Media Must Cease in Referring West, Texas Facility as a Fertilizer Plant

Fertilizer Plants Defined 101 from Combustible Dust Policy Institute

Quite alarming when nation-wide stakeholders don't believe they have anything in the magnitude of the West, Texas facility such as a fertilizer manufacturer yet have establishments supplying fertilizers to farmer end-users

Don't kid yourself folks, West Fertilizer was not a fertilizer manufacturer either, as the media incorrectly portrays in many instances. The Texas establishment supplied custom blended fertilizer to farmers in the area as a retail establishment in addition to operating a grain handling facility, yet exempt under the OSHA Process Safety Management (PSM) Standard, while handling a Highly Hazardous Chemical (anhydrous ammonia).

The media incorrectly labels the facility as a fertilizer plant. So a bakery that customs mixes flour and sugar is a flour mill or sugar refinery? As a result of this inaccurate information many stakeholders  don't believe they have potential fire and explosion hazards in their backyard.

This is a dangerous trend where safety professionals must educate the media on the facts before others incorrectly believe no hazards exist. Unfortunately Texas authorities did not learn from the Magnablend catastrophe  especially in regards to Local Emergency Planning Committees (LEPC).

NAICS 42451: Grain and Field Bean Merchant Wholesalers, in addition to West Fertilizer covered under EPA RMP handling anhydrous ammonia with OSHA PSM exemption.

Total number of facilities: 82
Number of deregistered facilities: 10
Number of processes that could reach off-site: 82
Total pounds of toxic chemicals in processes: 28,355,310
Total pounds of flammable chemicals in processes: 0
Number of 5-year accidents: 4
Number of deaths from 5-year accidents: 0
Number of injuries from 5-year accidents: 4
Amount of property damage from 5-year accidents: $0

NAICS 424910, Farm Supplies Merchant Wholesalers, additional establishments in USA under EPA RMP handling anhydrous ammonia with OSHA PSM exemption

Total number of facilities: 3,645
Number of deregistered facilities: 601
Number of processes that could reach off-site: 3,738
Total pounds of toxic chemicals in processes: 6,728,564,906
Total pounds of flammable chemicals in processes: 392,870
Number of 5-year accidents: 138
Number of deaths from 5-year accidents: 3
Number of injuries from 5-year accidents: 191
Amount of property damage from 5-year accidents: $209,774

NAICS 493130, Farm Product Warehousing and Storage. in addition to West Fertilizer covered under EPA RMP handling anhydrous ammonia

Total number of facilities: 260
Number of deregistered facilities: 121
Number of processes that could reach off-site: 267
Total pounds of toxic chemicals in processes: 101,485,227
Total pounds of flammable chemicals in processes: 72,000
Number of 5-year accidents: 5
Number of deaths from 5-year accidents: 0
Number of injuries from 5-year accidents: 4
Amount of property damage from 5-year accidents: $0

RMP was last updated on RTK Net with a set of EPA data made on May 30, 2012

TIER II Reporting To SEPC and LEPC's

Tier II in conjunction with LEPC' is a key element where many chemicals are not triggered with  thresholds in the EPA/RMP or OSHA/PSM programs. In contrast, TIER II when used as intended by the LEPC's engages the necessary hazard awareness on the other side of the fence-line throughout the community in preventing, planning and preparing for future accidents.

What is a Texas Tier Two Report?
"Two types of thresholds that determine whether a hazardous chemical will be included on the Texas Tier Two Report:

#1. There are very low thresholds for any of the listed EPA Extremely Hazardous Substances (500 pounds or the Threshold Planning Quantity in pounds for the specific listed chemical, whichever amount is less).

#2. For all other "generally hazardous chemicals" products which require a Safety Data Sheet (SDS) under the federal Occupational Safety and Health Administration's (OSHA's) Hazard Communication Standard], the threshold for reporting is 10,000 pounds."

LIST OF LISTS
• EPCRA Section 302 Extremely Hazardous Substances
• CERCLA Hazardous Substances
• EPCRA Section 313 Toxic Chemicals
• CAA 112(r) Regulated Chemicals For Accidental Release Prevention

"This consolidated chemical list includes chemicals subject to reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA), also known as Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and chemicals listed under section 112(r) of the Clean Air Act (CAA).

