Welcome Aboard the Combustible Dust Policy Institute site! In 2012, a preliminary analysis of 2011 NFIRS data indicated 500+ combustible dust related fires and explosions in many sectors throughout the United States with the majority of incidents "near misses." The primary goal of this site concerning the complex subject of combustible dust is to bring forth a situational awareness to global stakeholders, which hopefully will lessen the occurrence and reduce the severity of future accidents.
Reviewing the OSHA advance notice of proposed rulemaking (ANPR) creates quite a concern. For example in the second sentence of the "Summary" at the top of the page, "For the
purposes of this notice, the term "combustible dust" includes all
combustible particulate solids of any size, shape, or chemical
composition that could present a fire or deflagration hazard when
suspended in air or other oxidizing medium"
So for combustible dust to be hazard it must be suspended in air? What about smoldering layers of dust which also fire and explosion hazards? Before dust can be in suspension it first must be layered on horizontal surfaces. Personnel have been fatally and severely injured from smoldering dust initially not in suspension. Additionally facilities have burned to the ground due to layers of dust.
The problem of OSHA defining combustible dust solely in suspension became readily apparent when trade associations submitted comments in response to the ANPRM requesting their NAICS be removed from "Table 1--Industries Having at Least One Recorded Combustible Dust Incident Reported Since 1980," since combustible dust incidents at facilities they represented were dust layered fires and
not in suspension. Was the Dust Incident table (page 43 .pdf) listing severity of consequences (Kst's) instead of NAICS, during a topic of discussion at the 2011 OSHA Combustible Dust Expert Forum a response to the turmoil of defining combustible dust solely in suspension?
There is no mention whatsoever in the OSHA Combustible Dust ANPRM about catastrophic combustible dust related fires as a result of layered dust not in suspension. In stark and awakening contrast, the NFPA Fire Analysis and Research Division prepared a report, "Fires in U.S. Industrial and Manufacturing
Facilities" providing insightful information regarding combustible dust related structure fires in manufacturing properties from 2006-2010. The NFPA report noted that shop
tools and industrial equipment were involved in 29% of these structure fires.
Most importantly dust, fiber, or lint (including sawdust) was the item first ignited in 12% of manufacturing facility incidents. This would equate to over 600 combustible dust related incidents annually. A vast and disturbingly revealing difference from the 2006 CSB Dust Hazard Investigation Report identifying 281 combustible dust incidents from 1980-2005, or approximately 11 incidents annually. The educational NFPA report obtained fire incident data from the US Fire Administration'sNational Fire Incident Reporting System (NFIRS) data in conjunction with NFPA’s annual survey of U.S. fire departments.
Its quite alarming where our global trading partners in the IECEx Scheme and European ATEX System recognize dust layers as a fire and explosion hazard yet here in the USA we do not recognize these immediate hazards in the current combustible dust rulemaking process. Continuing to proceed in solely defining combustible dust as a hazard in suspension and ignoring dust layers will have serious consequences in the future as experienced now and in the past. Is it time for a revision of the OSHA Combustible Dust; Advance Notice of Proposed Rulemaking in accordance with reality or should we continue while in error?
On a side note, do you know the burning behavior of your dust? Additional information on burning behavior (VDI 2263). Currently OSHA nor CSB recognizes burning behavior in evaluating combustible dust fire and explosion workplace hazards.Unfortunately, we'll have to wait for another catastrophe before burning behavior is reconized like it is amongst our international trading partners.
Remove Appendix D-1 and D-2 from OSHA Combustible Dust NEP and replace with all NAICS in the manufacturing and non-manufacturing sectors that handle, generate, and process combustible dust. "All or None"
Many stakeholders are not aware if a facility is identified in the OSHA Combustible Dust National Emphasis Program NEP) for targeted inspections. Here are a few helpful steps to assist in obtaining the NAICS six digit designation then comparing with the NAICS in Appendix D-1 and D-2 of the OSHA ComDust NEP.
Step 1
Go to the OSHA Integrated Management Information System (IMIS) database and type the facility name in the Establishment Search
Here is an example of a facility already entered in IMIS:
Hoeganaes Corp
Gallatin, TN
SIC: 3399/Primary Metal Products, Not Elsewhere Classified
NAICS: 331111/Iron and Steel Mills
If the OSHA IMIS search does not populate a facility then an alternative would be to use the EPA Envirofacts search tool
Acquiring a NAICS at times can be frustrating and very time consuming since the above search methods will not always be successful. If the Standard Industrial Classification (SIC) is known, that will assist in determining the NAICS. For example type the SIC in the Google search box.
Google Search: SIC: 3399
The first hit at the top of the web page should be the Reference for Business website where the NAICS are found.
