It's the fires, stupid, Dust Explosion Precursors

Dust fire sends Elkhart plant employees into cold

It's the fires, stupid. Another combustible dust related fire, precursor to potential dust explosion. The NFPA Fire Analysis and Research Division report on U.S. STRUCTURE FIRES IN INDUSTRIAL AND MANUFACTURING PROPERTIES reported that annually 29% of the reported structure fires involved shop tools and industrial equipment. In 15% of fires, the leading area of origin was the process or manufacturing area or workroom. Additionally, leading items first ignited in 10% of fires was dust, fiber, lint, sawdust, or excelsior in industrial and manufacturing properties.

Potentially Explosive Atmospheres Global Requirements

DOWNLOAD Intertek WHITE PAPER:
"Potentially Explosive Atmospheres Requirements"

Complete the registration form with the link below to receive a free copy of Intertek's informative white paper, and learn more about the differences between North American and European rules.

via intertek-etlsemko.com

Excellent Intertek document that explains global classification systems of potentially explosive atmospheres such as flammable atmospheres of gases, mists, liquids, combustible dusts, and fibres. Describes important differences between the Zone (Europe and NEC505) and Division (NEC500) systems in hazardous (classified) locations?

Posted via web from ComDust

Proposed Combustible Dust PSM Standard

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ComDust_PSM_Std_proposed.pdf (169 KB)

Here is an idea on how a proposed OSHA Combustible Dust Process Safety Management Standard (PSM) could look like as an alternative regulatory approach. The commonality of combustible dust fire and explosion hazards in the workplace is process equipment. The most controversial aspect of a proposed ComDust PSM would be the threshold level. This is an area were valuable input from all stakeholders is needed. Many elements of PSM already are incorporated in the NFPA Combustible Dust Standards. So what do you think?

Posted via email from ComDust

Authority Having Jurisdiction-ComDust Explosive Atmospheres

I'd like to share this post that was authored by Robert Zuiderveld, General Manager at Pyroban Corp in the ComDust discussion group. It is an interesting and informative post as it provides insight regarding AHJ approval of powered industrial truck in a potentially combustible dust explosive atmosphere.OSHA PIT 1910.178 violations where third most cited violation according to the recent OSHA status report of the Dust NEP program

John called me and asked, " if getting a letter from a AHJ other than OSHA stating that the use of "S" type equipment in 1910.178 - Powered industrial trucks. 1910.178(c) Designated locations, Dust hazardous areas is OK and would satisfy OSHA regulatory requirements?"

NFPA 70 (aka NEC):
I always go back to this document since it is one of the few that get regularly updated and actually offers good answers to many questions in article 500:

Page 70-360 paragraph 500.8(A) states: Suitability of identified equipment shall be determined by one of the following:

(1) Equipment listing or labeling
(2) Evidence of equipment evaluation from a qualified testing laboratory or inspection agency concerned with product evaluation (RZ note: NOT necessarily and NRTL).
(3) Evidence acceptable to the authority having jurisdiction such as a manufacturer’s self evaluation or an owners engineering judgment.

Authority Having Jurisdiction (AHJ).
An organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure.

FPN: The phrase "authority having jurisdiction," or its acronym AHJ, is used in NFPA documents in a broad manner, since jurisdictions and approval agencies vary, as do their responsibilities. Where public safety is primary, the authority having jurisdiction may be a federal, state, local, or other regional department or individual such as a fire chief; fire marshal; chief of a fire prevention bureau, labor department, or health department: building official; electrical inspector; or others having statutory authority.

For insurance purposes, an insurance inspection department, rating bureau, or other insurance company representative may be the authority having jurisdiction. In many circumstances, the property owner or his or her designated agent assumes the role of the authority having jurisdiction; at government installations, the commanding officer or departmental official may be the authority having jurisdiction.

At the end of the day the burden of proof that equipment is unsafe rests on OSHA shoulders. You can get a letter from the Pope, but if OSHA can easily prove that your practices endanger the welfare of your employees then you are in violation. If they take you to court, and evidence is so obvious that they are right, you are out of even more money. This is the case with using any UL approved “S” type in any explosion hazardous areas. It is not a question if it is going to happen, more a question of when?

