Let's do a case study on All-Feed Processing and Packaging Inc as it relates to new growing and changing OSHA standards
Galva Illinois Production Plant
First focus - "if it can happen to me it can / will happen to you" which of the regulations are common to us all.
Second focus - what is the chance for compliance and what would TOTAL compliance look like.
Join in on the discussion in the Combustible Dust Policy Institute group.
Resources
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=16665
Interesting topic. Sort of a coincidence. Just recently heard a interesting story from a facility owner where OSHA combustible dust enforcement/inspection activities is stronger in one OSHA state plan state in contrast to weak in another state plan state across state lines. So Facility A is implementing costly best engineering practices to manage the combustible dust fire and explosion risk. Whereas Facility B, across state lines has minimal layers of protection.
This is all sort of like Déjà vu, when last year with a post on this subject," State Dust Emphasis Programs Voluntary," in regards to addressing combustible dust hazards.
Adoption ComDust NEP State Plan States
With the recent posting in the Federal Register of the OSHA combustible dust proposed ruling ANPRM, the complex subject of combustible dust has come to the forefront as a workplace health and safety issue. I encourage all stakeholders to join the Combustible Dust Policy Institute Group discussions where many topics concerning managing the risk are discussed amongst business owners and fire/explosion safety experts. Your input in the discussions is extremely valuable in providing a framework of general consensus so as to develop comprehensive input during the OSHA ComDust ANPRM comment period.
The group is open to everyone and all ComDust group members look forward to your input. Thanks
OSHA Underground
http://www.oshaunderground.blogspot.com/
Published by a group of health and safety industry experts
Written by five health and safety industry insiders, OSHA Underground is the “virtual watercooler” for all things OSHA. The bloggers don’t hold back on what they think about proposed regulations, safety violations, hazardous conditions, the failures of OSHA, and more.
Immediately following the preliminary release of the OSHA combustible dust Advanced Notice of Proposed Rulemaking (ANPRM) it became apparent that the issue would be contentious issue between opponents and proponents of the proposed combustible dust regulation. This was most evident with U. S. Labor Secretary, Hilda L. Solis's statement, "It's time for workers to stop dying in preventable combustible dust explosions."
The problem is, that no matter how stringent or how many regulations are implemented, primary dust explosions will continue to occur. Only the probability and severity is reduced. I believe what the Secretary meant to say, "It's time for workers to stop dying in preventable secondary combustible dust explosions."
Secondary Dust Explosions
Secondary devastating dust explosions are preventable when the fuel load is removed through good housekeeping as outlined in the OSHA general industry regulations. All the catastrophic dust explosions that the Chemical Safety Board has investigated were attributed to poor housekeeping where the pressure wave from the primary explosion suspended dust resting on horizontal surfaces into the path of the following flame/reaction front (fireball).
In contrast, implementing best engineering practices as referenced in the NFPA combustible dust standards will minimize the occurrence and reduce the severity of consequence of primary explosions. Without best engineering practices, there is the potential for injuries, fatalities, and economic damage adjacent to the process equipment from primary explosions. Yet no where near the magnitude of a secondary explosion where the entire facility experiences horrific structural integrity damage in addition to a terrible breach of life safety.
OSH Act
In regards to the proposed regulation that the Chemical Safety Board recommended to OSHA as a result of the 2006 CSB Dust Hazard Investigation. The OSH Act requires that before promulgating any occupational standard, OSHA must demonstrate based on substantial evidence in the record as a whole that the proposed standard will substantially reduce a significant risk of material harm. Well if good housekeeping that is already referenced in the OSHA general industry standards is followed then the significant risk of material harm would be substantially reduced.
So why a separate combustible dust standard for preventing catastrophic dust explosions, when the fuel load is removed according to good housekeeping? All the best engineering practices in the world as outlined in the NFPA combustible dust standards are irrelevant if the facility has layers of combustible dust waiting for a process upset and ignition source.
The Facts Please
It doesn't seem to matter anymore if critical analysis is entered into the equation for an equitable solution between labor and business interests. The line was drawn in the sand with the OSHA News Release this past April which stated, "since 1980 more than 130 workers have been killed and more than 780 injured in combustible dust explosions." Not true.
For example, in the CSB Dust Hazard Study, the data indicated that the injuries and fatalities were attributed to combustible dust fires and explosions, not solely explosions. Severe burn injuries from the fireball of a dust fire or dust explosion have severe consequences. I don't know why the combustible dust related fires are being ignored. Especially when over 80% of incidents in 2008 were fires.
