Follow this link to the numerous stakeholder comments for the OSHA Advanced Notice of Proposed Rulemaking on the Regulations.Gov site Better yet, got to the "View by Docket Folder" tab and Sign up for Email alerts on the right side of the page.
OSHA's inspection found that combustible particulate solids, which were generated during trimming and repair operations, were not collected into an adequately designed dust collection system, were allowed to accumulate on machinery and surfaces, and were not adequately cleaned up to prevent such buildup.
Housekeeping appears to be the major issue with this recent OSHA citation for combustible dust fire and explosion hazards at a Pawcatuck, Connecticut plant. Reviewing a MSDS sheet for glass-reinforced plastics (GRP) highlights that GRP is a compound based upon a mix of glass fibre in a polyester and styrene resin based mix.
The fire hazards of GRP arise when combustible dust from machining and fabrication operations of combustible particulate solids may be explosive if mixed with air in critical proportions in the presence of an ignition source. Additionally, during storage and handling the dust generated during normal manufacturing operations can represent both a health hazard and a fire hazard. Most importantly as the OSHA news release informs stakeholders to use dust control equipment at the point of generation in machining and sawing operations.
An often overlooked potential ignition source are powered industrial trucks where combustible dust mentioned in this news release was exposed to several potential ignition sources, including an LP gas-powered industrial truck. What class of forklift are you using at your facility? Is it rated for use in potentially explosive atmospheres? The recent status report on the OSHA Combustible Dust NEP emphasized that combustible dust citations for powered industrial trucks was the third most cited violation after hazardous communication and housekeeping violations.
The 5th Annual Industrial Fire, Safety, and Security Conference (IFSS) in Houston, Texas will be hosting a Full-Day Combustible Dust Workshop on February 2, 2010, which will provide information assisting stakeholders in addressing potential combustible dust ignition sources. During one segment of the workshop, guest speaker Robert Zuiderveld, General Manager of Business Development Americas from Pyroban Corp. will share with attendees specific information on the operation of powered industrial trucks in combustible dust. work environments. Information throughout the full day workshop will assist stakeholders in operating and maintaining a safe workplace in addition to achieving OSHA regulatory compliance.
Good housekeeping is a major issue at facilities with the generation of combustible dust from combustible particulate solids. Many facility managers and owners are not aware of the proper methods in cleaning up the dust. You just can't take a compressed air hose and start blowing down the area nor sweeping while unaware of the dust clouds that can be generated, which provide an explosive atmosphere similar to a flammable vapor cloud. Potential ignition sources in the process are inherent at many facilities. The safe and approved alternative is the use of an explosive-proof rated vacuum cleaner.
Guest speaker Bruce Gordon, Senior District Manager, from Nilfisk CFM will speak in the afternoon at the Combustible Dust workshop on "Proper Housekeeping and Explosion-Proof Vacuums Hazardous Locations" concerning good housekeeping that will minimize the likelihood of a combustible dust related fire or explosion in addition to achieving regulatory compliance. OSHA combustible dust citations are costly yet a catastrophic secondary dust explosion leveling the facility can be even more of problem. Do you know about the combustible dust hazards at your facility?
Resources
Glass-Reinforced Plastics (GRP)
the ACGIH® Industrial Ventilation Committee is hosting this webinar aimed at educating the EH&S community on the importance of preparing for and preventing dust related incidents in industrial ventilation systems.
Over 60% of combustible dust General Duty Clause citation examples in the recent OSHA status report on Combustible Dust National Emphasis Program were for industrial ventilation issues. Jonathan F. Hale, MS, founder and co-owner of Air System Corporation & Diagnostics and Marty Schloss, PE and General Manager, southeast operations, for KBD/Technic, Inc., a CECO Environmental Company will provide attendees to the webinar with strategies in dust control and ignition control in preventing combustible dust related fires and dust explosions in addition vital information in maintaining current and future regulatory compliance.
This webinar has been approved by the American Board of Industrial Hygiene (ABIH) for .42 ABIH (IH) Certification Maintenance (CM) Point (. This webinar qualifies for .15 BCSP (SP) Continuance of Certification (COC) Point for Certified Safety Professionals. Participants seeking CM and/or COC points must attend the live webinar or view the archive and submit a final exam and evaluation. Certificates of Completion will be issued in a timely manner after receipt and completion of these items.
Who Should Attend this Webinar?
* Industrial Hygienists
* Occupational and Environmental Health Professionals
* Safety Professionals
* Environmental Engineers
* Plant Managers
ACGIH® Members: $292.50 Nonmembers: $325.00
Test and Certificate of Completion Only:*** $25.00 per person
DOWNLOAD Intertek WHITE PAPER:
"Potentially Explosive Atmospheres Requirements"Complete the registration form with the link below to receive a free copy of Intertek's informative white paper, and learn more about the differences between North American and European rules.