This consolidated list has been prepared to help firms handling chemicals determine whether they need to submit reports under sections 302 and 313 of EPCRA and determine if releases of chemicals are reportable under CERCLA and section 304 of EPCRA. It will also help firms determine whether they will be subject to accident prevention regulations under CAA section 112(r)"

3rd IND EX Safety Congress Nuremberg, Germany April 24-25

 

Nuremberg Castle
Photo Credit: Vitold Muratov

Industrial explosion protection IND EX Safety Congress  in conjunction with POWTECH 2013 International Trade Fair for Mechanical Processing Technologies and Instrumentation.For instance, at  POWTECH 2011: 704 exhibitors from 73 countries, 15,498 trade visitors (including TechnoPharm)

Two days of explosion protection session topics which also includes live dust explosions (outdoors) at the Nürnberg Convention Center. IND EX, the German based Association of Experts for Explosion Safety, organizes this two day extravaganza. Keynote Speaker: Dr. Bert Reichert -Nürnberg Hospital for Burn Traumas- "Fatal consequences of insufficient safety concepts - burn and explosion traumas to the human body."

Sessions chaired by Dr.-Ing. Johannes Lottermann, Dipl.-Ing. Richard Siwek, and Stefan Penno

Presentation topics include:

• Dust explosion in a Fiber Board Factory

• Protection of Mixers and Blenders against explosions

• Combustion of Biomass - Influence of material specifications on explosion protection measures

• Are we sure that certified safety systems are really safe?

• Trends in norms, guidelines vs. old school approaches from the past

• The design of explosion proof Battery Rooms for solar driven boats and consequences for other applications in the field of renewable energy

• Modeling of Dust Explosions to determine optimum protection when EN standards and codes are not relevant or considered too conservative

• State of the art in explosion isolation

• Of using a belt as well as additional suspenders: Explosion safety repeated unnecessarily

• Explosion safety goes South America - about the ABNT + its standardization efforts in Brazil

• Simplified explosion protection of filters - explosion venting, explosion isolation + improved separation all in one

•  CFD simulations of the 20 liter explosion vessel

• Dispersion of two-phase jets from accidental releases in hydraulic pipes
• Hydrogen Hazards

 

 

Fact Sheet: 2011 Combustible Dust Related Incidents, NFIRS Analysis

Fact Sheet: 2011 Combustible Dust Related Incidents, NFIRS Analysis from Combustible Dust Policy Institute

A Combustible Dust Policy Institute (CDPI) preliminary analysis of 2011 National Fire Incident Reporting System (NFIRS) incident data provided by the National Fire Data Center of the U.S. Fire Administration indicated over 500 combustible dust related incidents in manufacturing facilities where dust was the item first ignited. Near misses include incidents that did not result in any harm to personnel, the facility, process, or product. Analysis did not include the grain sector or coal-fired energy plants.

Additionally, the CDPI analysis does not include many incidents that were not reported by fire departments to the National Fire Data Center. As a result there are many more combustible dust related incidents that cannot be evaluated in determining whether the incident was a near miss or not. 

Special thanks to the nation's Fire Departments, NFIC State Program Managers, and the National Fire Data Center at the U.S. Fire Administration in sharing this valuable Information.  

Casual Pathways Between Near Misses and Catastrophic Events 

Excellent article by Carsten Busch from Norway, highlighting Common Cause Hypothesis (CCH) which also pertains to near misses and catastrophic combustible dust related incidents. In the current OSHA ComDust rulemaking process and recently reintroduced proposed combustible dust bill H.R. 691, incidents resulting in property/content loss (30% NFIRS analysis) yet no casualties (approximately 95%) are considered near misses. Yet the casual pathways (ignition sources, dust management strategies, etc.) for the consequences of all combustible dust related incidents are all the same. 

The true definition of a "near miss" is an incident not resulting in any harm to personnel, the facility, process, or product. So why are near misses ignored in accounting for combustible dust related fire and explosion hazards in protection of the workplace in the OSHA ComDust rulemaking process and recently reintroduced proposed combustible dust bill H.R. 691?

Report on preliminary findings of a study of incident reporting systems for near misses in non­medical domains. This can also apply to combustible dust related incidents/accidents where NFIRS data provides a multitude of information in developing barriers for the prevention of future accidents.

Near Misses in Non­-medical Domains

"Consequently, the same patterns of causes of failure and their relations precede both adverse events and near misses." Sounds familiar with ComDust related incidents at facilities whether it was flash fire, dust explosion, or layer fire? They all have casual pathways of improperly managed ignition sources and fuel sources. A written fire prevention plan (FPP) addresses these casual pathways initially at the organizational level. The next step would be implementation at the technical and operational level.

"We defined a near miss as any event that could have had adverse consequences but did not and was indistinguishable from fully fledged adverse events in all but outcome." Note: National Fire Incident Reporting System (NFIRS) was not included in the report of near misses in non­medical domains. 