Acknowledge Explosive Atmosphere
Between the mainstream media following the lead with inaccurate data from governmental press releases in conjunction with statements from political appointees, one would think the entire manufacturing sector is going up in smoke with mass casualties from dust explosions. This is not the case and totally opposite from the facts.
Any loss of life or injury from a workplace accident is one to many. But there must be some balance into how much industry is to be regulated with special regulations. When already many OSHA general industry regulations are in place and all that is needed is a revision with the wording "combustible dust." and the acknowledgment that combustible dust poses an potentially explosive atmosphere.
More than About Dust
Initially when I started the ComDust research project 20 months ago it was solely about dust. But now it has evolved into more than that. With questions arising, in how can incomplete governmental data and inaccurate press releases be utilized in formulating public opinion through the mainstream media?
But if governmental agencies can do it with combustible dust issue then it can be done with more pressing issues that effects millions of Americans. It's been an interesting and fascinating lesson in how governmental policy is formulated. Combustible dust really doesn't even come up on the radar with the myriad of other issues that effect a majority of Americans more directly on a daily basis.
I still have a firm belief in President Abraham Lincoln's view as he stated in the November 19, 1863, Gettysburg Address, "...and that government of the people, by the people, for the people..." I guess what President Lincoln was trying to get across is that we are the government and the government is us. It hasn't seemed that way for a long time in Washington D.C., with the Republicans pitted against the Democrats with a winner take all scenario in a majority of issues. In contrast to a consensus with a half way point were each party gives away a few concessions in order to come to an equitable solution.
Bitter Feud
In the case of the proposed combustible dust regulation, I don't see any half way point. It will be contentious bitter feud between labor and business interests. Sound critical analysis of managing significant risk will go to the wayside. This is evident already from the sparse Republican agreement with the ComDust bill that was passed in the House of Representatives last year to the recent public statements by the Department of Labor that they will give no quarter to business interests.
I can't take sides with either group since my main interest is providing and sharing with stakeholders a proactive situational awareness on combustible dust related fire and explosion hazards in the workplace. In the meantime, it's been an interesting lesson in government 101.
A recent dust explosion at a wood pellet mill in Germany drives home the point that global collaboration concerning combustible dust fires and explosion hazards in the workplace must be a central theme in managing the risk. Without the knowledge of probability of occurrence, a comprehensive process hazard analysis cannot be developed. The problem is in obtaining the incident data. Solely relying on news accounts will not provide global coverage. Especially when all global ComDust incidents are not reported as such.
A good start would be for the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals to network with their prospective local professional associations, trade organizations, and governmental agencies. A network would enable stakeholders to share incident data, which could assist in managing the risk.
The recent OSHA ComDust ANPRM is an excellent example in obtaining an understanding of probability of occurrence, where in Table 1, national industries were listed that had previous combustible dust related fires and explosions. On an international perspective many manufacturing processes have similar process situations and process conditions. So just because a ComDust incident has not yet happened in one geographic region does not mean it will not happen in another global region with a similar manufacturing process.
A good example, are recent combustible dust explosions in Germany wood pellet mill and the earlier sugar silo explosion. Global manufacturers have similiar processes, which also includes the United States. OSHA in addition to acquiring information on probability of occurrence in the USA, which was illustrated in Table 1 of the combustible dust ANPRM, should also be aware of the global perspective. This global proactive situational awareness will assist all stakeholders in the proposed combustible dust rulemaking.
Dust explosion happened in Germany but it just as well could have occurred anywhere else. It's extremely important to understand that collecting data on global combustible dust related fires and explosions assists immensely in understanding the probability of occurrence and severity of consequence. Through lessons-learned, global trading partners can share information in the prevention and mitigation of future incidents in similar national industries.
OSHA did a great job in the preparation of the recent ANPRM proposed combustible dust rulemaking document in the introduction section, providing Table 1 illustrating national industries with a discernible probability of occurrence. Collecting incident data over a period of time assists in risk analysis. Especially in observing trends where incidents are occuring in specific national industries.
