Oregon OSHA Aknowledges Combustible Dust Hazard

http://www.oregonlive.com/business/index.ssf/2008/06/state_warning_of_dust_hazards.html

An interesting article was published today in the Pacific Northwest, written by veteran reporter Anne Saker of the Oregonian concerning Oregon OSHA and the hazard alerts the agency has sent out to approximately 2,500 manufacturing facilities in the state that handle combustible particulate solids which have the potential in generating combustible dust.

Combustible Dust Hazard Alerts is an excellent venue in bringing out an awareness concerning combustible dust. A follow-up to hazard alerts would be training concerning the complexities of combustible dust hazard recognition, hazard assessment, explosion hazard management, and understanding the numerous National Fire Protection combustible dust codes.

Other states can learn from example where Georgia is hosting a Fire Safety Symposium July 14-18 2008, which includes two days of training concerning combustible dust hazard recognition, which will be presented by Guy Colona, NFPA Vice President of Chemical Engineering and Amy Spencer NFPA Senior Chemical Engineer. Relying solely on good housekeeping is only one aspect of the solution in preventing and mitigating future combustible dust fires and explosions.

Georgia Leads in Preventing Combustible Dust Incidents

Georgia is now leading the nation in preventing future combustible dust incidents with a proactive program that requires all new and existing facilities that have operations involving the manufacturing, processing, and/or handling combustible particulate solids including manufacturing processes that create combustible dust to register with the state by July 1, 2008.

In addition to requiring facilities to register the Rules and Regulations for Loss Prevention Due to Combustible Dust Explosions and Fire were adopted by the state on March 7, 2008. These proactive measures provide a high level of safety awareness that will prevent and mitigate the occurrence of future combustible dust explosions and fires.

Georgia has adopted the International Fire Code, which makes reference to the numerous National Fire Protection Association combustible dust codes. Such as NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, which is available for free viewing and purchase on the NFPA website.

Georgia Fire Safety Symposium
While taking the lead, the Georgia Insurance and Safety Fire Commissioner, led by Commissioner John Oxendine has organized an educational program with the help of his professional staff, which is open to the public at the Georgia Fire Safety Symposium to be held at the Georgia Public Safety Training Center in Forsyth, Georgia on July 14-18 2008. Several educational tracks will cover engineering/building inspections, hazardous materials inspections, and fire safety education for fire professionals who work daily in the fire protection filed. The Symposium is the 37th annual event and is part of the Fire Education program that the state provides in accordance with the mandate of Official Code of Georgia Annotated Title 25, Chapter 2.

Combustible Dust Training
A special aspect of the Symposium will be two days of training concerning NFPA Standards on Dust Explosions on Hazards. Guy Colona, NFPA Vice President of Chemical Engineering and Amy Spencer NFPA Senior Chemical Engineer will be providing the presentations. Topics will include dust hazard characterization, background on lessons learned from previous combustible dust incidents, hazard recognition, hazard assessment, and explosion hazard management.

Participants attending the two days of combustible dust training in the 500 seat auditorium will gain an understanding of the numerous NFPA combustible dust codes that are referenced in the International Fire Code, which cover metals, agricultural and food products, wood, explosion venting, and explosion prevention systems.

Conclusion
The most unique aspect of the Symposium is that it is open to the public. So now all stakeholders who work, manage, or own manufacturing facilities that generate combustible dust from combustible particulate solids will have chance to gain an understanding of the complex subject concerning combustilbe dust. After June 20, 2008 tickets will cost $125.00, a very reasonable fee considering the scope and depth of the content.

Other states can now learn from Georgia's proactive example in also instituting measures in preventing and mitigating future combustible dust incidents in addition to providing combustible dust training to stakeholders in their region.

Resources:
2008 Brochure and Registration Forms
2008 Fire Safety Symposium Registration Form

Combustible Dust Characterization

Will it burn? Here is an excellent view of a combustible dust magnified over 1500X with the aid of a scanning electron microscope (SEM), the pictomicrograph provided by Phenom is 125 microns in height. So how many microns does a dust particle have to be in order to be considered a combustible dust? Electron microscopy can be quite useful in characterizing combustible particulate solids and the combustible dusts that are generated in the manufacturing process.