Step 2
Once the facility NAICS is obtained the next step is comparing the NAICS six digit designation with the NAICS in Appendix D-1 and D-2 of the OSHA ComDust NEP
Next time you read a news account of a combustible dust related fire or explosion use the above exercise to determine if the facility is recognized in the OSHA NEP for targeted inspections. Don’t be surprised if the NAICS is not specified in D-1 or D-2 of the ComDust NEP.
There are many elements in the NEP that have successfully educated stakeholders in identifying, evaluating, and controlling the hazard. Yet when fatalities and serious injuries occur in NAICS not recognized in the NEP this presents a serious problem. One more fatality or injury as a result of a workplace combustible dust related fire or explosion is not acceptable. The workplace is reaching a point of, “Occupy Combustible Dust Fires and Explosions.”
Update: NAICS Exercise: Chocolate and Confectionery Manufacturing from Cacao Beans
January 29, 2012 Workers burned at chocolate factory. Use steps above to determine if facility NAICS is recognized in OSHA Combustible Dust NEP.
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.
A combustible dust explosion occurred at a pharmaceutical preparation plant in Iowa prior to the end of the 2010 a few weeks ago. Luckily there were no injuries or fatalities and damage was minor according to the news account.
"There were no injuries. The explosion blew out doors on the building and dust collectors, with additional minor damage."
It appears the mention of doors blowing out in the dust collector might be referring to explosion ventilation panels. Being that the plant is involved in pharmaceutical preparation with a NAICS 325412, it is noted in the OSHA Combustible Dust NEP in Appendix D-1 as an Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires.
Over the past 12 months OSHA has been enforcing a myriad of regulations in addition to ComDust NEP emphasis in their site visits at pharmaceutical preparation facilities. The OSHA Integrated Management Information System also referred to as IMIS provides a helpful insight to these inspections.
An educational General Duty Clause citation for one Pharmaceutical Preparation Plant noted that "neither dust collector was equipped with deflagration venting panels directed to an unoccupied area or with a suppression system. The collectors were located inside an occupied area which employees entered to conduct maintenance on a daily basis."This is in contrast to the current incident where the dust collector was installed outside on the roof and appeared to have explosion vent panels.
Results of an internet search produced a MSDS for microcrystalline cellulose (MCC) Cellulose; flour cellulose which has combustible dust fire explosion hazards. For example in the Fire Fighting section it notes, "Fine dust dispersed in air in sufficient concentrations, and in the presence of an ignition source is a potential dust explosion hazard. For Cellulose: Minimum ignition temperature, dust cloud: 410C. Minimum explosible concentration: 0.045 g/l." This is helpful information so stakeholders can take proper administrative, PPE, and engineering control measures.
On a side note, another combustible dust related fire and explosion originated from the same company that occurred nearly two weeks prior to above incident, yet paper dust was the process material at a different facility instead of microcrystalline cellulose (MCC) according to the news account.
“Something caused the paper dust to explode. We don’t know what it was,” Battalion Chief Rick Palmer of the Portage Fire Department said. Palmer said the fire department has been called to explosions at the plant in the past, most recently about eight months ago. Small fires can develop wherever the dust settles in the plant following such an explosion, he said. “We just chase little fires all over the place,”
Stakeholders searching the OSHA Combustible Dust NEP will not find any paper industries that OSHA believes have More Frequent and/or High Consequence Combustible Dust Explosions/Fires or Potential for Combustible Dust Explosions/Fires. Don't know what the NAICS is for the facility that generated paper dust in the news account yet there is mention that the facility produces paper insulation. In either case whether or not a facility is listed in the OSHA ComDust NEP, if you generate ComDust then you need to identify, evaluate, and control the fire and explosion hazards.
Many stakeholders were anxious to hear the Chemical Safety Board (CSB) key findings and recommendations in the September 24, 2009 release of the final investigation report on the catastrophic dust explosion at Imperial Sugar Refinery. The CSB made five key recommendations with included adherence to NFPA combustible dust standards, comprehensive housekeeping, hazard communication training, emergency response, and that Imperial Sugar implement corrective actions in accordance with best engineering practices referenced in the NFPA standards. These recommendations were not solely directed at Imperial Sugar but the entire industrial sector that handles combustible particulate solids, which generate combustible dust. Yet CSB left out a key recommendation that workers don flame resistant clothing in the protection from flash fire severe burn injuries.