Last year, immediately after the Imperial Sugar incident I began collecting data from news accounts of combustible dust related fires and explosions in the United States. Subsequently, a week before the first combustible dust hearing was held by the House Committee on Education and Labor on March 12, 2008, over a dozen combustible dust related fires and explosions had occurred in the manufacturing sector, since the previous Imperial Sugar incident. The numbers just didn't add up? Especially with the CSB Dust Hazard Study reporting an average of 12 incidents annually.
Thinking geez, this is something that could help provide an enhanced awareness on the volatile subject. I eagerly contacted the House Committee on Education and Labor and offered to share this important incident data. Well things didn't work out. A staff member informed me that the the data couldn't be used at the Combustible Dust hearing , as congressional committee members would not find it acceptable, since it was coming from some guy in Texas on his computer. After hanging up the phone, the Combustible Dust Policy Institute went into action.
I'd like to thank the many friendships developed spanning the globe in supporting my combustible dust incident research efforts. Without your enthusiastic encouragement I don't think it would of been possible to continue such an endeavor with such intensity. Many times working 24-36 hours at a time in conjunction with 12 hour shifts with my regular job. Sort of a Dr. Jekyll/Mr. Hyde existence.
It's odd, nowadays unless one is represented by a million dollar lobby firm on K Street, then the voice of the average blue collar American working Joe on the street is worthless. That's the way things stand today in Washington, D.C. But the paradigm has changed. With the power of the Internet, one has the resources at hand as any Fortune 500 Corporation.. All it takes from there is a deep desire to seek the truth in what is reality in contrast to sometimes questionable governmental data and commercial mainstream media.
I encourage all Americans to go behind the scenes, like Toto did in the Wizard of Oz and pull the curtain back while the Wizard pulls the levers. Combustible dust is just a drop in the bucket in comparison to the myriad of social-economic issues that confront Americans, in which Congress and governmental agencies debate on a daily basis. Pick an issue that interests you and then go for it, researching topics that you hear about in the news.
Many news reports are solely commentary with supposedly facts and figures obtained from governmental press releases. After a few weeks of research, you just might find that the data in the governmental reports and mainstream media might not quite be reality. But once you do obtain information, start writing about the results of your research to share with others with similiar interests. Be sure to include hyperlinks of your sources in your content, so readers can obtain a fuller understanding of the subject.
Now with Web 2.0, utilizing Blogs, Twitter, Facebook, Linkedin, etc your story is effortlessly shared across international borders. Just remember content is king. So the more you post, the more the Google spider will find in keywords that will appear when potential visitors are seeking information on the subject in their searches.
In regards to occupational health and safety I'm certain that the future in achieving a safe workplace throughout industry in a comprehensive manner can be enhanced immensely utilizing all the resources that the Internet offers. I'd like to thank my good friend Xavier De Gea, Director en LPG Prevención y protección Explosiones from Barcelona, Spain for sharing the recent sugar dust explosion news account, which assists in providing a global awareness of a very complex subject.
Resources
News Article/Dust Explosion -German version
Photo Credit (Photo: Torben Liedtke) to the photo gallery
https://docs.google.com/fileview?id=0BwXCwzOQ_F0wYTc1YmJmZTMtN2FhNC00YzNlLTk2NTgtOWQyNjJhNGQ1YjFh&hl=en
Here is link to the OSHA ANPRM (15 pages) on combustible dust that was published in the Federal Register today. There are some excellent points on accident investigation and fire-fighter hazard awareness, which seeks public comment in addition to many other important issues.
With the OSHA combustible dust regulation Advance Noticed of Proposed Rulemaking (ANPRM) due to be published in the Federal Register any day now,(tomorrow?) many stakeholders are eager to provide comments in the rulemaking process. Initially, immediately after the dust explosion at Imperial Sugar Refinery in Port Wentworth, Georgia many were ready to place blame including myself. But after a cooling down period of a few weeks analyzing the situation it became readily apparent the combustible dust issue was a very complex topic.
It was the catastrophic Imperial Sugar explosion that galvanized Congress, the media, OSHA, and many other stakeholders into action. Sort of like the 9/11 of occupational health and safety. But instead of a threat from outside, the threat upon the nation’s manufacturing workforce was inside with insidious combustible dust.
The Chemical Safety Board became a major player in the accident investigation. Two years earlier, the CSB an independent governmental agency completed an informative Dust Hazard Study investigation in 2006 on combustible dust related fires and explosions in the industrial sector, following a series of dust explosions in 2003.
