NAICS Awareness ComDust Hazards Alert

I'd like to thank David Osbon, Product Manager of Unifirst, a provider of flame resistant clothing (FRC's) and contributing author of the ComDust Blog in sharing the above pie chart that encompasses 60%, (over 18,0000) of the 30,000 letters that OSHA sent to establishments which were identified by OSHA as national industries (NAICS) that have imminent and inherent combustible dust hazard along with a copy of OSHA's Combustible Dust SHIB. .

In the March 2008 letter, OSHA urged employers to review the information in the Combustible Dust SHIB and reminded stakeholders of their responsibilities to minimize combustible dust hazards and lessen the severity of future incidents that are inherent in the manufacturing and non-manufacturing process. It also reminded them of the assistance OSHA's on -site Consultation Program can provide confidentially and free of charge.

There is a problem here that needs to be addressed concerning industry awareness of combustible dust hazards. Since the beginning of the year, through media accounts, theres been 14 combustible dust related fires and explosions in the Paper Manufacturing sector, yet in the above pie chart it highlights that this manufacturing subsector was not identified as having a combustible dust hazards when letters where sent out. Below you'll note another pie chart of combustible dust explosion over the past year in the various subsectors




Thats odd, especially, through media accounts, 7% of the ComDust explosions have occurred in the Paper Manufacturing sector. In no way is this meant to be derogatory to this vital national industry with over 6,000 establishments and over 400,00 dedicated and hard-working employees. The Combustible Dust Policy Institutes's goal is to provide a proactive awareness and work collectively in stategic alliances with all stakeholders in the public and private sectors.

An especially critical aspect of hazard awareness is the OSHA Combustible Dust NEP, where Paper Manufacturing sector is excluded as Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires and Industries that may have Potential for Combustible Dust Explosions/Fires.

The paper manufacturing sector which includes 16 national paper industries (NAICS), not one national industry (NAICS) is listed in the OSHA Dust NEP. 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.

It was only yesterday when a Paperboard Mill experienced a combustible dust fire when paper dust ignited on a dryer area and went into the pneumatic conveying system. The news account further stated, "in January, an overheated piece of machinery sparked a fire that spread along the ceiling." This is the problem, as over 30% of the 122+ combustible dust related fires and explosion are reoccurring repeats, which eventually end up as the rare event of a combustible dust explosion.

The paper sector is not alone as not being referenced in the Dust NEP as national industries (NAICS) in the wood, food, textile, chemical.plastic/rubber, primary metal, machinery , furniture, miscellaneous , and non-manufacturing are also not included. Maybe a potential solution is to utilize a watered-down version of OSHA's Process Safety Management (PSM) for combustible dust, which has similar characteristics in explosion severity (Kg, PMax) as do flammable liquids and gases referenced in the OSHA PSM.

Webinar-Evidence-Based Compliance (free)

This just in. A free webinar at 2:00 PM EST November 19, 2008, sponsored by MSDSpro and hosted by EHS Today magazine discussing OSHA Hazard Communication Standard. An added awareness must be projected to the industry concerning combustible dust hazard awareness. Currently MSDS's do not provide the vital ignition sensitivity and explosion severity data.

The Combustible Dust Policy Institute is developing a Co-Op combustible dust testing service between Users Groups and testing laboratories. If a multitude of stakeholders from a niche national industry (NAICS) desire testing all at once, then costs of testing can exponentially go down. Lets do it! I need feedback both negative and positive from all stakeholders to proceed further.

Join the Combustible Dust Policy Institute Group on LinkedIn for additional discussions on this topic. See you there.

Fireball Combustible Dust Deflagration

Here is an excellent example of the fireball effects when combustible wood dust finds an ignition source. Warning don't try this at home! These people have way to much time on their hands. Thanks Justin for sharing

Grain Facility ComDust Fires and Explosions

Since the Destrehan, Louisiana grain elevator explosion two weeks ago that put the ADM/Growmark's largest export terminal in Louisiana out of service, through media accounts, eight additional grain facility combustible dust related fires and explosions occurred throughout the nation. The financial damage from these events has totaled over $200,000 and luckily no injuries.

So is the OSHA grain facility standard working? It is not possible for OSHA with limited resources to inspect thousands of these grain handling facilities ensuring workplace safety compliance. Will it take a dust explosion in the magnitude of the catastrophic Imperial Sugar Refinery explosion this year to finally address the situation with additional governmental accident investigations, congressional hearings, and costly studies.

The clock is ticking and there is no time to waste. Combustible dust related fires and explosions in the grain handling facility or manufacturing, utility, and non-manufacturing sectors all have the same devastating effects.

The current combustible dust bill (H.R. 5522) awaiting a vote in the Senate needs to be reevaluated with provisions for all combustible dust related explosions and fires. Lets get our eggs all in one basket instead of the chaos that has engulfed the nation's workplace concerning combustible dust hazards.

Combustible Dust Explosions 2008

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.

$3 million Combustible Dust Related Fire Unreported

How can a $3 million fire that destroyed a historic furniture factory in Salt Lake City, Utah four years ago be unreported in the Chemical Safety Board Combustible Dust Hazard Study? An excerpt from a news account states:

"Local fire officials suspect that the fire started in the dust collector at the 120-year-old factory owned by Jeffrey Cobabe and Associates."

Hundreds of Incidents not Reported
The troubling aspect of the incomplete CSB Dust Hazard study that was submitted to OSHA in 2006 is that public policy concerning worker health and safety was formulated in the OSHA Combustible Dust National Emphasis Program (NEP) directive. Additionally, in March 2008 the House Education and Labor Committee introduced to Congress (H.R.5522) The Worker Protection Against Combustible Dust Explosion and Fires, also utilizing the CSB Dust Hazard study as the guidance and foundation in the drafted bill.

Since the Imperial Sugar Refinery dust explosion, dozens of training classes at industry conferences hosted throughout the nation have been providing industry stakeholders with information on combustible dust hazards. Yet these training seminars also make continuing reference to the CSB dust study in addition to the OSHA Combustible NEP, which unfortunately omits hundreds of manufacturing sub-sectors (NAICS). This training is fine and much needed in the industry. A problem arises when plant owners and managers are not obtaining the complete picture of the magnitude and depth of combustible dust hazards.

The Chemical Safety Board is not to blame. This agency is the finest accident investigation agency in federal government and has provided the industry with crucial information in preventing future accidents. With a limited budget these dedicated professionals are on the front lines investigating catastrophic accidents finding the root cause. What the agency isn't, is a research organization like the Bureau of Labor Statistics

OSHA Dust NEP NAICS

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Get the Knack of the NAICS
Referring to the above destructive fire where a dust collector was involved in just one example of the hundreds of NAICS and tens of thousand of manufacturing plants not listed in the OSHA Combustible Dust NEP, where only 68 out of a 427 manufacturing NAICS are referenced in Appendix D-1 & D-2. Just because your facility is not one of the 68 NAICS listed in the NEP, don't for a second believe you have a free pass and all is fine and dandy.

If the process stream handles combustible particulate solids that generates combustible dust of any sort, then you are sitting on a bottle rocket waiting to go off when all the factors of ignition, heat, fuel, suspension, and confinement all come together in the rare moment. We all know what a vapor cloud explosion can do in the refinery sector. The same devastating overpressure effects occur with a dust explosion in the manufacturing sector. In fact, unbelievably for many combustible dusts, the deflagration index or explosion severity (Kst) is much higher.