Proposed Combustible Dust PSM Standard

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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

Unions Displeasure with CSB, Tip of the Iceberg

Another salvo was fired at the Chemical Safety Board recommendations, for failure to fully address workplace safety by several unions last week in regards to the INDSPEC Chemical Corporation's release of oleum. Earlier union concerns on the deficient CSB accident recommendations following the deadly explosion at the Slim Jim factory in Garner, North Carolina and T2 catastrophic explosion in Jacksonville, Florida is highlighted when a follow-up on lessons learned does not fully address worker health and safety.

The problem is exacerbated as the union voice only represents approximately 12 percent of the nation's workforce. A recent Bureau of Labor Statistics report on union membership illustrates that out of over 15 million American workers in the manufacturing sector only 1,732,000 are represented by the union. So what about the millions of other non-union workers? Who is representing them when governmental agencies do not fully address workplace health and safety issues?

Mike Wright, United Steel Workers, Health Safety and Environmental Director, was putting it mildly when he stated,"The CSB report process is broken." The problem with CSB's findings and recommendations is much more complex. Especially when only a handful of career governmental employees are directing the nation's occupational health and safety policy through their incomplete recommendations to OSHA.

In all fairness the accident investigations that the CSB conducts in determining root cause has provided essential proactive awareness in protecting the worker. Yet without comprehensive recommendations, injuries and fatalities will needlessly continue to occur when many layers of protection are thoughtlessly overlooked.

Severity of Consequence
The most recent example of CSB's full inattention to the human toil was following the Imperial Sugar refinery dust explosion in which 20 workers sustained life threatening burn injuries and were admitted to the Joseph M. Still Burn Unit in Augusta, Georgia. Six of the workers succumbed to their burns due to the high percentage of total burned surface area.

CSB recommendations included best engineering practices and administrative controls but failed to mention personnel protection equipment (PPE) in the donning of flame resistant clothing (FRC) when working in a environment that posed a potential flash fire or explosive environment, as is the case with combustible sugar dust.

None of the injured workers were wearing FRC's, so the flame front from the dust explosion ignited their clothing, which continued to burn as the flame front passed. The United Steelworkers also raised a concern with CSB concerning the INDSPEC oleum release, where personnel protection equipment was not recommended either.

Probability of Occurrence
Has the Chemical Safety Board forgotten to take into account the entire severity of the consequence in these prior incidents? It's just not the severity of consequence that is at issue but also the probability of occurrence in the risk analysis through lessons-learned. For example, the 2006 CSB Dust Hazard Investigation failed to address the thousands of prior combustible dust related fires and explosions that occurred from 1980-2005.

This resulted in an aberration of fatalities and injuries per incident, occurring in combustible dust related fires and explosions in the manufacturing, non-manufacturing, and utility sectors. The incident data that CSB provided to OSHA, the media, and the public, gave the appearance that fatalities and injuries occur at a high ratio per incident, which is grossly inaccurate.

Incomplete Information
This incomplete picture of the complex combustible dust issue became even more volatile following the catastrophic Imperial Sugar Refinery dust explosion when the House Education and Labor Committee held a hearing on combustible dust fire and explosion hazards in the industrial workplace. Shortly thereafter, a combustible dust bill passed in the House but stalled in the Senate.

The CSB Dust Hazard Study provided the public and stakeholders an excellent summary of fire and explosion hazards that combustible dust poses in the workplace. Yet the incident data concerning probability of occurrence was grossly underreported with mention of only 281 incidents in a twenty five year period in addition to stating that fatalities and injuries occur in 70% of incidents, which is not true.

With the appearance that fatalities and injuries were a regular occurrence in combustible dust incidents, Congress was forced to act. Now with the new administration, OSHA is in the rulemaking process, developing a general industry combustible dust standard. So what's next, a flammable gas, liquid, vapor, and mist general industry standard for fire and explosion hazards. I don't think so, as that doesn't make much sense and neither does a separate combustible dust standard.

Process Safety Management Solution
Instead, combustible dust needs to be addressed as a hazard to workers that provides a potentially explosive atmosphere, like flammable gases, vapors, and mists. Already, for nearly two decades, the OSHA Process Safety Management system (PSM) addresses potentially explosive atmospheres for flammable gases, vapors, and mists. A majority of PSM elements are incorporated in the NFPA combustible dust standards. So why reinvent the wheel when occupational health and safety policy already addresses propagating explosions in the industrial workplace?

