Occupy Combustible Dust Fires and Explosions :)

Remove Appendix D-1 and D-2 from OSHA Combustible Dust NEP and replace with all NAICS in the manufacturing and non-manufacturing sectors that handle, generate, and process combustible dust. "All or None"

Say no to anymore catastrophic combustible dust related fires and explosions and not just a select few of specific industries (NAICS).

9th International Symposium of Hazards, Prevention and Mitigation of Industrial Explosions-Poland

9^th International Symposium of Hazards, Prevention and Mitigation of Industrial Explosions (9^th ISHPMIE) between 22 and 27 July 2012. Cracow, Poland

"Roots of the Symposium reach far into the past. ISHPMIE was founded in 1996 as a joined meeting of Dust Explosion Colloquia Baranow (1984). The first ISHPMIE was organized in 1996 in Bergen."

THE SCOPE OF THE CONFERENCE PROBLEMS IS AS FOLLOWS:

• ignition;
• flame propagation;
• ases, dust, vapors explosiveness;
• deflagrations and DDT;
• detonations of gases, dusts, vapors;
• kinetics of chemicals reactions;
• formation of explosive mixtures in industrial conditions;
• blast waves;
• explosion prevention techniques and means;
• explosion mitigation /protection techniques and means;
• explosion risk assessment methods;
• explosion/ consequences analysis;
• case studies;
• standards and regulations;
• hydrogen safe

Special thanks to Dr. Bill Kauffman in sharing the event with the CDPI so other global stakeholders can be aware of International Symposium in Poland.

Identifying Facility NAICS: OSHA Combustible Dust NEP

Many stakeholders are not aware if a facility is identified in the OSHA Combustible Dust National Emphasis Program NEP) for targeted inspections. Here are a few helpful steps to assist in obtaining the NAICS six digit designation then comparing with the NAICS in Appendix D-1 and D-2 of the OSHA ComDust NEP.

Step 1

Go to the OSHA Integrated Management Information System (IMIS) database and type the facility name in the Establishment Search

Here is an example of a facility already entered in IMIS:

Hoeganaes Corp
Gallatin, TN

SIC: 3399/Primary Metal Products, Not Elsewhere Classified

NAICS: 331111/Iron and Steel Mills

If the OSHA IMIS search does not populate a facility then an alternative would be to use the EPA Envirofacts search tool

Acquiring a NAICS at times can be frustrating and very time consuming since the above search methods will not always be successful. If the Standard Industrial Classification (SIC) is known, that will assist in determining the NAICS. For example type the SIC in the Google search box.

Google Search: SIC: 3399

The first hit at the top of the web page should be the Reference for Business website where the NAICS are found.

Step 2

Once the facility NAICS is obtained the next step is comparing the NAICS six digit designation with the NAICS in Appendix D-1 and D-2 of the OSHA ComDust NEP

Combustible Dust National Emphasis Program (Reissued) Page 35-37 D-1 and D-2

(html version) OSHA ComDust NEP

Next time you read a news account of a combustible dust related fire or explosion use the above exercise to determine if the facility is recognized in the OSHA NEP for targeted inspections. Don’t be surprised if the NAICS is not specified in D-1 or D-2 of the ComDust NEP.

There are many elements in the NEP that have successfully educated stakeholders in identifying, evaluating, and controlling the hazard. Yet when fatalities and serious injuries occur in NAICS not recognized in the NEP this presents a serious problem. One more fatality or injury as a result of a workplace combustible dust related fire or explosion is not acceptable. The workplace is reaching a point of, “Occupy Combustible Dust Fires and Explosions.”

Update: NAICS Exercise: Chocolate and Confectionery Manufacturing from Cacao Beans
January 29, 2012 Workers burned at chocolate factory. Use steps above to determine if facility NAICS is recognized in OSHA Combustible Dust NEP.

November 29, 2007 Explosion Valencia, CA
May 20, 2001 Chocolate Factory Blast Chicago, IL

Example General Duty Clause Citation at Chocolate Factory 06/03/2009

OSHA Combustible Dust National Emphasis Program (NEP) a Dismal Failure

"Assistant Labor Secretary Jordan Barab says he believes it's too early to assess the effectiveness of the program." Too early to assess? So how many more catastrophes like Hoeganaes must occur before we figure out the Combustible Dust National Emphasis Program (NEP) is a dismal failure?

Since 2008, through researching media accounts of combustible dust related fires and explosions the Combustible Dust Policy Institute has determined that over 50% of incidents are occurring in specific industries (NAICS) not recognized in the OSHA ComDust NEP.