CSB Dust Hazard Study In 2006 CSB concluded a Dust Hazard Study following a series of catastrophic high consequence dust explosions that occurred in 2003. The important safety recommendations of the study were forwarded to OSHA, which provided the agency a foundation in the formulation of the 2007 and 2008 reissued Combustible Dust National Emphasis Program (NEP). Additionally, following the Imperial Sugar Refinery explosion, the House Education and Labor Committee drafted a combustible dust bill utilizing the CSB Dust Hazard Study recommendations as the framework of the bill. Currently OSHA is drafting a general industry combustible dust regulation, which also is utilizing the CSB Dust Hazard Study recommendations as guidance.
All the recommendations from the Chemical Safety Board prompting action addressing combustible dust hazards in the industrial workplace is great and long overdue yet many layers of protection have been overlooked in the recommendations. This was especially evident when the data from the Dust Hazard Study only recognizes that 281 incidents occurred from 1980-2005, when in reality the incidents are ten times that many. For example, in 2008, the Combustible Dust Policy Institute discovered through media accounts, there were over 150 incidents in the manufacturing, non-manufacturing, and utility sectors. Probability of occurrence is an important element in obtaining an understanding of the complex issue of combustible dust.
For instance, the OSHA Combustible Dust NEP lists several dozen manufacturing national industries (NAICS) that have the potential or have a high risk in experiencing combustible dust incidents. Yet over 50% of national industries that had combustible dust related fires and explosions in 2008 were not listed as target industries (NAICS). Not to be picking on the paper subsector but to use as an example to illustrate a point, it's national industries (NAICS)are absent from the Dust NEP. On a global perspective amongst our international trading partners, an April 2009 dust explosion at a South African paper printing plant resulted in 14 fatalities and dozen of injuries from burns. This incident highlights that paper dust has a high consequence and potential for combustible dust fires and explosions.
Importance of PPE Understanding probability of occurrence and severity of consequence is only one important aspect in addressing combustible dust hazards in the industrial workplace. Layers of protection are derived from administrative controls and best engineering practices with the final layer, personnel protection equipment (PPE). The Chemical Safety Board overlooked PPE in the recommendations following the key findings of the Imperial Sugar Refinery dust explosion. For instance the April 23, 2008 Chatham Emergency Management Agency, After Action Report mentions that 36 persons were injured and transported to Memorial hospital in Savannah, Ga; 14 of those were non life-threatening injuries. Eventually a total of 20 victims were relocated to the Joseph M. Still Burn Center at Doctors Hospital in Augusta, Georgia with life threatening burn injuries.
Traumatic Burn Injuries In a Burn Care Commentary time-line of the events following the dust explosion, the Joseph M. Still Burn Center highlights that the victims had," thermal burn injuries ranging from 5% Total Body Surface Area (TBSA) damage, treatable onsite and in area Emergency Departments, to 95% TBSA— critical burn damage that in most cases is not survivable." The Combustible Dust Policy Institute believes that if the workers had worn personnel protection equipment in the donning of flame resistant clothing (FRC), the Total Body Surface Area (TBSA) damage would of been less severe. Without FRC once a fireball makes contact with conventional clothing, the clothing ignites causing even more severe burns than the original flame.
A news account of a worker that succumbed to his burns at the Joseph M. Still Burn Center a week following the dust explosion indicated he had third degree burns on more than 80% of his body. Of the 20 workers that were admitted to the burn center, six (30%) did not survive due to the severity of their burn injuries. Malcolm Frazier, 47, of Savannah, a floor manager at the plant, with burns covering 85 percent of his body was the last one to succumb on August 22, 2008. Malcolm fought a brave fight hanging on for over seven months while his parents Richard and Hattie Frazier vigilantly stood by, encouraging him to persevere. Burn Injury Studies Chances of survival after life threatening burn injuries diminish rapidly in accordance with one's age group. In a 1991-1993 study conducted by the American Burn Association, results indicated Total Body Surface Area (TBSA) damage is a key survival factor for burn victims based on the age of the victim. For instance chances in survival of a victim in the 40-49 age group with over 75% TBSA is 30% versus 60% survivability for the 20-29 age group
Lawrence Manker Jr, 20, in the latter group was the last Imperial Sugar burn patient to be released from the burn center in October 2008. Lawrence, like Malcolm had burns to over 85% of his body. To assist the healing process, doctors medically induced him into a coma for six months so they could treat the severe burns. Studies have shown that burns to over 75% of the body can occur easily from the ignition and continued burning of conventional clothing versus workers that don FRC, which do not continue to burn when exposed to a flame source.
Flame Resistant Clothing in Industry Workers in industries such as the petroleum, petrochemical, and chemical sectors where flash fire hazards also are present, already are donning flame resistant clothing in adherence with the requirements of proper personnel protection equipment. There is a disconnect in the USA where many governmental agencies, legislative officials, trade associations, professional organizations, and numerous other stakeholders are not aware that a dust explosion is a propagating explosion like a vapor cloud explosion which occurred at the BP Texas City Refinery in 2005. Both explosions have the devastating effects of overpressure, thermal radiation, and ensuing projectiles.
