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.

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