Combustible Dust Hazards Training-Strategic Alliances

Stakeholders across a wide spectrum of industry through education can minimize the occurrence and reduce the severity of combustible dust hazards that are inherent aspect of the manufacturing process. Strategic alliances of user groups, safety councils, OSHA regional offices, and industry leaders are vital in developing a situational proactive awareness in reducing fatalities, injuries, and adverse economic impact caused by combustible dust related fires and explosions.

OSHA Regional Training
MNOSHA (State OSHA Plan) which is part of the Minnesota Department of Labor and Industry consists of separate enforcement and consultation services. Through the Workplace Safety Consultation Division, MNOSHA has already presented two combustible dust training seminars in St. Paul and Cloquet and will be presenting the third seminar, " Preventing Combustible Dust Explosions," seminar November 19, 2008 in St. Cloud, MN. Seating is limited, call 651-284-5060 for additional information.

Currently MNOSHA is working on adopting the Federal OSHA Dust NEP, which is voluntary for the 22 states that have their own separate State OSHA Plan. An excerpt from the Novemeber 2, 2007 Minutes of the Occupational Safety and Health Advisory Council mentions MNOSHA's "Intent to Adopt Identical" combustible dust emphasis program as outlined in the Federal NEP. Hopefully in the future other State OSHA Plan states will follow the example that is being developed in Minnesota. In the meantime MNHA is hosting combustible dust seminars in a strategic alliance with BS&B Pressure Safety Management

User Group Training
Manufacturing and Energy Utility user groups are vital in addressing their membership concerning "best practices." The PRB Coal Users Group is actively addressing the hazards of combustible dust in coal fired energy plants. When referring to the Combustible Dust NEP in Appendix D-1, Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires. coal fired energy plants are noted as NAICS 221112, Fossil Fuel Electric Power Generation . The PRB Coal Users Group in conjunction with Power Magazine is offering a Webinar "Combustible Dust: Proactive approaches to managing combustible dust,"
on Tuesday, October 28, 2008 at 10AM Central.

Safety Council Training
The Illinois Safety Council (ISC) has hosted several combustible dust training seminars over the past several months. Working closely with John Newquist, OSHA's Region V Assistant Regional Administrator for State Cooperative Programs and Joe Howicz, CSP and Fire Protection Expert, ISC will host additional training at the University of Illinois October 30, 2008 and November 20, 2008 with the Combustible Dust Explosion Inspection Seminars.

Industry Training
Chilworth Technology, an industry leader in providing process safety services throughout the industry is offering several one-day combustible dust training courses "OSHA Dust Explosion Inspection Preparatory Training," during November and December in Georgia, New Jersey, and Illinois. Chilworth Technology offers a wide range of consulting services in preventing and mitigating combustible dust hazards.

Combustible Dust Policy Institute
It's important that all stakeholders with concerns of combustible dust hazards work together through strategic alliances in addressing the complex issue of combustible dust . The Combustible Dust Policy Institute serves as an informational gateway in providing a situational awareness throughout the manufacturing and utility sectors. Feedback and input is much appreciated and I welcome visitors to the Combustible Dust site in joining the professional combustible dust network on LinkedIn.

The mission of the Combustible Dust Policy Institute is to minimize the severity and reduce the occurrence of combustible dust related fires and explosions in the nation’s workplace. Through ongoing research of combustible dust related incidents, which identifies and evaluates risk, the Combustible Dust Policy Institute provides risk assessment information that a diverse spectrum of stakeholders utilize in effectively controlling combustible dust hazards. Assisting stakeholders in this endeavor, health and safety compliance is achieved in addition to reducing workplace fatalities, injuries, and adverse economic impact.

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.

Google Map Web Links

State OSHA Plans

General Duty Clause Citations 9/07-9/08
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