Friday, January 28, 2011

Global Incident Awareness Can Save Lives

Two strikingly similiar pictures, two different countries, yet the explosive effects in these storage tanks were basically the same in the liquor pulping recovery process. In both catastrophic incidents fatalities occurred at corrugated packaging manufacturing facilities. The incident in France happened this month and the other in Wisconsin back in 2008, which the Chemical Safety Board is currently investigating. As a result of the Wisconsin incident CSB issued a March 2010 Safety Bulletin on Hazards of Welding and other Hot Work.

Christian Bourdon, the contract worker from Saint-Aubin, France died unnecessarily in the hospital as a result of injuries sustained from the explosion while doing hot work on the storage tank. Don't know if Christian or others in the global workforce had a chance to read the educational CSB bulletin. Incident investigations determining root cause and safety bulletins are great if the information is being received by OHS professionals then passed on to the workforce. Yet it is difficult to understand why repeatable catastrophic incidents are occurring when information is abundant concerning the hazards. Providing examples of these two incidents is even harder to grasp since the manufacturing and storage process were the same.

It is unacceptable that life-saving information resides securely within national borders when occupational health and safety is a global concern. In contrast global financial markets send and receive data real-time. So is the value of the buck of more importance than human life?

Paper & Pulp Mill Process Magnetrol International

Monday, January 17, 2011

Legislators, More Regulation is the ComDust Cure

Why is it that legislators seem to think that passing more bills and regulations is the cure all? Problem with the combustible dust issue is that no one in Washington D.C. has all the facts and solely utilizing the Chemical Safety Board's Dust Hazard Study provides a false perception of the enormity and complexity of the issues both social and economical.

"Their bill would tell OSHA to issue - within 90 days - an interim standard. It would require better housekeeping, engineering controls, worker training and a written combustible-dust safety program." article

For example, the CSB report states there were 281 ComDust incidents from 1980-2005, or an average of eleven incidents annually. In stark contrast, according to media accounts of ComDust related incidents since 2008 there have on an average 12 incidents a month. This would equate to approximately 4,000 ComDust incidents during the 1980-2005 timeframe.

Not understanding the depth of the issue is only part of the problem. For example FEMA/U.S. Fire Administration's, "National Fire Incident Reporting System 5.0 (NFIRS)" via local fire departments has failed to report and identify process situations, process conditions, and process materials regarding combustible dust related fires, precursors to catastrophic dust explosions.

If the local fire and explosions hazards can't be identified, then how can they be evaluated and controlled? Of course legislators at the national level seem to think legislation and regulation is the answer for a local/regional problem. That is the easy way out in attempting to solve a primarily fire life safety issue and secondarily an occupational safety issue.

The OSH ACT specifically states that to address workplace safety, issues of regulation, education, outreach, and research must be pursued. OSHA with its limited resources cannot do it all.

"by providing for research, information, education, and training in the field of occupational safety and health; and for other purposes."

What happened to NIOSH as the OSH ACT intended in getting involved with outreach/education regarding the combustible dust issue as it had done decades ago concerning coal mine dust explosions, prior to when the U.S Bureau of Mines (USBM) was transferred to NIOSH, Department of Energy (DOE), U.S. Geological Survey, and the Bureau of Land Management in 1995-97.

Let’s all grow up and stop singling out Imperial Sugar explosion as the problem. Currently Imperial Sugar is an industry leader in addressing ComDust fire and explosion hazards. What about the tens of thousands manufacturing facilities that have potential ComDust fire and explosion hazards? So now OSHA as Secretary of Labor states, "there's a new sheriff in town." So what we going to do, fine them all?

Outreach, training, research, and education through NIOSH and US Fire Administration are just a few examples in alternatives to more legislation and regulation. Question is, who has the vision in providing the leadership so all local, state, and federal agencies are working together in these tough economic times.

Resources -OSH Act

Saturday, January 15, 2011

Ten ComDust incidents per year...Say What?

At a recent combustible dust webinar last October, attendees to the educational event learned that about ten combustible dust incidents occurred annually from the early 1980s until 2005 in the U.S.A. This data was obtained from the Chemical Safety Board Dust Hazard Investigation that was completed in 2006, noting 281 ComDust incidents from 1980-2005.

Unfortunately, this is not reality in contrast to media reports that note over ten combustible dust incidents every month. Currently, OSHA is in the combustible dust rulemaking process utilizing this incomplete data from the CSB Dust Hazard Study. This presents a problem by not exposing the enormity and complexity of combustible dust related fires and explosions in the manufacturing, non-manufacturing, and utility sectors.

The problem is exasperated by the current OSHA Combustible Dust National Emphasis Program (NEP) that further lessens the magnitude of combustible dust incidents by solely listing certain national industries (NAICS) that have a potential for combustible dust incidents and excluding thousands of other manufacturing plants that do have a history of ComDust incidents not listed in the ComDust NEP. For example, in 2008 over 50% of facilities that had ComDust incidents were not listed in the Appendices D-1 and D-2 of the NEP.