Subsequently, the CSB Hoeganaes Case Study recommendation "Revise the Combustible Dust National Emphasis Program (NEP) to add industry codes for facilities that generate metal dusts(e.g., North American Industrial Classification System, NAICS, code 331111 Iron and Steel Mills, and other applicable codes not currently listed)," is only the tip of the iceberg.

What about the dozens of other industries throughout the entire manufacturing and non-manufacturing sectors not recognized in the NEP having a history of combustible dust incidents? Let’s stop fooling around and attempting to segment specific industries while Rome is burning. If you have combustible dust at your facility then it does not matter what you’re NAICS specific industry classification is.

As retired University of Michigan Professor of Aeronautical Engineering Bill Kauffman stated in the article, "It's not rocket science," If you don't believe it then check for yourself in the next news account of a combustible dust related incident where the specific industry (NAICS) is not recognized in the ComDust NEP. If this isn't a failure then I don't know what is.

Mystery of Airborne Combustible Dust Concentrations

So at what threshold should airborne concentrations of combustible dust trigger a concern for combustible dust related fires and explosions? Mention of industrial hygiene issues is reminiscent of the 2011 Foxconn catastrophic dust explosion in China, where initially workers complained of high levels of aluminum dust respiratory exposure during polishing operations.

Confusion still exists according to media accounts of the high airborne dust levels discovered in the WorkSafeBC inspections at the British Columbia, Canada facility a few weeks prior to Fridays catastrophic explosion. These high levels were for airborne concentrations in regards to respiratory exposure not combustible dust explosive concentration levels. Explosive airborne dust concentrations would require approximately 30,000 times more than the concentration found in the inspections depending on moisture content and particle size. For example, the highest airborne concentration was 5.9 milligrams/cubic meter, which was 2 times over the acceptable threshold of 2.5 milligrams/cubic meter, according to WorkSafeBC inspection reports released to the media.

To put this into perspective we must ask what exactly is 2.5 milligrams? Well if you put a pesky mosquito on a laboratory scale that would be your answer. Of course mosquitoes are not processed in sawmills, lumber is. But this does provide a general idea of 2.5 milligrams of mass. Alternately, using the mass of wooden toothpick provides better idea of how high suspended dust concentrations would be in one cubic meter of volume, such as the volume of a huge glass fish tank.

So here is the math. On an average, a wooden toothpick weighs approx. 100 milligrams on a laboratory scale. Now dissect the toothpick into 40 parts, which would equate to each of the forty toothpick parts weighing the same as a 2.5 milligram mosquito.

Now take three of those individual 2.5 milligram toothpick parts and grind them up to the consistency of sawdust. This would provide about total 7.5 milligrams of mass, a little over the 5.9 milligrams of the high airborne dust level that inspectors found in a cubic meter during the prior facility inspection.

So one must ask, is approx. 1/10 of wooden toothpick sawdust explosive in a cubic meter volume of air? The basis of a combustible dust explosive atmosphere is that the minimum explosive concentration (MEC) must be sufficient to have ignition while in suspension when combined with the fire triangle.Think of MEC analogous to the lower flammable/explosive level LFL/LEL of a flammable vapor or gas.

In contrast a minimum explosive concentration (MEC) of sawdust depending on moisture content and particle size is approximately 300 wooden toothpicks, weighing approximately 30 grams or 30 grams/cubic meter.Hope this helps obtaining insight in the difference between airborne respiratory hazards (milligrams) in contrast to airborne explosive concentrations (grams) of combustible dust. Of extreme importance is to ensure horizontal layers of dusts do not become airborne where a safe respiratory concentration can escalate rapidly into a minimum explosive concentration (MEC). Good housekeeping is key in this respect.

Full Report: Explosion of DeBruce Grain Elevator, Wichita, Kansas; June 8, 1998

Excellent overview on how a combustible dust explosion is investigated. Includes many educational pictures with comments in APPENDICE A Scientific basis for the analysis of the explosion

Grain Elevator Explosion Investigation Team (GEEIT), Vernon L. Grose, D.Sc., Editor Report Placed in Final Electronic Format By David K. McDonnell of OSHA in Cooperation with GEEIT

Special thanks to Dr.Bill Kauffman, for sharing the DeBruce report. Viewers will find chapters absent from the initial OSHA web page regarding the DeBruce Grain Elevator Explosion - Report in the section below

Chapter 1, Chapter 2, Chapter 3, Chapter 8, Chapter 14, initial OSHA web page

Cover

https://docs.google.com/open?id=0Bw8dBi76LJibYjMwZjg5MDgtZDdkNC00YzM0LWE2NTItYmIwNWViOGJhY2Ez