Could it be that governmental policy makers do not understand that a flame front from a vapor cloud explosion and dust explosion have similar behaviors. For instance, GexCon has developed a successful Flame Acceleration Simulation Code (FLACS), which utilizes computational fluid dynamics in analyzing the severity of consequence of vapor cloud explosions. This same computer code was utilized in the CSB accident investigation of the 2005 BP Texas City Refinery vapor cloud explosion.

Propagating Explosions
In addition to FLACS, GexCon has developed a Dust Explosion Simulation Code (DESC), which is derived from FLACS gas explosion simulations. Both codes utilize a burning velocity model determining the velocity of the flame relative to the reactants and a flame model that controls the localization and area of the flame. Vapor cloud and dust explosions are propagating explosions that have similiar characteristics of laminar and turbulent flow in their flame fronts. There is much more fascinating science behind this simple explanation and additional information can be found on the GexCon link

Conclusion
The important point here is that a dust explosion is a propagating explosion like a vapor cloud explosion and a separate OSHA combustible dust standard is unnecessary. Already protective and mitigative measures are in place within the OSHA regulatory framework with PSM. All that is needed now is to develop a hybrid PSM for combustible dust fire and explosion hazards. It is much easier for governmental policy makers to develop a separate OSHA combustible dust standard rather than critically analyzing the dynamics of combustible dust related fires and explosions, which are propagating just like vapor cloud explosions.

This alternative solution of combustible dust included in PSM is easier said than done as the damage has already been done with the preponderance of misinformation that's already been portrayed in the media and governmental press releases that all dust explosions can be prevented, fatality/injuries having a high occurrence in combustible dust incidents, and OSHA is at fault for prior inaction, all which are false.

The union's suggestion in their recent media advisory that the public, workers, and industry stakeholders be allowed to participate in the CSB investigation and recommendation process might just be one solution in getting the house in order so as to reduce the probability and minimize the severity of future accidents in the nation's workplace. Yet the problem runs much deeper than that, with the limited budget that the Chemical Safety Board has to work with. Especially with the heavy workload and understaffing investigating industry accidents with limited resources.

14th Annual VOSH Conference: Roanoke,Va

The Virginia Department of Labor and Industry will be hosting the 14th Annual Virginia Occupational Safety and Health Conference (VOSH) June 2-5 2009 at The Hotel Roanoke and Conference Center in Roanoke, Virginia, which is located at the western foot of the Blue Ridge Mountains in Roanoke Valley. Several dozen break-out sessions covering a diverse spectrum of topics on occupational health and safety will provide employers, employees, and health and safety professional the tools in developing a healthy and safer workplace.

Attendees also look forward to the Thursday morning keynote address by Chemical Safety Board Member, the Honorable Gary L.Visscher with the topic, "Heading Towards the Future in Workplace Safety." Visscher was appointed to the U.S. Chemical Safety Board by President Bush on August 2, 2004. Prior to the CSB appointment he served from 2001 as Deputy Assistant Secretary of the Occupational Safety and Health Administration (OSHA).

On Tuesday, June 2, pre-conference events will include an OSHA General Industry 10-Hour Course in addition to an OSHA Construction 10-Hour Course. Instructors from the Virginia Department of Labor and Industry, BECO Construction, Thor, Inc., Southern Air, and Western Refining Yorktown, Inc will be teaching these classes. Course fee is $55.oo

Wednesday, June 3 the VOSH Conference kicks off with Lunch and Conference Opening remarks by C. Ray Davenport, Commissioner of the Virginia Department of Labor and Industry and Jennifer S. Wester, Director of Cooperative Programs. Following lunch, nearly 50 hourly training break-out sessions will continue for two days until adjournment at noon Friday, June 5, 2009

Employers in the Commonwealth of Virginia will not want to miss the Wednesday and Thursday morning breakout sessions that Anna E. Jolly, JD, CHMM, will be presenting on, "Workers’ Compensation vs OSHA Recordkeeping Requirements." Ms. Jolly in addition to being an industrial hygienist is Vice President at Circle Safety and Health Consultants, a full service Occupational Safety and Health consulting company.

