Error in OSHA Combustible Dust; Advance Notice of Proposed Rulemaking

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's National 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.

OSHA NEP Conflicting with Fire Service Combustible Dust Fire Response

Wheel Alignment or New Tire?

Earlier this year a combustible dust fire and explosion at a North Carolina fiber recovery facility resulting in four injuries has safety professionals scratching their heads and wondering why OSHA continues to ignore the multitude of manufacturing sub-sectors (NAICS) in the OSHA Combustible Dust National Emphasis  Program ((NEP). For instance, the fiber recovery  facility is classified as NAICS: 322299, All Other Converted Paper Product Mfg. (515 establishments in 2007) which is not recognized in Appendix D-1 nor D-2 of the OSHA NEP as an industry that may have potential for combustible dust explosions or fires.

There are many more NAICS not recognized in Appendix D-1 or D-2 where combustible dust fires and explosions have occurred since the NEP was reissued in 2008. Continuing on the misguided approach of targeted inspections for a select few of NAICS while not recognizing a multitude of others is a path wrought with undesirable consequences. There is a commonality of process equipment, effective ignition sources, and potentially explosive atmospheres amongst all global manufacturing sub-sectors processing and handling combustible dust. Its not a matter of if, but when a combustible dust related incident will occur. Solely relying on a NAICS conflicts with reality in conjunction with fire service response to the multitude of repeatable combustible dust fires and explosions regardless of whether a NAICS is listed in the NEP or not.

Deputy Chief Greg Blackburn of the Ronda Fire Department put it more succinctly following the March 2012 fiber recovery facility incident, "It's happened before. It's not uncommon, this kind of situation," he said. On a larger scale the same can be said as we observe continually from nationwide news accounts  similar views following fire service response to combustible dust related fires and explosions of NAICS not recognized in the OSHA ComDust NEP.

For how much longer will the ComDust NEP continue to be a static document? Its already been over a half a decade since initially issued October 17, 2007. Will stakeholders have to wait for another tragic combustible dust catastrophe where the U.S. Chemical Safety Board will investigate providing key recommendations for root and contributing cause that we already know about? Continuing to ignore the fire service as a welcome partner in the combustible dust rule-making process fails to acknowledge the root of all catastrophic events.  This would be in the form of all the prior non-consequential combustible dust events the fire service is responding to repeatedly. 

We have it all backwards right now with all the focus on catastrophic dust explosions while ignoring the multitude of non-consequential combustible dust related fires. For instance, say your car is traveling down the freeway and you get a tire blowout due to a worn out tire treads. So you go to the tire shop for a new tire and the repair person notices your wheel alignment is off. Not having correct wheel alignment will cause your tires to wear improperly resulting in tires rapidly wearing down at the treads. 

New Tire or Wheel Alignment?

So what you going to do purchase a new tire and continue your highway travel or get a wheel alignment before purchasing a new tire? Having a tire blowout on the highway at high speed is analogous to a potential catastrophic event. A wheel alignment is just like addressing the fires in  minimizing the probability of a tire blowout while traveling on the highway. So is it time for a realignment? What do you think?  

Déjà vu Firefighters Killed & Injured in Repeatable Deadly Silo Explosions

Diagram. Aerial view of incident scene after 1997 explosion

Is anyone out there reading these accident reports prepared by the United States Fire Administration (1997) and NIOSH (2003)? Doesn't appear anyone is especially with the multitude of catastrophic incidents mirrored after each other like reruns on the television.

Time is way overdue for firefighting training on the practical aspects of combating combustible dust related fires. We already know about the physicochemical properties of combustible dust with the wealth of literature out there. Now is the time to get down dirty out on the training fire ground.

A real concern is in these two accident reports is continued mention of oxygen-limiting silos. This is incorrect as they were no longer oxygen-limiting silos but instead modified oxygen-limiting silos. Big difference between the two. Adding water to the top of any silo in conjunction with simultaneously opening access doors at the bottom and poking around with smoldering contents is wrought with danger. Do you feel lucky?

U.S. Fire Administration Fire Investigations Program:

The U.S. Fire Administration develops reports on selected major fires throughout the country. The fires usually involve multiple deaths or a large loss of property. But the primary criterion for deciding to do a report is whether it will result in significant “lessons learned.” In some cases these lessons bring to light new knowledge about fire--the effect of building construction or contents, human behavior in fire, etc...