If your facility generates combustible dust it doesn't matter whether OSHA acknowledges the hazard our not in the ComDust NEP. Bottom-line, you have a potential fire and explosion hazard that can cause grave burn injuries, fatalities, and severe property damage. Get your dust tested now or at least conduct a thorough process hazard analysis; identifying, evaluating, and hopefully controlling the hazard.

To learn more about combustible dust hazards be sure to check out the excellent Chemical Processing. com webinar moderated by Traci Purdum, Senior Editor/Digital Media. Presenters included Dr Vahid Ebadat Ph.D/Chilworth Technology, Inc., John Dauber, sales manager/Camfil Farr APC, Bob Korn, Director of Sales for Explosion Protection Products/Fike Corporation, and Guy Colonna, Division Manager, managing the Industrial and Chemical Engineering department for the National Fire Protection Association.

Google Map Dec 2010-Jan 2011 Combustible dust related fires and explosions
Dust Gets it's Due- By Seán Ottewell, Editor at Large-Chemical

Friday, January 14, 2011

Confined Structure Fires also Combustible Dust Related?

Just prior to the Christmas holiday a minor combustible dust related fire occurred in a dust collector at a Misc. Fabricated Metal Producing Manufacturing/NAICS 332999 facility in Wisconsin. These type of facilities are listed in Appendix D-2 of the OSHA ComDust NEP as Fabricated Metal Products, Not Elsewhere Classified with industries that may have Potential for Combustible Dust Explosions/Fires.

According to the news account:

The fire was extinguished and contained to the dust collector bag house. There was no fire extension into manufacturing plant.

The incident begs the question was this a confined structure fire? Where as in similiar small fire incidents that are limited in scope, are confined to noncombustible containers, rarely result in serious injury or large content losses, and are expected to have no accompanying property losses due to flame damage. The news account mentions no fire extension into manufacturing plant nor injuries which resulted in an estimated $10,000 damage to dust collection bag house. Since dust collectors are constructed of metal they would be non-combustible.

In the U.S. Fire Administration/National Fire Data Center, Investigation of Confined Structure Fires, Topical Fire Research Series, the report noted 2002 NFIRS 5.0 data contain abbreviated reporting for slightly over 52,000 confined structure fire incidents—37% of structure fires.These incidents accounted for $26 million in combined losses, 3 deaths, and nearly 500 injuries. Most confined structure fires (77.5%) occurred on residential properties. It is the other 23% that we are concerned about in manufacturing non-residential properties.

There is a problem in this US Fire Administration reporting in that it does not formally consider dust collectors or other process equipment in the manufacturing sector that are non-combustible as confined structure fires. Instead, cooking fires, trash or rubbish fires, chimney fires, commercial compactor, fuel burners, and incinerators are used as data element descriptors in these type of fires.

This does present a problem since fire service professionals can't identify combustible dust fire hazards in the NFIRS 5.0 reporting system, then how can they assist stakeholders in evaluating and controlling combustible dust fire hazards. All combustible dust related fires are failed catastrophic combustible dust explosions. Time is way overdue for the FEMA/US Fire Administration's National Fire Data Center to review their fire reporting methodology that omits the dozens of minor combustible dust related fires that have a history of evolving into catastrophic dust explosions.

Combustible Dust Explosion Pharmaceutical Preparation Plant

A combustible dust explosion occurred at a pharmaceutical preparation plant in Iowa prior to the end of the 2010 a few weeks ago. Luckily there were no injuries or fatalities and damage was minor according to the news account.

"There were no injuries. The explosion blew out doors on the building and dust collectors, with additional minor damage."
Eastern Iowa News Now

It appears the mention of doors blowing out in the dust collector might be referring to explosion ventilation panels. Being that the plant is involved in pharmaceutical preparation with a NAICS 325412, it is noted in the OSHA Combustible Dust NEP in Appendix D-1 as an Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires.

Over the past 12 months OSHA has been enforcing a myriad of regulations in addition to ComDust NEP emphasis in their site visits at pharmaceutical preparation facilities. The OSHA Integrated Management Information System also referred to as IMIS provides a helpful insight to these inspections.

An educational General Duty Clause citation for one Pharmaceutical Preparation Plant noted that "neither dust collector was equipped with deflagration venting panels directed to an unoccupied area or with a suppression system. The collectors were located inside an occupied area which employees entered to conduct maintenance on a daily basis."This is in contrast to the current incident where the dust collector was installed outside on the roof and appeared to have explosion vent panels.

