Wednesday, March 18, 2009

Dust Explosions-Not Cleared For Public Release

Its a bit odd and bewildering how data of combustible dust explosions in the Chemical Safety Board, Combustible Dust Hazard Investigation Report that was submitted to OSHA in November 2006 did not include the fatalities and injuries such as the incident that occurred at a Reconstituted Wood Product Manufacturing plant in Mount Jewett, PA back in February 2001. How can appropiate layers of protection be implemented in the workplace if stakeholders do not know the probability and severity of occurrences if full transparency of the complex combustible dust issue is not adhered to?

Incident # 190, which occurred 2/14/2001, is listed in the CSB Dust Incident Data File. But the description is omitted with the statement, "Information not cleared for public release. " How can that be, with the vital information not cleared, when adjacent to the date of the incident is the OSHA Activity Number which provides a description of the above incident and many others labeled "not cleared for public release."?

OSHA has been citing facilities for combustible dust hazards many years prior to the series of catastrophic dust explosions that occurred in 2003. These citations referenced the NFPA Combustible Dust Standards utilizing the General Duty Clause. OSHA through national consensus continues to cite facilities for combustible dust hazards with the power of the General Duty Clause.

Subsequently, OSHA needs to thoroughly review CSB's helpful recommendations in addition to instituting other layers of protection that will provide sufficient preventative and mitigative measures for the workplace in regards to combustible dust hazards. It shouldn't take an Act of Congress with the reissued combustible dust bill to get the ball rolling. Hopefully with the new administration and appointees within OSHA's leadership structure the entire combustible dust issue will be reevaluated in proper context.

The first step must be revising the Combustible Dust NEP so as to reflect the reality of the majority of incidents (over 60%) occuring in national industries (NAICS) not listed in the NEP. OSHA Region 4 has set an excellent example inspecting facilities for dust hazards that are not listed in the Dust NEP. A good rule of thumb would be if a facility has a dust collector on the premises, then there is a potential for a combustible dust related explosion or fire. Think of a dust collector as a hand grenade with the pin pulled and all that is needed next is an ignition source when the lever is released. That just might get everyone's attention with this sort of proactive attitude.

No matter how stringent OSHA enforcement and inspection activities are pursued, combustible dust explosions and fires will continue to occur. Legislators who drafted the current reissued combustible dust bill have all the great intentions in preventing further fatalities and injuries as occurred at Imperial Sugar Refinery last year. But the reality which they must be educated to understand is that dust explosions and fires cannot be totally prevented. Only the probability and severity can be reduced.

A good example is the ethanol plant explosion earlier this month in Hastings, Nebraska with the grain grinder explosion resulting in two injuries. Ethanol plants have the most stringent governmental regulations protecting the worker, public ,and environment with the EPA Risk Management Program (RMP), OSHA Process Safety Management Standard (PSM), in addition to the OSHA Grain Facility Standard. It doesn't get any more stringent than this. The current combustible dust bill as written won't even come close to providing this much of protection. Ironically, with all the layers of protection in this industry, it has the highest rate of explosions and fires over the past twelve months than any of the other 426 national industries (NAICS) in the manufacturing sector.

The current position that legislators and the CSB of possible protective measures is a great start. But should not be the sole solution, especially when other important aspects of the very complex and dynamic combustible dust hazard issue is not also addressed to the full extent. Hopefully insight from continued in-depth research on combustible dust related fires and explosions that the Combustible Dust Policy Institute is conducting will provide additional helpful information on a broad horizon useful to all stakeholders.

 

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