Theres many particles that will not pass through a 40 Mesh U.S Standard Testing sieve and would be inappropriately characterized as non-combustible. Such particles could be agglomerates that can be formed by triboelectric attraction or hydrogen bonding of hydrophillic particles . Does your manufacturing process generate agglomerates such as flocks in the manufacturing process?

In December 1995, the Malden Mills combustible dust explosion and fire destroyed the facility and injured 37. The Chemical Safety Board determined that static electricity ignited nylon flock fibers. What is the resistivity and minimum ignition energy (MIE) of the dust generated at your facility?

Can anyone guess what combustible dust is in the picture.? Just name it in the comments section and I'll let you know if you are correct. The winner will receive a free combustible dust report with the specific names of all the NAICS subsectors listed in Appendix D of the recent OSHA Combustible Dust NEP.

'Photo Credit: Phenom

Information Scanning Electron Microscope

Taking Responsibility For Worker Safety

Just one man's opinion.
by Curtis Gray

Having spent a large part of my life as executive management in manufacturing companies, often directly responsible for implementing safety compliance systems, I have to speak up on the notion of OSHA regulation.

In my experience, OSHA is a joke agency. All their efforts are spent running around trying to impose fines on small companies for failing to comply with this or that accident reporting requirements and not on safety inspections or regulatory compliance. The bigger the company the less likely they will ever see an OSHA inspector. Even when complaints are lodged by workers, the investigation consists of asking the company management for its side of the story, and then promptly accepting whatever explanation for the infraction is given.

Disband OSHA
Like most government regulatory agencies, OSHA is just a dog and pony show to placate people's need for "someone to do something" about a problem. They talk and talk, and spend millions of our tax dollars on developing regulations and then never really do anything but pay lip service to enforcement. To make matters worse, that same agency prevents any private recovery by barring employees from suing company owners for their willful negligence in taking calculated monetary risks with worker health and safety.

This is the true reason the agency even exists. Like most governmental agencies, OSHA was not founded "by, of and for" the people for some altruistic motive. OSHA was founded through collaboration between business owners whose primary concern was to protect themselves from lawsuits and to make the cost of killing people predictable as part of their financial risk management strategies, lawyers and insurance companies who thrive on regulatory environments, and legislators who can point to their efforts in support of regulation to show how “hard” they work for their constituents, especially in an election year.

So, in my opinion, the entire country might be MORE safe if OSHA was disbanded and the private sector was allowed to enforce safety by suing companies completely out of business that fail to provide safe work environments.

DeBruce Grain Elevator Explosion
I was just down the road a couple of miles when the De Bruce grain elevator in Wichita, KS exploded in 1998, killing seven and injuring several others. The ground shook so hard we believed that McConnell Air Force Base was under missile attack. Windows were shattered for blocks in every direction. Flames shot hundreds of feet into the air and the smoke plume choked us all.

We watched in horror as helicopters attempted to lift survivors from the burning roof. It is hard to imagine how many tax and private dollars were spent in rescue and firefighting efforts, or how much was lost by disruption of the companies all around the area. Then millions more was spent on legal fees while a flurry of lawsuits were attempted.

To my knowledge, no suits succeeded, because of OSHA regulations blocking those worker's families from such action. Instead, they were all given the "standard" $200K (the value OSHA places on a life) and told "too bad", that’s the way OSHA works. A recent article in the Wichita paper remembering the anniversary of the event says the fines to De Bruce for their part in the incident amounted to about $650K, if I remember the figure correctly.

I suspect that did not even cover the legal costs OSHA itself incurred in conducting the investigation and imposing the fine. I'm equally sure it meant nothing to De Bruce -- probably less than a week's profit, and probably paid by their insurance company, anyway. This was not the first incident for De Bruce, and not the first violation at that particular elevator.

