OSHA Ventilation Standard Revise for Combustible Dust

Reviewing the recent OSHA Combustible Dust NEP status report (Figure 6) illustrates that 90% of the citations for combustible dust arose from OSHA General Industry Standards. Approximately 10% of the citations were General Duty Clause citations where a majority of examples were for ventilation such as ductwork, dust collectors, and other aspects of the dust collection system used in ventilation. (pages 7-10 of 12 page .pdf)

The current OSHA General Industry Ventilation Standard 29 CFR 1910. 94 includes elements that address dust hazards in abrasive blasting, grinding, polishing, and buffing operations. Problem is, the Ventilation Standard originates more from an industrial hygiene viewpoint, where attention is directed towards respiratory hazards such as silica sand inhaled during blasting operations. What about combustible dust fire and explosion hazards from inadequate ventilation throughout the manufacturing sector?

Local Exhaust Ventilation
A key aspect in the fire triangle in reducing the possibility of a combustible dust fire or explosion is to remove the combustible dust fuel load. Good housekeeping alone will not completely remove the dust fuel load in most manufacturing processes, so dilution ventilation or local exhaust ventilation (LEV) must be utilized. Local exhaust ventilation (LEV) is the most effective in reducing explosive combustible dust concentrations.

Local exhaust ventilation (LEV) includes four major components: exhaust hood, ductwork, fan/ motor, and dust collector. The system must be properly designed and maintained so as to prevent and mitigate possible combustible dust related fires and explosions. Many of the combustible dust related fires occur or progress into the ventilation system. So it is extremely important that spark detection/flame suppression, abort gates, and explosion ventilation be incorporated in the industrial ventilation system.

General Industry Standards
The OSHA General Industry Ventilation Standard 1910.94(a)(2)(iii), does note that for abrasive blasting, the principles set forth in the National Fire Protection Association Explosion Venting Guide, NFPA 68-1954 be adhered to. What about other manufacturing processes where flammable or explosive dust mixtures may be present? There is a disconnect in many other General Industry Standards in not addressing combustible dust hazards such as in Hazard Communication, Housekeeping, and PPE. It's odd that Powered Industrial Trucks and Hazardous (Classified) Locations General Industry Standards address combustible dust, yet the majority of other General Industry Standards do not.

A proposed separate combustible dust standard does not address the antiquated OSHA General Industry Standards where many of the standards are from an industrial hygiene standpoint that fails to comprehensively address fire and explosion hazards concerning occupational safety. The Ventilation Standards in the maritime, construction, and general industry is an excellent example of this weakness.

For example, ventilation fire hazards in spray finishing are addressed in regards to solvent vapor there is the requirement 1910.94(c)(6)(ii) to dilute solvent vapor to at least 25 percent of the lower explosive limit of the solvent being sprayed. What about minimum explosive concentrations (MEC)/lower explosive limit (LEL) for combustible dust that is captured in the industrial ventilation system that are also possible fire and explosion hazards thoughout the manufacturing sector?

Potentially Explosive Atmosphere
Until OSHA recognizes that combustible dust is a potentially explosive atmosphere like in the above example for solvent vapors there will be a weakness in the Ventilation Standards that is mostly directed towards industrial hygiene. An excellent example where our international trading partners do understand that combustible dust poses an explosive atmosphere like flammable vapors, gases, and mists is the U.K DSEAR and EU ATEX Directives

OSHA cannot continue to address Industrial Ventilation as the most important engineering controls solely from an industrial hygiene standpoint. Industrial safety is just as important and must be on the flip side of the coin. The OSHA Salt Lake Technical Center(SLTC), which edited the informative and educational OSHA Ventilation Health and Safety Topics page should know better. Especially when SLTC is conducting all the testing for combustible dust ignition sensitivity and explosion severity.

U.S. Bureau of Mines
Over two decades ago Martin Marietta Laboratories and Marcom Associates, Inc. under contract from the U.S. Bureau of Mines (USBM closed in 1995 and transferred to NIOSH in 1996), prepared an excellent 220 page document, "Dust Control Handbook For Mineral Processing." The educational content was mostly centered on respiratory hazards concerning industrial hygiene in the mineral processing industry.

Many of the excellent chapters are applicable to the design and maintenance of industrial ventilation so as to minimize combustible dust fire hazards. In addition to the resource being located on the OSHA Safety and Health Topic Silica, Crystalline pages it should be cross-referenced on the OSHA Safety and Health Topic Ventilation Additional Information page.

