Saturday, October 10, 2009

Georgia Combustible Dust Regulation

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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 United States. On a state level and moving much faster than Federal actions, Georgia recently held a public hearing for their combustible dust regulation.

A diverse spectrum of the manufacturing sector attended a public hearing last week at the Fire Commissioners Hearing Room in Atlanta, Georgia where they submitted final comments to the Administrative Law Judge for consideration. Representatives of Georgia’s manufacturing sector are not opposed to fire and explosion safety in the workplace and have been working tirelessly with the Commissioners office in developing a consensus.

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 Georgia businesses.

Georgia’s combustible dust rulemaking process has national significance in that stakeholders across a diverse spectrum of state manufacturing subsectors are also representative on a larger scale of national manufacturing subsectors. So could the comments and input to Georgia government officials be a precursor to future comments in the upcoming federal action during the OSHA combustible dust rulemaking process?

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 Georgia public hearing on combustible dust and shares with listeners a first hand perspective of industry concerns that were presented to the Administrative Law Judge. These same concerns have a national significance in the Federal OSHA combustible dust rulemaking.

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 United States, a Berkshire Hathaway Company. He lives in Ringgold GA with his wife Cindy, daughter Katie (Senior at the University of GA) and son Alex aka “AJ” (freshman at Oglethorpe University)


Mark-up Georgia Combustible Dust Regulation 120-3-24-0.14
Georgia Emergency Regulation 120-3-24-0.12

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