Reviewing the OSHA NEP's for combustible dust and Process Hazard Management (PSM), OSHA management recommends that CHSO's (inspectors) wear flame resistant clothing when conducting inspections at facilities where flash fire hazards are present. Ironically after over 55% of the victims from the Imperial Sugar explosion sustained life threatening burn injuries that were admitted to the Joseph M. Still Burn Center, the Chemical Safety Board does not include a sixth recommendation that flame resistant clothing be worn in potentially combustible dust explosive environments.
Conclusion The only reason I can think that this recommendation was not included was due to the current litigation with millions of dollars at stake in potential compensation of all the burn victim survivors and families of the deceased. CSB must maintain neutrality and maintain impartiality in not placing blame. Including this important yet vital recommendation would of enhanced the plaintiffs case and been a damaging blow to the defendants. In all fairness, Imperial Sugar Refinery employees are now wearing FRC's in addtion to state of the art best engineering practices that CEO John Sheptor has implemented in the reconstruction efforts since the February 7, 2008 explosion.
An OSHA combustible dust standard is long overdue for general industry. In the past six years there's only been a handful of dedicated career governmental employees and legislators directing this much needed occupational health and safety policy. Last Thursday at the Hilton Savannah Desoto on East Liberty Street was a monumental and historical event where the CSB provided much needed recommendations to Imperial Sugar and the entire industry.
These recommendations will validate OSHA's current combustible dust rulemaking process. But that is where the problem arises, especially when all layers of protections are lacking, but must be considered in preventing future fatalities, severe injuries, and devastating economic damage. Personnel protection equipment in FRC's is just as important as housekeeping, training , emergency response, and NFPA best engineering practices. We owe it to Imperial Sugar Refinery explosion victims, survivors and families to get it right in the combustible dust rulemaking process so as to prevent and minimize future catastrophic occurrences.
UPDATE 9/25/09-OSHA combustible dust regulation submitted to OMB for Review. On the fast track now following CSB Imperial Sugar Recommendations http://ow.ly/rkV8 Thanks Larry, for sharing
Excellent article published inPulp & Paper Oct 2000 by Mark Williamson. The importance of addressing combustible dust related fires is highlighted here. Do you have spark detection and flame suppression as part of your dry dust collector system?
DUST IS AN UNDESIRABLE BUT inevitable byproduct of tissue manufacture. It settles everywhere in the machine room. In high concentrations, airborne dust is an occupational health concern
Maybe it just might be a good idea to add national industries (NAICS) in the paper sector as a potential for combustible dust related fires and explosions. Currently the paper sector does not exists in the OSHA Dust NEP. What do you think? - post by comdust
Scott Paper Limited in Lennoxville, Quebec,
Kruger Products Limited, formerly Scott Paper Limited, is Canada's leading manufacturer and distributor of towel and tissue products for consumer, in-home, use and for commercial, away-from-home, use. - post by comdust
The No. 5 machine at the Lennoxville mill generates high levels of dust. There are also high levels of static electricity in the mill, so dust sticks to the walls and the equipment.
So there is a combustible dust hazard with paper dust. Hmm..maybe someone at OSHA should also read this for helpful reference, so as to add the sector to the Dust NEP. - post by comdust
Machine cleaning was scheduled two times per week and each cleaning needed 45 minutes to 1 hour of downtime.
Housekeeping appears to be very costly - post by comdust
To significantly reduce airborne dust, reduce dust buildup and the potential for fires, and to lessen dust carryover to the final product, the mill looked for alternative dust control systems.
Here it is , the potential for combustible dust related fires. Fires are the precursors for combustible dust explosions. Yet they are ignored and dust explosions get all the emphasis instead. Fire departments are repeatedly responding to combustible dust related fired on a regular weekly basis - post by comdust
To protect against the spread of fires in a dry system, special fire control equipment such as spark detection systems, sprinkler systems, and fire doors are commonly used.
Notice the importance of best engineering practices as outlined in the NFPA combustible dust standards such as spark detection and flame suppression systems,. Flamex and Grecon are excellent sources for these systems. - post by comdust
Celeste Monforton, DrPH, MPH Assistant Research Professor in the Department of Environmental and Occupational Healthat the George Washington University and contributor of the public health blog, "The Pump Handle," has provided readers an excellent overview of Labor Secretary Hilda Solis's Regulatory Plan in her recent post with a discussion of the inner workings of the current Unified Agenda of Regulatory and Deregulatory actions, which includes Prerules of combustible dust and occupational exposure to silica, beryllium, and diacetyl.