Results of an internet search produced a MSDS for microcrystalline cellulose (MCC) Cellulose; flour cellulose which has combustible dust fire explosion hazards. For example in the Fire Fighting section it notes, "Fine dust dispersed in air in sufficient concentrations, and in the presence of an ignition source is a potential dust explosion hazard. For Cellulose: Minimum ignition temperature, dust cloud: 410C. Minimum explosible concentration: 0.045 g/l." This is helpful information so stakeholders can take proper administrative, PPE, and engineering control measures.

On a side note, another combustible dust related fire and explosion originated from the same company that occurred nearly two weeks prior to above incident, yet paper dust was the process material at a different facility instead of microcrystalline cellulose (MCC) according to the news account.

“Something caused the paper dust to explode. We don’t know what it was,” Battalion Chief Rick Palmer of the Portage Fire Department said. Palmer said the fire department has been called to explosions at the plant in the past, most recently about eight months ago. Small fires can develop wherever the dust settles in the plant following such an explosion, he said. “We just chase little fires all over the place,”

Stakeholders searching the OSHA Combustible Dust NEP will not find any paper industries that OSHA believes have More Frequent and/or High Consequence Combustible Dust Explosions/Fires or Potential for Combustible Dust Explosions/Fires. Don't know what the NAICS is for the facility that generated paper dust in the news account yet there is mention that the facility produces paper insulation. In either case whether or not a facility is listed in the OSHA ComDust NEP, if you generate ComDust then you need to identify, evaluate, and control the fire and explosion hazards.

Thursday, January 13, 2011

U.K Combustible Dust Fire with Metal Dust

The fire was on the mezzanine floor in a hopper containing metal dust"

OSHA needs to look at DSEAR and ATEX and include ComDust in the universe of potentially explosive atmospheres in the rulemaking process, which also includes flammable liquids, gases, vapors, and mists. Can't continue like the present situation in the USA with ComDust as a separate entity. Until then, the US Fire Administration will continue to ignore the fire and explosion hazards of ComDust with deficient incident reporting in the National Fire Incident Reporting System NFIRS 5.0

Process Upset Causes Combustible Dust Related Fire

Another minor combustible dust fire in the news with no injuries or fatalities. That is the good news..Yet stakeholders need to be aware that besides hot surfaces, arcs, sparks, static electricity, etc (process situations) that can ignite combustible dust, so can process upsets such as the case in this incident.

"combination of water and molten steel can cause a flash-up. That flash of fire likely set dust on fire, which then spread to a nearby storage room." (Watch the video)

WTOL-news article

OSHA is in the rulemaking process for a combustible dust regulation that is a continuum of the OSHA Combustible Dust National Emphasis Program (NEP). The primary problem with this approach, is that it solely notes specific national industries (NAICS)  that supposedly have a high probability or high consequence or potential for combustible dust incidents and ignoring others with potential fire/explosion hazards. Now for the bad news.. According to media account, over 50% of combustible dust related fires and explosions occur in national industries (NAICS) not listed in the the OSHA ComDust NEP, such as the case with this incident

For example, the real eye opener concerning this minor incident, is that this facility is an iron and steel mill national industry (NAICS 331111), which is not acknowledged in the OSHA Dust NEP as having high probability/consequence or potential for combustible dust incidents. So if the tree fell in the forest and no one heard it, did it fall?

There are dozens of other national industries composed of thousands of facilities in the wood, paper, plastic, metal, chemical, and food manufacturing sectors not listed in the OSHA ComDust NEP that have regular occurring minor combustible related dust fires which don't get notice from many other stakeholders either. This attitude is attributed to normalization of deviation as what occurred in the events leading up to the 1986 Space Shuttle Challenger disaster. Same thing with a catastrophic dust explosion as it is a rare event also.

It is time to face reality and get with the program, understanding the ComDust fire/explosion problem is a process condition (equipment) issue and not solely a national industry (NAICS) subject. Whether an industry is listed in the OSHA ComDust NEP or not as a non-NEP NAICS, they all have similar process materials (combustible dust) and process situations (ignition sources). So how can we say that one national industry has high probability/consequence or potential for a combustible dust incident because it is listed yet another one doesn't because it is not listed in the NEP? Yet both industries generate combustible dust during the manufacturing process. This train of thought does not hold water as America is burning. Just remember that any minor combustible dust related fire is a failed catastrophic combustible dust explosion.


Posted via email from ComDust

Wednesday, January 12, 2011

Combustible Dust Fire Incident Reporting Deficiencies

A problem arises in the national fire reporting system where there are no data elements specifically identifying manufacturing process equipment involved in ignition of combustible dust. If process condition fire hazards can't be identified, then how can they be properly evaluated and controlled through administrative, PPE and best engineering practices?

"Stakeholders seeking control measures to minimize the probability and severity of combustible dust incidents should work more closely with the fire service."

