPRM Stakeholder Meeting
OSHA Combustible Dust; Proposed Rule
Google Map Stakeholders Meetings-Washington, D.C.

Sunday, November 22, 2009

Grain Elevator Dryer Explosion (Dust Explosion)

a small explosion came from a grain dryer near the elevator around 8:45 a.m. - two employees nearby were hurt in the blast, one was working on a platform on the grain dryer at the time of the explosion - one worker was taken to a hospital and the other flown by air ambulance to a hospital - no other details at this time.


Bryan

Friday, November 20, 2009

Sensible solution for the Combustible Dust standard...that creates private sector jobs and provides FREE training for companies impacted by the std

Two paths to choose from:
1) add CD as a PSM covered chemcial without a threshold assigned to it. Why can we not establish a threshold? Unlike other PSM chemicals, CD is a hazard when it is OUTSIDE of the process and allowed to accumulate over time. This is unique to CD and if we set a threshold of even 100 pounds, then those who do not exceed this would be exempt. However, they process say 50 pounds of dust a year (VERY LOW) and over 10 years do you think they may have enough dust on the ledges and hidden drop ceilings to cause an explosion. So my take is no threshold. The PSM standard is a great standard and lays out the frame work of a management system for companies to follow.

The second path would be to mirror the frame work from the PRCS standard where the employer "conducts an evaluation" to determine the applicability of the standard. This path may be troublesome based on a recent OSHRC decision that vacated some OSHA citations where an employer did an evaluation without even visiting the spaces and no documentation. OSHRC stated that 1910.146 does not qualify who and how the eval is to be done and if a company says they did one, then OSHA can not cite them for determining a PRCS is not one and killing a worker.

EDUCATION is the key! With that said, we already have a GREAT frame work in place to educate businesses, safety professionals, engineers, and workers. OSHA's outreach training program could be revamped (since they are making major changes already due to issues with the program) to include a SPECIAL Combustible Dust course. Using the Susan Howard Training grants in 2010, OSHA develops a national training program, trains the trainers just like the OSHA 500/501 courses, and then uses the grant money to provide FREE training for businesses and professionals. If you are the one that will be doing a CD hazard evaluation, you MUST have completed the OSHA 30-hr CD course, which you can get for FREE. Each area office or regional office would select a reputable firm in their area as the FREE outreach instructors and that company would have to offer at least 12 courses for the next 12 months. These courses are FREE and the training company would be paid by OSHA and the company would use the OSHA training program. The training could be attended by consultants and company safety professionals alike. But any one doing a CD eval MUST have completed the 30-hour course. You would also become a SGE as we see used in VPP Assessment and could be a resource for OSHA to help out with CD inspections. Companies would have a choice...sign up for an SGE to do an inspection of your facility voluntarily or wait for OSHA to show up with a team using the CD CPL. We keep hearing that companies need help and this would provide OSHA with a set of eyes in the field looking specifically at this hazard as well as provide non-OSHA personnel as a resource to any businesses who want some help with their CD hazards. The SGE would almost be like the "consulting" side of OSHA where they make recommendations but have no enforcement role.

Even if we do not do the SGE, I think OSHA (if they are serious about this) should use the 2010 Susan Howard Grant money to focus solely on CD Hazard training. OSHA develops a OSHA 502 course for CD training. Anyone who attends the course becomes a certified OSHA CD Outreach training. Then OSHA uses the grant money to pay these instructors to conduct these outreach courses. The 10 hour is just a CD awareness course and the 30-hour certifies you to be able to conduct a CD hazard evaluation. The grant money is used to pay for the course and course materials so there is NO deterrent to companies sending their employees. It helps small businesses on both side of the standard: 1) those who have CD at their business can get free training and resources that OSHA has trained using OSHA materials and 2) it helps small private consulting firm by them doing the training over a one year period.