According to the combustible dust prerule, the Advance Notice of Proposed Rulemaking is planned in August 2009 (no exact date yet) with stakeholder meetings sometime in December 2009. It’s very troubling reading the Combustible Dust rulemaking abstract to learn that OSHA will be using information gathered from the reissued Combustible Dust NEP as the agency considers future rulemaking. This document does not provide a clear picture of reality. Especially considering that over 50% of combustible dust related fires and explosions in 2008, though media accounts, occurred in national industires (NAICS), not referenced in this outdated NEP.
Furthermore the 281 combustible dust incidents obtained from the CSB Dust Hazard Study does not address the thousands of incidents that have occurred over the past three decades. A sound occupational safety policy in protecting the workplace can only be formulated when stakeholders fully understand the probability of occurrence in addition to the severity. The CSB study was a great start but much more needs to be done in evaluating the hazard appropriately.
An OSHA comprehensive combustible dust standard is much needed but lets not get all warm and fuzzy by a quick fix like what has previously occurred decades ago with the OSHA Grain Facility Standard in which there was over 50 combustible dust related fires and explosions in 2008. Not counting the rare Feb. 7, 2008 Imperial Sugar Refinery incident, there was more economic damage and workplace injuries in the grain facility sector in 2008 than in the manufacturing sector from combustible dust related fires and explosions.
With such a complex subject as combustible dust spread across hundreds of national industries (NAICS), a negotiated rulemaking process like which occurred with cranes might be a viable option in addition to incorporating a hybrid process safety management (PSM) venue into the rulemaking process.
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.
Like a small tremor on the San Andreas fault line of the West Coast as a precursor to the big one, the recent explosion at the ethanol plant in Hastings, Nebraska provides a similar warning. In less than a year over a dozen combustible dust related fires and explosions have occurred at ethanol facilities throughout the Midwest. The importance of donning proper PPE such as flame resistant clothing (FRC) in such a work environment takes on added dimension with now learning the workers T-shirts were set on fire from the blast. A week prior to the Hastings explosion, according to media accounts, an ethanol plant in Casselton, North Dakota experienced a minor fire in the dust collection bin.
Ethanol plants have complex explosion and fire hazards not found in other manufacturing national industries (NAICS) where the attributes of a grain handling facility is combined with a chemical plant in the production of ethyl alcohol. Subsequently, these process facilities must follow stringent regulatory guidelines according to the OSHA Process Safety Management Standard (PSM) and EPA Risk Management Program (RMP). Additionally, combustible dust hazards are addressed in the OSHA Grain Facility Standard.
The confusing aspect of identifying in which area OSHA regulates this national industry besides the OSHA PSM standard is that SIC 2046 for Wet Corn Milling and SIC 2869 for Ethyl Alcohol Manufacturing is not listed as SIC's regulated in the OSHA Grain Facility Standard. In contrast, NAICS 311221 Wet Corn Milling is listed as a D-1 NAICS in the OSHA Dust NEP.
With the multitude of regulatory control measures protecting workers, the environment, and the public; accidents still happen. The question arises can the current high incident rate be minimized? In less than a year six ethanol plant explosions have occurred in Michigan, Arizona Minnesota, Kansas, Wisconsin, and Nebraska with ensuing injuries in 50% of these incidents.
So what is an unacceptable accident and injury rate before stakeholders reassess current administrative and best engineering control measures? All the proper administrative and best engineering control measures seem to be in place in the prevention and mitigation of fires and explosions. Yet the incidents are exponentially higher than any other national industry(NAICS) in the manufacturing sector. Hazard awareness through a multitude of educational programs is an excellent measure in addressing this issue.
For instance, ethanol trade associations such as the Renewable Fuel Association (RFA) has an proactive safety program addressing many of the hazards in ethanol production. Additionally, the RFA works collectively with the University of Illinois Fire Service in providing industry with educational programs that prevent future incidents.
Recently, Kirkwood Community College in Cedar Rapids, Iowa was awarded a $174,978 OSHA Susan Harwood Training Grant in hosting a 2 ½-hour awareness-level combustible dust safety course addressing grain dust and other organic dusts such as sugar, flour and paper. The training will provide 150 courses in 14 Midwestern states for 3,000 employers and employees primarily in the agriculture, food processing and fiber sectors with a focus on grain elevators and ethanol bio-refineries. Training is a great administrative approach in providing hazard awareness. But what about the current best engineering control measures and are they adequate?
