Friday, November 20, 2009

Sensible solution for the Combustible Dust standard...that creates private sector jobs and provides FREE training for companies impacted by the std

Two paths to choose from:
1) add CD as a PSM covered chemcial without a threshold assigned to it. Why can we not establish a threshold? Unlike other PSM chemicals, CD is a hazard when it is OUTSIDE of the process and allowed to accumulate over time. This is unique to CD and if we set a threshold of even 100 pounds, then those who do not exceed this would be exempt. However, they process say 50 pounds of dust a year (VERY LOW) and over 10 years do you think they may have enough dust on the ledges and hidden drop ceilings to cause an explosion. So my take is no threshold. The PSM standard is a great standard and lays out the frame work of a management system for companies to follow.

The second path would be to mirror the frame work from the PRCS standard where the employer "conducts an evaluation" to determine the applicability of the standard. This path may be troublesome based on a recent OSHRC decision that vacated some OSHA citations where an employer did an evaluation without even visiting the spaces and no documentation. OSHRC stated that 1910.146 does not qualify who and how the eval is to be done and if a company says they did one, then OSHA can not cite them for determining a PRCS is not one and killing a worker.

EDUCATION is the key! With that said, we already have a GREAT frame work in place to educate businesses, safety professionals, engineers, and workers. OSHA's outreach training program could be revamped (since they are making major changes already due to issues with the program) to include a SPECIAL Combustible Dust course. Using the Susan Howard Training grants in 2010, OSHA develops a national training program, trains the trainers just like the OSHA 500/501 courses, and then uses the grant money to provide FREE training for businesses and professionals. If you are the one that will be doing a CD hazard evaluation, you MUST have completed the OSHA 30-hr CD course, which you can get for FREE. Each area office or regional office would select a reputable firm in their area as the FREE outreach instructors and that company would have to offer at least 12 courses for the next 12 months. These courses are FREE and the training company would be paid by OSHA and the company would use the OSHA training program. The training could be attended by consultants and company safety professionals alike. But any one doing a CD eval MUST have completed the 30-hour course. You would also become a SGE as we see used in VPP Assessment and could be a resource for OSHA to help out with CD inspections. Companies would have a choice...sign up for an SGE to do an inspection of your facility voluntarily or wait for OSHA to show up with a team using the CD CPL. We keep hearing that companies need help and this would provide OSHA with a set of eyes in the field looking specifically at this hazard as well as provide non-OSHA personnel as a resource to any businesses who want some help with their CD hazards. The SGE would almost be like the "consulting" side of OSHA where they make recommendations but have no enforcement role.

Even if we do not do the SGE, I think OSHA (if they are serious about this) should use the 2010 Susan Howard Grant money to focus solely on CD Hazard training. OSHA develops a OSHA 502 course for CD training. Anyone who attends the course becomes a certified OSHA CD Outreach training. Then OSHA uses the grant money to pay these instructors to conduct these outreach courses. The 10 hour is just a CD awareness course and the 30-hour certifies you to be able to conduct a CD hazard evaluation. The grant money is used to pay for the course and course materials so there is NO deterrent to companies sending their employees. It helps small businesses on both side of the standard: 1) those who have CD at their business can get free training and resources that OSHA has trained using OSHA materials and 2) it helps small private consulting firm by them doing the training over a one year period.


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