Multi-Agency Approach Combustible Dust Hazard Awareness

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.