Dust Explosions: Prevention and Mitigation in the Grain Industry

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James E. Maness, President of JEM Safety Consultants shares with readers an excellent overview in the prevention and mitigation of combustible dust related fires and explosions. Back in the 1980's when the OSHA Grain Handling Facilities Standard was being developed, Mr. Maness chaired the NGFA's Safety, Health and Environmental Quality Committee in addition to serving as the Director of Engineering services for the National Feed Grain Association.

The informative article covers many important topics of understanding dust explosions, fuel, ignition sources, bucket elevators, confinement, emergency action plan, and numerous illustrative graphs, figures, and tables.

Posted via web from ComDust

Dust Explosion in Carpentry Shop-Fire Drill | Ahlener Zeitung

• Dust explosion in a carpentry operation -Fire Department Drill - Annotated-

  Great idea with fire department in Germany conducting drills working closely with manufacturing sector management preparing for a combustible dust related fire or explosion occurrence. When was the last time your facility had a fire drill working closely with the local fire department? "Know Before You Go"

  tags: fire-fighting, emergency response, emergency preparedness, dust explosion

  • Staubexplosion in einem Schreinereibetrieb
    • Dust explosion in a carpentry operation - post by comdust
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  • Zum Glück handelte es sich nur um eine Übung am Dienstag,
    • "Fortunately it was just an exercise on Tuesday" This is a great idea with fire department conducting fire drills at manufacturing facilities that generate combustible dust - post by comdust
    • 
      
  • „Durchzündung
    • Flash Overs (Durchzündung) - post by comdust
    • 
      
  • Spänebunker als Sammelbecken für die Absauganlage.
    • "Chip Bunker as reservoirs for the exhaust." One area where the combustible dust explosion hazard exists - post by comdust
    • 
      
  • Während der gesamten Übung wurde zudem erstmals das Verhalten der Feuerwehrleute digital festgehalten, sodass bei der anschließenden Manöverkritik im Gerätehaus die Bilder eine wertvolle Hilfe bei der Bewertung der Übung waren.
    • "Throughout the exercise was also the first time the behavior of the firefighters digitally recorded, so when the subsequent maneuvers Tool criticism in the pictures is a valuable aid in the evaluation of the exercise were." - post by comdust

Posted from Diigo. The rest of my favorite links are here.

Global Cooperation Needed Combustible Dust Hazards

Last month's fire that raged through the Paarl Print Factory in Paarl, South Africa that killed a 13 workers and seriously injured many more was reminiscent of fatalities and injuries that occur in the manufacturing sector here in the USA.

A press release issued by the Chemical, Energy, Paper, Printing, Wood and Allied Workers' Union (CEPPWAWU) spokesperson, Cedric Maluleke stated, "preliminary finding that the initial small fire in the cafeteria was propagated through the building by an ensuing dust explosion. This was fueled by paper dust that had accumulated on the open rafters of the building and which had been raised into the air by the shockwave."

The above description is a textbook example of a deflagration where the pressure wave moves at the speed of sound (768 mph) and a devastating fireball following shortly thereafter. Hopefully we can learn from our global trading partners in minimizing the severity and probability of future combustible dust incidents. Currently the OSHA Dust NEP has failed to list paper industries, like the above example, as a combustible dust hazard in the Appendix of the Dust NEP.

This is quite troubling especially when reviewing the Prerule abstract for the combustible dust rulemaking that the Dust NEP will be the foundation for the rulemaking process. Scary stuff. So who is the wizard behind the curtain at OSHA deciding which national industry (NAICS) has a combustible dust hazard or not? Over 50% of combustible dust incidents last year occurred in national industry's not listed in the Dust NEP.

Without acknowledgment that incidents are occuring in national industries not listed in the Dust NEP, stakeholders are unprepared in dealing with the hazards. The problem is intensified when OSHA Susan Harwood Grant Awardees of Combustible Dust Training also use the Dust NEP as the foundation for their training programs, which omits industries at high risk and types of materials (Did you Know?) that can create combustible dust hazards. Will it take an incident as catastrophic as the South African Paarl Print Factory for the wizard behind the curtain to wake up?