Posted via email from ComDust


1. National Fire Incident Reporting System (NFIRS 5.0) Complete Reference Guide

2. Report on Confined Structure Fires-February 2006, US Fire Administration

3. U.S. Industrial and Manufacturing Property Structure Fires, Oct. 2009, NFPA Fire Analysis and Research Division

4. US Chemical Safety Board, Combustible Dust Hazard Investigation, Nov. 2006

5. NFPA 901 Standard Classifications for Incident Reporting and Fire Protection

Biofuel Fires and Explosions-Google Maps

Google Maps

Ethanol Plant Fires and Explosions

Biodiesel Plant Fires and Explosions

Maps Compiled by John Astad, Director/Research Analyst, Combustible Dust Policy Institute

Combine Harvester Combustible Dust Fires

Informative article on the results of a research study on combustible dust related fires occurring in combine harvesters in the agricultural sector. The harvester diesel engine creates high temperatures resulting in very hot surfaces that can easily ignite the build-up of combustible dust that has low minimum ignition temperatures (MIT).
Stock & Land/Fairfax Media

The entire manufacturing sector can learn from this study as the process situations (ignition sources) of hot surfaces and static electricity can ignite combustible dust at facilities just like that do on a combine harvester. Good housekeeping is essential in minimizing the probability of occurrence in either case.


Posted via email from ComDust

Combustible Dust Fires. "It's the nature of the business"

Fire Chief states, "It's the nature of the business." "Part of the problem is the nature of the process that's there. It lends itself to having a fire to begin with. And it's not their fault" Caledon Enterprise

That is the problem here in the USA as many fire departments also believe it's the nature of the business and not the facilities fault. Fires in hoppers, dust collectors, etc. are really confined structure fires occuring in non-combustible containers in addition to in most cases; no fatalities, minor injuries, and no property damage.

Basically we are talking about a smoke scare and that is why these incidents are not reported in the US Fire Administration NFIRS 5.0. Why do we have to wait for a catastrophic ComDust explosion to take proactive action?

Posted via email from ComDust

Explosion Vents Reduce Severity of Explosion

Grain elevator had prior explosion in 2008 which caused much more damage and a worker injury. CEO notes that explosion protection best engineering practices lessened the severity of this recent explosion. This incident is a prime example of how ComDust incidents will continue to occur and only the probability and severity can be reduced through PPE, best engineering, and administrative controls.

Posted via email from ComDust

Fine dust buildup at Winnipeg feed-processing operation

"It's believed a spark from the machinery inside the hopper ignited the blaze, which is burning in the feed residue that had been encrusted along the walls of the bin." Prior fire several days earlier causing an estimated $20,000 damage.Winnipeg Free Press

Many other manufacturing facilities have similiar process situations (ignition sources) where either a spark or spontaneous ignition can ignite the process materials causing a combustible dust related fire. Good housekeeping and maintenance is essential in removing the buildup of combustible dust or residue. Without the fuel, a combustible dust related fire will not occur.

Posted via email from ComDust

Friday, January 7, 2011

Combustible Dust Laboratory Testing Primer

Potential combustible dust fires and explosions in the manufacturing, non-manufacturing, and utility sectors is a global problem. Across international borders the occupational safety regulatory standards for addressing combustible dust fire and explosion hazards varies. In contrast, the laboratory equipment in evaluating the hazard for ignition sensitivity and explosion severity is uniform with minor differences in methodology. For example, the 20 liter sphere is utilized worldwide in obtaining vital information on the maximum pressure and deflagration index (Kst) of combustible dust.

An excellent depiction of a dust explosion shown in the high speed video, shot at 600 frames per second, with 1 gram of custard powder dispersed in a glass tube past a hot coil ignition source. The glass tube has a volume of 1.2 litres, providing an explosive dust concentration of approximately 830 g/m3. Notice how the explosion pressure wave drives the dust ahead of it and out of the tube and debris from the explosion - mostly pieces of unburnt powder - continue to fall for some time afterwards. The second video sequence shows the same quantity of custard powder being ignited, but viewed from above. Note the thin plastic film held across the tube opening that acts as an explosion relief vent.

The catastrophic Imperial Sugar Refinery dust explosion in 2008 reminded global stakeholders how devastating industrial dust explosions can be. Measuring the explosive properties of the material being handled is, of course, the essential first step to understanding the hazard. Michael Ward of Explosion Hazard Testing in the U.K. has written an educational and very useful guide to explain combustible dust testing and what the lab results tell us in terms of explosion prevention and protection options.

The main points that the guide discusses:

  • UK statistics for fire and explosion
  • What a dust explosion is and the terminology involved
  • What laboratory tests are available and how they are conducted
  • What they tell us about the fire and explosive properties of the material
  • What tests are considered mandatory under U.K. and and EU legislation

The dust testing guide can be downloaded for free here


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