Excellent Intertek document that explains global classification systems of potentially explosive atmospheres such as flammable atmospheres of gases, mists, liquids, combustible dusts, and fibres. Describes important differences between the Zone (Europe and NEC505) and Division (NEC500) systems in hazardous (classified) locations?
Posted via web from ComDust
National Cotton Council (NCC)-urges OSHA to "use caution" in regulating textile mills concerning combustible dust in factories.
National Solid Wastes Management Association (NSWMA) -September 2008, OSHA issued an advisory stating there was no history of combustible dust events at transfer stations, materials recovery facilities (MRFs) or landfills
The Georgia Office of Insurance and Safety Fire Commissioner will be holding a 10:00 a.m hearing on the 7th Floor, West Tower, Floyd Building, 2 Martin Luther King, Jr. Drive in Atlanta, GA , Monday January 25, 2010 on a proposed combustible dust regulation.
Prior to the upcoming hearing Georgia adopted an emergency regulation last year, "Rules and Regulations for Loss Prevention Due to Combustible Dust Explosions and Fire"
The proposed regulation, solely relying on the national industries (NAICS) listed in the OSHA Combustible Dust NEP is a sure path to disaster. Over 50% of combustible dust incidents in 2008 occurred in national industries (NAICS) not listed in Appendix D-1/D-2 of the OSHA NEP . So what about industries that create combustible dust in specific industry groups that have experienced either frequent combustible dust incidents or combustible dust incidents with catastrophic consequences that the Georgia Office of Insurance and Safety Fire Commissioner failed to acknowledge with a history of incidents?
Additionally, there is no guidelines in the proposed regulation that MSDS's will provide employers and workers with the most current information needed to understand the hazards associated with combustible dusts, as well as appropriate protective measures to be taken.
Information such as physical data (melting point, boiling point, flash point, etc.) is fine. But it does not include ignition sensitivity such as minimum ignition temperature (MIT) and explosion severity of combustible dusts. Over 80% of incidents are combustible dust related fires. Facility owners/managers are not aware that they need an ignition control program to minimize probability of combustible dust related fires.
The NFPA Fire Analysis and Research Division recently published a report on U.S. Industrial and Manufacturing Property Structure Fires For example, U.S. fire departments responded to an estimated average of 10,500 structure fires in industrial and manufacturing properties per year in 2003-2006.How can stakeholders implement layers of protection for combustible dust related fires when there is no knowledge of MIT? It is dismaying that MIT is not mentioned in the physical properties but instead flash point is.
Another weak link in the proposed regulation is no mention that contractors also need training, same as employees, on the fire and explosion hazards of combustible dust. Many combustible dust related fires over the past two years have occurred due to contractors providing the ignition source while conducting hot work.
Hopefully some of these important issues will be brought up amongst the business, labor, and government stakeholders at the Monday morning meeting.
Posted via web from ComDust
Occupational Safety and Health Administration
Stakeholder Meetings on Combustible DustWednesday, February 17, 2010
9:00am - Noon and 1:30pm - 4:30pmMarriott Perimeter Center
Register now as a participant or observer for the OSHA Combustible Dust Rulemaking Stakeholder Meeting to be held in Atlanta, Georgia . Federal Register Notice January 25, 2010
Posted via web from ComDust
Investigators also determined that the shop was constructed under building and fire codes that don't allow for work on hazardous materials such as natural gas.
That kind of work falls under an occupancy rating that generally requires encased lighting fixtures and gas monitoring equipment that could have prevented the fire,
Ignition after natural gas contacting an arcing fluorescent light. Electrical fixtures in the destroyed maintenance shop not rated for Hazardous (Classified) Locations (29 CFR 1910.307). State Fire Marshal made an informal tour in May 2008 and didn't observe HazLoc weakness nor at an earlier inspection in the 1990's. Say What?
This story sounds so familiar of state fire marshal's not recognizing combustible dust fire and explosion hazards (explosive atmospheres) as mentioned in the 2006 Chemical Safety Board's Dust Hazard Investigation.
Posted via web from ComDust
The absurdity of including the manufacturing sector in the OSHA General Industry Standards really hit home the other day while working the graveyard shift at the refinery. A co-worker and I were having a discussion concerning the Sub-Parts of the General Industry Standards in which housekeeping, hazardous communication, ventilation, and PPE have the same requirements for refinery workers as they do for restaurant/fast food workers. This is were I had a bit of difficulty in justifying to Steve that the occupational hazards that we are exposed to in our 12 hour shifts our similar to food service workers as outlined in the General Industry Standards.
