Thursday, January 13, 2011

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.

 

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