 

Resources:

Industrial Silo Fire and Explosion1997 USFA
NIOSH LODD Report 2004

Management in Russia Factories Receives Prison Punishment, Combustible Dust Deaths

(Bryansk. Russia) "Feed Processing Facility operated without a special license, worn-out equipment continued to operate where there was no dust collection. Resulting in October 23, 2011 explosion killing two workers. A September 2011 order to eliminate the violations to the company's management was issued yet ignored. The criminal case was opened under Part 2 of Article 143 of the Criminal Code (violation of safety regulations and other safety rules that resulted in the death of a person)." Best industry practices in feed processing facilities can be found in NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities.

(Udmurtia, Russia) In another incident (1/2/2012). "Director at furniture factory, two workers killed and two injured, faces up to five years in prison. Charged under Part 2 of Art. 219 of the Criminal Code, (violation of fire safety, by a person, which was responsible for their implementation, if it resulted in the death of the person.). Fire was caused by a spark that causing combustible dust deposits paints and explosion. The reasons stated was for violation of fire safety: where in the shop cleaning was not carried out - on the floor, walls and furniture lacquers site (paint shop) accumulated dust deposits paints. According to experts, the cause of fire was a violation of the process for dismantling the ventilation ducts." Best industry practices in furniture factories  can be found in. NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities.

From the following excerpts of the Russia news stories you'll need to use Google Translate  to read the complete account when translating from Russian to your specific language.Copy and paste the URL into the Google Translate box for language translation.

Ignoring Combustible Dust Fires Results in Belarus Catastrophe

The October 25, 2010 catastrophic dust explosion at the Pinskdrev chipboard facility in Pinsk, Belarus resulting in fourteen fatalities has huge implications amongst the global manufacturing sector. Key findings from the accident investigation determined that prior to the afternoon explosion in the wood pellet area of the chipboard (particleboard) facility there was a history of  numerous fires.



This illustrates very graphically how non-consequential combustible dust related fires can be precursors to catastrophic secondary dust explosions. Currently combustible dust layer fires are  ignored. Where instead primary attention is directed towards more newsworthy dust explosions. This is a disastrous approach in putting the cart before the horse.

In the USA, the Chemical Safety Board (CSB) has completed accident investigations on five catastrophic dust explosions. All the CSB reports note, just as in the Pinksdrev incident, a history of non-consequential combustible dust related fires prior to the catastrophic events. If your facility has a history of non-consequential combustible dust related fires then you have a serious problem analogous to the tip of the iceberg which the passenger ship Titanic struck on her maiden Atlantic crossing. After any such fire it is imperative an accident investigation is undertaken in determining root and contributing cause so as to minimize the probability of the next incident occurring.

From the following excerpts of the Belarus news stories of the Pinskdrev explosion you'll  have to use Google Translate  to read the complete account when translating from Russian to your specific language.Copy and paste the URL into the Google Translate box for language translation. Special thanks to Vecherniy Brest (Вечерний Брест; Evening Brest) and Naviny.by. Belarusian News in their excellent news coverage which provided the opportunity to share the events with the global safety community. 

   

High Levels of Dust (NFPA 664)

Court proceedings discovery: "about a week before the events wall fan was turned off."
At this company repeatedly (in January, February, March, May, June and July 2010) had fire and sparking in the  mill site during the production of wood pellets, where always there was an increased level of dust. "According to the Prosecution," the requirements for equipment installation room automatic fire and automatic fire alarm was suppose to be made ​​in ... 2000. In addition, "the JV" Pinskdrev-DSP "willfully, without appropriate approvals of the Medical Service and Fire Department, installed a second production line for wood pellets.

Prior Combustible Dust Related Fires

"The audit found that the fire occurred in the enterprise before. Sometimes, that is not duly registered in the departmental professional fire protection guard traveled to the extinguishing of the fire up to four times a day. In 2010, the site for the production of wood pellets fire took place on 8 and 30 June, and October 13 - 12 days before the tragedy".

"These facts were hidden from Pinsk city Department of Emergency and were not counted as fires. Information about them from the workforce and the population in the MOE also been reported. And this despite the fact the enterprise is highly explosive.  For example, in May 11, 1997 because of the high concentration of dust in the room of the main building there was a dust explosion, accompanied by fire."

 “Prerequisites in the incident, apparently accumulated over a long time. The same Prosecutor General Grigory Vasilevich , visiting the site of tragedy in November 2010, said that "the company revealed serious violations of process discipline and safety rules were not complied with health standards. Repeatedly fires, which are eliminated on their own. " This was the warning calls future tragedy, says Grigory Vasilevich, but the responsibility for the safety of people officers ignored them"

This is the exact same problem here in the USA with the repeated combustible dust fires which are mostly non-consequential and extinguished in the incipient stage without any follow-up investigation of root and contributing cause,. Prior non-consequential combustible dust related fires have the potential escalating into catastrophic dust explosions.