Thursday, November 12, 2009

Forklift Operations in Potentially Explosive Atmospeheres

I'd like to share this post that was authored by Robert Zuiderveld, General Manager at Pyroban Corp in the ComDust discussion group.

The recent Forkliftaction.com article by contributing editor Tom Andel,"Keeping forklifts out of explosive situations," clearly illustrates that the majority of stakeholders do not understand the complexities involved in or consequences resulting from operating non- compliant powered industrial equipment in potentially explosion hazardous areas. Even though I appreciate the attention the article is putting on the issues at hand I am concerned with some in the information and statements published in the article.

CAL-OSHA

According to the OSHA IMIS citation and violation data, CAL-OSHA has not written a single OSHA 1910.178. C01 or C02 citation between Jan 1, 2003 and the present. Yet according to the NFIRS data approximately 432 fires were started by powered industrial equipment in California between 2003 and 2007.

As a matter of fact OSHA regions 9 and 10 (entire West Coast region) experienced approximately 600 and 742 fires respectively (according to the NFIRS), while only one (1) OSHA 1910.178. C01 citation was written (Nevada in 2003) between Jan 1, 2003 and the present in both regions.

I can only wonder why CAL-OSHA publishes an article about equipment fire and explosion safety while they appear to have completely ignored enforcement of the issue for at least 6 years?

Lack of Ex Hazard Awareness
I also have to question these statements:

“The problem is it’s not easy or cheap to find replacements,” he says. “For example, an electric forklift designed for heavy use in an outdoor location is not easy to come by. A number of my clients are concerned because they’ve been cited for having unapproved forklifts in their outdoor locations. We’re not sure what the fix is but we know it will be pretty expensive. You can’t use gasoline fired engines because of the various ignition sources. Now they’re coming after diesel.”

Availability of equipment:
The industry offers EX solution for diesel and electric powered trucks which are compliant with ATEX codes and regulation and can and may be safely operated in US facilities handling flammable materials. They are pretty easy to find for anybody with access to a computer, the Internet and the ability to type in “explosion proof forklift truck” in a Google, Yahoo or Bing search engine.

Cost of the equipment:
Yes, explosion protected equipment is more expensive than conventional equipment types. However when you compare their price to the cost involved in injuries, fatalities or adverse economic effects after an fire or explosions incident, there really is not that much money difference. Besides that it appears that litigious nature of society is eager to put a price on a human life, so I would like to challenge anyone to come up with putting a cost on a human life which lower than the cost of an EX forklift truck.

Equipment approvals:
It is true that UL approved EX diesel equipment is hard to find, for that matter none existent. This is due to the fact that UL never develop HAZLOC codes, regulations, construction specification or testing procedures for IC powered industrial equipment used in explosion hazardous areas.

ATEX ATmosphères EXplosibles
OSHA however has not objected to the use of ATEX compliant conversion in explosion hazardous areas in US as long as it passes a hazardous equivalency test and evidence of certification can be provided. OSHA has not cited companies using internationally certified EX equipment because of two little know OSHA enforcement facts:

1. OSHA has the “burden of proof” that equipment is unsafe
2. OSHA will allow the use of international certified equipment if not US certified alternative exists

ATEX certified solutions are available to industry and they meet both criteria, especially when it comes to diesel powered explosion proof equipment.

OSHA Powered Industrial Trucks
And these equipment type suitability/approval claims:

“OSHA’s diesel designations include DS (with safeguards to the exhaust, fuel and electrical systems) and DY (with all the safeguards of DS units plus temperature limitation features). The only forklifts approved for Division 1 hazardous locations are electric-powered, designated EX (with safeguards for use in atmospheres containing flammable vapors or dusts). DS, DY, EE (enclosed electrical equipment) and EX are approved for Division 2.”