Many of the key recommendations that CSB presented in the 118 page report have already moved forward. Such as combustible dust hazard awareness training at the OSHA Training Institute (OTI), a Combustible Dust NEP, communicate to the United Nations the need to amend the Globally Harmonized System (GHS) to address combustible dust hazards, and issue a combustible dust standard based on the NFPA combustible dust standards. The most important recommendation and most misunderstood and overlooked is to revise the OSHA Hazard Communication Standard (HCS) (1910.1200) in the prevention and mitigation of fire and explosion hazards that combustible dust presents in the nations’ workplace.
Material Safety Data Sheets
Hazard communication through the utilization of Material Safety Data Sheets (MSDS) in providing the workforce with vital information on the ignition sensitivity and explosion severity of combustible dust is crucial in managing the risk. Without specific information on the fire and explosion physical properties of combustible dust, workers and plant management are at risk in inadvertently providing an ignition source in completing the fire triangle or explosion pentagon.
During the research that CSB conducted for the Dust Hazard Study they discovered after reviewing 140 MSDS’s across a wide spectrum of industry that none of the data sheets had the physical properties of ignition sensitivity and explosion severity (physical data parameters, such as Kst MIE, MEC, and MIT). Oh really? Well that should not come as a big surprise since the raw product manufacturers who prepares the MSDS’s usually have no idea of the specific process conditions or situations that reconstitute their raw product during the manufacturing process into final products that also generates combustible (explosive) dust.
Pertinent Legal Authority
In the recent OSHA Hazard Communication Proposed Rule concerning global harmonization there is quite an interesting discourse on the subject in the section VI. Pertinent Legal Authority.
“chemical manufacturers and importers tend to have greater knowledge and scientific expertise with respect to the composition of the chemicals they make or import. See 48 FR 53306, 53322. Therefore, they are usually in the best position to assess the inherent hazards associated with them.”
How can upstream raw product manufacturers in the life-cycle be in a better position to know the particle size distribution, particle size, moisture content, etc in determining the explosion severity and ignition sensitivity in managing the risk? But then immediately after that position statement a conflicting view.
“However, it is the downstream users and their employees who tend to have the best information about the means and methods of exposure, and are therefore usually in the best position to determine the risk arising from the use of the chemical in their workplaces. See 48 FR 53295–96, 53307; 59 FR 6132”
So which is it? The raw product manufacturers or the downstream users in the best position in providing the essential physical properties of probability of occurrence and severity of consequence in the MSDS’s? Now it all makes sense that 80% of combustible dust incidents that occurred in 2008, according to media accounts were combustible dust related fires. The majority of downstream users had no idea of the ignition sensitivity and they still don’t.
Warm and Fuzzy Feeling
So an OSHA combustible dust standard is going to make things all warm and fuzzy? A quick fix? Sure it’s much easier to implement a regulation; after all we don’t have enough regulations inundating the business community already. The steeper road to follow would be to fix the broken OSHA Hazard Communication Standard, the heart of the problem in identifying, evaluating, and communicating the risk.
It’s troubling that the OSHA combustible dust standard rulemaking process is based on the Chemical Safety Board’s 2006 Dust Hazard investigation, which does not provide policy makers with all the facts. Another excerpt from VI. Pertinent Legal Authority, states:
Development of a combustible dust standard under the OSH Act should be based upon research, demonstrations, experiments, and such other information as may be appropriate. In addition to the attainment of the highest degree of health and safety protection for the employee, other considerations shall be the latest available scientific data in the field, the feasibility of standards, and experience gained under this and other health and safety laws. Whenever practicable, the standard promulgated shall be expressed in terms of objective criteria and of the performance desired. 29 U.S.C. 655(b)(5).
The data from research that the CSB presented to OSHA is incomplete and does not take into account a full risk analysis of probability of occurrence and severity of consequence throughout the manufacturing sector For example, up to the week prior to the March 12, 2008 congressional committee hearing on combustible dust, over a dozen combustible dust related fires and explosions occurred in the four weeks immediately after the February 7, 2008, Imperial Sugar dust explosion. Yet the CSB Dust Hazard Study stated in the incident data, which they provided to OSHA, Congress, media, and the public, an average of 12 combustible dust incidents annually occurred from 1980-2005, or 281 total.