Combustible dust hazards topics will also be included at the VOSH conference with presentations that provide insight and potential solutions in minimizing the probability of incidents occuring at facilities. Currently OSHA is in the Prerule stage in developing a general industry comprehensive combustible dust standard and stakeholders must begin developing potential cost effective risk management solutions so as to provide input to OSHA during the comment period of the lengthy OSHA rulemaking process.

Subsequently, the combustible dust sessions will provide an overview of national industries (NAICS) experiencing combustible dust incidents not listed in the Dust NEP in addition to helpful insight and possible cost effective administrative control measures that are also utilized in the OSHA Process Safety Management (PSM) standard where deflagration hazards also exist with vapor cloud explosions.

On-site fee for the VOSH Conference is $290.00. Major contributors to the VOSH conference include:
• Virginia State Association Of Occupational Health Nurses
• Colonial and Tidewater chapters of the American Society of Safety Engineers
• Central and Tidewater VA sections of the American Industrial Hygiene Association
• Virginia AFL-CIO

Resource
VOSH Conference Brochure

Dust Explosions-Not Cleared For Public Release

Its a bit odd and bewildering how data of combustible dust explosions in the Chemical Safety Board, Combustible Dust Hazard Investigation Report that was submitted to OSHA in November 2006 did not include the fatalities and injuries such as the incident that occurred at a Reconstituted Wood Product Manufacturing plant in Mount Jewett, PA back in February 2001. How can appropiate layers of protection be implemented in the workplace if stakeholders do not know the probability and severity of occurrences if full transparency of the complex combustible dust issue is not adhered to?

Incident # 190, which occurred 2/14/2001, is listed in the CSB Dust Incident Data File. But the description is omitted with the statement, "Information not cleared for public release. " How can that be, with the vital information not cleared, when adjacent to the date of the incident is the OSHA Activity Number which provides a description of the above incident and many others labeled "not cleared for public release."?

OSHA has been citing facilities for combustible dust hazards many years prior to the series of catastrophic dust explosions that occurred in 2003. These citations referenced the NFPA Combustible Dust Standards utilizing the General Duty Clause. OSHA through national consensus continues to cite facilities for combustible dust hazards with the power of the General Duty Clause.

Subsequently, OSHA needs to thoroughly review CSB's helpful recommendations in addition to instituting other layers of protection that will provide sufficient preventative and mitigative measures for the workplace in regards to combustible dust hazards. It shouldn't take an Act of Congress with the reissued combustible dust bill to get the ball rolling. Hopefully with the new administration and appointees within OSHA's leadership structure the entire combustible dust issue will be reevaluated in proper context.

The first step must be revising the Combustible Dust NEP so as to reflect the reality of the majority of incidents (over 60%) occuring in national industries (NAICS) not listed in the NEP. OSHA Region 4 has set an excellent example inspecting facilities for dust hazards that are not listed in the Dust NEP. A good rule of thumb would be if a facility has a dust collector on the premises, then there is a potential for a combustible dust related explosion or fire. Think of a dust collector as a hand grenade with the pin pulled and all that is needed next is an ignition source when the lever is released. That just might get everyone's attention with this sort of proactive attitude.

No matter how stringent OSHA enforcement and inspection activities are pursued, combustible dust explosions and fires will continue to occur. Legislators who drafted the current reissued combustible dust bill have all the great intentions in preventing further fatalities and injuries as occurred at Imperial Sugar Refinery last year. But the reality which they must be educated to understand is that dust explosions and fires cannot be totally prevented. Only the probability and severity can be reduced.

A good example is the ethanol plant explosion earlier this month in Hastings, Nebraska with the grain grinder explosion resulting in two injuries. Ethanol plants have the most stringent governmental regulations protecting the worker, public ,and environment with the EPA Risk Management Program (RMP), OSHA Process Safety Management Standard (PSM), in addition to the OSHA Grain Facility Standard. It doesn't get any more stringent than this. The current combustible dust bill as written won't even come close to providing this much of protection. Ironically, with all the layers of protection in this industry, it has the highest rate of explosions and fires over the past twelve months than any of the other 426 national industries (NAICS) in the manufacturing sector.