Crucial Mistake
Unfortunately OSHA is making a commonly made crucial mistake by implying the suitability of UL approved DS, DY and EE equipment types for use in explosion hazardous areas. UL does not test, certify or approve the use of these equipment types for use in explosion hazardous areas. If equipment is tested and certified for hazardous areas, the appropriate hazardous area classification will be shown on the ID tag of the equipment. If contact your equipment OEM or UL for a written statement of the hazardous area suitability of the of DS, DY and EE type you will be able to quickly verify this info.

Authority Having Jurisdiction:
Keep in mind Lawyers are not listed in the NEC/NFPA standards as an Authority Having Jurisdiction (AHJ) and their technical judgment of equipment suitability or code interpretation is completely irrelevant.

More interesting to the law factor is the actual US product law:

S.3014
To amend title 18 of the United States Code to penalize the knowing and reckless introduction of a defective product into interstate commerce. IN THE SENATE OF THE UNITED STATES

September 7, 2000
Mr. SPECTER introduced the following bill; which was read twice and referred to the Committee on the Judiciary.

A BILL To amend title 18 of the United States Code to penalize the knowing and reckless introduction of a defective product into interstate commerce. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled.

SECTION 1. DEFINITIONS.
(a) A 'defective' product is one with a flaw in design, manufacture, assembly, or instruction which renders the product dangerous to human life and limb beyond the reasonable and accepted risk associated with such or similar products lacking such a flaw.

(b) To 'introduce' a product into the stream of interstate commerce is to manufacture, assemble, import, sell, or otherwise produce or transfer the product in question.

(c) 'Person' means the employees of any corporation, company, association, firm,
partnership, or other business entity.

(d) 'Serious bodily injury' means bodily injury which involves--
(1) a substantial risk of death;
(2) extreme physical pain; or
(3) protected or impairment of the function of a bodily member, organ, or mental faculty.

SEC. 2. ENACTMENTS.
(a) A person who in gross deviation from a reasonable standard of care introduces into interstate commerce a product known by that person to be defective which causes the death of any individual shall be guilty of murder in the second degree and shall be imprisoned for a term of up to fifteen years.

(b) A person who in gross deviation from a reasonable standard of care introduces into interstate commerce a defective product which causes serious bodily injury to any individual shall be imprisoned for a term of up to 5 years.

Post By
: Robert Zuiderveld

Resources:

OSHA Powered industrial trucks. - 1910.178

NFPA 505: Fire Safety Standard for Powered Industrial Trucks

Contact Info
Robert Zuiderveld-General Manager at Pyroban Corp.
T: +1-973-748-0760
F: +1-973-842-0508
E: salesusa@pyroban.com


Wednesday, November 11, 2009

OSHA Underground No More

Many visitors here on the ComDust site, have also have visited the OSHA Underground site where a diverse spectrum of health and safety information could be found. Unfortunately the OSHA Underground site was removed a few days ago and visitors will no longer be able to read the helpful information that Kane and contributing authors provided concerning workplace health and safety issues.

As a contributing author, I was much at loss as others into what happened. Especially with all the great content, now vanished at the click of a mouse, that Kane and others provided through comments and posts. To a large extent the ability to write and post content on OSHA Underground as a contributing author enabled me to continue successfully in my combustible dust research project. On many a occasions, Kane and numerous visitors on the site always provided welcome encouragement to continue, which provided the much needed extra boost following hundreds of hours of researching combustible dust incidents.

Recently Abel, the owner of OSHA Aboveground site, obtained an e-mail from Google, the owners of Blogger. I'd like to share with others the content of the email:

Hello,
Google has received a subpoena for information related to anonymous comments posted on your blog. The case is entitled Secretary of Labor v. Wal-Mart Stores, Inc., United States Occupational Safety and Health Review Commission, Case number SDT-9-0181.

To comply with the law, unless you or an anonymous commenter provide us with a copy of a motion to quash the subpoena (or other formal objection filed in court) via email at legal-support@google.com by 5pm Pacific Time on November 26, 2009, Google will assume you do not have an objection to production of the requested information and may provide responsive documents on this date.