OSHA ComDust Enforcement Activity
It seems every other week; we read another media account of OSHA combustible dust enforcement and inspections activities that includes costly citations that an employer received due to combustible dust hazards. So will an OSHA combustible dust standard make things better and remedy the significant risk with even more combustible dust citations? Again referring to the proposed HAZCOM rule section in the Federal Register: VI. Pertinent Legal Authority
Where, however, OSHA is confronted with two feasible methods of reducing risk to the appropriate level, OSHA must chose the cheaper method. Id. at 513 n.32; International Union, UAW v. OSHA, 37 F.3d 665, 668 (D.C. Cir. 1994).
Conclusion
Addressing the deficiencies in the current HAZCOM standard would be more appropriate in addition to more feasible. Doesn’t make sense to put the cart before the horse when the hazards have yet to acknowledged in the MSDS’s. It’s a revised OSHA Hazard Communication Standard that is needed not a combustible dust standard. No one was demanding an OSHA flammable gas, liquid, and vapor standard after the nearly two dozen such incidents that CSB has investigated since 2003.
Resources
Flammable Liquid and Gas Fires/Explosions since 2003-CSB
http://www.inmaricopa.com/NEWS/NewsArticleDetails.aspx?ArticleID=6798&&mid1=390
Early morning fire and explosion at Pinal Energy ethanol plant. This is an excellent example of NFPA combustible dust standards best engineering practices minimizing the severity of consequence of combustible dust related fires and explosions. In reality, combustible dust explosions cannot be totally prevented, only the probability of occurrence reduced and the severity of consequence minimized.
In the global workplace, identifying and evaluating the risk from combustible dust related fires and explosions supposedly begin with the information provided on Safety Data or Material Safety Data Sheets (SDS/MSDS). These essential documents provide essential hazard identification, information on ingredients, first aid measures, fire-fighting procedures, handling and storage information, exposure controls/personnel protection, physical and chemical properties, etc.
Yet vital combustible dust physical characteristics of ignition sensitivity and explosion severity is lacking in a majority SDS’s. So how do stakeholders manage the risk in the workplace if important fire and explosion data is lacking?
Physical Fire and Explosion Hazards
An important development in hazard communication amongst international trading partners is the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This system provides a universal method of communicating the potential health and physical hazards that chemicals pose in the workplace, during transportation, or consumer usage of chemical products. Yet unfortunately, harmonization in communicating the physical and chemical hazards of combustible dust is also deficient in the newly implemented United Nations GHS.
Additionally a major problem arises with materials that are not chemicals, such as wood, paper, food, etc that are not included in the GHS Safety Data Sheet hazard communication protocol. How are the physical hazards of potential combustible dust related fire and explosions suppose to be communicated to the workplace from these non-chemical substances? The problem is intensified with the requirement that the raw product manufacturer or importer must provide the physical property data in the initial preparation of the SDS.
Life-cycle Hazard Awareness
This is great at the initial stage of a raw product’s lifecycle. But what about later on in the life-cycle when a product manufacturer utilizes the raw product in the production process? The production process handles the combustible particulate solid and generates combustible dust in operations such as cutting, grinding, polishing, crushing, conveying, mixing, sifting or screening of materials.
Now all of a sudden the physical properties have changed from a raw bulk product with a minimal hazard to a substance that provides a potentially explosive atmosphere under the right conditions. All that is needed for a dust explosion in addition to the basic fire triangle is a rendezvous with confinement and suspension .Understanding the parameters to initiate a combustible dust flash fire or dust explosion is where the SDS should come into the picture in managing the fire and explosion risk, but unfortunately does not.
Global Harmonization Deficiency
Back in April 2009, the USA Occupational Health and Safety Administration (OSHA) submitted a working document to the United Nations Committee of Experts on the Transport of Dangerous Goods on the Globally Harmonized System of Classification and Labeling of Chemicals. The document requested that the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling form a conference committee in developing classification criteria for combustible dusts in the Safety Data Sheets.
Currently GHS recognizes combustible dust is a hazard by identifying dust in the SDS. Solely identifying is not sufficient enough. The global workplace needs additional information such as guidance in fire-fighting measures, exposure controls/personnel protection, handling/storage, physical and chemical properties, etc.
Explosive Atmospheres
Additionally combustible dust needs to be classified like flammable liquids and gases, which also can present an explosive atmosphere in the global workplace. In the EU, the ATEX Directives (Appareils destinés à être utilisés en ATmosphères EXplosibles) already recognizes the explosive nature of combustible dust that have the same explosive severity as vapor cloud explosions. Yet communicating the risk amongst international trading partners is another story through the GHS Safety Data Sheets.