The USA is not the only stakeholder that is at loss with reality through lack of information. Especially when reading the press release from our South African trading partners that,"Dust explosions in industry are relatively rare. They are most often encountered in the coal mining industry and in the grain-handling and processing industries. Coal dust, grain dust and paper dust are inflammable and, when raised into the air, can explode."

So dust explosions are rare and most often only encountered in coal mining industry and in the grain-handling and processing industries ? I wish that were the case, but last year there were over 30 combustible dust related explosions in the manufacturing and non-manufactruing sectors here in the USA according to media reports.

Lessons learned from the tragic incident in South Africa and incidents here on our own shore is that before any rulemaking process can proceed in a manner that protects the workplace is to have an understanding of the the probability and severity of combustible dust related fires and explosions throughout the manufacturing, non-manufacturing and utility sectors.

The current Dust NEP formulated through the Chemical Safety Board recommendations is a start but stakeholders throughout industry still have a long way to go in order to protect the workplace from future fatalities and injuries when dust deflagrations occur.

Resources
Paarl Print plant fire disaster-Media Release

2008 Dust Explosions and Fires Overview

The Combustible Dust Policy Institute found through researching media accounts in 2008 that over 150+ combustible dust related fires and explosions occurred in the manufacturing, non-manufacturing and utility sectors in the United States. Over 30% of these incidents are repeats of prior fires and explosions that fire departments are responding to. Subsequently, these reoccurring incidents mostly go unnoticed by OSHA, unless there are at least three injuries or one fatality.

The current OSHA Combustible Dust National Emphasis Program (NEP) directive does not address the majority of national industries (NAICS) where incidents are frequently occurring. For example, over 60% of incidents in 2008 occurred in national industries not listed in Appendix D-1 and D-2 of the NEP. Too much emphasis and resources is being directed toward the OSHA Dust NEP, when the majority of incidents are occurring in national industries not referenced in the NEP.

To further complicate the situation, the Chemical Safety Board Combustible Dust Hazard Study did not include in the profile of affected industries, the Paper, Textile, and Non-Manufacturing subsectors as industries where a combustible dust hazard exists. For example, in 2008, over 22% of incidents occurred in these subsectors. Without this important information, OSHA did not include paper national industries in the NEP. Over 10% of combustible dust related incidents in 2008 occurred in paper national industries.

In contrast, over 7% of incidents in 2008 occurred in the rubber/plastics subsector, where these national industries were referenced 90% of the time in the OSHA Dust NEP. A NAICS listing in the NEP does not guarantee the probability of occurrence will be lessened. For instance, the national industry NAICS: 326150/Urethane and Other Foam Product Manufacturing, the U.S Census Bureau lists over 433 firms in the USA. In 2008, OSHA inspected 9% (37) of these facilities with only three inspected for an emphasis on combustible dust.

For 2008, media accounts of combustible dust related fires and explosions occurred in thirty-six states. The states with 10 more or more incidents included Ohio (12), Illinois (10), Maine (10), Pennsylvania (10), and Iowa (10). Injuries occurred in 12% of the incidents. Of the total incidents reported by the media in 2008, 20% were combustible dust explosions.

Reviewing the the grain sector, through media accounts, over 50 combustible dust related fires and explosions occurred in 2008 with over 30% (15) were dust explosions. The adverse economic impact from dust explosions in this sector was much greater than the economic impact from explosions in the manufacturing sector. A question does arise if it makes good sense to model the current pending combustible dust legislation after the OSHA Grain Facility Standard, when so many injuries and economic damage is occurring from dust explosions similar to what’s happening in the manufacturing sector?

This brief overview of combustible dust related incidents in 2008 will hopefully provide all stakeholders additional insight into the complexity of combustible dust hazards in the workplace. The current occupational health and safety regulatory framework does not currently address the magnitude of the problem that encompasses all the national industries where incidents are repeatedly occurring throughout the manufacturing and non-manufacturing sector.

