Figure 7. Percent Combustible Dust Related Violations DistributionsThe recent status report on the OSHA combustible dust National Emphasis Program (NEP) provides helpful insight into recent targeted enforcement and inspection activities. It does get a bit bewildering in deciphering all the calculus when the numbers do not add up.
For example in Figure 6 the total combustible dust related violations is 2,214. Yet according to the introductory paragraph concerning enforcement findings, there was more than 4,900 violations. So which is it 2,214 or 4,900?
Many facility managers and owners attempting to manage the risk in addition to being regulatory compliant might just find themselves at the other end of a citation if not careful. For example, the NEP status report provides information on Violations Related to Combustible Dust Hazards:
"Under the NEP, the Hazard Communication standard is the standard most frequently cited with respect to combustible dust related hazards, followed by the housekeeping standard"
Yet there is no mention of violations in regards to powered industrial trucks in Figure 7. In contrast, review Figure 6 in the status report you'll note it's the third most frequent type of violation. So are you using an explosion-proof industrial powered truck (fork-lift)at you facility if there is combustible dust present?
Better check that factory nameplate for either DY, EE, or EX depending on the Hazardous Location Division 1 or 2. It could be the defining difference between a costly fine or not.
On a side note National Safety Council recently sent out a press release stating:
"The U.S. Department of Occupational Safety and Health Administration (OSHA) has revealed the preliminary top 10 most-frequent workplace safety violations for 2009 as part of a presentation at the NSC's annual Congress & Expo. The number of top 10 violations has increased almost 30 percent over the same time period in 2008."
Powered Industrial Trucks is 8th on the list.
8. Powered Industrial Trucks - 2,993 violations
Each year, tens of thousands of injuries related to powered industrial trucks (PIT), or forklifts, occur in US workplaces. Many employees are injured when lift trucks are inadvertently driven off loading docks, lifts fall between docks and an unsecured trailer, they are struck by a lift truck, or when they fall while on elevated pallets and tines.
Resources
OSHA Reg 1910.178 Powered industrial trucks.
Informative article - Explosion-proof forklifts
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