For more information about the subpoena, you may wish to contact the party seeking this information at:

Michael D. Billok
Gibson, Dunn & Crutcher LLP
1050 Connecticut Avenue, NW, Suite 300
Washington, DC 20036
(202)887-3500

So that's it. I called Mr. Billok, the attorney representing Wal-Mart and he could not legally provide any additional information that wasn't already in the above letter. It appears that the OSHA Underground site was voluntarily removed by Kane, the owner of the site.

This is a bittersweet ending to the recent award that LexisNexis bestowed on the OSHA Underground as one of the Top 25 Blogs for 2009. I was honored to be one of the four contributing authors in addition to Kane that wrote on subjects concerning workplace issues, which potentially had an impact amongst the readers.

Since the site is down and I can't express my feelings there, so here on the ComDust site I'd like to extend my sincere thanks to all the OSHA Underground readers for your support with your diverse comments that made the site so special as a unique outlet in discussing workplace health and safety issues. Like a friend that you grew up together with in the old neighborhood, all that is left is good memories from those days gone by.

Alternative: Facility Licensing that Generate Combustible Dust

I'd like to share this post that was authored by Timothy Anderson, Owner, Allfeed Process and Packaging Inc in the ComDust discussion group.

Information is powerful and it’s easy to become complacent when life experiences do not match the statistics. For instance, when you operate fork trucks for 30 years and never heard of an LPS classification of forklift or understood that there are also additional classes of electric fork trucks, then its easy to stop looking or stop asking questions to answers you didn't knew exist. Additionally, when the OEM (original equipment manufacturer), does not enlighten you or when OSHA inspectors visit your facility, when you have two, then three, then four trucks, and says nothing until you have ten forklifts then fines you $60,000 dollars, you then immediately realize you can not count on them (and shouldn't) for the answers.

Having farmed for some years (late 70’s to mid 80’s) it was common a few times each day to open the engine compartment to put out the embers from soybean or corn dust that accumulated on the engine and were smoldering. We never looked to see if there were any, there always were, we were just hunting them down.

In the grain elevator business, running corn dryers, we did fire watches each hour. Again not to look to see if there were hot spots but to find the ones that were always there. So in the feed business, when we get done running our LP or diesel equipment, we simply blew down the motors and put out any embers that might be there, and sometimes there are.

This is how it has been done for a long time. I agree with the changes that are coming down the pike but don’t agree with how they are coming down. Licensing is the real answer. Upgrade the test annually so changes are small. These pendulum swings from no knowledge to no tolerance is bad business.

Posted by Timothy Anderson

Resources
Combustible Dust Discussion Group

Monday, November 9, 2009

Wanna play the OSHA 191.178 C02 lottery?

I'd like to share this post that was authored by Robert Zuiderveld, General Manager at Pyroban Corp in the ComDust discussion group. It is an interesting and informative post as it provides insight regarding equipment protection levels of powered industrial trucks and equipment type’s suitability in a potentially combustible dust explosive atmosphere. OSHA PIT 1910.178 violations where third most cited violation according to the recent OSHA status report of the Dust NEP program


Robert Zuiderveld analyzed OHSA citations given for OSHA 1910.178 C02 violations for powered industrial trucks (use of improper equipment types in explosion hazardous areas) between 2003 and 2008.

2003 - 10 citations
2004 -18 citations
2005 -14 citations
2006 -16 citations
2007 -18 citations
2008 -31 citations


Units Sold

During that same time the following estimated number of “rated” forklift trucks (“S”, EE & DY types) were sold based on a 2% market share of total trucks sold (figure agreed upon by forklift OEMs)

2003 - approx. 2800 ES, EE, LPS, DS, DY units sold
2004 - approx. 3300, ES, EE, LPS, DS, DY units sold
2005 - approx. 3600, ES, EE, LPS, DS, DY units sold
2006 - approx. 3800, ES, EE, LPS, DS, DY units sold
2007 - approx. 3500, ES, EE, LPS, DS, DY units sold
2008 - approx. 3000, ES, EE, LPS, DS, DY units sold