Dust Explosions Public Relations Priorities

Over that past couple weeks several dust explosions have occurred in facilities throughout the United States. These events mostly go unnoticed by the national media unless there are a multitude of injuries or fatalities like the recent coal-fired energy plant in Wisconsin that sustained a dust explosion in the dust collector, where several contractors sustained burn injuries.

Congressional leaders where quick to respond with a press release after the Wisconsin coal dust explosion with Representative Lynn Woolsey (D-CA), chair of the Workforce Protections Subcommittee, stating that, “ yesterdays accident was just another reminder of the unacceptable risk posed to workers by outdated regulations on combustible dust,”

This knee jerk emotional response to a multi-dimensional problem of dust explosions throughout our nation’s industrial sector where fuel and ignition sources are continually present does not fully address workplace protection measures that already are in place.

National Consensus Standards
For example, We Energies, the facility where the coal dust explosion occurred had already instituted proactive protective measures with national consensus good engineering practices in minimizing the probability and reducing the severity of dust explosion as outlined in the National Fire Protection Association (NFPA) combustible dust standards. Reading in between the lines of many news accounts the reader will find mention of explosion ventilation panels that vented the harmful overpressure effects of the explosion to safe levels, preventing the duct collector from fragmentating like a hand grenade.

Explosion ventilation panels ensure that after an explosion, life safety, structural integrity, and mission continuity of a facility is maintained. Unfortunately life safety was breached with the burn injuries to the contractors, yet the facility continued functioning in providing electricity to its customers. There is always a risk to workers when handling combustible particulate solids that generate combustible dust in the diverse spectrum of industries and injuries cannot be totally prevented, only minimized as was the case in this incident where fortunately there were no fatalities on site.

Reintroduction Combustible Dust Bill
Most importantly, the protective and mitigative control measures that We Energies utilized in protecting the worker from harm is in the same content of the recently reintroduced congressional bill that was initiated last year following the Imperial Sugar Refinery dust explosion. The Worker Protection Against Combustible Dust Explosions and Fires Act, H.R. 849, will require the U.S. Occupational Safety and Health Administration to issue rules regulating combustible dust in industry. The bill explicitly states that the proposed rules would be based on effective voluntary standards devised by the National Fire Protection Association. Ironically, We Energies are following the rules. So what outdated regulations on combustible dust, is the Congresswoman referring too?

Facilities that sustain dust explosions where injuries and fatalities occur are best served in providing complete transparency to the public, as We Energies has done, in sharing information to the media concerning protective administrative and engineering control measures that have been implemented such as the case with the explosions ventilation panels. Many coal fired electrical energy plants throughout the nation are collectively addressing combustible dust hazards through the PRB Coal Users Group in which We Energies and many other plants are alliance members.

Combustible Dust Industry Awareness
Most recently, several members of this alliance attended the Combustible Dust Hazard Awareness workshop, hosted by the Combustible Dust Policy Institute at the 4th Annual Industrial Fire, Safety, Security Conference in Houston, Texas February 3-6 2009 in the Reliant Center (next to the Astrodome). In addition to understanding how to identify, evaluate, and control combustible dust hazards at a facility, it is equally important after a major incident to provide the media essential information concerning the proactive control measures that were utilized.

Without this information, a negative reaction is likely to occur as is the case with the recent congressional press release that provides the public with an inaccurate depiction of the events. The Combustible Dust Policy Institute, with a diverse knowledge of combustible dust incidents and regulations, can assist all stakeholders when major catastrophic incidents occur in working collectively with public relations personnel in the development of positive proactive post incident media response.