In the United States recognition of the fire and explosion hazards from combustible dust that have the potential of an explosive atmosphere is not on the same level of awareness as the ATEX Directives in the EU. Currently in the USA, there is no occupational health and safety regulation that specifically references combustible dust in the industrial setting. In contrast there is an OSHA Grain Facility Standard that was implemented back in the 1980’s that addresses combustible dust hazards in grain mills, feed mills, etc.
Rulemaking Process
Following the catastrophic 2008 Imperial Sugar Refinery dust explosion in Port Wentworth, Georgia OSHA began taking enhanced measures in addressing combustible dust in the manufacturing workplace. Currently OSHA is in a general industry combustible dust rulemaking process. An undisclosed source says that OSHA will announce next week in the Federal Register the Advanced Notice of Proposed Rulemaking (ANPRM) where stakeholders can comment in the development of the proposed general industry regulation.
On another front, concerning hazard communication, OSHA is proposing to modify its existing Hazard Communication Standard (HCS) that includes Materiel Safety Data Sheets to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Two weeks ago OSHA issued its proposed rule in the Federal Register concerning harmonization of its current Hazardous Communication System with GHS and will seek comments from stakeholders for a ninety day period.
In addition to proposing to the United Nations committee that combustible dust be classified in the GHS Safety Data Sheets its also seeking comments from stakeholders in the USA whether the interim coverage of combustible dust as an unclassified hazard in the GHS SDS is sufficient in communicating the risk throughout the workplace. Hopefully stakeholders will provide OSHA with a plethora of comments on this very complex issue of combustible dust related fires and explosion in the industrial workplace.
Conclusion
Presently all global manufacturing facilities are at risk with the deficient ignition sensitivity and explosion severity information not included in the Safety Data and Material Data Sheets. The only alternative in properly managing the risk proactively would be for plant owners and managers to have their combustible dust tested for minimum ignition temperature (MIT), minimum ignition energy (MIE), minimum explosive concentration (MEC), explosion severity, volume resistivity, etc. Solely relying on physical fire and explosion hazard data in the SDS or MSDS that the raw product manufacturer or importer provided at the top of the lifecycle is an accident waiting to happen.
Resources
Classification and Labeling of Chemicals (GHS).
ATEX directive
Hazard Communication Guidance ComDust
OSHA HazCom Proposed Rule GHS
Another salvo was fired at the Chemical Safety Board recommendations, for failure to fully address workplace safety by several unions last week in regards to the INDSPEC Chemical Corporation's release of oleum. Earlier union concerns on the deficient CSB accident recommendations following the deadly explosion at the Slim Jim factory in Garner, North Carolina and T2 catastrophic explosion in Jacksonville, Florida is highlighted when a follow-up on lessons learned does not fully address worker health and safety.
The problem is exacerbated as the union voice only represents approximately 12 percent of the nation's workforce. A recent Bureau of Labor Statistics report on union membership illustrates that out of over 15 million American workers in the manufacturing sector only 1,732,000 are represented by the union. So what about the millions of other non-union workers? Who is representing them when governmental agencies do not fully address workplace health and safety issues?
Mike Wright, United Steel Workers, Health Safety and Environmental Director, was putting it mildly when he stated,"The CSB report process is broken." The problem with CSB's findings and recommendations is much more complex. Especially when only a handful of career governmental employees are directing the nation's occupational health and safety policy through their incomplete recommendations to OSHA.
In all fairness the accident investigations that the CSB conducts in determining root cause has provided essential proactive awareness in protecting the worker. Yet without comprehensive recommendations, injuries and fatalities will needlessly continue to occur when many layers of protection are thoughtlessly overlooked.
Severity of Consequence
The most recent example of CSB's full inattention to the human toil was following the Imperial Sugar refinery dust explosion in which 20 workers sustained life threatening burn injuries and were admitted to the Joseph M. Still Burn Unit in Augusta, Georgia. Six of the workers succumbed to their burns due to the high percentage of total burned surface area.
CSB recommendations included best engineering practices and administrative controls but failed to mention personnel protection equipment (PPE) in the donning of flame resistant clothing (FRC) when working in a environment that posed a potential flash fire or explosive environment, as is the case with combustible sugar dust.
