Monday, December 21, 2009

It's the fires, stupid! Mfg Plant Two Fires, One Day

Bell said there was a small explosion in one of the silos in the first one of the day. It did damage to the top of the silo, he said, and the fire was contained within the silo.

Wood Window and Door Manufacturing plant in Bayport, MN has two fires and one explosion in one day. It's not unusual from the over 150+ combustible incidents that occurred in 2008 when a Fire Chief mentions to reporters that It's not uncommon to have a fire..."

OSHA does not realize that the majority of incidents in the manufacturing sector are combustible dust related fires. In these incidents workplace fatalities and injuries are rare. Instead the flurry of national press releases that OSHA posts on their site stating that all combustible dust incidents are explosions resulting in fatalities and injuries. This is an inaccurate statement of reality and does not address the heart of the problem. So how many facilities could of been proactively engaged in addressing layers of protection if an accurate depiction of probability of occurrence and severity of consequence was provided?

So what do you think? Should the OSHA proposed combustible dust rulemaking process be solely centered on secondary dust explosions that occur due to poor housekeeping. What about the combustible dust related fires that are a local and regional jurisdictional issue and not federal.

The proposed combustible dust rulemaking does not address the antiquated OSHA General Industry Standards. This fact was illuminated through the recent OSHA ComDust NEP status report where 90% of the citations were General Industry citations, (see figure 6) such as HazCom, Housekeeping, Powered Industrial Trucks, PPE, and Hazardous (Classified) Locations.

Combustible Dust NEP Status Report - October 2009
"It's the economy, stupid"

Posted via web from ComDust

Hazard Communication -MSDS-Wood Dust

Hazard Communication. I like this MSDS Sheet that Radiance Wood Products has prepared. The stakeholder communicates the hazard to the workers that this wood dust is potentially explosive. As you review the MSDS, notice that the minimum explosive concentration MEC (lower flammability limit) and minimum ignition temperature MIT (autoignition temperature) is included.

So what do you think? Should more fire and explosion physical properties be included?

Posted via web from ComDust

Global Scope of Explosive Atmospheres
Here is an illustrative global view of potentially explosive atmospheres which includes combustible dust. This is a slide from the presentation that was made at the 5th SIEEE meeting, 2 September 2009, Melbourne, Australia. Mr. Frank Lienesch was the Coordinator, Sectoral Initiative on Equipment for Explosive Environments. The session also reviewed the work underway by the Initiative and in particular the survey of the regulatory environment in the sector of Equipment for Environments with an Explosive Atmosphere

The specific purpose of the Sector Project is to develop common regulatory objectives (CROs) for the regulation of placing Equipment and Services for Explosive Environments placed on the market. The CROs shall include area classification, verification of the equipment and its production, installation, inspection, maintenance, repair and the related conformity assessment procedures for products, services and competency of personnel. The aim is to eliminate barriers against the free trade of equipment and services. This goal is quite similar to Global Harmonization Standard concerning the Hazard Communication Standard that OSHA is seeking comments on.

In regards to the current proposed OSHA Combustible Dust Standard it would benefit all stakeholders to address combustible dust under the same framework where flammable gases, vapors, and mists also present a potentially explosive environment. It does not make sense to separate combustible dust from the other explosive atmospheres. What do you think?

Equipment for Explosive Environments (SIEEE) .pdf
Working Party on Regulatory Cooperation and
Standardization Policies (WP.6)

Posted via email from ComDust


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