Probability of Occurrence

A recent dust explosion at a wood pellet mill in Germany drives home the point that global collaboration concerning combustible dust fires and explosion hazards in the workplace must be a central theme in managing the risk. Without the knowledge of probability of occurrence, a comprehensive process hazard analysis cannot be developed. The problem is in obtaining the incident data. Solely relying on news accounts will not provide global coverage. Especially when all global ComDust incidents are not reported as such.

A good start would be for the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals to network with their prospective local professional associations, trade organizations, and governmental agencies. A network would enable stakeholders to share incident data, which could assist in managing the risk.

The recent OSHA ComDust ANPRM is an excellent example in obtaining an understanding of probability of occurrence, where in Table 1, national industries were listed that had previous combustible dust related fires and explosions. On an international perspective many manufacturing processes have similar process situations and process conditions. So just because a ComDust incident has not yet happened in one geographic region does not mean it will not happen in another global region with a similar manufacturing process.

A good example, are recent combustible dust explosions in Germany wood pellet mill and the earlier sugar silo explosion. Global manufacturers have similiar processes, which also includes the United States. OSHA in addition to acquiring information on probability of occurrence in the USA, which was illustrated in Table 1 of the combustible dust ANPRM, should also be aware of the global perspective. This global proactive situational awareness will assist all stakeholders in the proposed combustible dust rulemaking.