None of the injured workers were wearing FRC's, so the flame front from the dust explosion ignited their clothing, which continued to burn as the flame front passed. The United Steelworkers also raised a concern with CSB concerning the INDSPEC oleum release, where personnel protection equipment was not recommended either.
Probability of Occurrence
Has the Chemical Safety Board forgotten to take into account the entire severity of the consequence in these prior incidents? It's just not the severity of consequence that is at issue but also the probability of occurrence in the risk analysis through lessons-learned. For example, the 2006 CSB Dust Hazard Investigation failed to address the thousands of prior combustible dust related fires and explosions that occurred from 1980-2005.
This resulted in an aberration of fatalities and injuries per incident, occurring in combustible dust related fires and explosions in the manufacturing, non-manufacturing, and utility sectors. The incident data that CSB provided to OSHA, the media, and the public, gave the appearance that fatalities and injuries occur at a high ratio per incident, which is grossly inaccurate.
Incomplete Information
This incomplete picture of the complex combustible dust issue became even more volatile following the catastrophic Imperial Sugar Refinery dust explosion when the House Education and Labor Committee held a hearing on combustible dust fire and explosion hazards in the industrial workplace. Shortly thereafter, a combustible dust bill passed in the House but stalled in the Senate.
The CSB Dust Hazard Study provided the public and stakeholders an excellent summary of fire and explosion hazards that combustible dust poses in the workplace. Yet the incident data concerning probability of occurrence was grossly underreported with mention of only 281 incidents in a twenty five year period in addition to stating that fatalities and injuries occur in 70% of incidents, which is not true.
With the appearance that fatalities and injuries were a regular occurrence in combustible dust incidents, Congress was forced to act. Now with the new administration, OSHA is in the rulemaking process, developing a general industry combustible dust standard. So what's next, a flammable gas, liquid, vapor, and mist general industry standard for fire and explosion hazards. I don't think so, as that doesn't make much sense and neither does a separate combustible dust standard.
Process Safety Management Solution
Instead, combustible dust needs to be addressed as a hazard to workers that provides a potentially explosive atmosphere, like flammable gases, vapors, and mists. Already, for nearly two decades, the OSHA Process Safety Management system (PSM) addresses potentially explosive atmospheres for flammable gases, vapors, and mists. A majority of PSM elements are incorporated in the NFPA combustible dust standards. So why reinvent the wheel when occupational health and safety policy already addresses propagating explosions in the industrial workplace?
Could it be that governmental policy makers do not understand that a flame front from a vapor cloud explosion and dust explosion have similar behaviors. For instance, GexCon has developed a successful Flame Acceleration Simulation Code (FLACS), which utilizes computational fluid dynamics in analyzing the severity of consequence of vapor cloud explosions. This same computer code was utilized in the CSB accident investigation of the 2005 BP Texas City Refinery vapor cloud explosion.
Propagating Explosions
In addition to FLACS, GexCon has developed a Dust Explosion Simulation Code (DESC), which is derived from FLACS gas explosion simulations. Both codes utilize a burning velocity model determining the velocity of the flame relative to the reactants and a flame model that controls the localization and area of the flame. Vapor cloud and dust explosions are propagating explosions that have similiar characteristics of laminar and turbulent flow in their flame fronts. There is much more fascinating science behind this simple explanation and additional information can be found on the GexCon link
Conclusion
The important point here is that a dust explosion is a propagating explosion like a vapor cloud explosion and a separate OSHA combustible dust standard is unnecessary. Already protective and mitigative measures are in place within the OSHA regulatory framework with PSM. All that is needed now is to develop a hybrid PSM for combustible dust fire and explosion hazards. It is much easier for governmental policy makers to develop a separate OSHA combustible dust standard rather than critically analyzing the dynamics of combustible dust related fires and explosions, which are propagating just like vapor cloud explosions.
This alternative solution of combustible dust included in PSM is easier said than done as the damage has already been done with the preponderance of misinformation that's already been portrayed in the media and governmental press releases that all dust explosions can be prevented, fatality/injuries having a high occurrence in combustible dust incidents, and OSHA is at fault for prior inaction, all which are false.
The union's suggestion in their recent media advisory that the public, workers, and industry stakeholders be allowed to participate in the CSB investigation and recommendation process might just be one solution in getting the house in order so as to reduce the probability and minimize the severity of future accidents in the nation's workplace. Yet the problem runs much deeper than that, with the limited budget that the Chemical Safety Board has to work with. Especially with the heavy workload and understaffing investigating industry accidents with limited resources.