So why does construction, agriculture, and the maritime trades have separate OSHA Standards, yet manufacturing doesn't? Each of these sectors have their own unique occupational hazards in the workplace. In 2007 there were 400 fatalities in the manufacturing sector. Leading cause of fatalities in 2007 were from contact with objects and equipment (140), transportation incidents (102), and falls (48).
In 2008, Bureau of Labor Statistics (BLS) reported 689,700 recordable injury or illness cases in manufacturing industries with more than half of these requiring days away from work, job transfer or restriction.. The nearly 14 million workers in this sector had the highest numbers and rates of occupational illnesses with more than 25% of these were hearing loss. So what is so general about this, to be referred as General Industry?
Manufacturing workers have specific risks to hazards that others in General Industry are not exposed to. Such as contact with machinery and equipment, physical exertion, repetitive motions causing musculoskeletal disorders, hazardous exposure to toxic substances, organic solvents, pesticides, dust, isocyanates, chemicals, aerosols, nanoparticles, carbon monoxide, explosions, structural failures, and noise. For example, manufacturing sector fatal work injuries involving fires and explosions was up 14 percent in 2008.
What other General Industry sectors are exposed to as much risk? All the above are specific hazards that are not general in nature and must be addressed accordingly so as to minimize fatalities, injuries, and illnesses. Utilizing these General Industry Standards, relics of the 1970's when the Rubik's Cube was cool and the drive-in movie was still in fashion is not the solution for the 21st Century.
An earlier post with the example of the Ventilation General Industry Standard that is mostly occupational hygiene in nature and not occupational safety concerning inherent fire and explosions hazards in the manufacturing sector is only the tip of the iceberg. Currently OSHA's answer to address this inadequacies is to develop separate standards for different fire and explosion hazards such as combustible dust. So whats next, a Vapor Cloud Explosion Standard.?
After-all, there are many, many more fatalities and injuries as the result of these sort of incidents such as the BP Texas City Refinery incident. It's quite evident that Process Safety Management (PSM) has not had stellar results. So lets have a Vapor Cloud Explosion Standard next. Of course this is not the appropriate solution but only further illustrates the absurdity of the manufacturing sector referred to as General Industry.
The appropriate and most obvious solution is to revise the current OSHA Standards to reflect current occupational hazards that workers are exposed to on a daily basis. Manufacturing is vital to the economic health and security of our nation, which had gross output of $4.5 trillion in 2005, and the most important sector of the U.S. economy in terms of total output (Bureau of Economic Analysis 20081). It's long overdue for manufacturing to be have it's own OSHA Standard like construction, agriculture, and the maritime sectors. Until then all stakeholders can expect additional red-tape and bureaucracy of separate standards included in the OSHA General Industry Standards. Is that the course desired?
Combustible Dust Pre-Conference Workshop at the 5th Annual Industrial Fire, Safety, and Security Conference-IFSS 2010 upstairs in the George R. Brown Convention Center in downtown Houston, Texas, February 2 2010 from 8:00 AM- 5:00 P.M. (Lunch Included) Topics will introduce attendees to the hazards of combustible dust fires and explosions in the manufacturing, non-manufacturing, and utility sectors. Stakeholders will acquire important information, which they can utilize in identifying, evaluating, and controlling combustible dust hazards. The educational workshop will assist stakeholders in minimizing and preventing combustible dust incidents in addition to achieving OSHA regulatory compliance.
Currently a situational awareness is lacking nationwide that combustible dust poses a potentially explosive atmosphere the same as flammable gases, vapors, and mists. Are you aware of the dust hazards at your facility, which can result in OSHA citations?
Guests speakers: Tim Anderson, Owner, All Feed Processing and Packaging Inc "Regulatory Compliance Small Business Perspective"
Robert Zuiderveld, General Manager, Pyroban Corporation "Powered Industrial Equipment Operation in Potentially Explosion Hazardous Locations"
Bruce Gordon, Senior District Manager, Nilfisk , "Proper Housekeeping and Explosion-Proof Vacuums Hazardous Locations"
WHO ATTENDS IFSS Workshops and Seminars?
Attendees from across the United States converge at IFSS every year to meet with their peers - industrial emergency response and security leaders throughout the industrial and energy marketplace.
INDUSTRIAL FIRE, SAFETY & SECURITY Attendees Include:
FEDERAL/STATE/MUNICIPAL
By Joe Lederman
Throughout the greater part of the 20th century, a naturally-occurring mineral known as asbestos was utilized in a variety of applications. Due to its flame resistant, highly durable and inexpensive qualities, it became the ideal choice for manufacturers. Asbestos can appear in roof shingles, dry wall, attic insulation, popcorn ceilings and electrical wires.
