Friday, February 15, 2013

Inaccurate Data Distorts Complexities of Combustible Dust Hazards

Columbia Graphophone of 1901.

It's like a broken record going round and round for nearly a decade with inaccurate incident data distorting the complexities of workplace combustible dust hazards. Now the Democrat House Committee on Education and the Workforce has reintroduced a combustible dust bill  (H.R. 691) utilizing the same inaccurate incident data (approximately 10 incidents annually) as OSHA utilized in the 2009 Combustible Dust Advanced Notice of Proposed Rulemaking ANPRM (page 2 .pdf Table 1).

CSB stated in a disclaimer from their 2006 Dust Hazard Study, "The combustible dust incidents included here are likely only a small sampling, as no federal or state agency keeps specific statistics on combustible dust incidents..." This is an inaccurate statement especially since local fire departments, state fire marshals, and the National Fire Data Center/U.S Fire Administration of the Department of Homeland Security collects specific data on combustible dust incidents in accordance with the Federal Fire Prevention and Control Act of 1974 with the National Fire Incident Reporting System (NFIRS). For instance NFIRS data element #94 (dust, fiber, or lint. Includes sawdust) as item first ignited is entered in the NFIRS Fire Module (page 104 .pdf) by local fire departments following a response to an incident.

The Combustible Dust Policy Institute (CDPI) conducted preliminary analysis of NFIRS 2006 and 2011 combustible dust related incident data and determined between 500-600 combustible dust related incidents occurring annually in manufacturing plants, not 10-15 annually as indicated in the 2009 OSHA Combustible Dust ANPRM published in the Federal Register and recent Democrat House Committee on Education and the Workforce press release.

If congressional and administrative policy makers cannot accurately identify the magnitude of the combustible dust problem then how can it be expected to comprehensively evaluate the situation so as to develop cost effective control measures in protecting the nation’s valued workforce?

Comparing the partial success of the OSHA Grain Facility Standard in mitigating and preventing grain explosions to non-grain facilities generating combustible dust is like comparing apples to oranges. There are tens of thousands of facilities in a multitude of sectors in addition to manufacturing with combustible dust fire and explosion hazards compared to the much smaller number of grain facilities.

There is no doubt a standard or regulation is needed either through legislative action or OSHA administrative action. It’s like pouring the concrete foundation for a house or high-rise, you need plenty of rebar so the foundation does not become unstable later on. Not acknowledging the magnitude of combustible dust incidents fails to identify the precursors to catastrophic combustible dust incidents. A misguided and not well thought out regulation will only provide a warm and fuzzy feeling with huge economic and fire safety implications.  

NFPA Report:
Fires in U.S. Industrial and Manufacturing Facilities
OSHA Combustible Dust Expert Forum (page 45 .pdf  Dust Incidents Table)
The Many Uses of NFIRS Data


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