Photo Credit: Enrique Rodriquez-Journal Sentinel

Resources:
Oak Creek Power Plant expansion
Journal Sentinel- excellent news coverage

Flame Resistant Clothing/Combustible Dust Hazards-Podcast#5

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David Osbon, Product Manager at Unifirst shares with listeners the importance of wearing flame resistant clothing (FRC) at facilities that handle combustible particulate solids that generate combustible dust. In the instance of a combustible dust related fire or explosion the thermal effects can cause severe burn injuries in addition to fatalities

The importance of workers donning personnel protective equipment (PPE) takes on an added dimension with the threat from combustible dust related fires and explosions in the workplace. Many manufacturing facility managers, owners, and employees are not aware of the fire hazard from combustible dust incidents when workers can sustain life threatening burns like occur in the refinery sector from vapor cloud explosions and flash fires, where the wearing of FRC's is required.

Reviewing the OSHA Combustible Dust NEP reference is made in the citations section:

Personal Protective Equipment (PPE) Violations. Citations under 1910.132(a) (the general requirement to provide and assure the use of protective equipment, including protective clothing) may be issued, if an employee exposure to potential burn injuries can be documented. For example, if employees are not wearing protective clothing, such as flame-resistant clothing , in areas of the plant (e.g., bagging areas) where employees may be exposed to potential flash fire hazards, then citations under 1910.132(a) may be issued. A citation may be issued whether or not an accident precipitated the inspection.

Additionally, in regards to the life safety issue of donning FRC's in the workplace, the OSHA General Duty Clause requires that employers provide FRC's to employees when a hazard is potentially present from combustible dust related fires and explosions. Furthermore the OSHA Dust NEP states:

"...National Fire Protection Association (NFPA) 2113, Standard on Selection, Care, Use and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire is a national consensus standard which applies to, among others, chemical, refining, and terminal facilities with flash fire hazards..."

Resources:
NFPA 70E Electrical Safety in the Workplace
NFPA 2112: Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, National Consensus Standard
ASTM Committee E27.05 on Explosibility and Ignitability of Dust Clouds
ASTM Committee F-23 on Protective Clothing
Podcasts-Combustible Dust Hazard Awareness

200+ Combustible Dust Fires and Explosions in 2008

A new year is upon us. Will we learn from the past? Through media accounts, the Combustible Dust Policy Institute researched over 200+ combustible dust related fires and explosions that occurred in 2008 in the grain, manufacturing, non-manufacturing, and utility sectors. Good housekeeping is a partial solution in preventing and mitigating incidents, especially in regards to secondary explosions, but only one aspect of a multi-dimensional complex subject concerning combustible dust hazards.

For instance, utilizing good engineering practices (GEP) as outlined in the NFPA Combustible Dust Standards would assist in lessening the likelihood and reducing the severity of many incidents that occurred in 2008. Additionally, administrative controls such as hot work permits, inspection, maintenance, and employee/contractor training of combustible dust hazard awareness would proactively provide enhanced measures cost effectively.

The recent grain facility dust explosion in Arizona is a wake up call that dust explosions are prevalent across all sectors. Combustible dust related fires and explosions is an inherent throughout industry. It's only through mitigative and preventative measures that potential fatalities, injuries, and adverse impact will be lessened.



The Combustible Dust Policy Institute proposes an alternate solution addressing the entire spectrum of combustible particulate solids that generate combustible dust across all sectors. Instead of haphazardly piecing together costly regulations singling out individual occupational sectors. Legislators must be educated that all explosions transform energy into blast waves (overpressure), thermal radiation, and ensuing projectiles. It doesn't matter if its runaway reaction explosion, condensed phase explosion, vapor cloud explosion, or dust explosion.

NFPA 654, "Standard for the Prevention of Fires and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids," has already provided a good start in considering a regulatory framework with mention of a process hazard analysis as already implemented at refineries with the OSHA process safety management (PSM) program. For instance. 29 CFR 1910.119 is intended to prevent or minimize the consequences of a catastrophic explosion from a process.


What about combustible dust explosions in other occupational sectors that are of high consequence like the catastrophic Imperial Sugar Refinery explosion earlier last year and now this past week the Arizona Grain explosion that sent three workers with burn injuries to the hospital ? Scientific data compiled from laboratory combustible dust testing has proven that the devastating blast waves and thermal radiation from dust explosions are just as devastating as a vapor cloud explosions.

