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.

 

Questions, Problems, Feedback? Please send email by clicking this link...Thanks

©Copyright 2008-2012. Combustible Dust Policy Institute
The information in http://dustexplosions.blogspot.com/ is not meant to be a substitute for the Code of Federal Regulations (CFR), Federal Register, and other OSHA documents, which should serve as the primary source of regulatory guidance. The information on this site should not be used in place of appropriate technical or legal advice related to your company's specific circumstances. Combustible Dust Policy Institute tries to provide quality information, but we make no claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained in or linked to this web site and its associated sites. Combustible Dust Policy Institute has no liability arising from or relating to the use, interpretation, or application of the information or its accuracy or inaccuracy. Copyright notice: All materials in this site are copyrighted by the Combustible Dust Policy Institute. No materials may be directly or indirectly published, posted to Internet and intranet distribution channels, broadcast, rewritten for broadcast or publication or redistributed in any medium without permission.