60 Minutes Story
I read with interest the story produced earlier this month by "60 Minutes", as well as the long list of comments made by readers concerning dust explosions. All one has to do to really understand a huge underlying problem is to look at those comments, along with information available on this web site. People in this country spend too much time trying to get someone else to do something about their problems instead of dealing with the issue directly themselves.

One person says it's OSHA's fault, Another says it's the company's fault. They blame the workers. Another says the insurance companies should fix the problem. Good grief. There is only one fix. Hello to the workers of America - REFUSE TO WORK IN THOSE CONDITIONS. GO ON STRIKE OR GET ANOTHER JOB.

More Lawyers and Legislators
The only sure way to stop companies from taking advantage of the savings associated with failure to provide a safe work environment is for them not to able to get anyone to work for them. It’s all about the money. That is the nature of capitalism. We had a saying I remember growing up, “money talks, sh__ walks.” More tax dollars spent on bigger government and more unenforceable regulations will never solve the problem. People will continue to die and be injured. The only thing that will change with new legislation is that more lawyers and legislators will make more money.

The only way any public company has ever been forced to change anything about its behavior is through clipping its revenue stream. Fines and such mean nothing. It does not come out of “their” pocket, it comes out of “ours”. When a company is fined or the insurance rates go up because a law suit is lost, that just becomes another cost of doing business.

Costs are just rolled into price. The stock holders and managers don’t dig into their pockets and pay the fine. The price of the product just goes up. So, ultimately, passing regulations that result in fines to businesses only serves as another taxing mechanism for the government. No one gets hurt but the consumer, and of course, the worker.

Accountability
True worker safety is about workers behaving in a safe manner, not about rules telling them they should. Don't we have enough history under our belts yet on this earth to recognize that people don't follow rules unless they want to? God himself, Creator of the universe, gave us rules to follow that have been violated since the dawn of time.

Why do we think rules made by OSHA will be any more respected? Even severe consequences, no matter by whom imposed, won't get it done. Again I site the consequences for failure to comply with God's rules. I don't think it can be much more severe than that. But we still don't follow the rules a great majority of the time because it is not convenient or expedient for us on an individual level.

My heart goes out to those who have been directly affected by every incident in the work place, dust explosion or otherwise. Thousands of workers are injured or killed at work every year. I have been injured on the job myself and spent years recovering to 90%, which is the best I will ever do. But it happened because I didn’t think about the unsafe manner in which I was behaving, not because I didn’t have Big Brother standing over my shoulder. I think most workplace injuries fall into that category. They are truly just legitimate accidents caused by the imperfect nature of the humans involved.

Conclusion
However, many ARE the direct result of known, unsafe working conditions for which regulations are already in place, like the De Bruce incident. The conditions are known both to the management AND the workers. And though I feel the corporations are complicate and liable, if you walk out in front of cars every day and eventually get hit by one, it's hard for me to place all the blame the driver or the manufacturer of the vehicle, even if they were speeding and talking on a cell phone, and even if the pedestrian had the legal “right of way”.

My dad only finished the 6th grade, but he was smart enough to teach me that rules don’t protect people – people have to protect themselves.

YOUR TURN: OSHA has lost its map

Where: Combustible Dust Explosions/Fires?

Since the February 7, 2008 Imperial Sugar Refinery combustible dust explosion, over 52 reported combustible dust related explosions and fires have occurred in the United States. The majority of incidents are in rural areas where media exposure is limited and a Google Internet search does not provide an accurate number of the actual occurrences in manufacturing facilities.

Overall Picture
A general picture of incidents in the United States is beginning to develop through research conducted by the Combustible Dust Policy Institute in Santa Fe, Texas, utilizing Google Alerts and RSS feeds. When news reports do not include information whether or not an incident is combustible dust related, then a follow-up telephone call acquiring additional information from the local fire investigator or fire chief is conducted to ensure accuracy of the reporting methodology. Once confirmation is achieved then the incident's geographical location is placed on the Google Combustible Dust Incident Map.