Cover inside

https://docs.google.com/document/d/15JyKtxN5C8ztmkhp4GtgGnppwvRwlzBwmFAWuDdjF0Q/edit

Report Table of Contents

https://docs.google.com/document/d/1Q1tynPH2_SSqPJN6akZAl5f21-5-w1ON8zV3EoKP3sk/edit

List of Figures in the Report

https://docs.google.com/document/d/1jA6z5ayoMDRy2JfGXvFXIlRuXRojaP9xGbz_5dOs1HA/edit

Chap 4 DeBRUCE MANAGEMENT ROLE IN EXPLOSION

https://docs.google.com/open?id=0Bw8dBi76LJibZDM3ZGI0NTgtNjA5Yi00NTc1LTk2ZmEtNjczMGRmMjdhNjI1

Chap 5 DeBRUCE OPERATIONAL ROLE IN EXPLOSION

https://docs.google.com/open?id=0Bw8dBi76LJibZmYyYWU5NDMtMThkMy00ZjI0LTg0ZGQtZTI1NGMyODMyYWRh

Chap 6 ELEVATOR STATUS AT EXPLOSION

https://docs.google.com/open?id=0Bw8dBi76LJibMWRmMzUyYjEtNTAzMS00NzliLThmNTktZmMwN2EwMTdlMmYx

Chap 7 GRAIN ELEVATOR EXPLOSION FACTORS

https://docs.google.com/open?id=0Bw8dBi76LJibMjM4NTIzMjYtMGIwYy00N2Q3LThlOWUtMzk0NTAzYTE5MTlh

Chap 9 WITNESS TESTIMONY

https://docs.google.com/open?id=0Bw8dBi76LJibN2QwMDIxYzAtNjVlOC00OGRlLWEyMmUtYWIzNjQ3MmE4MzZm

Chap 10 TRENDS IN GRAIN HANDLING

https://docs.google.com/open?id=0Bw8dBi76LJibMGE5NDg3OWEtNTg1Yi00ODZiLTk5OWUtNDcyMDE3ZGE4MzYz

Chap 11 ECONOMICS OF GRAIN DUST

https://docs.google.com/open?id=0Bw8dBi76LJibZWNmZTI0NjEtZWQxYi00NmRiLWEwNmYtNGEwMTI0NTE2ZWYy

Chap 12 ROLE OF WORKERS COMPENSATION

https://docs.google.com/open?id=0Bw8dBi76LJibN2Q0ZmFiMGQtNDdiZS00Yzg5LTgwYzQtZDFlOWVlNjcyNzRj

Chap 13 INVESTIGATION LESSONS LEARNED

https://docs.google.com/open?id=0Bw8dBi76LJibMmZkMjc0MWItYjkzNi00N2Q5LWE0ODItZTBhZjMzOWYxNzFm

APPENDICE A Scientific basis for the analysis of the explosion

https://docs.google.com/open?id=0Bw8dBi76LJibMjBhMGE3ZWMtNDJlMi00MzFkLWEzNGEtZjAwN2E3Y2VjYjUx

APPENDICE B Industrial Maintenance, Inc. solicited proposals

https://docs.google.com/open?id=0Bw8dBi76LJibN2NkNGY0OWItNzMyNS00ZjZiLTgzYTgtMzE1YmNhZTZlMWQ4

Proposals

https://docs.google.com/open?id=0Bw8dBi76LJibOGZjYmJmM2YtYTRhOC00NTM5LWI0MzYtZTA0NmQ2YjMyZjQ5

APPLICABLE FEDERAL REGULATIONS

https://docs.google.com/open?id=0Bw8dBi76LJibNDBhNjRlMTAtYjU5OS00OTU5LWEwZTQtMGRkMjA1MGQzMGFj

REFERENCES

https://docs.google.com/open?id=0Bw8dBi76LJibOTU5NjQ1NzQtYTgxOS00NzAzLWI4MDAtZGMxOTNkMjUwM2U0

ACKNOWLEDGEMENTS

https://docs.google.com/open?id=0Bw8dBi76LJibZDVmY2M4MjItOTgwNi00MzE4LWFjOTctZDRhMjc2MGVhOWI1

GEEIT MEMBERSHIP

https://docs.google.com/open?id=0Bw8dBi76LJibMDY5MWJlOGUtYWQ1ZS00ZDkxLWI1ZTItMzRiZDM0ZDc1N2Nl