The learning curve is now complete concerning the hazards of combustible dust in the workplace. All stakeholders must cohesively work together with local, state, and national governmental leaders in developing a comprehensive combustible dust occupational safety framework that ensures the safety of all workers in explosive high consequence occupations.

For additional information on identifying, evaluating, and controlling the hazards of combustible dust related fires and explosions, the Combustible Dust Policy Institute in conjunction with the 4th Annual Industrial Fire, Safety, and Security Conference -IFSS 2009 will be hosting a Two Day Combustible Dust Hazard Workshop at the Reliant Center(next to the Astrodome), February 3-4, 2009, in Houston Texas.

Concerned stakeholders will acquire important information during Day One of the workshop that can be utilized in preventing and mitigating future incidents in addition to understanding the necessary steps in achieving regulatory compliance concerning the OSHA Combustible Dust National Emphasis Program.

Currently a situational awareness is lacking nationwide that combustible dust also poses a potential explosive atmosphere in the same light as flammable gases, vapors, and mists. Instead of vapor cloud or BLEVE explosions that occur in the refining sector there are deflagrations and dust explosions in the manufacturing sector.

Day Two of the workshop will include fire-fighting suppression techniques, equipment, and training resources that are currently available. In addition to active participation through panel discussions, Fire Chiefs from around the nation that respond to combustible dust incidents will share successful fire-fighting tactics in combating combustible dust fires.

WHO ATTENDS IFSS Workshops and Seminars?

Attendees from across the United States converge at IFSS every year to meet with their peers - industrial emergency response and security leaders throughout the industrial and energy marketplace.

INDUSTRIAL FIRE, SAFETY & SECURITY Attendees Include:

FEDERAL/STATE/

MUNICIPAL

* Regulatory Agencies
* Emergency Management Departments
* LEPC's - Local Emergency Planning Committees
* Municipal Fire Districts - Mutual Aid

OPERATORS/INDUSTRY

* Oil & Gas Exploration & Production
* Refineries
* Petrochemical/Chemical Facilities
* Pipelines
* Terminals/Storage Facilities
* Power Plants
* LNG Facilities
* Process Industries
* Transportation/Shipping/Rail
* Emergency Response Teams
* Industrial Fire Brigades
* Security

Preparing for Tomorrow’s Emergencies in Today’s World.

EH&S. Hazmat. Fire. Security. Rescue. Safety. Medical.
Whatever aspect of emergency management you work in, IFSS is the essential destination for staying ahead of the curve – and getting that edge that can make all the difference in your next situation.

IFSS delivers an unsurpassed learning experience!

* Learn about best practices for all types of incidents from industry leaders and technical experts.
* Get three days of answers to your most pressing questions.
* Discover the most innovative products and services at a one-of-a-kind exhibition.
* Hear about valuable “lessons learned” from true-life situations.
* Connect with your peers from around the country.

IFSS is only four days… but the value it provides will pay off all year-long. You will take-away intel, insights and info that will help you on an ongoing basis as you protect America's industrial plant facilities, personnel, energy infrastructure, and critical assets against all hazards.


IFSS 2009 Conference Contacts
Phone: (832) 242-1969
Fax: (832) 242-1971

# # #

The goal of Combustible Dust Policy Institute is to minimize the severity and reduce the occurrence of combustible dust related fires and explosions in the global workplace. Through ongoing exchange of best practices and lessons learned of combustible dust related incidents, which identifies and evaluates risk, the Institute shares risk assessment information that a diverse spectrum of members utilize in effectively controlling combustible dust hazards. Assisting stakeholders in this endeavor, health and safety compliance is effectively achieved in addition to reducing preventable workplace fatalities, injuries, and adverse economic impact. Contact John Astad, Chairperson :Combustible Dust Hazard Workshop@ 409-440-7185

OSHA Grain Facility Standard Not Working

If the OSHA grain facility standard is suppose to reduce the prevalence of combustible dust accidents in the grain industry here in the United States, then why has 10 grain facility explosions occurred over the past ten months? Since the tragic Imperial Sugar Refinery dust explosion, the Combustible Dust Policy Institute has recorded on the Google Grain Facility Incident Map through online news reports, 17 combustible dust fires and explosions at grain facilities with 35% of these events occurring as explosions.