If you don’t wear a seat belt while driving a car, you will be fine until you get into an accident. If you use UL approved "S" type equipment in explosion hazardous areas you will most likely start a fire or blow yourself when an accidental release takes place.

It is possible to challenge a OSHA judgment, but you must be able to substantiate your claims and provide evidence. Historic fact is not a solid defense in the age of IT. -Robert Zuiderveld

John's Note:
Robert is referring to type S equipment, in NFPA 505, which you'll find in the top row of Table 4.2 Summary Table on Use of Powered Industrial Trucks.

In row 13, For Class II Division 2 Group G, you'll notice 11 different types of equipment that are listed, seven which require AHJ approval. But thats the problem, these haven't be certified for explosive atmosphere. Only EX is certified for explosive atmosphere by UL.

Contact Info
Robert Zuiderveld-General Manager at Pyroban Corp.

T: +1-973-748-0760
F: +1-973-842-0508
E: salesusa@pyroban.com

Resources,
Ignition source protection gaps
UL Letter- Explosive Atmospheres Certification
NFPA 505 Powered Industrial Trucks

Minimizing the Severity of Consequence

http://www.inmaricopa.com/NEWS/NewsArticleDetails.aspx?ArticleID=6798&&mid1=390

Early morning fire and explosion at Pinal Energy ethanol plant. This is an excellent example of NFPA combustible dust standards best engineering practices minimizing the severity of consequence of combustible dust related fires and explosions. In reality, combustible dust explosions cannot be totally prevented, only the probability of occurrence reduced and the severity of consequence minimized.

200+ Combustible Dust Fires and Explosions in 2008

A new year is upon us. Will we learn from the past? Through media accounts, the Combustible Dust Policy Institute researched over 200+ combustible dust related fires and explosions that occurred in 2008 in the grain, manufacturing, non-manufacturing, and utility sectors. Good housekeeping is a partial solution in preventing and mitigating incidents, especially in regards to secondary explosions, but only one aspect of a multi-dimensional complex subject concerning combustible dust hazards.

For instance, utilizing good engineering practices (GEP) as outlined in the NFPA Combustible Dust Standards would assist in lessening the likelihood and reducing the severity of many incidents that occurred in 2008. Additionally, administrative controls such as hot work permits, inspection, maintenance, and employee/contractor training of combustible dust hazard awareness would proactively provide enhanced measures cost effectively.

The recent grain facility dust explosion in Arizona is a wake up call that dust explosions are prevalent across all sectors. Combustible dust related fires and explosions is an inherent throughout industry. It's only through mitigative and preventative measures that potential fatalities, injuries, and adverse impact will be lessened.



The Combustible Dust Policy Institute proposes an alternate solution addressing the entire spectrum of combustible particulate solids that generate combustible dust across all sectors. Instead of haphazardly piecing together costly regulations singling out individual occupational sectors. Legislators must be educated that all explosions transform energy into blast waves (overpressure), thermal radiation, and ensuing projectiles. It doesn't matter if its runaway reaction explosion, condensed phase explosion, vapor cloud explosion, or dust explosion.

NFPA 654, "Standard for the Prevention of Fires and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids," has already provided a good start in considering a regulatory framework with mention of a process hazard analysis as already implemented at refineries with the OSHA process safety management (PSM) program. For instance. 29 CFR 1910.119 is intended to prevent or minimize the consequences of a catastrophic explosion from a process.


What about combustible dust explosions in other occupational sectors that are of high consequence like the catastrophic Imperial Sugar Refinery explosion earlier last year and now this past week the Arizona Grain explosion that sent three workers with burn injuries to the hospital ? Scientific data compiled from laboratory combustible dust testing has proven that the devastating blast waves and thermal radiation from dust explosions are just as devastating as a vapor cloud explosions.

The learning curve is now complete concerning the hazards of combustible dust in the workplace. All stakeholders must cohesively work together with local, state, and national governmental leaders in developing a comprehensive combustible dust occupational safety framework that ensures the safety of all workers in explosive high consequence occupations.

