Over 17,000 combustible dust related fires (1980-2005) USA

NFIRS Data From USFA

Extrapolating NFPA's Fire Analysis and Research Division estimates  from the report "Fires in U.S. Industrial and Manufacturing Facilities," provides in-depth insight into combustible dust related fire statistics in manufacturing facilities from the 2006-2010 period. Subsequently, the Combustible Dust Policy Institute noted over 17,000 combustible dust related fires in the twenty-five year period 1980-2005 while extrapolating the 2006-2010 data. Dust, fiber, or lint (including sawdust) was the item first ignited in 12% of 5,670 manufacturing facility fires/ (2006-2010) annual average. Data from the U.S. Fire Administration’s (USFA) National Fire Incident Reporting System (NFIRS) and the NFPA annual fire department experience survey was utilized in compiling NFPA Fire Analysis and Research Division estimates.

The educational NFPA report provides valuable insight into area of origin, heat source, factors contributing to ignition, and equipment involved in ignition (EII). For example, the leading factor contributing to ignition was mechanical failure or malfunction. Regarding heat sources, the leading factor was unclassified heat from powered equipment followed by radiated or conducted heat from operating equipment.


                                Manufacturing Facility Fires (2006) Source: NFIRS 5.0 USFA

To assist stakeholders in understanding the modules in the NFIRS reporting system here is a list of several elements regarding ignition with their pages from the NFIRS 5.0 Reference Guide. Note: This is a large file (9.7  mb) and may take considerable time to download on slower connections.

Area of Fire Origin 4-13

Heat Source  4-17

Operating Equipment

Hot or Smoldering Object

Other Open Flame or Smoking Materials

Chemical, Natural Heat Sources

Heat Spread From Another Fire. Excludes operating equipment.

            Other Heat Sources

Item First Ignited 4-19

Cause of Ignition 4-24

Factors Contributing to Ignition 4-25

Mechanical Failure, Malfunction

Electrical Failure, Malfunction
Design, Manufacturing, Installation Deficiency

Operational Deficiency

Equipment Involved in Ignition 4-29

Shop Tools and Industrial Equipment

Manufacturing establishments diminished from 373,000 (1990) to 332,000 (2007), a 11% decrease in manufacturing facilities. In a ten year trend of nonresidential fires (1992-2001) there was a 21% decease in fires. (page 119 .pdf)

Nonresidential Fires (1992-2001)

USFA and U.S. Census Bureau statistics depicting decreases in nonresidential fires and manufacturing establishments illustrates a higher number of annual fires in the 25 year period (1980-2005) than in the more recent (2006-2010) time-frame. As a result, the 680 combustible dust related fires annual average (2006-2010) would extrapolate into even more annual incidents from 1980-2005.

U.S. Bureau of Labor Statistics: Manufacturing Establishments (2001-2011)

Very Unusual Trend

U.S. Fire Administration: Fire Estimates. Manufacturing Fires Drop 38% (2007-2010) From 6,200 (2007) to 3,900 (2010), during the same period nonresidential fires drop 18%. U.S. Bureau of Labor Statistics indicated the number of manufacturing establishments dropped 7%. So has incidents of combustible dust related fires and explosions also dropped 38% in the 2007-2010 time frame?

About NFIRS
NFIRS is not representative of all fire incidents in the United States and is not a census of fire incidents or casualties. For example,  NFIRS is a voluntary system, and it includes only those fire incidents reported to the system by fire departments that report to NFIRS. Also, not all States participate in NFIRS, and all fire departments that report to NFIRS within a State do not necessarily report all of their fire incidents. Additionally, some fire departments that report fire incidents do not report associated casualties. States and/or fire departments that report in one particular year may not report to NFIRS the following year.

Partial list of Federal Government organizations (page 12 .pdf) that use NFIRS: U.S. Consumer Product Safety Commission, Military Services (Air Force, Army, Coast Guard, Marines, Navy), U.S. Commerce Department, National Institute on Standards and Technology, Center for Fire, Research, U.S. Department of Transportation, National Highway Traffic Safety Administration, U.S. Congress, House Basic Research Subcommittee, U.S. Public Health Service, Centers for Disease Control and Prevention, U.S. Department of Justice, Federal Bureau of Investigation, U.S. Department of Housing and Urban Development, U.S. Department of Treasury, Bureau of Alcohol, Tobacco, and Firearms, Library of Congress, etc.