In contrast, over the past six months with over 70 combustible dust explosions and fires in the manufacturing sector, 22 % have been explosions. Surprisingly, the number of injuries when comparing to combustible dust events between the two industry sectors are approximately the same.

Acceptable Explosions
Recent Senate testimony at a combustible dust hearing by governmental officials have stated that the number of grain facility combustible dust fires and explosions have been reduced since the OSHA Grain Facility Standard was introduced two decades ago. So what is an acceptable number of accidents if combustible grain dust explosions and fires are happening at the same pace as incidents in manufacturing plants?

The only difference between the two is the tragic event at Imperial Sugar, which gained the attention of congressional leaders to take preventative action. It's only a matter a time before the magnitude of the Georgia event catches up with the grain industry.

Take a fast rewind over 3o years ago, to 1977 when several grain silo facilities eerily exploded within days of each other creating a heavy death toll. It was these events that initiated legislation for the OSHA Grain Facility Standard. Earthquakes on the West Coast of high magnitude in metropolitan areas have the same effect. The events are spaced out many years apart but still result in high fatalities, injuries, and extreme economic damage.

Right Idea...Misguided Approach
It's commendable that legislators desire OSHA regulations with protective action to prevent further workplace injuries and fatalities. The problem is with the methodology in achieving this goal. For example, regarding the case with Imperial Sugar and the huge loss of life, concerned legislators were immediately outraged as was the public. Something had to get done and quickly to prevent additional occurrences of accidents of that magnitude. Quick it was, then ensuing congressional testimony began to turn into attacks on OSHA, the director of OSHA, and even the Secretary of Labor.

This is where the problem arose in drafting the Worker Protection Against Combustible Dust Explosion and Fires Act (H.R. 5522). Emotions entered into the picture instead of a reasoned approach which should of consulted all stakeholders concerning life safety, structural integrity, mission continuity, and mitigation of fire and explosions as outlined in the National Fire Protection Association (NFPA) standards.

Jurisdictional Collaboration
Congress needs to reevaluate the stark and unyielding provisions of the pending combustible dust bill, which has all the good intentions of accident prevention and worker safety. Instead the local jurisdictional aspect with collaborative partnerships must be aligned between federal, state, and local entities in the prevention and mitigation of future combustible dust incidents.

Already it is proven the federal provision in the OSHA Grain Facility Standard does not reduce the occurrences of combustible grain dust incidents. How can it? Doesn't take much higher math to figure there are not enough OSHA inspectors to inspect all the grain facilities on a regular basis. Besides it's not up to the federal government to ensure a facility will not go off like a Chinese bottle rocket to the moon at moments notice.

An excellent example of local jurisdictional cooperation with state, local, and federal alliances is Homeland Security. Billions of dollars have gone into that program and millions more too local and state jurisdictions. Is Homeland Security working? Maybe it's too early to tell. But the resources have been spent. Isn't our nations manufacturing sector just as vital or important?

Photo Credit: OSHA

Dust Explosions Prior to Senate Hearing

Three days prior to the July 29, 2008 Senate Hearing on workplace Safety, “ Dangerous Dust: Is OSHA Doing Enough to Protect Workers,” ICO Polymers in Asbury, New Jersey witnessed an early morning explosion that severely burned one worker who is in critical condition with burns to his face and arms from the explosion in the plastic pulverizing unit. In the same week four other combustible dust incidents occurred throughout the nation. The cause at ICO Polymers is yet to be determined but all the ingredients are there again for another combustible dust explosion.