The mineral was mixed into paint, combined with cellulose to make fiberboard and wallboard, mixed with cement to make siding shingles and formed into felt for use as roof felting and backings on vinyl flooring. Asbestos was even used in joint compound, which was used in dozens of different kinds of applications.
Hidden from the public for decades, exposure to asbestos can lead to the development of the mesothelioma disease, as well as many other health ailments that are extremely difficult to treat and diagnose. Due to these effects, it is recommended that men and women in the workplace receive proper information and tips to avoid any inhalation of asbestos. The use of asbestos became extremely prevalent in various industries which lead to many tradesmen being wrongfully exposed to airborne asbestos fibers.
Workers from practically all trades were involved with asbestos, even those that worked in the unlikeliest of professions. Asbestos was used in a variety of different products and was largely found in shipyards, power plants, chemical plants, factories, steel mills, building construction, and the telephone industry. Some of the occupations that commonly came in contact with asbestos include: asbestos textile mill, automobile production, building engineers, electrical workers, military personnel, custodians, pipefitters, railroad workers and firefighters.
Healthy Tips & Info
Asbestos exposure is easily prevented by taking simple precautions. Any home or building built before 1980 has a good chance of still containing asbestos. Even firehouses should be inspected for asbestos as many of them were constructed prior to any asbestos ban.
Licensed abatement contractors who remove asbestos, will be familiar with the regulations in protecting you and themselves from exposure to asbestos. They must wear protective equipment such as masks and gloves to avoid any exposure. The area is usually isolated from the rest of the house by shutting down ventilation systems and sealing them.
If you locate any suspected asbestos, most experts advise to leave it alone and un-disturbed. When asbestos is left alone, it is harmless. But if the material is disturbed or becomes damaged, millions of tiny fibers are released into the air where they can then be inhaled or ingested. If you encounter black or dark asphalt floor tiles, they may contain high levels of asbestos fibers.
These fibers become lodged in the tissue of organs (most often the lungs) and can eventually cause a number of illnesses such as malignant mesothelioma and asbestosis. Diagnosis of this asbestos-related lung illness is a difficult task due to a long latency period and many symptoms mimicking less serious ailments. A reported 2,000 to 3,000 mesothelioma cases are diagnosed every year in the United States alone, which averages out to three percent of the total cancer diagnoses. A patient’s prognosis can be affected by many factors, these include: age of diagnosis, treatment methods and cigarette smoking.
If you are or have worked in any of the listed trades and believe you have experienced asbestos exposure, it is important to receive regular screenings by physicians to identify a possible disease. It should be known asbestos exposure does not always lead to a disease, but because the latency periods associated with asbestos illnesses can last 20 to 50 years, a regular check up is advisable.
Resource
Asbestos.com
Reviewing the recent OSHA Combustible Dust NEP status report (Figure 6) illustrates that 90% of the citations for combustible dust arose from OSHA General Industry Standards. Approximately 10% of the citations were General Duty Clause citations where a majority of examples were for ventilation such as ductwork, dust collectors, and other aspects of the dust collection system used in ventilation. (pages 7-10 of 12 page .pdf)
The current OSHA General Industry Ventilation Standard 29 CFR 1910. 94 includes elements that address dust hazards in abrasive blasting, grinding, polishing, and buffing operations. Problem is, the Ventilation Standard originates more from an industrial hygiene viewpoint, where attention is directed towards respiratory hazards such as silica sand inhaled during blasting operations. What about combustible dust fire and explosion hazards from inadequate ventilation throughout the manufacturing sector?
Local Exhaust Ventilation
A key aspect in the fire triangle in reducing the possibility of a combustible dust fire or explosion is to remove the combustible dust fuel load. Good housekeeping alone will not completely remove the dust fuel load in most manufacturing processes, so dilution ventilation or local exhaust ventilation (LEV) must be utilized. Local exhaust ventilation (LEV) is the most effective in reducing explosive combustible dust concentrations.
Local exhaust ventilation (LEV) includes four major components: exhaust hood, ductwork, fan/ motor, and dust collector. The system must be properly designed and maintained so as to prevent and mitigate possible combustible dust related fires and explosions. Many of the combustible dust related fires occur or progress into the ventilation system. So it is extremely important that spark detection/flame suppression, abort gates, and explosion ventilation be incorporated in the industrial ventilation system.
