Unions Displeasure with CSB, Tip of the Iceberg

Another salvo was fired at the Chemical Safety Board recommendations, for failure to fully address workplace safety by several unions last week in regards to the INDSPEC Chemical Corporation's release of oleum. Earlier union concerns on the deficient CSB accident recommendations following the deadly explosion at the Slim Jim factory in Garner, North Carolina and T2 catastrophic explosion in Jacksonville, Florida is highlighted when a follow-up on lessons learned does not fully address worker health and safety.

The problem is exacerbated as the union voice only represents approximately 12 percent of the nation's workforce. A recent Bureau of Labor Statistics report on union membership illustrates that out of over 15 million American workers in the manufacturing sector only 1,732,000 are represented by the union. So what about the millions of other non-union workers? Who is representing them when governmental agencies do not fully address workplace health and safety issues?

Mike Wright, United Steel Workers, Health Safety and Environmental Director, was putting it mildly when he stated,"The CSB report process is broken." The problem with CSB's findings and recommendations is much more complex. Especially when only a handful of career governmental employees are directing the nation's occupational health and safety policy through their incomplete recommendations to OSHA.

In all fairness the accident investigations that the CSB conducts in determining root cause has provided essential proactive awareness in protecting the worker. Yet without comprehensive recommendations, injuries and fatalities will needlessly continue to occur when many layers of protection are thoughtlessly overlooked.

Severity of Consequence
The most recent example of CSB's full inattention to the human toil was following the Imperial Sugar refinery dust explosion in which 20 workers sustained life threatening burn injuries and were admitted to the Joseph M. Still Burn Unit in Augusta, Georgia. Six of the workers succumbed to their burns due to the high percentage of total burned surface area.

CSB recommendations included best engineering practices and administrative controls but failed to mention personnel protection equipment (PPE) in the donning of flame resistant clothing (FRC) when working in a environment that posed a potential flash fire or explosive environment, as is the case with combustible sugar dust.

None of the injured workers were wearing FRC's, so the flame front from the dust explosion ignited their clothing, which continued to burn as the flame front passed. The United Steelworkers also raised a concern with CSB concerning the INDSPEC oleum release, where personnel protection equipment was not recommended either.

Probability of Occurrence
Has the Chemical Safety Board forgotten to take into account the entire severity of the consequence in these prior incidents? It's just not the severity of consequence that is at issue but also the probability of occurrence in the risk analysis through lessons-learned. For example, the 2006 CSB Dust Hazard Investigation failed to address the thousands of prior combustible dust related fires and explosions that occurred from 1980-2005.

This resulted in an aberration of fatalities and injuries per incident, occurring in combustible dust related fires and explosions in the manufacturing, non-manufacturing, and utility sectors. The incident data that CSB provided to OSHA, the media, and the public, gave the appearance that fatalities and injuries occur at a high ratio per incident, which is grossly inaccurate.

Incomplete Information
This incomplete picture of the complex combustible dust issue became even more volatile following the catastrophic Imperial Sugar Refinery dust explosion when the House Education and Labor Committee held a hearing on combustible dust fire and explosion hazards in the industrial workplace. Shortly thereafter, a combustible dust bill passed in the House but stalled in the Senate.

The CSB Dust Hazard Study provided the public and stakeholders an excellent summary of fire and explosion hazards that combustible dust poses in the workplace. Yet the incident data concerning probability of occurrence was grossly underreported with mention of only 281 incidents in a twenty five year period in addition to stating that fatalities and injuries occur in 70% of incidents, which is not true.

With the appearance that fatalities and injuries were a regular occurrence in combustible dust incidents, Congress was forced to act. Now with the new administration, OSHA is in the rulemaking process, developing a general industry combustible dust standard. So what's next, a flammable gas, liquid, vapor, and mist general industry standard for fire and explosion hazards. I don't think so, as that doesn't make much sense and neither does a separate combustible dust standard.

Process Safety Management Solution
Instead, combustible dust needs to be addressed as a hazard to workers that provides a potentially explosive atmosphere, like flammable gases, vapors, and mists. Already, for nearly two decades, the OSHA Process Safety Management system (PSM) addresses potentially explosive atmospheres for flammable gases, vapors, and mists. A majority of PSM elements are incorporated in the NFPA combustible dust standards. So why reinvent the wheel when occupational health and safety policy already addresses propagating explosions in the industrial workplace?

Could it be that governmental policy makers do not understand that a flame front from a vapor cloud explosion and dust explosion have similar behaviors. For instance, GexCon has developed a successful Flame Acceleration Simulation Code (FLACS), which utilizes computational fluid dynamics in analyzing the severity of consequence of vapor cloud explosions. This same computer code was utilized in the CSB accident investigation of the 2005 BP Texas City Refinery vapor cloud explosion.

Propagating Explosions
In addition to FLACS, GexCon has developed a Dust Explosion Simulation Code (DESC), which is derived from FLACS gas explosion simulations. Both codes utilize a burning velocity model determining the velocity of the flame relative to the reactants and a flame model that controls the localization and area of the flame. Vapor cloud and dust explosions are propagating explosions that have similiar characteristics of laminar and turbulent flow in their flame fronts. There is much more fascinating science behind this simple explanation and additional information can be found on the GexCon link

Conclusion
The important point here is that a dust explosion is a propagating explosion like a vapor cloud explosion and a separate OSHA combustible dust standard is unnecessary. Already protective and mitigative measures are in place within the OSHA regulatory framework with PSM. All that is needed now is to develop a hybrid PSM for combustible dust fire and explosion hazards. It is much easier for governmental policy makers to develop a separate OSHA combustible dust standard rather than critically analyzing the dynamics of combustible dust related fires and explosions, which are propagating just like vapor cloud explosions.

This alternative solution of combustible dust included in PSM is easier said than done as the damage has already been done with the preponderance of misinformation that's already been portrayed in the media and governmental press releases that all dust explosions can be prevented, fatality/injuries having a high occurrence in combustible dust incidents, and OSHA is at fault for prior inaction, all which are false.

The union's suggestion in their recent media advisory that the public, workers, and industry stakeholders be allowed to participate in the CSB investigation and recommendation process might just be one solution in getting the house in order so as to reduce the probability and minimize the severity of future accidents in the nation's workplace. Yet the problem runs much deeper than that, with the limited budget that the Chemical Safety Board has to work with. Especially with the heavy workload and understaffing investigating industry accidents with limited resources.