British Columbia Combustible Dust Hazards Awareness Workshops

Workplace combustible dust related fires and explosions occur with alarming regularity in the global grain, mining, forestry and manufacturing sectors. Although the majority of incidents do not result in fatalities, injuries, or property damage, historically many of these non-consequential incidents have been precursors to catastrophic events.

The complex topic of combustible dust hazards recently came to the forefront in British Columbia when WorkSafeBC issued a directive order for all sawmills to conduct a comprehensive risk assessment resulting in an effective dust control program. 

In conjunction with FireWise Consulting Ltd., John Astad, Director and Research Analyst from the Combustible Dust Policy Institute (CDPI) will be presenting a series of one day Combustible Dust Hazards Awareness Workshops throughout British Columbia. The goal of the CDPI is to minimize the severity and reduce the occurrence of combustible dust related fires and explosions through research of combustible dust related incidents. For more information on the CDPI  view brochure here.

The Combustible Dust Hazards Awareness Workshop will provide stakeholders with the knowledge to minimize the probability of occurrence and severity of consequence of future combustible dust related incidents. In addition the workshop will assist stakeholders in developing a comprehensive dust control program as noted in the revised WorkSafeBC OHS Guidelines. Key aspects of the workshop are identifying, evaluating, and controlling combustible dust hazards in addition to providing guidance in conducting facility inspections and risk assessments.

Facility owners and managers concerns in reducing the probability of a catastrophic secondary dust explosion include good housekeeping, employee training, maintenance, and management of ignition sources. Prevention of future incidents begins with awareness of the problem and a robust hazard mitigation framework which consists of a facility risk assessment, written combustible dust program, and hazard communication.

This combustible dust workshop will discuss the importance of these topics and more in addition to the BC Fire Code referencing the National Fire Protection Association (NFPA) combustible dust standards. NFPA best industry practices include engineering controls for deflagration suppression, deflagration isolation, and explosion venting in the mitigation of combustible dust explosions. The NFPA 664 Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities provides excellent guidance in this area and is a key resource for the workshop.  Click here for a detailed course outline.

COURSE DETAILS


June 11, 2012  Prince George

June 12, 2012  Williams Lake

June 14, 2012  Vernon

June 18, 2012  Port Alberni

June 19, 2012 Township of Langley


Time: 0800 to 1600
Registration Fee: $149.00 plus tax (includes lunch)

Register on-line by clicking on the FireWise Consulting Registrations link or register by mail, e-mail or fax by printing and filling out the form at the following link: Registration Form

GAO Report Results: OSHA and NIOSH Need to Work Together

Occupational health and safety should not solely be inspection, enforcement, and rulemaking. Regarding combustible dust workplace fire and explosion hazards, outreach, education, training, and research is essential. All these elements are included in the OSH Act. The enlightening GAO report sheds light on the fact that the OSH Act is not being adhered to. I encourage all EHS professionals to read the OSH Act, Sections 20, 21, 22

Solely relying on a regulation in providing a warm and fuzzy feeling is not the complete solution. A prime example, would be the multitude of grain elevator explosions following the OSHA Grain Facility Standard  So now we have reached a point where X fatalities is not acceptable but Y fatalities is acceptable. OSHA does not have the resources to be everywhere at once. The time has now come in the 21st century where the paradigm must change to shared responsibility engaging all stakeholders.

In contrast,  "Clinical Professor of Environmental and Occupational Health Michael Silverstein claimed that OSHA and NIOSH have been working together for the past 40 years"
Then why  hasn't NIOSH been a primary stakeholder in the OSHA Combustible Dust rulemaking?
Full Committee Hearing - Time Takes Its Toll: Delays in OSHA’s Standard-Setting Process and the Impact on Worker Safety.
 
Maybe this GAO report will open dialogue on establishing and coordinating local, state, and federal standardization, interoperability, compatibility, and responder health and safety to prepare for, train and respond to, mitigate, and recover from any incident by identifying requirements for an all-hazards incident response which includes OSHA, NIOSH, and US Fire Administration?

"The InterAgency Board (IAB) is a voluntary collaborative panel of emergency preparedness and response practitioners from a wide array of professional disciplines that represent all levels of government and the voluntary sector. The IAB provides a structured forum for the exchange of ideas among operational, technical, and support organizations to improve national preparedness and promote interoperability and compatibility among local, state, and federal response communities."

Doesn't catastrophic ComDust related fires and explosions in the workplace warrant federal standardization, interoperability, and compatibility?

GAO Report: WORKPLACE SAFETY AND HEALTH, Multiple Challenges Lengthen OSHA’s Standard Setting.

