Global Cooperation Needed Combustible Dust Hazards

Last month's fire that raged through the Paarl Print Factory in Paarl, South Africa that killed a 13 workers and seriously injured many more was reminiscent of fatalities and injuries that occur in the manufacturing sector here in the USA.

A press release issued by the Chemical, Energy, Paper, Printing, Wood and Allied Workers' Union (CEPPWAWU) spokesperson, Cedric Maluleke stated, "preliminary finding that the initial small fire in the cafeteria was propagated through the building by an ensuing dust explosion. This was fueled by paper dust that had accumulated on the open rafters of the building and which had been raised into the air by the shockwave."

The above description is a textbook example of a deflagration where the pressure wave moves at the speed of sound (768 mph) and a devastating fireball following shortly thereafter. Hopefully we can learn from our global trading partners in minimizing the severity and probability of future combustible dust incidents. Currently the OSHA Dust NEP has failed to list paper industries, like the above example, as a combustible dust hazard in the Appendix of the Dust NEP.

This is quite troubling especially when reviewing the Prerule abstract for the combustible dust rulemaking that the Dust NEP will be the foundation for the rulemaking process. Scary stuff. So who is the wizard behind the curtain at OSHA deciding which national industry (NAICS) has a combustible dust hazard or not? Over 50% of combustible dust incidents last year occurred in national industry's not listed in the Dust NEP.

Without acknowledgment that incidents are occuring in national industries not listed in the Dust NEP, stakeholders are unprepared in dealing with the hazards. The problem is intensified when OSHA Susan Harwood Grant Awardees of Combustible Dust Training also use the Dust NEP as the foundation for their training programs, which omits industries at high risk and types of materials (Did you Know?) that can create combustible dust hazards. Will it take an incident as catastrophic as the South African Paarl Print Factory for the wizard behind the curtain to wake up?

The USA is not the only stakeholder that is at loss with reality through lack of information. Especially when reading the press release from our South African trading partners that,"Dust explosions in industry are relatively rare. They are most often encountered in the coal mining industry and in the grain-handling and processing industries. Coal dust, grain dust and paper dust are inflammable and, when raised into the air, can explode."

So dust explosions are rare and most often only encountered in coal mining industry and in the grain-handling and processing industries ? I wish that were the case, but last year there were over 30 combustible dust related explosions in the manufacturing and non-manufactruing sectors here in the USA according to media reports.

Lessons learned from the tragic incident in South Africa and incidents here on our own shore is that before any rulemaking process can proceed in a manner that protects the workplace is to have an understanding of the the probability and severity of combustible dust related fires and explosions throughout the manufacturing, non-manufacturing and utility sectors.

The current Dust NEP formulated through the Chemical Safety Board recommendations is a start but stakeholders throughout industry still have a long way to go in order to protect the workplace from future fatalities and injuries when dust deflagrations occur.

Resources
Paarl Print plant fire disaster-Media Release

Combustible Dust Standards Task Group Forming

The Non-Ferrous Founders' Society (NFFS) is forming a task group in preparation for the lengthy OSHA combustible dust rulemaking process. Other national industries should also be forming task groups so as to provide the much needed input to OSHA during the comment period which includes stakeholder meetings that will be held in the future. The ANPRM will be published shortly in the Federal Register so stay tuned for further developments.

Are there other national industries (NAICS) forming Combustible Dust Standards Task Groups?

14th Annual VOSH Conference: Roanoke,Va

The Virginia Department of Labor and Industry will be hosting the 14th Annual Virginia Occupational Safety and Health Conference (VOSH) June 2-5 2009 at The Hotel Roanoke and Conference Center in Roanoke, Virginia, which is located at the western foot of the Blue Ridge Mountains in Roanoke Valley. Several dozen break-out sessions covering a diverse spectrum of topics on occupational health and safety will provide employers, employees, and health and safety professional the tools in developing a healthy and safer workplace.

Attendees also look forward to the Thursday morning keynote address by Chemical Safety Board Member, the Honorable Gary L.Visscher with the topic, "Heading Towards the Future in Workplace Safety." Visscher was appointed to the U.S. Chemical Safety Board by President Bush on August 2, 2004. Prior to the CSB appointment he served from 2001 as Deputy Assistant Secretary of the Occupational Safety and Health Administration (OSHA).