Magnetic Separators

"The investigation of the accident revealed that during operation  fire safety rules  were violated. Above the conveyor feed hopper in front of the hammer mill and in itself is not installed iron catcher (magnets), which paved the way for the entry into the equipment of metal objects and sparks of mechanical origin, which could be a source of ignition of an explosive dust air mixture."

Explosion Venting (NFPA 68)

"Nor were installed devices that provide fire and explosion hazard shedding dust and gas mixtures and gases in the event of an explosive tank valve hammer mill was prevented delivery fire and explosion hazard and gas mixtures through the safety valves and blow-off line manual bleed into the production room. Wood dust collection system placed directly in the room area."

Inadequate Local Exhaust Ventilation

"In addition, due to the fact that the primary hammer mill did not provide load two pelleting presses, in October 2010, it was replaced by the more powerful. After mounting between it and discharge hopper formed unclosed space through which the room area ejected wood dust and crushed chips, leading to a dusty room"

History North America Particleboard Combustible Dust Incidents
  
Two Injured, Explosion and fire at particle board plant in Smithers, BC (2008)


Explosion and fire at particleboard factory kill two, injures 8, Pennsylvania (Feb. 2001)“The fire was contained in a silo that abuts the plant, McKean County emergency management director Ken Mostyn said. A dust collection system that runs along the plant's roof and feeds the silo was heavily damaged, he said. Authorities said fire spread through sawdust piles in the building and quickly overwhelmed Temple-Inland's on-site fire brigade.”

OSHA issued three willful violations, with a proposed penalty of $189,000 and 16 serious violations with a penalty of $59,400.

"The alleged willful violations address the company failure to prevent excessive accumulations of wood dust, failure to shut down a conveyor that carried sparks to other combustibles and unapproved electrical service in restricted areas," said John Stranahan, area director of the Erie OSHA office. "Wood dust is recognized as the single greatest hazard for fire and explosion in the particleboard manufacturing industry." “Dust levels throughout portions of the plant were documented in some locations between four and six inches. The National Fire Protection Association recommends that wood dust not exceed one-eight of an inch.”

Conclusion
Hopefully sharing the tragic account of the Pinskdrev Belarus incident in addition to the history of prior particleboard facility incidents in North America will assist stakeholders in understanding combustible dust fires and explosions is a global hazard. Robust engineering controls incorporated into local exhaust ventilation will ensure dust layers are minimized. When processing wood it is essential magnetic separators are installed upstream so as to prevent foreign materials from providing an ignition source downstream. Addressing the combustible dust related fires(fire triangle) immediately in determining root and contributing cause will ensure the unwelcome fire triangle will never have a chance to visit a facility.


 

Firefighter Injuries Unacceptable Combating Combustible Dust Related Fires

Recent firefighter injuries such as fighting a combustible dust related fire at plastics material and resin manufacturing are unacceptable. This brings back dark memories of the 1993 fire and catastrophic dust explosion at a wood fiber facility in Langerak, Netherlands resulting in 2 firefighter fatalities and 10 firefighter injuries. A question arises whether firefighters should be afforded the same workplace protection as workers in the private sector noted in the OSHA regulations?

State and local government agencies such as the Monroe Fire Department are not subject to the regulations established by Federal OSHA. For instance, Section 3(5) of the Occupational Safety and Health Act of 1970 (the Act) specifically excludes the employees of State and local government from coverage under Federal OSHA. This does present a huge problem where a failure to assess and identity combustible dust fire and explosion hazards can have severe consequences.

“While attempting to extinguish the fire, Centers said “there was a dust explosion” that caused the three injuries. He said firefighters were attempting to remove the material, which was through a 2-1/2-inch pipe at the bottom of the tank. “Dust that was created while they were pulling the dry material out found an ignition source and ignited,” he said.” Bridging and Rat-holing come to mind? What do you think?

In contrast, the OSHA General Duty Clause is applicable to practically any fire-fighting operation where combustible dust fire and explosion hazards are present. Fire Departments are required to identify the combustible dust hazards that firefighters may be exposed to. This can be implemented by providing firefighters the necessary standard operating procedures, combustible dust training, and equipment to safely mitigate the hazard.