General Industry Standards
The OSHA General Industry Ventilation Standard 1910.94(a)(2)(iii), does note that for abrasive blasting, the principles set forth in the National Fire Protection Association Explosion Venting Guide, NFPA 68-1954 be adhered to. What about other manufacturing processes where flammable or explosive dust mixtures may be present? There is a disconnect in many other General Industry Standards in not addressing combustible dust hazards such as in Hazard Communication, Housekeeping, and PPE. It's odd that Powered Industrial Trucks and Hazardous (Classified) Locations General Industry Standards address combustible dust, yet the majority of other General Industry Standards do not.
A proposed separate combustible dust standard does not address the antiquated OSHA General Industry Standards where many of the standards are from an industrial hygiene standpoint that fails to comprehensively address fire and explosion hazards concerning occupational safety. The Ventilation Standards in the maritime, construction, and general industry is an excellent example of this weakness.
For example, ventilation fire hazards in spray finishing are addressed in regards to solvent vapor there is the requirement 1910.94(c)(6)(ii) to dilute solvent vapor to at least 25 percent of the lower explosive limit of the solvent being sprayed. What about minimum explosive concentrations (MEC)/lower explosive limit (LEL) for combustible dust that is captured in the industrial ventilation system that are also possible fire and explosion hazards thoughout the manufacturing sector?
Potentially Explosive Atmosphere
Until OSHA recognizes that combustible dust is a potentially explosive atmosphere like in the above example for solvent vapors there will be a weakness in the Ventilation Standards that is mostly directed towards industrial hygiene. An excellent example where our international trading partners do understand that combustible dust poses an explosive atmosphere like flammable vapors, gases, and mists is the U.K DSEAR and EU ATEX Directives
OSHA cannot continue to address Industrial Ventilation as the most important engineering controls solely from an industrial hygiene standpoint. Industrial safety is just as important and must be on the flip side of the coin. The OSHA Salt Lake Technical Center(SLTC), which edited the informative and educational OSHA Ventilation Health and Safety Topics page should know better. Especially when SLTC is conducting all the testing for combustible dust ignition sensitivity and explosion severity.
U.S. Bureau of Mines
Over two decades ago Martin Marietta Laboratories and Marcom Associates, Inc. under contract from the U.S. Bureau of Mines (USBM closed in 1995 and transferred to NIOSH in 1996), prepared an excellent 220 page document, "Dust Control Handbook For Mineral Processing." The educational content was mostly centered on respiratory hazards concerning industrial hygiene in the mineral processing industry.
Many of the excellent chapters are applicable to the design and maintenance of industrial ventilation so as to minimize combustible dust fire hazards. In addition to the resource being located on the OSHA Safety and Health Topic Silica, Crystalline pages it should be cross-referenced on the OSHA Safety and Health Topic Ventilation Additional Information page.
Conclusion
In conclusion from reviewing the OSHA Combustible Dust NEP status report it appears that too much emphasis is being directed toward the General Duty Clause. Especially when over 30 percent of the report provides examples of General Duty Clause combustible dust citations where a majority of these citations are for industrial ventilation issues. What the ComDust NEP status report failed to emphasize, was the 90% of citations arose from General Industry Standards. Powered Industrial Trucks was not even included in Figure 7 of the report. Many of these antiquated General Industry Standards have not come to terms with combustible dust fire and explosion hazards from an industrial safety standpoint.
A separate combustible dust standard will provide many with a warm and fuzzy feeling but does not address an alternative regulatory approach in revising the current General Industry Standards so as to comprehensively come to terms with the 21st century occupational safety fire and explosion hazards in the workplace.
Resources
Designing Dust Collection Systems by Gary Q. Johnson-Workplace Exposure Solutions
Trying to connect all the dots in seeking solutions to combustible dust hazard awareness is a never ending and exciting adventure. During the Christmas/New Years holiday period in-between working the graveyard shift at the refinery I came across the exciting NIOSH National Occupational Research Agenda (NORA), which has been an ongoing project with NIOSH since 1996. I'd like the thank Dr. Sidney C. Soderholm, PhD, /NIOSH/NORA Coordinator for accepting my comments concerning Draft National Manufacturing Agenda NIOSH Docket 184, past the 5:00 p.m., December 15, 2009 deadline. I wonder how many other stakeholders are unaware of the proposed Strategic Goals in the NIOSH National Manufacturing Agenda?
Industrial and Manufacturing Facilities Report
Yesterday David Slaw, a partner with management consulting firm D5 shared the excellent Industrial and Manufacturing Facilities Report Abstract (Oct 09), authored by Jennifer Flynn of NFPA´s Fire Protection Research Foundation. Data in the report was acquired from the U.S. Fire Administration's version 5.0 of the National Fire Incident Reporting System(NFIRS) in addition to the National Fire Protection Association’s (NFPA) annual fire department experience survey. Jennifer did an awesome job in transferring the data into Tables, where readers can easily interpret and assimilate the wealth of information.