Fires

According to the National Fire Incident Reporting System (NFIRS) during this same time period the following number of fires were ignited by forklift trucks and loader:

2003 – 532 fires (+/- 2233 fires if you incl. construction equipment, cranes and misc ind. equipment)
2004 - 572 fires (+/- 2469 fires if you incl. construction equipment, cranes and misc ind. equipment)
2005 - 657 fires (+/- 2795 fires if you incl. construction equipment, cranes and misc ind. equipment)
2006 -686 fires(+/- 2982 fires if you incl. construction equipment, cranes and misc ind. equipment)
2007 -795 fires (+/- 3149 fires if you incl. construction equipment, cranes and misc ind. equipment)
2008 –not available yet


Equipment Protection Levels

Based on this data, it appears that OSHA inspectors may lack the ability to recognize equipment protection levels and equipment type’s suitability allowing the use of equipment types which are not tested, certified or suitable for use in the Class I and Class II explosion hazardous areas.

Additionally it appears that OSHA enforcement and fines are inconsistent. Citations for 1910.178 C02 are none existent or far and few between in some of the states with the highest number of forklift fires. http://www.pyroban.us/NFIRS-data.htm

If you are located in CA for example you have nothing to worry about. CAL-OSHA appears to be too busy with CARB to address equipment fire safety issues.

Fines have been relatively low ($250 – $2500), unless you have an incident that arouses OSHA scrutiny. Then things get really ugly really quick.


Imperial Sugar $350,000.00
All-feed $35,000.00

Off course if you are an oil refinery a different set of rules appear to apply, since BP Texas City nor Calumet, Shreveport were cited for using unprotected industrial equipment, even though a pickup truck and a vacuum truck were responsible for igniting those explosions.

Many more examples, mostly not cited by OSHA, can be found on our site at:
http://www.pyroban.us/Information_incidentCosts.htm

Why the double standard....only OSHA knows

With 45,000 Dust facilities to inspect (for some unknown reason these industries with known dust fire hazards were not included in the OSHA NEP SIC lists: paper related industries, ethanol plants, Cotton farms) and probably a similar number of companies handling Class I flammable materials. OSHA has its work cut out for them and your chances of getting audited may be similar to your chance of winning the lottery.


Note:

Thanks Robert for the valuable insight. Fantastic job on the excellent research and sharing with others


Contact Info
Robert Zuiderveld-General Manager at Pyroban Corp.
T: +1-973-748-0760
F: +1-973-842-0508
E: salesusa@pyroban.com

Combustible Dust ANPRM-Stakeholder Meeting

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21185

SUMMARY:
OSHA invites interested parties to participate in informal stakeholder meetings on the workplace hazards of combustible dust. OSHA plans to use the information gathered at these meetings in developing a proposed standard for combustible dust.

OSHA believes the stakeholder meeting discussion should center on major issues such as:

• Possible regulatory approaches
• Scope
• Organization of a prospective standard
• The role of consensus standards
• Economic impacts
• Additional topics as time permit

Meetings Location
The December 14, 2009, meetings will be held at the Marriott at Metro Center, 775 12th Street, N.W., Washington, DC, 20005. The 2010 meeting dates and locations will be announced in one or more subsequent notices.

Dates/Times for the stakeholder meetings are:

• December 14, 2009, at 9 a.m., in Washington, DC
• December 14, 2009, at 1 p.m., in Washington, DC
• Additional meetings are planned for early 2010, and will be announced in
one or more subsequent notices.

Registration
Submit your notice of intent to participate in one of the scheduled or future stakeholder meetings with the following weblink:

• Electronic. Register at
https://www2.ergweb.com/projects/conferences/osha/register-osha-stakeholder.htm
(follow the instructions online).

Resources
Google Map

Saturday, November 7, 2009

Read the OSHA General Industry Standards Lately?

