Wednesday, November 25, 2009

Antiquated OSHA General Industry Standards is the Problem

Several OSHA General Industry Standards already specify combustible dust such as hazardous (classified) locations, powered industrial trucks, and ventilation. The problem is that a majority of OSHA general industry standards are antiquated and do not reflect the 21st century where technology and the wealth of knowledge has exceeded the level from when a majority of OSHA standards were initially written over three decades ago.

It's easy for local elected officials to demand that a separate standard be developed for combustible dust when they have no understanding that combustible dust explosions are propagating explosions like vapor could explosions and require similar layers of protection concerning damaging overpressure effects, harmful thermal radiation, and life threatening ensuing projectiles.

A separate standard for combustible dust only further deviates from the fact that combustible dust poses a potentially explosive atmosphere like flammable gases, vapors, and mists. An excellent example of global protective and mitigative measures would be the ATEX Directives for explosive atmospheres that our international trading partners have implemented in the European Union.

The realistic urgent issue nationwide regarding propagating explosions is not dust explosions but the multitude of flammable liquid, vapor, and gas explosions that have plagued the nation's workplace. Since 2003, the Chemical Safety Board has investigated two dozen of these incidents compared to only four combustible dust incidents in nearly a decade.

In a politically and emotionally charged environment the hard and true facts are being misreported in governmental press releases that all fatalities and injuries since 1980 have occurred due to dust explosions. This totally contradicts the results of the CSB governmental 2006 Dust Hazard Study, which reported that combustible dust related fires and explosions are the culprit, not solely explosions.

Over 80% of the combustible dust incidents in 2008, according to media accounts, were fires not dust explosions. Any workplace fatality or injury is one to many. Fortunately in 2008, excluding the Imperial Sugar explosion, the human toll was minimal. The few injuries that did occur consisted of flash fire burn injuries and would not even come up on the radar as a national problem, in contrast to the rash of recent workplace flammable liquid, gas, and vapor explosions.

Jumping to incorrect conclusions that dust explosions with fatalities are prevalent and occur on a regular basis does not reflect current reality. The Imperial Sugar Refinery explosion was tragic and preventable. Something definitely needs to be done with the current OSHA regulatory scheme. But a separate dust standard is the wrong direction. If good housekeeping in removing the fuel load was adhered to as outlined in the current OSHA General Industry Standards then the secondary devastating dust explosions in the Imperial Sugar and prior catastrophic 2003 incidents would never have occurred.

To further complicate the matter is the call by legislators to supersede the OSHA combustible dust rulemaking process with a bill that would force OSHA to enact a standard four months after the bill became law. This is economically unrealistic in a time when the nation is experiencing the worst recession since the 1930’s with many facilities shutting down permanently and laying of workers.

Already through OSHA’s targeted national emphasis program through combustible dust enforcement and citation activities, businesses have began to lay-off workers so as to implement costly abatement actions. It’s just a matter of time following a proposed separate combustible dust standard or bill that many more small businesses in the manufacturing sector will be force to close down.

In conclusion, there needs to be an equitable balance between occupational safety and business economics, which reflects the reality of potential workplace fatalities and injuries due to combustible dust related fires and explosions.


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