The most impressive aspect of the report is that it assists in identifying areas of origin, heat sources, equipment involved, leading causes of structure fires, and item first ignited concerning potential combustible dust related fires. For example, concerning item that first ignited in Table 9: of the 7,330 annual average of incidents from 2003-2006, 10% were dust, fiber, lint, sawdust or excelsior was involved. The new word for the day is excelsior. From the list it is difficult to ascertain whether combustible dust was specifically involved.
In regards to Area of Origin in Table 8: Processing, manufacturing area, or workroom was the leading area of origin for these fires in 15% of the incidences. Furthermore, Table 5 illustrates that the leading causes of structure fires in industrial and manufacturing properties was shop tools and industrial equipment. Unfortunately, an annual average of 30% of civilian deaths and 45% of civilian fire injuries were from these leading causes.
Stakeholders can be extremely proactive concerning their combustible dust ignition control program at their facility after reviewing Table 7: by Heat Source, which assists in providing an idea of probability of occurrence. So do you know the minimum ignition temperature (MIT) of the combustible dust that is generated at your facility? The majority of MSDS's from the raw product manufacturer usually does not have this physical fire property. Might be the time to have your combustible dust tested at a testing facility
* 14% Unclassified heat from powered equipment
* 11% Radiated, conducted heat from operating equipment
* 10% Spark, ember or flame from operating equipment
* 8% Arcing
Following each of the ten tables in the report a "Note" states:
These are national estimates of fires reported to U.S. municipal fire departments and so exclude fires reported only to Federal or state agencies or industrial fire brigades...
Media Accounts-Fires and Explosions
Another excellent source of information concerning combustible dust related fires is from news accounts. This resource is especially helpful for events not captured in NFIRS. For example, in many combustible dust related fires and explosions, volunteer fire departments respond to these incidents. If there are no fatalities and minimal injuries, the incident is not noticed in any formal manner where the probability of occurrence could prove most useful in future risk analysis prevention and mitigation strategies.
A major problem in relying on news accounts is that reporters are not knowledgeable about basic process equipment in a combustible dust related fires or explosion at a manufacturing facility. So the event is solely reported as just another industrial fire with no details of areas of origin, heat sources, equipment involved, or the item that first ignited. NIOSH has addressed this issue in STRATEGIC GOAL 15 – Engage the media more effectively to raise awareness and improve safety and health in construction in the October 2008 NORA National Construction Agenda.
A recent story comes to mind where last month a fire occurred at a Massachusetts facility. The fire chief provided information to the reporter that a large machine, which is approximately 11 feet tall, four feet wide and four feet deep that collects fine metal shavings ignited. So how would this event be captured in any sort of reporting system? Many of the combustible dust related incidents that OSHA and CSB become aware of are through news accounts, not the NFIRS system.
Maybe a possible solution would be for occupational health and safety professionals to submit abstracts for presentations at future media conferences so as to educate reporters on the basics of process equipment that are susceptible and have a history of combustible dust related fires and explosions. That might alleviate reports of a large machine (dust collector) that ignited.
Multi-Agency Approach
It's time now in the 21st century that all stakeholders start thinking outside of the box beyond the traditional systems that we are all accustomed to in regards to occupational safety concerning fire and explosion hazards in the manufacturing sector. A multi-agency approach utilizing information technology can close the gaps between DOL/OSHA, DHHS/NIOSH, and DHS/FEMA/U.S Fire Administration.
A problem with this vision for the future is that the above governmental departments and agencies have their own agendas that do not necessarily dove-tail into each other. With OSHA, we hear in national headlines there is a new sheriff in town with enforcement, inspections, and citations the rule. Yet in stark contrast, NIOSH is proceeding aggressively with their exciting National Sector approach in research, information, education, training, and outreach. Then there is the U.S. Fire Administration with their innovative NFIRS in the middle of the two.
All of the above in three separate cabinets of the Executive Branch of the U.S Government. Attempting to put it all together will be like herding cats at a four day Fourth of July rodeo.
Continuing Professional Development
Gas, Vapour & Dust
EXPLOSION HAZARDS
Protection, Mitigation and PredictionMonday 22 - Friday 26 March 2010
10% discount for IFE Members - CPD 33hrs
Programme
Course formatThe Explosion Hazards short course will be delivered by a team of practitioners and academics, all experts in their particular fields of contribution. The course has been extensively revamped in response to the positive feedback from participants and the continuing interests and rapid developments in the field.
