Wednesday, May 13, 2009

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fires and explosions in 2008, though media accounts, occurred in national industires (NAICS), not referenced in this outdated NEP.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.

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


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)
alaska_avo (Mount Redoubt Volcano Updates)
Everything Twitter


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