Stakeholders in the manufacturing, non-manufacturing, and utility sectors are eagerly awaiting OSHA’s Advanced Notice of Proposed Rulemaking (ANPRM) in the Federal Register. Following the Chemical Safety Board’s recent key findings and recommendations on the Imperial Sugar Refinery dust explosion, OSHA submitted the combustible dust regulation for review to the Office of Management and Budget, a Cabinet-level office within the Executive Office of the President of the
A diverse spectrum of the manufacturing sector attended a public hearing last week at the Fire Commissioners Hearing Room in
Since the Imperial Sugar Refinery explosion, stakeholders have worked closely with Georgia Insurance and Safety Fire Commissioner, John Oxendine, in developing a combustible dust regulation that will provide appropriate layers of protection in minimizing the probability and reducing the severity of future combustible dust related fires and explosions.
In contrast, a point of contention does arise within the manufacturing sector concerning the feasibility of a regulation during the nation’s economic recession. For instance, costly best engineering practices for combustible dust fire and explosion hazards is not required amongst many global trading partners and many argue this would result in a competitive disadvantage for
The Combustible Dust Policy Institute proposes a possible solution in alleviating economic concerns. This would initially include administrative control measures and safe working practices that would not put small businesses at a global competitive disadvantage.
For example, good housekeeping (CSB recommendation), OSHA hazard communication training, contractor participation (PSM), explosion protection documents (ATEX) and accident investigation (PSM) protocol would minimize the severity and likelihood of future incidents immensely.
Essential but costly, best engineering practices and inherent safety design, phased in over a period of several years in conjunction with the global economy rebounding is a viable option that needs further discussion. An excellent example of a phase-in- period occurred with the EU ATEX directives for potentially explosive atmospheres in the workplace.
In this podcast segment, Jeff Romine, a Corporate Safety Director for national flooring manufacturer, attended the
Mr. Romine has over 20 years of experience in consultation, auditing, safety, education and insurance, and is a Certified Safety Professional (CSP), Certified Professional Environmental Auditor (CPEA), and OSHA Outreach General Industry Trainer. Mr. Romine is currently serving as a Senior Corporate Safety Manager in the Risk Management Department for Shaw Industries one of the leading flooring manufactures in the
Resources
Mark-up Georgia Combustible Dust Regulation 120-3-24-0.14
Georgia Emergency Regulation 120-3-24-0.12
With the recent Chemical Safety Board accident investigation recommendations following the Imperial Sugar Refinery explosion, stakeholders in the manufacturing sector are even more pressed in addressing combustible dust hazards in the workplace. One of the five key recommendations was for stakeholders to develop training materials for employees and contractors on the hazards of combustible dust. That is easier said than done. There have been several excellent combustible dust training programs developed through the Susan Harwood Training Grant over the last two years.
The problem is gaining access to this safety training material that the taxpayers have already paid for. In contrast, the training videos on combustible dust that the North American Die Casting Association produced through the Susan Harwood Grant is easily accessible for free on YouTube. So far, haven't been so lucky on the web in viewing the training materials on combustible dust hazards that Georgia Tech Research Institute, Kirkwood Community College, and the Texas Engineering Extension Service developed from over $500, 000 in grant money through the 2008 Susan Harwood Program.
Training is definitely needed on combustible dust hazards in the workplace there is no arguing that. Over $448,000 was awarded to two recipients in 2009 to also develop combustible dust safety training. So how many times do we need to develop combustible dust safety training? Wouldn't once be enough? Seems like the combustible dust safety videos that the North American Die Casting Association has available for free is the direction that combustible dust hazard awareness program should be going. But what the heck if you got an extra couple $100, 000 in the kitty, then let's spread the love. Who said the nation was in the worst recession since the Great Depression?
Turning up stones always seems to get me in trouble, especially when I end up with more questions than answers. Sort of like when the CSB reported in their 2006 Combustible Dust Hazard Study that there was 281 combustible dust incidents from 1980-2005 or on an average 12/annually. Yet in 2008, after over a thousand hours of research I discovered in media reports over 150 ComDust incidents in the manufacturing, non-manufacturing and utility sectors. If only the CSB would have provided the disclaimer in their press releases concerning incident data, then the media, legislators, stakeholders, the public, and OSHA would have had a better idea of the complexity of the combustible dust issue.
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