The current position that legislators and the CSB of possible protective measures is a great start. But should not be the sole solution, especially when other important aspects of the very complex and dynamic combustible dust hazard issue is not also addressed to the full extent. Hopefully insight from continued in-depth research on combustible dust related fires and explosions that the Combustible Dust Policy Institute is conducting will provide additional helpful information on a broad horizon useful to all stakeholders.

Malt Silo Explosion in Germany kills 1, injures 7

http://www.iht.com/articles/ap/2008/11/30/europe/EU-Germany-Factory-Explosion.php

Here in the USA we all pray for the families and emergency responders that experienced a tragic event quite similar to the Imperial Sugar Refinery dust explosion at Port Wentworth, Georgia in Feb. 2008. The German news account stated, "There was a first explosion at 07.00 AM causing the fire fighters to rush in, then at 09.00 AM there was in the midst of firefighting activities a second explosion, fatal for one fire fighter, injuring 7 others." Sounds eerily familiar, a more deadly secondary explosion.

Combustible dust related fires and explosions are a constant threat to fire-fighters responding to such events. In many instances the hazards of seemingly harmless combustible particulate solids that generate combustible dust are unknown.

The explosion severity of many combustible dusts are quite similar to flammable vapors, liquids, and gases. Currently many national manufacturing industries in the USA have not acknowledged this fact.

This catastrophic event in GLOBAL MALT GMBH & CO KG, in Germany should be a wake up call for stakeholders in the USA in following similar process safety management (PSM) programs that are required by OSHA at petrochemical refineries where a thorough process hazard analysis is conducted, which identifies, evaluates, and institutes control measures in lessening the occurrence and reducing the severity of future events.

Note: You can easily translate from German to English if add the Google Toolbar to your browser. Click the link for free download

Photo Credit: SWR

Resources:

Brewing Process-
Dave Statter's Blog: STATter 911
German News Article
Aftermath Pictures http://is.gd/9Dd6

PSM Oriented Towards Dust Hazards?

A process safety management (PSM) oriented program that addresses combustible dust hazards in the manufacturing, non-manufacturing, and utility sectors needs to be implemented as it is in the chemical and refinery sectors. The main problem, is a disconnect concerning wood, food, paper, textiles, etc. process streams as not being considered like the 136 highly hazardous chemicals (HHC) as outlined in OSHA's Process Safety Management regulation (29 CFR 1910.119).

OSHA National Emphasis Programs (NEP)
Last year, the OSHA Combustible Dust National Emphasis Program (NEP) became effective four months after the Petroleum Refinery Process Safety Management (PSM) National Emphasis Program (NEP). There is a vast difference in the two OSHA NEP's with the goal of protecting the nations workforce and outlying communities from the harmful effects of industrial fires, explosions, and toxic releases.

In reviewing the background information for the Refinery PSM NEP, its disturbing when comparing and contrasting fatalities and catastrophes(FAT/CAT) between refineries and facilities that handle combustible particulate solids that generates combustible dust. For instance, on pg. 4 the Refinery NEP states:

"According to OSHA’s IMIS database, since May 1992, 36 fatality/catastrophe (FAT/CAT) incidents related to HHC releases in the refining industry have occurred. These incidents included 52 employee deaths and 250 employee injuries, 98 of these injuries required hospitalization."

Fatalities and Catastrophes (FAT/CAT)
Over the same fifteen year period, according to the results of the Chemical Safety Board Dust Hazard Investigation, there were over 95 fatalities and hundreds of injuries as the result of over 160 combustible dust related fires and explosions in the manufacturing, non-manufacturing , and utility sectors. Basically there are three times as many fatalities and catastrophes (FAT/CAT) in sectors that generate combustible dust than in the refinery sector.

Yet Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) and administrative control measures to protect the manufacturing workplace are dismally lacking. So is the rapidly diminishing manufacturing sector that provides a base for our national economic security even worth protecting? It doesn't seem so with the obvious inattention thats been misdirected elsewhere, to supposedly more urgent aspects of workplace occupational health and safety.

Highly Hazardous Chemicals (HHC)
Combustible dusts have similar explosion severity (Pmax, Kst) effects as flammable liquids, gases, and vapors concerning destructive overpressure, thermal radiation, and ensuing projectiles. Facilities that maintain processes with over 10,000 pounds of flammable liquids and gases must consider these products as highly hazardous chemicals (HHC) as outlined in the OSHA's Process Safety Management regulation (29 CFR 1910.119). So if combustible dusts have similar devastating explosive effects causing fatalities and catastrophes (FAT/CAT) like flammable liquids and gases, why aren't they listed as a highly hazardous chemicals(HHC)?