U.S. Chemical Safety Board (CSB): Near Misses.
Dust Explosion Hazard Awareness / Imperial Sugar Management and Workers
(Page 54 .pdf) "The CSB concluded that the small events and “near-misses” caused company management, and the managers and workers at both the Port Wentworth, Georgia, and Gramercy, Louisiana, facilities to lose sight of the ongoing and significant hazards posed by accumulated sugar dust in the packing buildings."

CSB Key Findings: Imperial Sugar Refinery
Page 48 .pdf)  # 4 "Company management and the managers and workers at both the Port Wentworth, Georgia, and Gramercy, Louisiana, refineries did not recognize the significant hazard posed by sugar dust, despite the continuing history of “near-misses’”

Hoeganaes
(Page 14 ,pdf) "Operators and mechanics reported being involved in multiple flash fires during their employment at the Gallatin facility. At the time of the incidents, many were aware that the iron dust could burn or smolder. However, they were not trained to understand the potentially severe hazard when accumulated dust is dispersed in air. Rarely would operators report the minor flash fires and “near-misses” that periodically occurred."

(page 27 .pdf) CSB Recommendations to Hoeganaes 2011-4-I-TN-R9
"Develop and implement a “near-miss” reporting and investigation policy that includes the following at a minimum:"
• Ensure facility-wide worker participation in reporting all near-miss events and operational disruptions (such as significant iron powder accumulations, smoldering fires, or unsafe conditions or practices) that could result in worker injury.

• Ensure that the near-miss reporting program requires prompt investigations, as appropriate, and that results are promptly circulated throughout the Hoeganaes Corp.

• Establish roles and responsibilities for the management, execution, and resolution of all recommendations from near-miss investigations

• Ensure the near-miss program is operational at all times (e.g. nights, weekends, holiday shifts).  

Conclusion 

Near misses can no longer be ignored. It's very distressing that OSHA in the combustible dust rulemaking process in conjunction with the legislators in the reintroduction of the proposed combustible dust bill H.R. 691 have chosen to ignore 95% of combustible dust related incidents in manufacturing facilities, which do not result in personnel casualties. Yet these very same incidents, as history illustrates are precursors to catastrophe. 

 

Explosion Relief Systems Free AIA Webinar May 1st

“Explosion Relief Systems for Low Strength Enclosures”

Date : Wednesday the 1^tst of May 2013 @ 11am EST

C/S Explovent, a division of C/S Construction Specialties, is inviting you to join a free webinar about “Explosion relief systems for low strength enclosures”!

Introduction:

The issue of venting violent overpressures is a critical one for owners of facilities where potentially explosive atmospheres, materials, and processes exist including combustible dust. Recent statistics indicate that the average damage due to explosions in industrial establishments is approximately $3.4 million, compared to $210,000 for  an average fire. The possibility of an explosion occurring must be seen as a real concern considering only three common elements must be in place for an event to occur: ignition source, a fuel, and confinement.  As obvious as it sounds, even fine dust particles and a spark can create an explosive atmosphere.  We might not think of this, but if something can burn, it can likely explode.  

An explosion vent is designed to be the weakest part of the external structure. As the explosion vent experiences the pressure rise, it opens quickly allowing the rapidly expanding heated gases to be released to the outside. By doing so, the internal walls, floor, and ceiling are spared from the damaging overpressure experienced during a deflagration.

To successfully limit damage to the vented area, vent design and the pressure resistant structure must be in keeping with guideline authority recommendations. As such, C/S Explovent® explosion relief systems have been designed in accordance with the NFPA 68 Venting of Deflagrations guideline and Factory Mutual 1-44 Damage Limiting Construction document. Explovent® has been tested, approved, and labelled by Factory Mutual and tested and approved by the Canadian Center for Mineral and Energy Technology for explosion relief applications.

 

Participants will learn:

• What explosion relief is
• What industries have a true need for explosion venting products
• Types of explosions & catalysts as they relate to the industry
• Why explosion venting should be specified
• Code drivers & their impact on today's specifiers
• Overview of available explosion venting products

To register and get more details about this free webinar, just click on the link and follow the step!

About C/S Construction Specialties: For 60 years, Construction Specialties has been a leader in architectural specialty products, including : Acrovyn® Wall and Door Protection, Pedisystems® Entrance Flooring, Expansion Joint Covers, Cubicle Track and Curtains, Smoke and Explosion Venting Systems, Architectural Grilles, Architectural Louvers and Sun Controls.  We have operations throughout the world and can provide C/S Products virtually anywhere. For a complete list of our international locations, visit www.c-sgroup.com.

This presentation is AIA Accredited

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