Prior Explosions
For instance, one year ago, last July, the same facility experienced a similar event that after an OSHA accident investigation, was deemed a combustible plastic dust explosion in Building One’s Ambient Mill. Where micronized powders of polypropylene, polystyrene, and ethylene were allowed to accumulate, which ignited and exploded, injuring a worker who suffered burns to his hands and back of his head. In this recent incident, New Jersey Fire Officials closed the facility due to the extensive structural damages to the building, which posed an imminent threat.

Recent news reports in the Hunterdon County Democrat, uncovered additional fires at the ICO Polymers facility in 1999 and several explosions in 1997, 1990, and 1989, which also injured workers. In earlier years the plant was owned by Wedco. Change of ownership has not reduced the severity or magnitude of injuries with the events reoccurring in an alarming manner.

Combustible Dust Legislation
A troubling aspect of the recent Senate hearing on combustible dust in conjunction with the recent explosion in New Jersey is that our nation’s legislators and policy makers don’t seem to understand the magnitude of the complex issue concerning combustible dust.

Since the “Worker Protection Against Combustible Dust Explosions and Fires Act of 2008,” was introduced by Congressman George Miller (D-CA) on March 4, 2008 as a result of the February 7, 2008 catastrophic Imperial Sugar Refinery dust explosion in Port Wentworth, Georgia there have been prior hearings held in Congress. Basically, the message has been the same at all the congressional hearings, that there is a problem with the hazards of combustible dust in the nation’s manufacturing sector workplace.

NFPA Combustible Dust Standards
Yet no consensus solutions have been proposed. Instead sole blame has been placed on OSHA which doesn’t have a general industry comprehensive combustible dust standard like the grain facility standard that is already part of OSHA work-place health and safety standards since 1989.

The central aspect of the proposed legislation is incorporating National Fire Protection Association (NFPA) combustible dust standards. This is would be great if OSHA had enough resources to inspect the thousands of manufacturing plants in the nation but it doesn’t. So how will such regulations be enforced unless Congress appropriates additional funding to OSHA? It’s like declaring war yet not sending the troops for lack of funding.

Manufacturing facilities are already required to follow NFPA combustible dust standards through general consensus and nationally recognized standards of care which is recognized by the American National Standards Institute (ANSI). When a violation of combustible dust is found, OSHA inspectors can cite the facility under the General Duty Clause (GDC), Section 5(a)(1) of the Occupational Safety and Health Act.

Local Jurisdiction Enforcement
Local fire and building inspectors that already conduct local inspections need to be utilized more thoroughly in the prevention and mitigation of future combustible dust fires and explosions. These are the professionals that are on the front lines daily and interact daily with local fire departments concerning specific issues that need to be addressed concerning the life safety and structural integrity of commercial buildings.

Fire codes such as the ICC International Fire Code and NFPA Uniform Fire Code already address combustible dust with references to the numerous NFPA combustible dust standards. Following the 2006 Combustible Dust Hazard Investigation, the Chemical Safety Board in addition to recommending an OSHA comprehensive combustible dust standard also outlined that many fire and building inspectors are not knowledgeable concerning combustible dust hazards.

Why hasn’t this aspect of preventing and mitigating future combustible dust incidents been included in congressional testimony? Instead attention has solely been directed at the recent Imperial Sugar incident and placing blame on OSHA as a solution in the policymaking process.

Conclusion
While all the political spin and maneuvering between both political parties concerning labor and business has been taking place over the past five months in regards to pending combustible dust legislation, over 70 combustible dust related fires and explosions have occurred in the nation’s manufacturing sector. The Combustible Dust Policy Institute has discovered through research that approximately 20% of these events are combustible dust explosions and an alarming number are reoccurring like the ICO Polymers accident last week.

A comprehensive combustible dust bill will not solve the problem of combustible dust fires and explosions. It’s only through the cooperation between all stakeholders throughout the national, regional, and local levels that the complex issue of combustible dust can be properly addressed in lessening the severity of future incidents.