Out of curiosity I thought I'd review a few of the applicable OSHA General Industry Standards as they relate to combustible dust citations. This interest especially came about after the recent OSHA STATUS REPORT on the COMBUSTIBLE DUST NATIONAL EMPHASIS PROGRAM. In addition to General Duty Clause citations for combustible dust, facilities are also cited due to violations of the OSHA General Industry Standards. For example the status report lists several general industry regulations violations in Figure 6. Number of Combustible Dust Related Violations

The report states, "Hazard Communication standard is the standard most frequently cited with respect to combustible dust related hazards, followed by the housekeeping standard." On a prior ComDust post mention was made of the powered industrial trucks, which was the third most cited general industry violation. But then I got to thinking, "what about the OSHA Ventilation Standard 1910.94"?

OSHA Ventilation Standard

Reviewing the standards online it is interesting to note that 1910.94 is mostly concerned with industrial hygiene as it relates to grinding, polishing, buffing, abrasive blasting, and spray finishing operations. Elements of combustible dust fire and explosion protection is noted briefly in the definitions applicable to ventilation 1910.94(a)(2)(iii). Specifically, incorporated by reference as specified in § 1910.6. National Fire Protection Association Explosion Venting Guide, NFPA 68-1954. Okay that's great. But what does that 1954 at the end of NFPA 68 mean? After-all it is over a half a century later, here in 2009. That couldn't mean the year 1954, no way..?

Well as I always do, and ending up getting in more trouble, I decided to turn up more rocks and find out for myself. Sure enough a click here and a select there, and I'm on the NFPA site viewing NFPA 68 and reading the origins and development of NFPA 68. Well sure enough, NFPA was first printed as a guide using "rules of thumb," for explosions venting. I believe that was before the Russian Sputnik satellite was launched, which initiated America's space race.

ComDust NEP Status Report
The recent ComDust NEP status report summarizes some General Duty Clause citations issued by OSHA under the Combustible Dust NEP. Nearly half of these GDC citations in the summary have to do with ventilation such as ductwork, dust collectors, air handling, etc. It appears facility stakeholders have no clue in proper ventilation best engineering practices and procedures in minimizing the combustible dust fire and explosion hazards. Well after reviewing the OSHA ventilation standards and noting the sparsity of any information and guidance except reference to an over half a century NFPA standard it's no wonder there are so many of these GDC citations.

Now the primary argument in the recently published OSHA combustible dust ANPRM that a separate combustible dust standard is needed and in a recent OSHA news release is:

"The NEP has resulted in an unusually high number of general duty clause violations, indicating a strong need for a combustible dust standard. The general duty clause is not as effective as a comprehensive combustible dust standard would be at protecting workers."

Overhaul General Industry Standards

Of course there would be an unusually high number of GDC's especially with the outdated OSHA General Industry Standards, that were written over three decades ago. Smoke and mirrors are fine and dandy attending the circus once a year when it comes to town. But how can we even begin to start a national discourse on any separate standard when the problem lies squarely in a much needed overhaul of the OSHA General Industry Standards?

Look at HazCom, no mention of the physical properties issue as it relates to midstream in the manufacturing life-cycle. Housekeeping is hidden beneath Subpart D: Walking-Working Surfaces and can't even find the word "fire" in the General Requirements. Then there is PPE, with chemical hazards, radiological hazards, or mechanical irritants. What about PPE for thermal radiation hazards from flash fires?

Conclusion
The list goes on and on with these outdated OSHA General Industry Standards that don't reflect the current situation in the workplace that was not initially acknowledged in an entirely different era of the 1970's when our American troops were in Vietnam and it was still cool to go to the movie drive-in, watching the Godfather.

Protection of the workplace from hazards will need dozens more separate standards like the proposed combustible dust standard, if the dire situation continues in not addressing the current outdated General Industry Standards. So have you read them lately?

 

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