Wood, food, textiles, paper and many other seemingly harmless materials in manufacturing process streams are not considered toxic, reactive, or corrosive like the over 130 highly hazardous chemicals (1910.119 App A) under the Process Safety Management program. It's their combustible and explosive characteristics that need to be addressed as it is for flammable liquids and gases HHC (highly hazardous chemicals) in the OSHA PSM standards.

Recognizing the hazards of combustible dust is the first step through a process hazard analysis which is the foundation in lessening the occurrence and reducing the severity of future combustible dust related fires and explosions. Once the hazards are identified and evaluated control measures can be implemented in similar fashion as outlined in the OSHA Process Safety Management program. A few of the measures in the current PSM with debatable input to a possible Combustible Dust PSM include:

Operating Procedures
For instance, the implementation written operating procedures addressing operating limits with consequences of deviation with steps to follow to correct deviations such as high operating temperatures. These operating procedures must include safety and health considerations concerning quality control for raw materials and control of dust emissions. Additionally, precautions necessary to prevent combustible dust related fires and explosions, which also includes engineering controls, administrative controls, and personal protective equipment.

Contractor Participation
A process safety management program would also require contractor participlation. Over the past year a large percentage of combustible dust related fires have involved contractors conducting hot work adjacent to process equipment. A Combustible Dust PSM would properly and proactively inform contract employers of the known potential combustible dust fire, explosion hazards related to the contractor’s work and the process. This would lessen the occurrence of future incidents.

Mechanical Integrity (MI)
Mechanical integrity (MI) issues in a Combustible Dust PSM, would address the potential ignition sources that cause combustible dust related fires and explosions at facilities. For instance duct work, dust collectors, dryers, mixers, blenders, ovens, bulk storage enclosures are reoccurring problem areas concerning combustible dust related fires and explosions.

The refinery sector Mechanical Integrity PSM program addresses pressure vessels and storage tanks, piping, relief and vent systems and devices, and emergency shutdown systems controls. In contrast the manufacturing sector has bulk storage enclosures (silos, bins), pneumatic conveying duct systems, air material separators (dust collectors), in addition to relief and venting with explosion ventilation panels in reducing the severity of dust explosions.

Implementing written procedures to maintain the integrity of the above process equipment would provide employees with an overview of the mechanical integrity process and the combustible dust hazards that have been identified in a prior process hazard analysis. Process equipment inspection, maintenance, and testing would also be a vital aspect in the MI at the facility where deficiencies can be addressed in a proactive manner.

Incident Investigation
Reoccurring incidents of combustible dust related fires and explosions have been a common theme in the manufacturing sector over the past year. This year, over 30% of incidents are repeats of prior fires and explosions at facilities. In many instance a combustible dust fire is a precursor to a a rare event, the combustible dust explosion.

Without proper incident investigation by the facility, the exact cause of the fire goes unnoticed and the combustilbe dust hazard remains present for the next preventable and predictable incident. A Combustible Dust PSM would identify the chain of events and causes where corrective measures such as Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) can be developed and appropriately implemented.

Conclusion: Do I feel lucky?
The above examples are just a few proactive measures that could be crucial aspects of a Combustible Dust PSM that is similar to the current PSM utilized for facilities which process highly hazardous chemicals (HHC). Other measures in the PSM include Hot Work Permits, Emergency Planning and Response, Management of Change, and Compliance Audits. Many of the areas are already covered in the National Fire Protections Association (NFPA) combustible dust standards.

Until combustible dusts are recognized as having similar explosive severity characteristics as flammable liquids and gases (highly hazardous chemicals) of the current OSHA PSM, preventable and predictable combustible dust related fires and explosions will continue to occur. Hopefully on a bit of borrowed time the next rare event will not be in the magnitude of the recent Imperial Sugar Refinery dust explosion. Like in the 1971 Dirty Harry movie, Detective Inspector Harry Callahan played by Clint Eastwood asks, "You've got to ask yourself one question: 'Do I feel lucky?"