On Tuesday, June 2, pre-conference events will include an OSHA General Industry 10-Hour Course in addition to an OSHA Construction 10-Hour Course. Instructors from the Virginia Department of Labor and Industry, BECO Construction, Thor, Inc., Southern Air, and Western Refining Yorktown, Inc will be teaching these classes. Course fee is $55.oo

Wednesday, June 3 the VOSH Conference kicks off with Lunch and Conference Opening remarks by C. Ray Davenport, Commissioner of the Virginia Department of Labor and Industry and Jennifer S. Wester, Director of Cooperative Programs. Following lunch, nearly 50 hourly training break-out sessions will continue for two days until adjournment at noon Friday, June 5, 2009

Employers in the Commonwealth of Virginia will not want to miss the Wednesday and Thursday morning breakout sessions that Anna E. Jolly, JD, CHMM, will be presenting on, "Workers’ Compensation vs OSHA Recordkeeping Requirements." Ms. Jolly in addition to being an industrial hygienist is Vice President at Circle Safety and Health Consultants, a full service Occupational Safety and Health consulting company.

Combustible dust hazards topics will also be included at the VOSH conference with presentations that provide insight and potential solutions in minimizing the probability of incidents occuring at facilities. Currently OSHA is in the Prerule stage in developing a general industry comprehensive combustible dust standard and stakeholders must begin developing potential cost effective risk management solutions so as to provide input to OSHA during the comment period of the lengthy OSHA rulemaking process.

Subsequently, the combustible dust sessions will provide an overview of national industries (NAICS) experiencing combustible dust incidents not listed in the Dust NEP in addition to helpful insight and possible cost effective administrative control measures that are also utilized in the OSHA Process Safety Management (PSM) standard where deflagration hazards also exist with vapor cloud explosions.

On-site fee for the VOSH Conference is $290.00. Major contributors to the VOSH conference include:
• Virginia State Association Of Occupational Health Nurses
• Colonial and Tidewater chapters of the American Society of Safety Engineers
• Central and Tidewater VA sections of the American Industrial Hygiene Association
• Virginia AFL-CIO

Resource
VOSH Conference Brochure

Tank Battery Explosion from 200 yards away

Regular Speed of Video

David Drummond says,
"While shooting some ENG/stock footage last night of a tank battery fire near Lamesa, TX that was ignited by lightning, an explosion took place that sent a foot and half long, 4" diameter pipe valve from 200 yards away arcing directly into the front of my storm chase vehicle causing extensive damage.

This is closer than you EVER want to be to an explosion!

Firefighters from Lamesa and Andrews, TX fought to keep the fire down and the tanks cooled off for an hour before it finally exploded. Miraculously, all managed to escape without injury!

Video aired today on NBC, CBS, ABC, CNN, TWC"

Videographer: David Drummond



Resources
STATter 911 (slow motion of explosion)
Firefighter gives detailed account

OSHA Combustible Dust Prerule Agenda

Celeste Monforton, DrPH, MPH Assistant Research Professor in the Department of Environmental and Occupational Health at the George Washington University and contributor of the public health blog, "The Pump Handle," has provided readers an excellent overview of Labor Secretary Hilda Solis's Regulatory Plan in her recent post with a discussion of the inner workings of the current Unified Agenda of Regulatory and Deregulatory actions, which includes Prerules of combustible dust and occupational exposure to silica, beryllium, and diacetyl.

According to the combustible dust prerule, the Advance Notice of Proposed Rulemaking is planned in August 2009 (no exact date yet) with stakeholder meetings sometime in December 2009.

It’s very troubling reading the Combustible Dust rulemaking abstract to learn that OSHA will be using information gathered from the reissued Combustible Dust NEP as the agency considers future rulemaking. This document does not provide a clear picture of reality. Especially considering that over 50% of combustible dust related fires and explosions in 2008, though media accounts, occurred in national industires (NAICS), not referenced in this outdated NEP.

Furthermore the 281 combustible dust incidents obtained from the CSB Dust Hazard Study does not address the thousands of incidents that have occurred over the past three decades. A sound occupational safety policy in protecting the workplace can only be formulated when stakeholders fully understand the probability of occurrence in addition to the severity. The CSB study was a great start but much more needs to be done in evaluating the hazard appropriately.

An OSHA comprehensive combustible dust standard is much needed but lets not get all warm and fuzzy by a quick fix like what has previously occurred decades ago with the OSHA Grain Facility Standard in which there was over 50 combustible dust related fires and explosions in 2008. Not counting the rare Feb. 7, 2008 Imperial Sugar Refinery incident, there was more economic damage and workplace injuries in the grain facility sector in 2008 than in the manufacturing sector from combustible dust related fires and explosions.