With the current progression of incidents, this unique national industry with a primary NAICS 325193 Ethyl Alcohol Manufacturing and secondary NAICS 311211 Wet Corn Milling is quite similiar to tectonic plates shifting, one upon the other, and its only a matter of time before another event occurs in the seismic proportion of the 2007 Steamboat, Iowa explosion, causing millions of dollars in damage in addition to potential fatalities and injuries.
Overall, in the majority of these recent ethanol plant incidents, life safety, structural integrity and mission continuity objectives of the NFPA combustible dust standards have been maintained. This is an excellent example illustrating that combustible dust related explosions cannot be totally prevented only the severity reduced. The task now is to somehow reduce the probability.
This overview is not meant to place blame on the ethanol industry which is actively striving to reduce incident rates. Hopefully the information from tracking and researching these incidents will provide stakeholders an enhanced awareness concerning trends that have been developing. With this information possible preventative and mitigative strategies can be devised in minimizing the occurrence of another tremor.
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.
The recent grain elevator explosion in Louisiana last week brought back stark memories of over three decades ago, in 1977, when a series of similar dust explosions occurred in grain elevators throughout the south, which resulted in dozens of workplace fatalities. Fortunately in the recent explosion no injuries or fatalities were reported, just a lot of frayed nerves from nearby residents with electrical service briefly interrupted along the Mississippi River.
30 Combustible Dust Explosions Over the past year, through media accounts, 30 combustible dust related explosions have occurred in the wood, food, chemical, metal, plastic, rubber, utility, and paper manufacturing sectors. On the western bank of the meandering Savannah River, workers weren't so lucky in escaping injuries or fatalities on the evening of February 7, 2008 when a catastrophic Imperial Sugar Refinery dust explosion occurred in Port Wentworth, Georgia. Subsequently, national media coverage created a much needed awareness concerning combustible dust hazards in the workplace.
Additionally, intense outrage amongst Democratic Congressional leaders responded with an emotionally drafted general industry combustible dust bill, which passed in the House, and now awaiting vote in the Senate. Results of the presidential election, with a potential shake-up of public policy concerning workplace health and safety will determine the future of the bill.
118+ Fires and Explosions Unfortunately this year, the Imperial Sugar dust explosion was not an isolated incident. For instance over the past year, through media accounts, 118+ combustible dust related fires and explosions have occurred in the manufacturing, utility, and non-manufacturing sectors.
Trying to make sense of it all and why even dust explodes is an exercise in science combined with business and public policy across the vast ocean of the public and private sectors. The on-going tug of war between the interests of big business and labor complicates the matter even further in arriving at a cost effective solution in preventing future fatalities, injuries, and adverse economic damage.
Cursory Solution : Incomplete Data Of major concern is how can public policy be created in Congress with ensuing OSHA health and safety regulation's if the extent of the problem is not completely evaluated? Costly governmental studies were completed, which resulted in federal directives that only provide a cursory solution to the combustible dust problem. In the meantime our nation's infrastructure in the manufacturing base is at threat from continuing preventable combustible dust related fires and explosions.
For instance the OSHA Combustible Dust National Emphasis (NEP) program is not even required in nearly half of the states with State OSHA Plans (strictly voluntary). That's only the tip of the iceberg, especially over the past year, where explosions and fires are occurring at facilities with dozens of NAICS not listed in the NEP.
Food Manufacturing Reviewing the food sector, six out of the seven combustible dust explosions occurred in national food industries (NAICS) not listed in the NEP. With explosions occurring more than once at dehydrated food and evaporated diary product manufacturing plants. This is where a ComDust Hazard Alert goes out next, especially when these industries are not on the NEP radar. OSHA inspectors are actively inspecting these facilities as the following excerpt from a recent General Duty Clause (GDC) citation at a dehydrated food manufacturing plant in Wisconsin will illustrate:
"...The following C.O.W (cream of wheat) equipment did not have explosion/deflagration containment, suppression, inserting, or venting protection: a) Cooker room dust collector, approximately 375 cubic feet, was located inside the building lacking explosion venting. b) silo did not have explosion venting. d) pneumatic conveyor did not have spark detectors or propagation shut off devices to prevent explosion propagating forward or aft. "AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD..."
Overall, out of the 17 combustible dust related fires and explosion in the food sector, over 70% happened at facilities not listed in the OSHA Dust NEP. Are we seeing a trend here?
Paper Product Manufacturing A glance at the paper manufacturing sector which includes 16 national paper industries (NAICS), not one is listed in the OSHA Dust NEP. So how many explosions and fires this year? How about 11 fires and explosions, which included two dust explosions. It's like a snowball rolling down the hill as the plot gets bigger and bigger with four paper mill combustible dust related fires, three sanitary paper product manufacturing fires, and two combustible dust fires at corrugated solid and fiber box manufacturing plants.
