tag:blogger.com,1999:blog-1874081452734583083.post865916812881068540..comments2023-04-10T08:50:44.255-05:00Comments on Combustible Dust Explosions and Fires-ATEX: OSHA Ventilation Standard Revise for Combustible DustJohn Astadhttp://www.blogger.com/profile/13183032143746688649noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-1874081452734583083.post-50315730491123237852010-01-21T18:45:36.338-06:002010-01-21T18:45:36.338-06:00Good review Anon. If you note the OSHA Combustible...Good review Anon. If you note the OSHA Combustible Dust NEP status report it includes inspection/citation data from October 2007 through June 2009. These dates include during and after the Asst. Secretary Foulke tenure.<br /><br />Disturbing number of GDC violations? The majority of GDC violations were for industrial ventilation such as ductwork and dust collectors. Problem here, is is that 1910.94 Ventilation General Industry Standard was written mostly for occupational hygiene. What about fire and explosion hazards in regards to occupational safety? <br /><br />A quick fix combustible dust standard as being debated does not address the antiquated General Industry Standards. So whats next a Vapor Cloud Explosion Standard, were there are many more fatalities and injuries from vapor cloud fires and explosions?<br /><br />The OSHA standards were never developed to solely provide instructions for best engineering practices. A good example is the refinery industry which utilizes national consensus standards as reference for best engineering practices. <br /><br />Currently the only reason that OSHA is developing a seperate standard is due to the CSB recommendations from the 2006 Dust Hazard Investigation. Not that all of sudden Solis, Michaels and Barb came up with the idea. Solutions in developing layers of protection is much more complex than the subjective recommendations that CSB provided. It is a great start, but much more complex in addressing solutions, which includes outreach, research, information, education, and training as the OSH Act mandated.<br /><br />So special lobbying interests are not involved in the current OSHA rulemaking? Interesting.John Astadhttps://www.blogger.com/profile/13183032143746688649noreply@blogger.comtag:blogger.com,1999:blog-1874081452734583083.post-30015606023818910292010-01-21T09:25:58.470-06:002010-01-21T09:25:58.470-06:00Perhaps the reason why 90% of the violations where...Perhaps the reason why 90% of the violations where for general industry standards in the OSHA Combustible Dust NEP is because of then Asst. Secretary Foulke's stated position that a seprate combustible dust standard wasn't necessary and the hazards being found by complinace officers could be covered under existing standards? In fact, a close reading of the Com Dust NEP directive instructs inspectors to do just that. Yet even with Foulke's stated position and the compliance advice provided in the directive, OSHA compliance officers still had to issue many GDC violations in order to address hazards where their standards failed them. <br /><br />As Rich Fairfax has noted, the uptick in GDC violations as a result of the Combustible dust NEP is indeed "disturbing". When OSHA has to fall back on the GDC, it clearly shows that existing standards are not capable of preventing the hazards and the standard writers need to start scribbling. Looks like Solis, Michaels and Barb recognized this fact and so the process of vetting a new standard has begun. <br /><br />The good news is the standard is being developed under the normal rulemaking process which demands industry participation rather than being adopted according to Congressional mandate where Congress and special lobbying interests would have crafred the language. Let's just hope OSHA can get the job done before we have another Imperial Sugar.Anonymousnoreply@blogger.com