Thursday, May 28, 2009

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.

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?


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