The OSH Act is not all inclusive of the 26 States currently authorized by OSHA to run their own safety and health programs (OSHA State-Plan states), enforcing OSHA regulations that apply to both public and private employees in state-plan states.  Additionally, “NFPA recommends that all fire departments establish a policy of providing and operating with "the highest possible levels of safety and health for all members" [NFPA 1992]. Several NFPA standards apply to fire-fighting operations such as NFPA 1500 specifying the minimum requirements for a fire department's occupational safety and health program.

Typical Fire with Combustible Dust?
Questions arise in whether fire departments do have the necessary training in understanding combustible dust fire and explosion hazards while combating combustible dust related fires? For example, in a recent news report a fire chief mentioned the fire at the plastics material and resin manufacturing “was typical of all fires” (01:20) video.

Since when is a combustible dust related fire typical? Especially when it has the explosive severity and severity of consequence of a flammable gas or vapor?

This post is in no way is meant to discredit the fire service, fire chief’s, and brave firefighters risking their lives everyday protecting life and property. It is solely to bring the subject to the table where the fire service must be welcomed to join in the current OSHA Combustible Dust Rulemaking process which must also include education, outreach, and training for all stakeholders and not just a select few. At the 2011 OSHA Combustible Dust Expert Forum held in Washington, D.C. not one member from the fire service was invited.
"Houston, we've had a problem".

Learning from Prior Incidents
Similar incident Feb. 2012 at Advanced Environmental Recycling Technologies (AERT), no one was injured in the blast. Dust explosion at Arkansas facility that recycles polyethylene plastic and waste wood fiber in the manufacturing of windows, doors, and decking. AERT wood composite MSDS

Responding to any combustible dust related fire is not a "typical fire." All that is needed to complete the explosion pentagon (fire triangle on steroids) is suspension and confinement. Dust suspension alone can also occur. When extinguishing this type of Class A fire, extreme care needs to be taken. For example, since a direct stream of water into the pile from a fire hose could cause the burning or smoldering material to become airborne resulting in a catastrophic flash fire or even spreading the fire to other areas. Source: Handbook of Industrial Loss Prevention, 1967, Factory Mutual Engineering Corporation, McGraw-Hill Book Company New York, NY.

In Langerak, Netherlands (1993) "firefighters responded to a small fire in a wood fiber processing plant where unexpectedly an explosive spread of fire occurred. As a result, eventually three persons, including two firefighters, deceased and fourteen individuals, most of them firefighters were injured. The fire from the beginning was initially believed to be a fire without special risks."
 
Theres a wealth of scientific and layman literature on the physicochemical properties on combustible dust. The missing link is the practical aspects and hazards of combating a combustible dust related fire,. Such as the example above in caution using a hard stream of water from a hose or a avoiding pressured burst from a fire extinguisher. Then there is the bridging (arching) and ratholing hazards in overhaul of bulk storage enclosures (silios, bins, etc). The list goes on in practical aspects...


Near-Miss Accident Reporting
Reviewing lessons-learned from ComDust incidents on the National Fire Fighter Near-Miss Reporting System site it appears many in fire service management believe the primary consideration is PPE. How about lessons-learned in preventing envelopment by a raging fireball in the first place?

Dec. 21, 2007 "The lieutenant reported that workers were on the scene and that the fire "appeared to be extinguished". The lieutenant and a firefighter stretched a 1 3/4" attack line to an elevated platform approximately 15' from the ground to a hatch on the side of the silo. Once the line was charged the lieutenant opened the hatch and immediately heard a loud roaring sound followed by a flash fire erupting form the hatch opening engulfing the lieutenant."

Hold on the story gets even more interesting...

"The second engine arrived and was given the suppression assignment. The charged hoseline from the first engine was still in place so they utilized it. The second crew was not aware of the events that had taken place, only that the lieutenant was down. Once on the landing, the second lieutenant opened the hatch and again a loud roaring noise followed by a flash fire and explosion occurred engulfing the second Lieutenant and firefighter." Years of fire service experience: 24 - 26, Region: FEMA Region III

We cannot continue to ignore the combustible dust related fires anymore. How many more firefighter fatalities and injuries as a result of combating combustible dust related fires and explosions must occur before it is no longer acceptable?

Resources:
One Firefighter Fatality; Eight Injured WI, NIOSH Accident Report
Seven Firefighters Injured CA Facility, NIOSH Accident Report
Example Fire Department Training Program Compliance with OSHA Regs.
OSHA Combustible Dust Expert Forum, Washington, D.C, (2011)
Composite and PVC Decking