Identifying Facility NAICS: OSHA Combustible Dust NEP

Many stakeholders are not aware if a facility is identified in the OSHA Combustible Dust National Emphasis Program NEP) for targeted inspections. Here are a few helpful steps to assist in obtaining the NAICS six digit designation then comparing with the NAICS in Appendix D-1 and D-2 of the OSHA ComDust NEP.

Step 1

Go to the OSHA Integrated Management Information System (IMIS) database and type the facility name in the Establishment Search

Here is an example of a facility already entered in IMIS:

Hoeganaes Corp
Gallatin, TN

SIC: 3399/Primary Metal Products, Not Elsewhere Classified

NAICS: 331111/Iron and Steel Mills

If the OSHA IMIS search does not populate a facility then an alternative would be to use the EPA Envirofacts search tool

Acquiring a NAICS at times can be frustrating and very time consuming since the above search methods will not always be successful. If the Standard Industrial Classification (SIC) is known, that will assist in determining the NAICS. For example type the SIC in the Google search box.

Google Search: SIC: 3399

The first hit at the top of the web page should be the Reference for Business website where the NAICS are found.

Step 2

Once the facility NAICS is obtained the next step is comparing the NAICS six digit designation with the NAICS in Appendix D-1 and D-2 of the OSHA ComDust NEP

Combustible Dust National Emphasis Program (Reissued) Page 35-37 D-1 and D-2

(html version) OSHA ComDust NEP

Next time you read a news account of a combustible dust related fire or explosion use the above exercise to determine if the facility is recognized in the OSHA NEP for targeted inspections. Don’t be surprised if the NAICS is not specified in D-1 or D-2 of the ComDust NEP.

There are many elements in the NEP that have successfully educated stakeholders in identifying, evaluating, and controlling the hazard. Yet when fatalities and serious injuries occur in NAICS not recognized in the NEP this presents a serious problem. One more fatality or injury as a result of a workplace combustible dust related fire or explosion is not acceptable. The workplace is reaching a point of, “Occupy Combustible Dust Fires and Explosions.”

Update: NAICS Exercise: Chocolate and Confectionery Manufacturing from Cacao Beans
January 29, 2012 Workers burned at chocolate factory. Use steps above to determine if facility NAICS is recognized in OSHA Combustible Dust NEP.

November 29, 2007 Explosion Valencia, CA
May 20, 2001 Chocolate Factory Blast Chicago, IL

Example General Duty Clause Citation at Chocolate Factory 06/03/2009

Michigan Composites Fire and Explosions

Yesterday morning 8/14/08, a devastating fire at Michigan Composites, a marine urethane core component facility on the south side of Nile, Michigan resulted in nearly a dozen fire departments responding with over 70 firefighters from two states. Residents in over 40 homes were evacuated and a three mile radius safety perimeter was implemented by fire protection officials.

News accounts have reported that workers heard numerous explosions following a machine that caught fire. Additionally, the owner stated the fire started in the dust collection system in a piece of sanding equipment. Hopefully the fire investigation results of the cause of the tragic fire will be forthcoming soon. In the meantime, workers at the plant no longer have a place of employment in the already economically depressed state of Michigan.

Urethane core components in the manufacturing subsector 326 Plastics and Rubber Products Manufacturing follow under NAICS 326150 Urethane and Other Foam Product (except Polystyrene) Manufacturing. Reviewing the OSHA Combustible Dust NEP, it's noted that this niche industry has a Potential for Combustible Dust Explosions/Fires in Appendix D-2.

The U.S Census Bureau historical statistics for NAICS 326150, highlights 623 establishments in the United States that utilize urethane in the manufacturing process. Since the beginning of the year, OSHA has inspected 19 of these establishments, or three percent, in the entire nation according to the Integrated Management Information System (IMIS) database.

California (74), North Carolina (60), Texas (47), and Michigan (44) are the leading states in this NAICS. So far none of Michigan 's NAICS 326150, that are similar to Michigan Composites have been inspected this year. Would an OSHA prior inspection prevented or reduced the severity of yesterdays devastating fire that wracked havoc on the Niles, Michigan community?

Composites is an interesting subject. In the maritime construction of yachts it is an excellent substitute for wood. When utilizing this building material, either low density polyisocyanurate foams or high density polyurethane foams are used . Manufacturers can combine the two to achieve even more diverse results. In the manufacturing process when utilizing polyisocyanates, additional provisions must be incorporated in the collection of dust due to its nature in shedding dust very easily.

A questions arises by the casual observer whether the above foams provided the dust in the dust collection system that contributed to the explosions and fire that was mentioned by the plant owner and workers in earlier news reports. Only time well tell the final results of the fire investigation. In the meantime, the other 622 establishments spread across the nation, with NAICS 326150 (Urethane and Other Foam Product (except Polystyrene) Manufacturing) can reassess their preventative and mitigative measures in reducing potential fire and explosion hazards from combustible particulate solids.

Recent Urethane/Plastic Combustible Dust Related Fires and Explosions

• 7/1/08 Cope Plastics -explosion/fire dust collector
• 5/6/08 Apex Millworks-fire in urethane dust bin/ sanding
• 3/30/08 Quality Cushion & Pad- polyurethane foam-fire/grinding

News Update: Niles Daily Star Friday, August 15, 2008 5:31 PM EDT

According to Niles Township Fire Chief Gary Brovold, the fire started when sparks coming from a sanding unit spread to what sales manager Brian Carpenter called "polyurethane saw dust."