For additional information on identifying, evaluating, and controlling the hazards of combustible dust related fires and explosions, the Combustible Dust Policy Institute in conjunction with the 4th Annual Industrial Fire, Safety, and Security Conference -IFSS 2009 will be hosting a Two Day Combustible Dust Hazard Workshop at the Reliant Center(next to the Astrodome), February 3-4, 2009, in Houston Texas.

Concerned stakeholders will acquire important information during Day One of the workshop that can be utilized in preventing and mitigating future incidents in addition to understanding the necessary steps in achieving regulatory compliance concerning the OSHA Combustible Dust National Emphasis Program.

Currently a situational awareness is lacking nationwide that combustible dust also poses a potential explosive atmosphere in the same light as flammable gases, vapors, and mists. Instead of vapor cloud or BLEVE explosions that occur in the refining sector there are deflagrations and dust explosions in the manufacturing sector.

Day Two of the workshop will include fire-fighting suppression techniques, equipment, and training resources that are currently available. In addition to active participation through panel discussions, Fire Chiefs from around the nation that respond to combustible dust incidents will share successful fire-fighting tactics in combating combustible dust fires.

WHO ATTENDS IFSS Workshops and Seminars?

Attendees from across the United States converge at IFSS every year to meet with their peers - industrial emergency response and security leaders throughout the industrial and energy marketplace.

INDUSTRIAL FIRE, SAFETY & SECURITY Attendees Include:

FEDERAL/STATE/

MUNICIPAL

* Regulatory Agencies
* Emergency Management Departments
* LEPC's - Local Emergency Planning Committees
* Municipal Fire Districts - Mutual Aid

OPERATORS/INDUSTRY

* Oil & Gas Exploration & Production
* Refineries
* Petrochemical/Chemical Facilities
* Pipelines
* Terminals/Storage Facilities
* Power Plants
* LNG Facilities
* Process Industries
* Transportation/Shipping/Rail
* Emergency Response Teams
* Industrial Fire Brigades
* Security

Preparing for Tomorrow’s Emergencies in Today’s World.

EH&S. Hazmat. Fire. Security. Rescue. Safety. Medical.
Whatever aspect of emergency management you work in, IFSS is the essential destination for staying ahead of the curve – and getting that edge that can make all the difference in your next situation.

IFSS delivers an unsurpassed learning experience!

* Learn about best practices for all types of incidents from industry leaders and technical experts.
* Get three days of answers to your most pressing questions.
* Discover the most innovative products and services at a one-of-a-kind exhibition.
* Hear about valuable “lessons learned” from true-life situations.
* Connect with your peers from around the country.

IFSS is only four days… but the value it provides will pay off all year-long. You will take-away intel, insights and info that will help you on an ongoing basis as you protect America's industrial plant facilities, personnel, energy infrastructure, and critical assets against all hazards.


IFSS 2009 Conference Contacts
Phone: (832) 242-1969
Fax: (832) 242-1971

# # #

The goal of Combustible Dust Policy Institute is to minimize the severity and reduce the occurrence of combustible dust related fires and explosions in the global workplace. Through ongoing exchange of best practices and lessons learned of combustible dust related incidents, which identifies and evaluates risk, the Institute shares risk assessment information that a diverse spectrum of members utilize in effectively controlling combustible dust hazards. Assisting stakeholders in this endeavor, health and safety compliance is effectively achieved in addition to reducing preventable workplace fatalities, injuries, and adverse economic impact. Contact John Astad, Chairperson :Combustible Dust Hazard Workshop@ 409-440-7185

OSHA Grain Facility Standard Not Working

If the OSHA grain facility standard is suppose to reduce the prevalence of combustible dust accidents in the grain industry here in the United States, then why has 10 grain facility explosions occurred over the past ten months? Since the tragic Imperial Sugar Refinery dust explosion, the Combustible Dust Policy Institute has recorded on the Google Grain Facility Incident Map through online news reports, 17 combustible dust fires and explosions at grain facilities with 35% of these events occurring as explosions.