"Improve coordination with other agencies: Experts and agency officials noted that OSHA has not fully leveraged available expertise at other federal agencies, especially NIOSH, in developing and issuing its standards. OSHA officials said the agency considers NIOSH’s input on an ad hoc basis but OSHA staff do not routinely work closely with NIOSH staff to analyze risks of occupational hazards. "

"However, OSHA can coordinate more routinely with NIOSH on risk assessments and other analyses required to support the need for standards, saving OSHA time and expense. In our report being released today, we recommend that OSHA and NIOSH more consistently collaborate on researching occupational hazards so that OSHA can more effectively leverage NIOSH expertise in its standard-setting process. Both agencies agreed with this recommendation."

This is only the tip of the iceberg of agencies not working together regarding workplace ComDust fire and explosion hazards. For example, OSHA has ignored the US Fire Administration in the ComDust Rulemaking process. When a ComDust related fire goes beyond the incipient stage, who you going to call to extinguish the fire? 

Resources:
Multiple Challenges Lengthen OSHA's Standard Setting (GAO Report)

Mountain Pine Beetle Infested Trees Moisture Content in Evaluating Fire & Explosion Hazards

Numerous MPB working papers were written for the Mountain Pine Beetle Initiative (MPBI) administered by the Canadian Forest Service. The MPBI began in 2002 and was a six-year package of programs with a total budget of $40 million.

Stakeholders will find a wealth of information in the numerous working papers such as moisture content in infested trees regarding time since death (tsd). The stages infested trees go through after the green stage include the red stage, where the tree shows characteristics of dying (i.e., red needles) in the stand for 2-4 years,and the grey-stage, where the tree has been dead in the stand for 5 or more years.

During the evaluation of moisture content (MC) it is important to understand that fiber saturation point (FSP) varies with tree species. FSP is when there is no longer any free water between the cell structures.(see page 18 .pdf)  NFPA 664 defines deflagrable wood dust when the moisture content (wet basis) is less than 25% and the median particle size is less than 500 microns.  Converting from dry-basis to wet-basis moisture content calculations.

A problem arises when the science is not applied when conducting a hazard evaluation of the fire and explosion properties of wood dust. When the raw material input changes from green wood with high moisture content to low moisture content MPB infested trees a management of change (MOC) is warranted.

For group members desiring additional info on MC here is a link to the OSHA ComDust NEP. Scroll down to Appendix E ,Combustible Dust Tests Conducted at SLTC

"Moisture in dust particles raises the ignition temperature of the dust because of the heat absorbed during heating and vaporization of the moisture. The moisture in the air surrounding a dust particle has no significant effect on the course of a deflagration once ignition has occurred.

There is however, a direct relationship between moisture content and minimum energy required for ignition, minimum explosive concentration, maximum pressure, and maximum rate of pressure rise. For example, the ignition temperature of cornstarch may increase as much as 122 Fahrenheit, with an increase of moisture content from 1.6 percent to 12.5 percent.

As a practical matter, however, moisture content cannot be considered an effective explosion preventive, since most ignition sources provide more than enough heat to vaporize the moisture and to ignite the dust. In order for moisture to prevent ignition of dust by common sources, the dust would have to be so damp that a cloud could not be formed." (Source: Fire Protection Handbook, 19th Edition). 

An excellent resource concerning moisture content in MPB infested trees versus non-infested trees is the paper Moisture changes in lodgepole pine before and after attack by the mountain pine beetle by Dr Rob Reid who worked at the Forest Entomology and Pathology Branch, Department of Forestry, Calgary, Alberta. Dr. Reid conducted moisture content studies on MTB trees near Invermere, British Columbia, and Banff, Alberta, in the period 1955-1960.

The nine page .pdf has excellent figures and tables illustrating moisture content in MPB infested trees versus non-infested trees. Many of the scientific papers written were the result of the $40 million dollar Canadian Mountain Pine Beetle Initiative (MPBI) program (2002-2008) which reference Dr Reid's 1961 paper.

The problem we have now is that industry has not utilized the wealth of scientific data acquired in the Mountain Pine Beetle Initiative (MPBI) in assessing fire and explosion risk when these infested trees are processed.

Resources
NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities  
Moisture content of lumber produced from dead western white pine and Lodgepole Pine trees.

 Rate of deterioration, degrade and fall of trees killed by mountain pine beetle: A synthesis of the literature and experiential knowledge (2005)  
Current knowledge of characteristics and utilization of post-mountain pine beetle wood in solid wood products

A wood and fibre quality-deterioration model for mountain pine beetle-killed trees by biogeoclimatic subzone 
The mountain pine beetle : a synthesis of biology, management, and impacts on lodgepole pine (2006)