Monday, January 25, 2010

Industry Groups Responses to OSHA Rulemaking

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


Dehong Kong said...

Textile industry includes a variety of materials which have different ignition sensitivities and explosion violence. One catastrophic dust explosion we investigated, which would be considered one of the worst and most tragic dust explosion incident, did a occur in a linen (flax) textile plant in Harbin, China in 1987. The linen (flax) dust explosion claimed 58 lives and injured 177 workers, among 327 people working in the plant at that time.

Cotton dust explosions, even if not common, had occurred in the past. Laboratory test data show that in closed vessel, cotton dust (median particle size < 44 ┬Ám) can produce 7.2 barg explosion overpressure, however, the rate of pressure is much lower than many other combustible dusts. As in other industrial plants, the actual fire and explosion hazards and risk are determined by the fire/explosion properties of the materials, process equipment, process conditions, operations, plant layout and preventive/protective measures provided. It is therefore very important to assess not only the dust explosion hazards but also all the fire and explosion hazards. For example, if a dust explosion cannot be initiated by mechanical sparks, it can still be ignited by other sources such as a fire or small explosion of other flammable/combustible material. Only through thorough assessments using all relevant data, one can reach a sensible conclusion about the actual fire and explosion hazards. It would be hard to imagine that the OSHA dust standard can be a “one-fit-all” cookbook for all industries to get detailed technical guidelines.

Dehong Kong, Ph.D., PE, CSP
Princeton Safety Solutions, Inc.
5 Spruce Court
Plainsboro, New Jersey 08536
Phone: 609 240 7545
Fax: 609 799 9012

John Astad said...

Thanks Dehong for your helpful input, especially the Harbin, China example of probability of occurrence.

On December 11,1995 the Malden Mills fire in Methuen, Massachusetts is another good example where textile fibers were a contributing factor.

I don't understand where the National Cotton Council is coming from with the statement that textiles that have "no demonstrated history of combustible dust incidents."


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