In contrast, over the past six months with over 70 combustible dust explosions and fires in the manufacturing sector, 22 % have been explosions. Surprisingly, the number of injuries when comparing to combustible dust events between the two industry sectors are approximately the same.

Acceptable Explosions
Recent Senate testimony at a combustible dust hearing by governmental officials have stated that the number of grain facility combustible dust fires and explosions have been reduced since the OSHA Grain Facility Standard was introduced two decades ago. So what is an acceptable number of accidents if combustible grain dust explosions and fires are happening at the same pace as incidents in manufacturing plants?

The only difference between the two is the tragic event at Imperial Sugar, which gained the attention of congressional leaders to take preventative action. It's only a matter a time before the magnitude of the Georgia event catches up with the grain industry.

Take a fast rewind over 3o years ago, to 1977 when several grain silo facilities eerily exploded within days of each other creating a heavy death toll. It was these events that initiated legislation for the OSHA Grain Facility Standard. Earthquakes on the West Coast of high magnitude in metropolitan areas have the same effect. The events are spaced out many years apart but still result in high fatalities, injuries, and extreme economic damage.

Right Idea...Misguided Approach
It's commendable that legislators desire OSHA regulations with protective action to prevent further workplace injuries and fatalities. The problem is with the methodology in achieving this goal. For example, regarding the case with Imperial Sugar and the huge loss of life, concerned legislators were immediately outraged as was the public. Something had to get done and quickly to prevent additional occurrences of accidents of that magnitude. Quick it was, then ensuing congressional testimony began to turn into attacks on OSHA, the director of OSHA, and even the Secretary of Labor.

This is where the problem arose in drafting the Worker Protection Against Combustible Dust Explosion and Fires Act (H.R. 5522). Emotions entered into the picture instead of a reasoned approach which should of consulted all stakeholders concerning life safety, structural integrity, mission continuity, and mitigation of fire and explosions as outlined in the National Fire Protection Association (NFPA) standards.

Jurisdictional Collaboration
Congress needs to reevaluate the stark and unyielding provisions of the pending combustible dust bill, which has all the good intentions of accident prevention and worker safety. Instead the local jurisdictional aspect with collaborative partnerships must be aligned between federal, state, and local entities in the prevention and mitigation of future combustible dust incidents.

Already it is proven the federal provision in the OSHA Grain Facility Standard does not reduce the occurrences of combustible grain dust incidents. How can it? Doesn't take much higher math to figure there are not enough OSHA inspectors to inspect all the grain facilities on a regular basis. Besides it's not up to the federal government to ensure a facility will not go off like a Chinese bottle rocket to the moon at moments notice.

An excellent example of local jurisdictional cooperation with state, local, and federal alliances is Homeland Security. Billions of dollars have gone into that program and millions more too local and state jurisdictions. Is Homeland Security working? Maybe it's too early to tell. But the resources have been spent. Isn't our nations manufacturing sector just as vital or important?

Photo Credit: OSHA

Dust Explosions Prior to Senate Hearing

Three days prior to the July 29, 2008 Senate Hearing on workplace Safety, “ Dangerous Dust: Is OSHA Doing Enough to Protect Workers,” ICO Polymers in Asbury, New Jersey witnessed an early morning explosion that severely burned one worker who is in critical condition with burns to his face and arms from the explosion in the plastic pulverizing unit. In the same week four other combustible dust incidents occurred throughout the nation. The cause at ICO Polymers is yet to be determined but all the ingredients are there again for another combustible dust explosion.

Prior Explosions
For instance, one year ago, last July, the same facility experienced a similar event that after an OSHA accident investigation, was deemed a combustible plastic dust explosion in Building One’s Ambient Mill. Where micronized powders of polypropylene, polystyrene, and ethylene were allowed to accumulate, which ignited and exploded, injuring a worker who suffered burns to his hands and back of his head. In this recent incident, New Jersey Fire Officials closed the facility due to the extensive structural damages to the building, which posed an imminent threat.

Recent news reports in the Hunterdon County Democrat, uncovered additional fires at the ICO Polymers facility in 1999 and several explosions in 1997, 1990, and 1989, which also injured workers. In earlier years the plant was owned by Wedco. Change of ownership has not reduced the severity or magnitude of injuries with the events reoccurring in an alarming manner.

