Thursday, March 28, 2013

California Lower Rate of Combustible Dust Related Incidents Due to FPP?

How come California with more manufacturing facilities than any other state (approx. 40,000 establishments-U.S. Census Bureau-2010) yet has a lower rate of combustible dust related incidents than any other state? Could it be that they require fire prevention plans (FPP) for all facilities whereas other states don't? Shouldn't a state with the highest number of facilities also have the highest number of incidents? Quite interesting accidentally connecting the dots between combustible dust related incidents in a preliminary analysis of 2011 NFIRS data and fire prevention plans (FPP) 29 CFR 1910.39.

It’s back to school for us all after coming across this helpful resource with the University of California Riverside's Fire Prevention Plan (FPP) providing an excellent framework with FPP key elements as required by the California Code of Regulations (CCR) Title 8, Section 3221. The detailed FPP document includes a section on Fire Extinguishers where "all faculty and staff are annually provided the opportunity to receive hands-on training and experience in using portable fire extinguishers."

California is one of the approved State Plan States that went beyond minimum federal OSHA regulatory requirements concerning FPP's (Exemptions. 1910.157(b)(1))  For example, California facilities not requiring the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal are required to have a Fire Prevention Plan (CCR Title 8, Section 3221).

Whereas Federal OSHA states don’t require a Fire Prevention Plan (FPP) in this scenario unless the facility follows under one of these three host standards: Ethylene Oxide, 1910.104, Methylenedianiline, 1910.1050, and 1,3 Butadiene, 1910.105. Additionally FPP required where the written fire safety policy requiring the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal.

With a bit of imagination the University of California Riverside's Fire Prevention Plan (FPP) provides an excellent framework for a voluntary FPP’s which should include controlling ignition and fuel sources in the prevention of combustible dust fires and explosions. The U.S. Chemical Safety Board (CSB) did not make any FPP recommendations in the 2006 Dust Hazard Study. As a result OSHA has not recognized FPP in the 2008 Combustible Dust National Emphasis Program (NEP), 2009 Combustible Dust Advanced Notice of Proposed Rulemaking, 2011 OSHA Combustible Dust Expert Forum, nor on the OSHA Combustible Dust Hazards webpage. The Democrat Committee Education and the Workforce has acknowledged this error with the reintroduction of the proposed bill, "H.R. 691 Worker Protection Against Combustible Dust Explosions and Fires in the Workplace," where 40% of the requirements in the bill are from content in the OSHA Fire Prevention Plan (FPP) 29 CFR 1910.39.

Fire prevention plans (FPP) are an excellent administrative and procedural control measure in minimizing the probability of occurrence of future combustible dust related incidents by managing and controlling potential ignition and fuel sources. Without FPP's  combustible dust related incidents will continue to occur in an unabated manner. The majority of combustible dust related incidents are "near misses" precursors to catastrophe. As a result combustible dust hazards are primarily a fire issue and secondarily a potential explosion problem.


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