Conclusion
In conclusion from reviewing the OSHA Combustible Dust NEP status report it appears that too much emphasis is being directed toward the General Duty Clause. Especially when over 30 percent of the report provides examples of General Duty Clause combustible dust citations where a majority of these citations are for industrial ventilation issues. What the ComDust NEP status report failed to emphasize, was the 90% of citations arose from General Industry Standards. Powered Industrial Trucks was not even included in Figure 7 of the report. Many of these antiquated General Industry Standards have not come to terms with combustible dust fire and explosion hazards from an industrial safety standpoint.

A separate combustible dust standard will provide many with a warm and fuzzy feeling but does not address an alternative regulatory approach in revising the current General Industry Standards so as to comprehensively come to terms with the 21st century occupational safety fire and explosion hazards in the workplace.

Resources
Designing Dust Collection Systems by Gary Q. Johnson-Workplace Exposure Solutions

State OSHA Plans Absent

After seven months collecting data of over 90+ combustible dust related explosions and fires from media accounts, the questions arises if any trends are developing throughout the nation in the manufacturing sector? The most glaring trend is State OSHA participation of combustible dust inspections and enforcement is minimal.

Explosions are happening in nearly 20% of incidents and repeatable incidents over 30% . The dust collector is involved in over 40% of events, either from a spark traveling downstream through the duct work or ignition originating locally in the air material separator.

General Duty Clause
Reviewing over 4,500 OSHA inspection reports on the IMIS Database that CSHO's have completed in the last twelve months and comparing with all the NAICS in Appendix D-1/D-2 of the OSHA Combustible Dust National Emphasis Program (NEP) Directive, resulted in 24 combustible dust General Duty Clause citations.

None of the GDC combustible dust citations occurred in a locale with a State OSHA Plan. According to the OSHA Combustible Dust NEP, it's strictly voluntary for these states to conduct targeted NAICS inspections and enforcement for combustible dust violations as outlined in the NEP. This presents a huge problem and a distorted picture of actions concerning federal OSHA offices in conjunction with the overall Combustible Dust NEP program.

North Carolina leads the OSHA State Plans in conducting inspections with an emphasis on combustible dust at manufacturing facilities throughout the state. In contrast, CHSO's from Pennsylvania federal OSHA offices lead the nation issuing General Duty Clause citations for combustible dust.

Prior Dust Inspections
Additionally, the media and congressional leaders have absorbed the political spin of an independent governmental investigative agency that submitted recommendations to OSHA in 2006. An emotional knee jerk reaction to the recent Imperial Sugar Refinery dust explosion and prior catastrophic dust explosions in 2003 in conjunction with the CSB recommendations resulted in drafting a combustible dust bill that now awaits a vote in the Senate.

After several congressional hearings on combustible dust, the word out on the street is that OSHA is not doing it's job in enforcement and inspection activities concerning combustible dust. How can this be, especially when Federal OSHA offices have been citing facilities on combustible dust violations for many years prior to the Imperial Sugar Refinery explosion?

Two OSHA's
In contrast, according to media accounts, over 50% of combustible dust explosions in the last seven months have occurred in states with State OSHA Plans, where an organized proactive Combustible Dust NEP is absent. Basically, there are two different and totally separate OSHA's nationwide, which is divided amongst Federal and State offices. Collecting data of recent combustible dust incidents reinforces the fact of two separate OSHA entities.

Collective Cooperation
A comprehensive combustible dust regulation will not solve the problem of preventable combustible dust related explosions and fires. It's only through the combined efforts of State and Federal OSHA offices in conjunction with local fire inspectors where the complex combustible dust issue can be addressed properly.

OSHA does not have the personnel and financial resources to inspect more than 10% of manufacturing facilities in the nation. What about the other 90% ? Cooperation with state and local Authorities Having Jurisdiction (AHJ) is the direction all stakeholders should be championing in developing a proactive comprehensive combustible dust plan. Not a comprehensive combustible dust regulation with the absent financial backing.

Costly Dust Testing
Incident data illustrating State OSHA Plan inactivity does not truly represent the entire situation. For example, additional funding is needed for combustible dust testing in manufacturing facilities, which would enhance State OSHA inspection and enforcement activity. Laboratory testing at the OSHA Salt Lake Technical Center for ignition sensitivity and explosion severity is very expensive, costing thousands of dollars.

Why wasn't this crucial aspect of the combustible dust bill discussed during the several congressional hearings? Who is going to pay ? It all looks good on paper and makes one feel warm and fuzzy but the reality begins to sink in when viewing the data of what actually is occuring.

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General Duty Clause Citations 9/07-9/08
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