Sunday, November 18, 2012

Firefighter Injuries Unacceptable Combating Combustible Dust Related Fires

Recent firefighter injuries such as fighting a combustible dust related fire at plastics material and resin manufacturing are unacceptable. This brings back dark memories of the 1993 fire and catastrophic dust explosion at a wood fiber facility in Langerak, Netherlands resulting in 2 firefighter fatalities and 10 firefighter injuries. A question arises whether firefighters should be afforded the same workplace protection as workers in the private sector noted in the OSHA regulations?

State and local government agencies such as the Monroe Fire Department are not subject to the regulations established by Federal OSHA. For instance, Section 3(5) of the Occupational Safety and Health Act of 1970 (the Act) specifically excludes the employees of State and local government from coverage under Federal OSHA. This does present a huge problem where a failure to assess and identity combustible dust fire and explosion hazards can have severe consequences.

“While attempting to extinguish the fire, Centers said “there was a dust explosion” that caused the three injuries. He said firefighters were attempting to remove the material, which was through a 2-1/2-inch pipe at the bottom of the tank. “Dust that was created while they were pulling the dry material out found an ignition source and ignited,” he said.” Bridging and Rat-holing come to mind? What do you think?
In contrast, the OSHA General Duty Clause is applicable to practically any fire-fighting operation where combustible dust fire and explosion hazards are present. Fire Departments are required to identify the combustible dust hazards that firefighters may be exposed to. This can be implemented by providing firefighters the necessary standard operating procedures, combustible dust training, and equipment to safely mitigate the hazard.

The OSH Act is not all inclusive of the 26 States currently authorized by OSHA to run their own safety and health programs (OSHA State-Plan states), enforcing OSHA regulations that apply to both public and private employees in state-plan states.  Additionally, “NFPA recommends that all fire departments establish a policy of providing and operating with "the highest possible levels of safety and health for all members" [NFPA 1992]. Several NFPA standards apply to fire-fighting operations such as NFPA 1500 specifying the minimum requirements for a fire department's occupational safety and health program.

Typical Fire with Combustible Dust?
Questions arise in whether fire departments do have the necessary training in understanding combustible dust fire and explosion hazards while combating combustible dust related fires? For example, in a recent news report a fire chief mentioned the fire at the plastics material and resin manufacturing “was typical of all fires(01:20) video.

Since when is a combustible dust related fire typical? Especially when it has the explosive severity and severity of consequence of a flammable gas or vapor?
This post is in no way is meant to discredit the fire service, fire chief’s, and brave firefighters risking their lives everyday protecting life and property. It is solely to bring the subject to the table where the fire service must be welcomed to join in the current OSHA Combustible Dust Rulemaking process which must also include education, outreach, and training for all stakeholders and not just a select few. At the 2011 OSHA Combustible Dust Expert Forum held in Washington, D.C. not one member from the fire service was invited.
"Houston, we've had a problem".

Learning from Prior Incidents
Similar incident Feb. 2012 at Advanced Environmental Recycling Technologies (AERT), no one was injured in the blast. Dust explosion at Arkansas facility that recycles polyethylene plastic and waste wood fiber in the manufacturing of windows, doors, and decking. AERT wood composite MSDS

Responding to any combustible dust related fire is not a "typical fire." All that is needed to complete the explosion pentagon (fire triangle on steroids) is suspension and confinement. Dust suspension alone can also occur. When extinguishing this type of Class A fire, extreme care needs to be taken. For example, since a direct stream of water into the pile from a fire hose could cause the burning or smoldering material to become airborne resulting in a catastrophic flash fire or even spreading the fire to other areas. Source: Handbook of Industrial Loss Prevention, 1967, Factory Mutual Engineering Corporation, McGraw-Hill Book Company New York, NY.

In Langerak, Netherlands (1993) "firefighters responded to a small fire in a wood fiber processing plant where unexpectedly an explosive spread of fire occurred. As a result, eventually three persons, including two firefighters, deceased and fourteen individuals, most of them firefighters were injured. The fire from the beginning was initially believed to be a fire without special risks."
 

Theres a wealth of scientific and layman literature on the physicochemical properties on combustible dust. The missing link is the practical aspects and hazards of combating a combustible dust related fire,. Such as the example above in caution using a hard stream of water from a hose or a avoiding pressured burst from a fire extinguisher. Then there is the bridging (arching) and ratholing hazards in overhaul of bulk storage enclosures (silios, bins, etc). The list goes on in practical aspects...


Near-Miss Accident Reporting
Reviewing lessons-learned from ComDust incidents on the National Fire Fighter Near-Miss Reporting System site it appears many in fire service management believe the primary consideration is PPE. How about lessons-learned in preventing envelopment by a raging fireball in the first place?

Dec. 21, 2007 "The lieutenant reported that workers were on the scene and that the fire "appeared to be extinguished". The lieutenant and a firefighter stretched a 1 3/4" attack line to an elevated platform approximately 15' from the ground to a hatch on the side of the silo. Once the line was charged the lieutenant opened the hatch and immediately heard a loud roaring sound followed by a flash fire erupting form the hatch opening engulfing the lieutenant."
Hold on the story gets even more interesting...

"The second engine arrived and was given the suppression assignment. The charged hoseline from the first engine was still in place so they utilized it. The second crew was not aware of the events that had taken place, only that the lieutenant was down. Once on the landing, the second lieutenant opened the hatch and again a loud roaring noise followed by a flash fire and explosion occurred engulfing the second Lieutenant and firefighter." Years of fire service experience: 24 - 26, Region: FEMA Region III
We cannot continue to ignore the combustible dust related fires anymore. How many more firefighter fatalities and injuries as a result of combating combustible dust related fires and explosions must occur before it is no longer acceptable?

Resources:
One Firefighter Fatality; Eight Injured WI, NIOSH Accident Report
Seven Firefighters Injured CA Facility, NIOSH Accident Report
Example Fire Department Training Program Compliance with OSHA Regs.
OSHA Combustible Dust Expert Forum, Washington, D.C, (2011)
Composite and PVC Decking 

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