Combustible Dust Legislation
A troubling aspect of the recent Senate hearing on combustible dust in conjunction with the recent explosion in New Jersey is that our nation’s legislators and policy makers don’t seem to understand the magnitude of the complex issue concerning combustible dust.

Since the “Worker Protection Against Combustible Dust Explosions and Fires Act of 2008,” was introduced by Congressman George Miller (D-CA) on March 4, 2008 as a result of the February 7, 2008 catastrophic Imperial Sugar Refinery dust explosion in Port Wentworth, Georgia there have been prior hearings held in Congress. Basically, the message has been the same at all the congressional hearings, that there is a problem with the hazards of combustible dust in the nation’s manufacturing sector workplace.

NFPA Combustible Dust Standards
Yet no consensus solutions have been proposed. Instead sole blame has been placed on OSHA which doesn’t have a general industry comprehensive combustible dust standard like the grain facility standard that is already part of OSHA work-place health and safety standards since 1989.

The central aspect of the proposed legislation is incorporating National Fire Protection Association (NFPA) combustible dust standards. This is would be great if OSHA had enough resources to inspect the thousands of manufacturing plants in the nation but it doesn’t. So how will such regulations be enforced unless Congress appropriates additional funding to OSHA? It’s like declaring war yet not sending the troops for lack of funding.

Manufacturing facilities are already required to follow NFPA combustible dust standards through general consensus and nationally recognized standards of care which is recognized by the American National Standards Institute (ANSI). When a violation of combustible dust is found, OSHA inspectors can cite the facility under the General Duty Clause (GDC), Section 5(a)(1) of the Occupational Safety and Health Act.

Local Jurisdiction Enforcement
Local fire and building inspectors that already conduct local inspections need to be utilized more thoroughly in the prevention and mitigation of future combustible dust fires and explosions. These are the professionals that are on the front lines daily and interact daily with local fire departments concerning specific issues that need to be addressed concerning the life safety and structural integrity of commercial buildings.

Fire codes such as the ICC International Fire Code and NFPA Uniform Fire Code already address combustible dust with references to the numerous NFPA combustible dust standards. Following the 2006 Combustible Dust Hazard Investigation, the Chemical Safety Board in addition to recommending an OSHA comprehensive combustible dust standard also outlined that many fire and building inspectors are not knowledgeable concerning combustible dust hazards.

Why hasn’t this aspect of preventing and mitigating future combustible dust incidents been included in congressional testimony? Instead attention has solely been directed at the recent Imperial Sugar incident and placing blame on OSHA as a solution in the policymaking process.

Conclusion
While all the political spin and maneuvering between both political parties concerning labor and business has been taking place over the past five months in regards to pending combustible dust legislation, over 70 combustible dust related fires and explosions have occurred in the nation’s manufacturing sector. The Combustible Dust Policy Institute has discovered through research that approximately 20% of these events are combustible dust explosions and an alarming number are reoccurring like the ICO Polymers accident last week.

A comprehensive combustible dust bill will not solve the problem of combustible dust fires and explosions. It’s only through the cooperation between all stakeholders throughout the national, regional, and local levels that the complex issue of combustible dust can be properly addressed in lessening the severity of future incidents.

OSHA Combustible Dust Blame Game

Over the past year OSHA has constantly been negatively portrayed in the national headlines concerning workplace safety issues. Several weeks ago CBS 60 Minutes aired a segment, questioning whether current OSHA workplace health and safety regulations are adequate in protecting the nation's workforce from the hazards of combustible dust in the manufacturing sector.

Prior to this sensationalism in journalism , the House Education and Labor Committee through the leadership of Congressman George Miller (D-CA), drafted a crafty bill and held congressional hearings on combustible dust. Now after passage in the House, HR 5522, the Worker Protection Against Combustible Dust Explosions and Fires Act awaits hearings and a vote in the Senate and eventually the Presidents signature.