• NFIRS is the world's largest, national, annual database of fire incident information.
• 50 states and the District of Columbia report NFIRS data.
• 37 fire departments with a population protected of over 500,000 participate in the NFIRS.
• About 23,000 fire departments report in the NFIRS each year.
• The NFIRS database comprises 75 percent of all reported fires that occur annually.

Like many of the above governmental organizations, why didn’t the OSHA Directorates use NFIRS fire incident data when developing the OSHA Combustible Dust ANPRM for the rulemaking process? Only relying on incomplete CSB incident data (281 incidents 1980-2005) does not provide stakeholders enough information so as to understand the complexities and magnitude of the combustible dust fire problem in the USA manufacturing sector. As a result of solely using CSB incident data, the definition of combustible dust is explicitly in “suspension” and ignores layered combustible dust related fires (dust not in suspension). So what do you think, should we continue to ignore combustible dust related fires not in suspension?

Resources:
NFPA's "Fires in U.S. Industrial and Manufacturing Facilities"
NFIRS Reporting Form
Uses of NFIRS
NFIRS 5.0 Reference Guide 
Nonresidential Building Fires (USFA) page 75 Mfg. Buildings
Nonresidential Fire Trend 2006-2010
OSHA Combustible Dust; Advance notice of proposed rulemaking

Error in OSHA Combustible Dust; Advance Notice of Proposed Rulemaking

Reviewing the OSHA advance notice of proposed rulemaking (ANPR) creates quite a concern. For example in the second sentence of the "Summary" at the top of the page, "For the purposes of this notice, the term "combustible dust" includes all combustible particulate solids of any size, shape, or chemical composition that could present a fire or deflagration hazard when suspended in air or other oxidizing medium"

So for combustible dust to be hazard it must be suspended in air? What about smoldering layers of dust which also fire and explosion hazards? Before dust can be in suspension it first must be layered on horizontal surfaces. Personnel have been fatally and severely injured from smoldering dust initially not in suspension. Additionally facilities have burned to the ground due to layers of dust.

The problem of OSHA defining combustible dust solely in suspension became readily apparent when trade associations submitted comments in response to the ANPRM requesting their NAICS be removed from "Table 1--Industries Having at Least One Recorded Combustible Dust Incident Reported Since 1980," since combustible dust incidents at facilities they represented were dust layered fires and not in suspension. Was the Dust Incident table (page 43 .pdf) listing severity of consequences (Kst's) instead of NAICS, during a topic of discussion at the 2011 OSHA Combustible Dust Expert Forum a response to the turmoil of defining combustible dust solely in suspension?

There is no mention whatsoever in the OSHA Combustible Dust ANPRM about catastrophic combustible dust related fires as a result of layered dust not in suspension. In stark and awakening contrast, the NFPA Fire Analysis and Research Division prepared a report, "Fires in U.S. Industrial and Manufacturing Facilities" providing  insightful information regarding combustible dust related structure fires in manufacturing properties from 2006-2010. The NFPA report noted that shop tools and industrial equipment were involved in 29% of these structure fires. 

Most importantly dust, fiber, or lint (including sawdust) was the item first ignited in 12% of manufacturing facility incidents. This would equate to over 600 combustible dust related incidents annually. A vast and disturbingly revealing  difference from the 2006 CSB Dust Hazard Investigation Report identifying 281 combustible dust incidents from 1980-2005, or approximately 11 incidents annually. The educational NFPA report obtained fire incident data from the US Fire Administration's National Fire Incident Reporting System (NFIRS) data in conjunction with NFPA’s annual survey of U.S. fire departments. 

Its quite alarming where our global trading partners in the IECEx Scheme and European ATEX System recognize dust layers as a fire and explosion hazard yet here in the USA we do not recognize these immediate hazards in the current combustible dust rulemaking process. Continuing to proceed in solely defining combustible dust as a hazard in suspension and ignoring dust layers will have serious consequences in the future as experienced now and in the past. Is it time for a revision of the OSHA Combustible Dust; Advance Notice of Proposed Rulemaking in accordance with reality or should we continue while in error? 

On a side note, do you know the burning behavior of your dust? Additional information on burning behavior (VDI 2263). Currently OSHA nor CSB recognizes burning behavior in evaluating combustible dust fire and explosion workplace hazards.Unfortunately, we'll have to wait for another catastrophe before burning behavior is reconized like it is amongst our international trading partners.