OSHA Combustible Dust National Emphasis Program (NEP) a Dismal Failure

"Assistant Labor Secretary Jordan Barab says he believes it's too early to assess the effectiveness of the program." Too early to assess? So how many more catastrophes like Hoeganaes must occur before we figure out the Combustible Dust National Emphasis Program (NEP) is a dismal failure?

Since 2008, through researching media accounts of combustible dust related fires and explosions the Combustible Dust Policy Institute has determined that over 50% of incidents are occurring in specific industries (NAICS) not recognized in the OSHA ComDust NEP.

Subsequently, the CSB Hoeganaes Case Study recommendation "Revise the Combustible Dust National Emphasis Program (NEP) to add industry codes for facilities that generate metal dusts(e.g., North American Industrial Classification System, NAICS, code 331111 Iron and Steel Mills, and other applicable codes not currently listed)," is only the tip of the iceberg.

What about the dozens of other industries throughout the entire manufacturing and non-manufacturing sectors not recognized in the NEP having a history of combustible dust incidents? Let’s stop fooling around and attempting to segment specific industries while Rome is burning. If you have combustible dust at your facility then it does not matter what you’re NAICS specific industry classification is.

As retired University of Michigan Professor of Aeronautical Engineering Bill Kauffman stated in the article, "It's not rocket science," If you don't believe it then check for yourself in the next news account of a combustible dust related incident where the specific industry (NAICS) is not recognized in the ComDust NEP. If this isn't a failure then I don't know what is.

Explosion Suppression and Spark Detection

The 2008 Process Technology Expo International Conference to be held at the Donald Stephens Convention Center on the outskirts of Chicago on May 6-8 2008 is the extravaganza to attend concerning combustible dust explosion prevention and mitigation equipment. Exhibitors will be displaying new technologies that the process manufacturing industry utilizes in the prevention and mitigation of future preventable and predictable combustible dust incidents.

Since the tragic Imperial Sugar explosion there's been over 30 combustible dust fires and explosions throughout the United States. OSHA's Combustible Dust National Emphasis Program highlights nearly 70 North American Industrial Classification codes (NAICS) of over 63,000 firms that have frequent and/or high consequence combustible dust explosions/fires in addition to industries that may have potential for combustible dust explosions/fires

The Combustible Dust Policy Institute has localized an additional 47,000 (NAICS) firms that also have occurrences of combustible dust related fires and explosions. With over 110,000 firms potentially exposed to explosive atmospheres in the process manufacturing industries, its' crucial that proactive measures be instituted

Initially firms must conduct a risk analysis of their unique processes in determining if hazards exist. For a minor investment of several thousand dollars, commercial testing facilities can assist in determining the minimum ignition temperature, minimum ignition energy , minimum explosive concentration, and explosive severity of the dust generated in their process.

With the information obtained concerning the ignition sensitivity and explosion severity, plant management can plan on the technical mitigative and preventive measures to implement. Protective and mitigative equipment could include spark detection systems, spark suppression, mechanical isolation valves, explosion vent panels, in conjunction with a multipoint monitoring system.

The PTXi show in Chicago will have a diverse spectrum of combustible dust protection manufacturers exhibiting such equipment and answering technical questions that arise concerning specific applications in the thousands of process industries throughout the nation.

Hope to see you there.

Explosion Protection Resource

(OSHA) Combustible Dust National Emphasis Program (NEP)

2008 Process Technology Expo International Conference

North American Industry Classification System (NAICS)