False Presumption
Through all the political hoopla and national media attention after the tragic sugar dust explosion at the Imperial Sugar Refinery on February 7, 2008 in Port Wentworth , Georgia many including the provider of content on this site have mistakenly concluded that OSHA is at fault in not providing sufficient combustible dust regulations. This is a false presumption when the facts of the complex combustible dust issue are revealed.

Its much easier for congressional leaders to place all the blame on OSHA instead of fully researching the cause and effect of combustible dust incidents. Unfortunately, the media picks up on this misinformation and political spin that is perpetuated in conjunction with the Imperial Sugar Refinery tragedy.

Local Issue not Federal
Hazards of combustible dust in the manufacturing sector is a municipal, state or regional issue, not a federal problem. Whenever there is a fire or explosion at a manufacturing facility with combustible dust involved, who are the first responders in extinguishing the fire? Of course, it's either the facility fire brigade or the local fire department.

What jurisdictional protections must be followed to ensure the life safety and structural integrity of commercial buildings is instituted and maintained? Yes, thats correct, building and fire codes. Since when has it been OSHA's responsibility to act as first responders to industrial fires and enforcement of fire codes?

Fire Codes
Currently states are either utilizing the International Code Council, International Fire Code (IFC) or the National Fire Protection Association, Uniform Fire Code(UFC) with references to the numerous NFPA combustible dust codes. Following the 2006 Dust Hazard Study, the Chemical Safety Board determined that many fire inspectors are not knowledgeable concerning the hazards of combustible dust that are referenced in the fire codes. Additionally, the CSB report discovered that the IFC or UFC fire codes adopted by several states had not been properly addressed in relation to combustible dust concerning commercial buildings.

Standard of Care
So is the fire code issue an OSHA problem? As enforcement action, OSHA currently utilizes the General Duty Clause for manufacturing facilities that violate workplace health and safety standards concerning combustible dust hazards. These standards in addition to current OSHA regulations include nationally recognized standards of care that is recognized by industry consensus through the American National Standards Institute (ANSI). Many of these standards of care include NFPA 484 (metal dust), NFPA 664 (wood dust), NFPA 61 (agricultural/food dust), NFPA 654 (combustible particulate solids), and NFPA 120 (coal dust).

Conclusion
The combustible dust bill, HR 5522, the Worker Protection Against Combustible Dust Explosions and Fires Act is redundant, which will require OSHA to incorporate the NFPA combustible dust codes that already are part of state fires codes. Furthermore, OSHA does not have enough financial resources and inspectors to inspect local manufacturing facilities with regularity like local jurisdictions do.

Georgia has taken the lead in requiring manufacturing facilities that generate combustible dust to register with the state. This action is similar to the European Union combustible dust ATEX directive requiring explosion protection document submittal from manufacturing facilities. Workplace protection from the hazards of combustible dust need not be controlled at the federal level.

Instead of the question,"Would combustible dust explosions occur if an OSHA comprehensive combustible dust standard was instituted?" The appropiate question would be, "Would combustible dust explosions occur if current fire codes followed the references to the NFPA combustible dust codes?"

Oregon OSHA Aknowledges Combustible Dust Hazard

http://www.oregonlive.com/business/index.ssf/2008/06/state_warning_of_dust_hazards.html

An interesting article was published today in the Pacific Northwest, written by veteran reporter Anne Saker of the Oregonian concerning Oregon OSHA and the hazard alerts the agency has sent out to approximately 2,500 manufacturing facilities in the state that handle combustible particulate solids which have the potential in generating combustible dust.

Combustible Dust Hazard Alerts is an excellent venue in bringing out an awareness concerning combustible dust. A follow-up to hazard alerts would be training concerning the complexities of combustible dust hazard recognition, hazard assessment, explosion hazard management, and understanding the numerous National Fire Protection combustible dust codes.

Other states can learn from example where Georgia is hosting a Fire Safety Symposium July 14-18 2008, which includes two days of training concerning combustible dust hazard recognition, which will be presented by Guy Colona, NFPA Vice President of Chemical Engineering and Amy Spencer NFPA Senior Chemical Engineer. Relying solely on good housekeeping is only one aspect of the solution in preventing and mitigating future combustible dust fires and explosions.