Plastics/Rubber Product Manufacturing In all fairness the plastics and rubber manufacturing sector is well covered in the NEP. For example, seven combustible dust fires and explosions occurred this year which includes three explosions. There does need to be a reevaluation of whether these national plastic/rubber industries have a potential /D-2 or more frequent/D-1 history of combustible dust fires/explosions as outlined in appendix D-1 and D-2 of the NEP. All these explosions occurred in NAICS that were referenced in D-2 (potential for an incident). If incidents are reoccurring with explosions then wouldn't that move them from a potential/D-2 to a frequent/D-1 in the Appendix?
Conclusion Other sectors in wood, chemical, textile, machinery and metal national industries have their share of explosions and fires as depicted in the chart for incidents in 2008. Stakeholders with financial interests in all these manufacturing and non-manufacturing sectors must understand that the OSHA Combustible Dust NEP is solely a directive which provides guidelines for OSHA inspectors in conducting enforcement and inspection actions at facilities.
It should not be used as guidance in preventing and mitigating future incidents, while misinterpreting that since your facility is not a listed NAICS in the NEP, you are out of danger from the hazards of combustible dust. Over 50% of the combustible dust explosions this year were at facilities with NAICS (national industries) not listed in the NEP. Don't be a statistic. As soon as possible initiate a process hazard analysis which identifies, evaluates, and controls the inherent combustible dust hazards at your facility.
For additional information if your national industry has a history of potential or high occurrence of combustible dust related fires/explosions contact John Astad at the Combustible Dust Policy Institute.
Here is a success story in regards to a recent fire at a textile mill in Pennsylvania. A news account in the Republican-Herald reported that the automatic fire alarm alerted the local Pine Grove, Pennsylvania fire department and upon their arrival the fire was extinguished by the factory’s fire-suppression system.
"Pine Grove Fire Chief Dave Sattizahn said a heat buildup of more than 300 degrees started the fire.“Lint or something got caught up in there,” he said. “I’m not exactly sure what yet. I don’t know if it was blocked. These things happen. It’s a common thing in the fabric industry."
The fire occurred in the duct work connected to a process machine. Guilford Performance Textiles is a global leader in textile and fabric finishing for over six decades. Additionally, the company is leading by example with the proactive mitigative fire protection measures that management has instituted in the plant with fire detection and suppression systems that reduced the severity of the recent incident.
Ignition and fuel sources are an inherent aspect at manufacturing facilities and fires unfortunately will continue to occur. It's through a comprehensive process hazard analysis that the likelihood and severity of incidents can be minimized. Plant managers and owners throughout the manufacturing sector can learn from this incident in minimizing the risk at their plant.
Guliford is listed as NAICS: 313312-Textile and Fabric Finishing Mills and not found in the OSHA Combustible Dust NEP where only 16% manufacturing sector NAICS are targeted for OSHA inspections with an emphasis on dust. Additionally, more than 50% of the 90+ combustible related fires and explosions in the last seven months are not listed in the NEP either. Relying solely on the OSHA Dust NEP as a solution does not address the complex combustible dust issue.
Even if your facility does have a NAICS that is listed in the NEP the chance of an OSHA inspection with a dust emphasis is very slim. For example of the over 2,000 NAICS 313311 Broadwoven Fabric Finishing Mills, 4%(29) had a facility inspection within the last twelve months by a CHSO and only 0ne of these was with an emphais for combustible dust. There are many more recent examples like this, which the Combustible Dust Policy Institute has discovered through research of incidents provided through news accounts.
Across the nation, informative training seminars are conducted for stakeholders on preventative and mitigative measures in reducing the likelihood of combustible dust related explosions and fires. During these very educational workshops, the most referenced document in addtion to the CSB Dust Hazard Study and NFPA combustible dust standards, is the OSHA Dust NEP.
This is fine if your facility has NAICS that is listed in the NEP. But what about the other 84% NAICS in the manufacturing sector. Of course not all of these handle combustible particulate solids that generate combustible dust. Yet over 50% of the manufacturing facilities that experienced combustible dust incidents in the last seven months had NAICS not listed in the NEP.
So are you going to gamble on a 50:50 chance that your plant won't have a troubling combustible dust related fire and explosion in the near future? Worrying about an OSHA inspection should be a secondary thought. As outlined in the NFPA combustible dust standards, the life safety, mission continuity, and structural integrity of the premises is of utmost importance.
The recent statistical data of incidents and OSHA inspection reveals the true story. If you are the majority and not the minority then don't fall under the false presumption that the OSHA Dust NEP will provide the answer. Take steps now as Guilford and many other facilities not listed in the NEP have already done.