With such a complex subject as combustible dust spread across hundreds of national industries (NAICS), a negotiated rulemaking process like which occurred with cranes might be a viable option in addition to incorporating a hybrid process safety management (PSM) venue into the rulemaking process.

Resources
Agency Rule List - Spring 2009 (Select Dept of Labor in Dropdown)
Introduction to the Unified Agenda (must read ! )
OSHA-Reg-Agenda-Combustible-Dust (1910.307 Hazard Communication ???
OSHA's Regulatory Agenda and Guidance Projects-OSHA ASSE Presentation

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Twitter Combustible Dust

Twitter, a social networking and micro-blogging resource is an excellent utility in which stakeholders can communicate in real-time amongst themselves concerning combustible dust hazard issues. This is especially important with the current OSHA combustible dust hazard rulemaking process that is occurring under the new administration in the Department of Labor.

Stakeholders can share ideas concerning possible regulatory methods in regards to data and comments on issues that OSHA is requesting related to combustible dust such as hazard recognition, assessment, communication in addition to defining combustible dust and other concerns.

Farr Air Pollution Control (APC) a company that provides dust collectors to the manufacturing sector is leading the pack in providing helpful information through Twitter on combustible dust testing, anatomy of a dust collector, how a dust collector works, and other helpful information. In 2008, through media reports over 30% of combustible dust related fires and explosions occurred in dust collectors. The information that Farr APC provides on Twitter in addition to their blog, "Industrial Dust Collectors-Info and News," reduces the probability of future combustible dust incidents through their helpful posts.

It's easy to sign up for Twitter, just provide an email address and password. Then to set up with your BlackBerry Smartphone for updates install the TwitterBerry icon for posting updates to Twitter. It works over the data network, so you don't need to use SMS. Once you are all set up, you can use the keyword, "combustible dust," when searching for resources on your Twitter Home page.

Hope to see more informational and educational content in the future concerning combustible dust on Twitter, like Farr APC is providing, which needs to be addressed in providing a safe workplace in the prevention and mitigation of future combustible dust related fires and explosions.

Update 5/18/09
Now Explovent (explosion ventilation panels) and Nilfisk CFM (explosion-proof vacuums) are posting on Twitter, which is an excellent venue in reaching the workers concerning combustible dust hazards. So far all this combustible dust hazard awareness has been mostly directed towards management, which is fine. But we need to reach the workers who work long shifts on the factory floor and are exposed daily to potentially explosive atmospheres of combustible dust.

Update 5/21/09
South East Fire Prevention, Inc. on Twitter Providing solutions to special hazards associated with dust collection and manufacturing; mission, purpose and cause is to help prevent industrial combustible dust fires and explosions

Other Helpful Twitter Post Examples
newmdiajim (CBS News Cameraman)
hurricanes
alaska_avo (Mount Redoubt Volcano Updates)
Everything Twitter

Combustible Dust Hazard OnlineTraining-Free

The North American Die Casting Association (NADCA) hosts a free combustible dust hazard training program on their website through a series of 39 videos, which also includes a section quiz after viewing each video segment . OSHA through a Susan Harwood training grant awarded NADCA funding so as to develop these excellent combustible dust hazard training videos.

Other national industries (NAICS) that have combustible dust hazards present in the workplace will discover that many of the video segments are pertinent to their application in regards to identifying, evaluating, and controlling the risk from combustible dust related fires and explosions.

The North American Die Casting Association (NADCA) represents the worlds most effective die casters that create the worlds best cast products. Working with a North American die caster guarantees innovation, integrity, accessibility, and reliability.

2008 Susan Harwood Grant Awardees
Combustible Dust Training

Georgia Tech Applied Research Corporation
Atlanta, GA
$203,327

Georgia Tech will conduct a needs assessment and develop an 8-hour proficiency-level module on combustible dust prevention and mitigation. The training will focus on National Fire Protection Association, National Electric Code, OSHA Combustible Dust National Emphasis Program (NEP), Process Safety Management and Incident Command Systems information. Georgia Tech will deliver 10 courses for 500 employers and employees reaching safety and health professionals, plant managers, maintenance and front-line supervisors in industries most commonly affected by combustible dust issues. Next class: June 15th, 2009 | Nashville, TN Combustible Dust Free One Day Seminar

Kirkwood Community College
Cedar Rapids, IA
$174,978

The College will develop, deliver, and evaluate a 2 ½-hour awareness-level combustible dust safety course addressing grain dust, bio-solids, and other organic dusts such as sugar, flour and paper. Trainers will conduct 150 courses in 14 midwestern states for 3,000 employers and employees primarily in the agriculture, food processing and fiber sectors with a focus on grain elevators and ethanol bio-refineries.


