Saturday, January 28, 2012

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.


Steven J Luzik said...

I would disagree. as a consultant with Chilworth Global these past three years we have worked with many clients that have had OSHA come in and inspect their plants under the NEP program. As a result of the inspections many safety issues were identified with regard to fire and explosion hazards associated with their operations where combustible dusts were being generated. We have successfully worked with our clients to address OSHA's concerns and help abate the citations by assisting them in conforming to the applicable NFPA combustible dust standaards. I believe that we were able to significantly reduce the risk associated with these operations and prevent future incidents fromoccurring in thiese operations. The improvements made would probably not have been possible without the NEP program and the diligent actions of the OSHA inspectors. Sure the program has room for improvement but to call it i dismal failure is disingenuous.
Steven j Luzik PE, CFEI

John Astad said...

Thanks Steven for your valuable insight on the preventative and mitigative actions conducted at facilities identified in the NEP in Appendix D-1 and D-2. In contrast, the initial post is referring to the specific industries (NAICS) encompassing thousands of facilities not recognized in the NEP.

NEP must include all specific industries (NAICS) that generate, process, and handle combustible dust and not just a select few. The CSB Hoeganaes Case Study recommendations is a wake up call since the facility NAICS was not recognized in the OSHA NEP. This is only the tip of the iceberg with many more NAICS below the waterline not identified in the NEP.

In contrast, there are many elements in the NEP that have successfully educated stakeholders in identifying, evaluating, and controlling the hazard. Yet when fatalities occur in NAICS not recognized in the NEP this presents a serious problem. As a result, I have a hard time embracing the NEP as a success.

Keep up the great work consulting with clients identifying combustible dust fire and explosion hazards in the workplace.

If I can prevent only one workplace fatality or minimize another injury in bringing this NEP inadequacy to the table then I guess you are correct, in being disingenuous.

Teresa Long said...

All dust should be considered combustible until laboratory testing determines otherwise, whether or not a facility's NAICS is recognized in the OSHA NEP.

Required testing and reporting of results to the local fire department as well as OSHA is a viable solution and could potentially save lives and protect property.

John Astad said...

Reporting ignition sensitivity and explosion severity lab results to the local fire department? Now that is a new one, good idea. Never thought of it in that respect.

So in addition to the MSDS's that the local fire department should have, now they would have a better idea of the fire and explosion hazards of the dust when responding to the multitude of ComDust related fires at facilities nationwide.

If they already know the flashpoints and lower flammable limits of flammable liquids, vapors, and gases from the MSDS's then they should at least have this info also for ComDust with MIT and Kst.

John Astad said...
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