Statistical NAICS reports of prior OSHA inspections and combustible dust related incidents are now available at the Combustible Dust Policy Institute, which are utilized in the process hazard analysis in determining the likelihood and severity of combustible dust incidents. Unfortunately, while thinking outside the box, the research in acquiring this data does not rely solely on the Combustible Dust NEP.
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.
The recent box manufacturing plant fire Thursday evening at Longview Fibre in Yakima, Washington brings to mind a combustible dust related fire three months earlier at Lincoln Paper & Tissue in Lincoln, Maine. In the Washington incident, the facility fire sprinkler system in conjunction with a team effort from the the industrial fire brigade prevented the fire from destroying the facility.
In contrast, with the assistance from local mutual aid, Lincoln Fire Department Fire-fighters subdued the New England blaze after a three hour battle. Luckily no one was injured in both instances, only damaged egos of plant managers and owners. The Longview facility in the Pacific Northwest, sustained an estimated $100,000 in damages according to news reports from the Yakima Herald-Republic.
Inspectors Find No Dust Less than three weeks prior to the New England paper mill fire, the Federal OSHA Augusta, Maine office cited the facility for electrical, hazardous materials, and exit route hazards. According to news reports from WABI TV, the facility experienced a similar fire months earlier in January 2008. No mention of dust hazards are noted in the online OSHA accident and citation report.
Reviewing OSHA inspection reports for the Longview Fibre paints a revealing picture. Over the past decade Washington OSHA inspectors visited Longview Fibre Washington plants over two dozen times for complaints, referrals, follow-ups, and planned visits. The last citation "serious" was in 11/02/05, for an Ammonia (NH3) infraction. No issues concerning a combustible dust hazard were noted at this facility either.
NAICS Emphasis The current OSHA Combustible Dust National Emphasis Program (NEP) initially became effective on October 18, 2007 and was reissued March 12, 2008, over a month after the Imperial Sugar Refinery sugar dust explosion. The only difference between the two NEPS, besides the change of the date at the top right hand corner, is that the newer directive divides the NAICS into Appendix D-1 and D-2 with two diverse classifications:
Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires D-1
Industries that may have Potential for Combustible Dust Explosions/Fires D-2
In either case, the Paper Manufacturing subsector, with Industry Groups of Pulp, Paper, and Paperboard Mills and Converted Paper Product Manufacturing are not covered in the revised OSHA Combustible Dust (NEP).
Amazingly, NAICS 322211/corrugated and solid fiber box manufacturing at Longview Fibre and NAICS: 322121/paper mills at Lincoln Paper & Tissue are not under the OSHA radar as having a combustible dust hazard present at their facilities. Yet combustible dust related incidents can still occur at hundreds of other facilities in the Paper Manufacturing sector without proactive preventative and mitigative measures being addressed in addition to not being listed in the OSHA Combustible Dust NEP.
State Dust NEP Voluntary The most stunning aspect concerning the OSHA Combustible Dust NEP, is that for states like Washington that have there own OSHA program similar to Cal-OSHA, is that State plan participation in this national emphasis program is strongly encouraged but is not required.
Thats correct, participation is voluntary. The Combustible Dust Policy Institute recently talked with an official from Washington OSHA and it was reaffirmed that the state does not have an emphasis program for combustible dust due to financial resource considerations.
Not If, But When Combustible dust related fires and explosions will continue throughout the year in the manufacturing sector. At the present rate, the Combustible Dust Policy Institute has projected with approximately 12 incidents/monthly, an additional 50 combustible dust related fires and explosions will occur before years end.
Don't gamble with borrowed time, even if your facility is not a listed NAICS in the OSHA Combustible Dust NEP and generates combustible dust from combustible particulate solids. Perform a process hazard analysis now and have your dust tested for ignition sensitivity and explosion severity immediately as time permits while the sands in the hour glass are dwindling.
The information in http://dustexplosions.blogspot.com/ is not meant to be a substitute for the Code of Federal Regulations (CFR), Federal Register, and other OSHA documents, which should serve as the primary source of regulatory guidance. The information on this site should not be used in place of appropriate technical or legal advice related to your company's specific circumstances. Combustible Dust Policy Institute tries to provide quality information, but we make no claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained in or linked to this web site and its associated sites. Combustible Dust Policy Institute has no liability arising from or relating to the use, interpretation, or application of the information or its accuracy or inaccuracy. Copyright notice: All materials in this site are copyrighted by the Combustible Dust Policy Institute. No materials may be directly or indirectly published, posted to Internet and intranet distribution channels, broadcast, rewritten for broadcast or publication or redistributed in any medium without permission.
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