Oral presentations will concentrate, where appropriate, on the implications and practical application with example calculations of the research findings (so please bring a calculator). Detailed course notes will provide comprehensive coverage of research methodologies and results.
ContactFor a full programme and registration form by email or post, contact:
Rachael Lawson, CPD Course and Events Co-ordinator,
CPD Unit, Faculty of Engineering,
School of Civil Engineering, Room 209,
University of Leeds, LEEDS, LS2 9JT, UK.
Telephone: + 44 (0)113 343 8104 Fax.: + 44 (0)113 343 2511
Email: cpd@engineering.leeds.ac.uk
This is the sort of courses that we need more of in the United States in understanding that combustible dust poses a potentially explosive atmosphere like flammable gaes, vapours, and mists (ATEX). All the rules and regulations in the world is only cursory until all stakeholders understand that combustible dust explosions and flash fires are propagating events similiar to vapor cloud flash fires and explosions. Can one differentiate the differences in the catastrophic results of overpressure, thermal radiation, and ensuing deadly projectiles between a dust explosion and vapor cloud explosion?
Posted via web from ComDust
James E. Maness, President of JEM Safety Consultants shares with readers an excellent overview in the prevention and mitigation of combustible dust related fires and explosions. Back in the 1980's when the OSHA Grain Handling Facilities Standard was being developed, Mr. Maness chaired the NGFA's Safety, Health and Environmental Quality Committee in addition to serving as the Director of Engineering services for the National Feed Grain Association.
The informative article covers many important topics of understanding dust explosions, fuel, ignition sources, bucket elevators, confinement, emergency action plan, and numerous illustrative graphs, figures, and tables.
Posted via web from ComDust
OSHA is scheduling informal public hearings on its proposal to revise the Hazard Communication Standard.
OSHA will be holding hearings on the revision of the Hazard Communication Standard so as to conform the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The classification, identification, and control of combustible dust hazards in the Safety Data Sheets (SDS)/MSDS is one aspect of the complex revision.
Currently the Hazard Communication Standard requires the raw product manufacturers to provide combustible dust fire and explosion physical properties in the MSDS/SDS. In contrast there are no provisions in the HazCom Standard for raw products at the top of the lifecycle that change from bulk form to combustible dust that is generated from combustible particulate solids midstream in the lifecycle during the manufacturing process. Without this vital aspect being thoroughly addressed, combustible dust related fires will continue unabated since information on minimum ignition temperatures (MIT) of a variety of combustible dusts is unknown by the midstream manufacturer.
DATES: Informal public hearing. The hearing will begin at 9:30 a.m., local time, on the following dates:
March 2, 2010, in Washington, DC;
March 31, 2010, in Pittsburgh, PA; and
April 13, 2010, in Los Angeles, CA.
Docket Folder for docket number OSHA-H022K-2006-0062
Posted via web from ComDust
aluminum dust sparked a fire in a dust collector, WISC-TV reported.
"The fine dust just sparked and started the filtering system on fire,"
Lessons learned from the past. NFPA 484: Standard for Combustible Metals is an excellent resource in minimizing the probability and reducing the severity of future incidents. The majority of combustible dust incidents are combustible dust related fires, precursors to potential dust explosions
The article mentions that one worker suffered a flash burn. This is where the importance of workers adjacent to process equipment must don flame resistant clothing (FRC)/PPE to minimize the severity of the effects of thermal radiation from flash fires.
Posted via web from ComDust
fire appeared to start in the ceiling above one of the paper machines, likely from dust that somehow ignited
News accounts stated that the fire was in the ventilation system in the space between the tin roof and the ceiling. A little more than a year ago, the same area of the facility caught fire.
The paper sector is not listed in the OSHA Combustible Dust NEP as an industry that may have potential for combustible dust explosions or fires. In many instances combustible dust related fires throughout the manufacturing sector are precursors to potential combustible dust explosions.
Currently to much emphasis is being put on combustible dust explosions in the OSHA Combustible Dust Advanced Notice of Proposed Rulemaking. What about the combustible dust related fires? Address the fires and the probability of a dust explosions will be minimized. The most recent OSHA national news releases have stated that all the fatalities and injuries that have occurred since 1980 resulted solely from dust explosions. This is not true and has delineated from the results of the Chemical Safety Board's 2006 Combustible Dust Hazard Investigation, which includes fire and explosions. In 2008, over 80% of combustible dust incidents were fires. Continually ignoring the fires is charting a course into dangerous waters.