Texas Engineering Extension Service
College Station, TX
$188,166

TEEX will conduct several existing courses on Process Safety Management and Dust Behavior in OSHA Region VI, which includes Texas, Arkansas, Louisiana, Oklahoma and New Mexico . It will also develop and conduct Combustible Dust Explosion Hazards Awareness courses. A total of 19 courses will be conducted for 325 participants. Recruiting will be targeted to industries in SIC codes at risk for dust explosions. The Mary Kay O'Connor Process Safety Center will offer a course in "Dust Explosion Behavior."


Resources
YouTube-NACDA Combustible Dust Training

Combustible Dust Hazards OSHA Rulemaking

In the near future OSHA will be accepting comments and data concerning a future combustible dust regulation, through an Advanced Notice of Proposed Rulemaking (ANPRM). A very informative definition of the entire rulemaking process can be found on Wikipedia.

The helpful informational YouTube video is a brief overview of how the rulemaking process proceeds according to the Administrative Procedures Act

Advance Notice of Proposed Rulemaking. This optional step entails publishing the agency's initial analysis of the subject matter, often asking for early public input on key issue. Any data or communications regarding the upcoming rule would be made available to the public for review. Occasionally, a board of potentially affected parties is comprised to do give-and-take bargaining over rulemaking subject-matter which would otherwise result in deadlocked opposition by an interested party.^[2]This is commonly called "negotiated rulemaking"^[2], and results in more custom-tailored proposed rule.

Did OSHA miss a step here in not allowing negotiated rulemaking with such a complex subject?

The ANPRM is an ideal time for all stakeholders to provide input on the very complex topic of combustible dust hazards in the workplace. Especially when the current data provided by the Chemical Safety Board concerning the number of workplace combustible dust incidents since 1980 is inaccurate. Additionally, input from stakeholders would assist OSHA in acquiring a better overview of the current situation concerning combustible dust related fires and explosions. The reissued OSHA Combustible Dust NEP has left out many national industries (NAICS) that are experiencing repetitive combustible dust incidents.

Any attempt to model a general industry combustible dust standard after the OSHA Grain Facility Standard would not be wise. Especially when in 2008 there was over 50 combustible dust related fires and explosions in the grain industry, which included 15 explosions according to media reports. Furthermore, the OSHA press release notes a recent grain facility explosion (SIC 2048) that occured last month, injuring three workers in Illinois in the same sentence as the Imperial Sugar incident. Dust explosions cannot be entirely prevented, only the probability and severity reduced through administrative controls and best engineering practices as outlined in the NFPA combustible dust standards.

A hybrid of the OSHA Process Safety Management (PSM) concerning combustible dust would be the most appropiate venue and would include layers of protection not yet mentioned in the NFPA combustible dust standards. Stakeholder input is vital in this area with combustible dust incidents that involve deflagrations similiar in explosive severity as flammable gases, liquids, and
vapors.

Below is a brief overview of the timeline for the current OSHA Grain Facility Standard 29 CFR 1910.272 which was formulated over two decades ago in protecting workers from grain dust explosions.

Overview: Rulemaking Process Grain Facilty Standard

• 1977, deaths of 13 USDA inspectors killed in grain elevator explosions prompted USDA to set up a special task force on grain elevator safety and explosions
• 1978 , National Academy of Sciences (NAS) conducted an international symposium on grain elevator explosions. Following the symposium, OSHA requested NAS to establish a Panel on Causes and Prevention of Grain Elevator Explosions
• 1979, a General Accounting Office (GAO) study on grain dust explosions recommended that the U.S. Department of Labor evaluate the adequacy of the coverage for grain elevators in the OSHA general industry standards
• 1980, OSHA published a request for comments and information and notice of public meetings, concerning the safety and health hazards in grain handling facilities
• 1984, OSHA published a Notice of Proposed Rulemaking (NPR)
• 1987, OSHA Grain Handling Facilities Final Rule published
  
• 1988, effective date OSHA Grain Handling Facilities Final Rule
• 1989, a ruling by the Fifth Circuit Court of Appeals, National Grain and Feed Association (NGFA) v. OSHA
• 1990 OSHA issued an ANPRM
• 1996, OSHA amended its Grain Handling Standard
• November 8, 1996, OSHA issued a compliance directive, CPL 2-1.4C, "Inspection of Grain Handling Facilities."

Resources
REGULATORY REVIEW OF OSHA'S GRAIN HANDLING FACILITIES STANDARD 29 CFR 1910.272