Sunday, January 29, 2012

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


1 comment:

Jeffrey C. Nichols said...

Excellent references for identifying and determining combustible dust processes by NAICS and SIC.

 

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