Posted via web from ComDust
A prime example of the sort of education and outreach that must be conducted in regards to combustible dust fires and explosions in the manufacturing sector workplace would be to review the NIOSH Safety and Health Topic on Agriculture. The Centers for Agricultural Disease and Injury Research, Education, and Prevention is an excellent example of how NIOSH and stakeholders have worked collaboratively together in their efforts to minimize fatalities and injuries in the agricultural sector. Isn't manufacturing just as important to the economic security and vitality of our nation?
The National Agricultural Safety Database (NASD) is another prime example in educating workers so as to minimize the probability and reduce the severity of consequence of workplace incidents. This diverse database contains a myriad of educational materials, which includes fact sheets, training materials, PowerPoint presentations, and videos. Additionally,this superb resource is interactive and provides information in Spanish and other languages. So why doesn't OSHA provide similar information on combustible dust hazards to American workers?
Over the past several years, hundreds of thousands of dollars have been awarded in the OSHA Susan Harwood Grant program for combustible dust training, yet none of these training resources are available online for stakeholders in the manufacturing sector. Instead OSHA inspectors have received specialized training on combustible dust so as to issue citations in their inspection and enforcement activities.
Recently the OSHA Combustible Dust NEP status report illustrated this weakness of where business owners were not knowledgeable about OSHA General Industry Standards in regards to combustible dust. For example, 90% of citations where for General Industry Standard violations such as hazard communication, housekeeping, powered industrial trucks, and PPE. Wouldn't educating these stakeholders on combustible dust hazards like the training OSHA inspectors recently received been more appropriate?
It's time that the OSH Act is brought back as the Congress mandated where OSHA is required to work in concert with NIOSH in protecting the entire nation's workforce from fatalities, injuries, and illnesses. Solely directing the main emphasis to strong enforcement with costly citations without including the outreach and educational aspect is not a productive path in maintaining a strong manufacturing economic sector.
It's time for OSHA and NIOSH to work together in a comprehensive collaborative effort instead of the divergent manner that has been occurring in the past. The OSH Act 1970 mandated that NIOSH would carry out the policy set forth in Section 2 - Congressional Findings and Purpose of the Act and to perform the functions of the Secretary of Health and Human Services under Section 20 - Research and Related Activities and Section 21 - Training and Employee Education of the Act.
NIOSH has been conducting an excellent job in research, education, and outreach, providing stakeholders in the nation's workplace with their excellent products. The problem is that many of their products cannot be found on the OSHA Safety and Health Topics Pages. Many businesses are not aware of NIOSH, which is federal agency responsible for conducting research and making recommendations for the prevention of work-related injury and illness. NIOSH is part of the Centers for Disease Control and Prevention (CDC) within the U.S. Department of Health and Human Services.
OSHA in addition to conducting enforcement and inspection activities in the workplace also has many excellent occupational health and safety products. In contrast many stakeholders are aware of OSHA activities through citations and their collaborative outreach programs and educational resources available on the OSHA website. The problem with the OSHA and NIOSH educational resources and products is that they are located on two different websites.
For example, viewing OSHA's Safety and Health Topics Pages., one of the first topics in the search drop-down menu is Agricultural Operations There are many excellent links to:
two-day workshop includes an outline of OSHA standards, environmental health controls, fire protection, grain handling and conveyor safety, electrical safety, and railroad and materials handling safety.
Combustible dust hazards also present in ethanol production. Such as the secondary aspect of ethanol production where dryers are used to dry distillers grains. Or where dust particles can be be ignited by a heating system used in the drying process, which dries corn by-product prior to processing it into ethanol.
In 2009, according to media accounts, there were 14 fires and explosions at ethanol plants. Where either flammable gases, liquids, or combustible dust was involved in the incident. According to Ethanol Producer Magazine there are 184 ethanol plants in operation http://www.ethanolproducer.com/plant-list.jsp
For additional information on the Two-Day Ethanol Safety Workshop:
please contact or Email: James Manning, Program Director.Engineering Extension, SDSU, Brookings, SD 57007 Phone: 605-688-4101,, Email: james.manning@sdstate.edu
Website http://www.engineering.sdstate.edu/~engrext/index1.html
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Docket ID: OSHA-2009-0023Agency: OSHA
Have you provided comments yet concerning the OSHA Combustible Dust ANPRM? Submit electronically by the January 19, 2010 deadline. Participation by all stakeholders is needed. Still need input from the state and local fire protection service, insurance industry, NIOSH, U.S. Fire Administration, etc.
Enter OSHA-2009-0023 in the Keyword or ID search bar on http://www.regulations.gov Home Page. Or go directly to the Docket Folder.
Posted via web from ComDust
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