2008 Dust Explosions and Fires Overview

The Combustible Dust Policy Institute found through researching media accounts in 2008 that over 150+ combustible dust related fires and explosions occurred in the manufacturing, non-manufacturing and utility sectors in the United States. Over 30% of these incidents are repeats of prior fires and explosions that fire departments are responding to. Subsequently, these reoccurring incidents mostly go unnoticed by OSHA, unless there are at least three injuries or one fatality.

The current OSHA Combustible Dust National Emphasis Program (NEP) directive does not address the majority of national industries (NAICS) where incidents are frequently occurring. For example, over 60% of incidents in 2008 occurred in national industries not listed in Appendix D-1 and D-2 of the NEP. Too much emphasis and resources is being directed toward the OSHA Dust NEP, when the majority of incidents are occurring in national industries not referenced in the NEP.

To further complicate the situation, the Chemical Safety Board Combustible Dust Hazard Study did not include in the profile of affected industries, the Paper, Textile, and Non-Manufacturing subsectors as industries where a combustible dust hazard exists. For example, in 2008, over 22% of incidents occurred in these subsectors. Without this important information, OSHA did not include paper national industries in the NEP. Over 10% of combustible dust related incidents in 2008 occurred in paper national industries.

In contrast, over 7% of incidents in 2008 occurred in the rubber/plastics subsector, where these national industries were referenced 90% of the time in the OSHA Dust NEP. A NAICS listing in the NEP does not guarantee the probability of occurrence will be lessened. For instance, the national industry NAICS: 326150/Urethane and Other Foam Product Manufacturing, the U.S Census Bureau lists over 433 firms in the USA. In 2008, OSHA inspected 9% (37) of these facilities with only three inspected for an emphasis on combustible dust.

For 2008, media accounts of combustible dust related fires and explosions occurred in thirty-six states. The states with 10 more or more incidents included Ohio (12), Illinois (10), Maine (10), Pennsylvania (10), and Iowa (10). Injuries occurred in 12% of the incidents. Of the total incidents reported by the media in 2008, 20% were combustible dust explosions.

Reviewing the the grain sector, through media accounts, over 50 combustible dust related fires and explosions occurred in 2008 with over 30% (15) were dust explosions. The adverse economic impact from dust explosions in this sector was much greater than the economic impact from explosions in the manufacturing sector. A question does arise if it makes good sense to model the current pending combustible dust legislation after the OSHA Grain Facility Standard, when so many injuries and economic damage is occurring from dust explosions similar to what’s happening in the manufacturing sector?

This brief overview of combustible dust related incidents in 2008 will hopefully provide all stakeholders additional insight into the complexity of combustible dust hazards in the workplace. The current occupational health and safety regulatory framework does not currently address the magnitude of the problem that encompasses all the national industries where incidents are repeatedly occurring throughout the manufacturing and non-manufacturing sector.

Ill Advised Combustible Dust Bill

The current combustible dust bill waiting for a vote in the Senate and passed earlier in the House is a faulty draft of proposed OSHA health and safety legislation. Posing as a quick fix with no bite, due to the lack of OSHA resources. Policy- makers failed to take in account the magnitude of the problem with the prevalence of combustible dust fires and explosions occurring across a wide swath of the manufacturing sector.

Furthermore, utilizing OSHA’s Combustible Dust National Emphasis Program (NEP), as recommended by the Chemical Safety Board does not fully address many manufacturing sectors that are experiencing combustible dust explosions and fires that were not included in the NEP.

North America Industrial Classification System (NAICS)
Of particular importance when assessing industries that have a frequent and/or high consequence of combustible dust explosions and fires is an understanding of the North America Industrial Classification System (NAICS), that OSHA utilizes in Appendix D-1 of the Combustible Dust NEP.

NAICS is a six digit hierarchical industry coding and classification system that the Bureau of Labor and the U.S Census Bureau also utilizes to measure economic activity in the United States. It enables policy-makers across a wide spectrum of government to understand the business cycle and how it relates to the flow of trade.

U.S. NAICS example

• Sector 33 Manufacturing
  • Subsector 339 Miscellaneous Manufacturing
    • Industry Group 3399 Other Miscellaneous Manufacturing
      • Industry 33994 Office Supplies (except Paper) Manufacturing
        • U. S. Industry 339941 Pen and Mechanical Pencil Manufacturing

Older Standard Industrial Classification (SIC) system
NAICS groups are divided into 20 sectors, with five sectors goods-producing and fifteen services-producing sectors. The NAICS system replaced the older Standard Industrial Classification (SIC) system beginning in 1997. Additionally, there are 474 NAICS industries in the manufacturing sector from a total of 1,170 NAICS industries in contrast to the 1,004 found in the previous SIC.

A confusing aspect of the 2006 Chemical Safety Board, Combustible Dust Hazard Study is that the data spreadsheet referenced combustible dust incidents from 1980-2005 with the old SIC system. For the user of the data, it very difficult to ascertain the specific national industry that experienced combustible dust accidents. In contrast, OSHA began using the North American Industry Classification System (NAICS) for industry identification back in January 2003.

In addition to Appendix D-1, with the listing of 17 manufacturing NAICS in the OSHA NEP, there is Appendix D-2, listing another 50 manufacturing NAICS. OSHA believes these industries may have potential for combustible dust explosions/fires instead of a high frequency rate like in D-1.

Invisible Industries
This is where the problem arises, in solely relying on the OSHA Combustible Dust NEP as a yardstick for whether or not a manufacturing facility has a dust problem or not. The Combustible Dust Policy Institute has discovered through intensive research utilizing media reports and interviews over the past six months that 64% of the 70 combustible dust related explosions and fires since the Imperial Sugar Refinery explosion are not listed in Appendix D-1/D-2 NAICS list of the OSHA Combustible Dust National Emphasis Program (NEP).

Furthermore, of the 16 combustible dust explosions that have occurred, only 50% of the NAICS are listed in the NEP. How can a sound preventative safety policy be instituted if over 50% of the nation’s manufacturing sectors are ignored?

Photo Credit: by exfordy on Flickr "Creative Commons"