Over 75% of the 52 combustible dust explosions and fires have occurred east of the Mississippi. Further distilling the data, along the Atlantic Seaboard states, stretched from Florida to Maine, over 50% of the incidents have happened . Additionally, in the geographical triangle bordered between the Great Lakes, Appalachian Mountains, and the Mississippi River over 30% of the incidents are taking place.

Geographical Hot Spots
Locating geographical hot spots where combustible dust incidents are occurring more frequently will allow all stakeholders to develop proactive measures in preventing future occurrences and at the same time not misdirecting resources where incidents are not happening. Many states do not have a large manufacturing sector that handle combustible particulate solids, so combustible dust fires and explosions are minuscule if not nonexistent problem in these geographical areas.

Time and Space
It's to early to ascertain whether the OSHA Combustible Dust National Emphasis Program (NEP) has any impact on minimizing combustible dust explosions and fires. Currently there is no reduction in combustible dust explosions and fires and at the present rate, an event is taking place nearly every other day somewhere in the United States. Since the Imperial Sugar Refinery catastrophe, injuries have been minimal and it's only a matter of time, space, and luck running out before more fatalities happen.

Voluntary NEP
Much fanfare and hoopla has surrounded the OSHA Combustible Dust NEP, which has really turned into a Trojan horse sort of placebo. The problem is exacerbated at the state level where 22 States have there own OSHA program and not required to have a Combustible Dust NEP, which is voluntary. For example, North Carolina over the past four months is the leading state with six reported combustible dust explosions and fires and at the same time does not have a combustible dust NEP since it has it's own State OSHA program and not federal. Several other State OSHA programs without the voluntary combustible dust NEP's also lead in combustible dust incidents.

Conclusion
The complex issue of combustible dust explosions and fires is more of a regional and geographical problem rather than a national one. It's only when a catastrophic incident occurs with mass fatalities and injuries that a national consciousness arises but this should not be confused with the heart of the problem and that is the geographic nature of manufacturing facilities in the United States. Limited financial resources in the current economy can best be allocated in the specific hot spots and manufacturing sub-sectors where incidents are happening.

A geographical aspect of the complex combustible dust issue needs to be addressed in the upcoming Senate hearing where the combustible dust bill will be voted on prior to arrival on the President's desk. A combustible dust workplace standard definitely needs to be implemented very soon, yet in an intelligent manner that directs regulatory resources efficiently.

Flare-up Combustible Dust Explosions/Fires

Over the past nine days a multitude of combustible dust related explosions and fires have occurred across eight states on both sides of the Mississippi in a myriad of manufacturing industries. Recent incidents include paper, wood, textile, chemical, and plastic manufacturing sectors.

The equipment involved includes a silo, oven, dryer, electrical panel , external burner, auger, and ductwork. Luckily, injuries have been limited to a burn victim in last week's unfortunate wood fiber silo explosion. Prayers still go out to the family and worker for a speedy recovery.

Overall economic damage is in the tens of thousands of dollars. Over 50% of the incidents are reoccurences with combustible dust as the culprit causing a repeat of a dust fire or explosion. For three days last week there was two combustible dust explosions and fires/day, totaling six incidents in three days.

Hopefully after the rash of 14 combustible dust fires and explosions for the month of May, no additional incidents will occur. So lets all cross our fingers for the next two days and pray that the dragon takes a much needed rest. If it keeps up at this pace, 2008 will accumulate a dismal scorecard of over 160 reported combustible dust fires and explosions.

This is in stark contrast to the average of 12 combustible dust explosions and fires/year that the Chemical Safety Board submitted in their Combustible Dust Hazard study with recommendations to OSHA for the period of 1980-2005, which included 281 incidents.

The problem with only acknowledging 281 incidents, is that over 90% of the complex issue concerning combustible dust has not been recognized by industry, governmental regulatory agencies, trade associations, safety professionals, and state/federal legislators. Until all stakeholders recognize and acknowledge that over 3,000 combustible dust explosions and fires have occurred in the past three decades then an understanding of the depth and breadth of the problem will be absent.

In the meantime incidents will occur throughout the nation's manufacturing industries with the explosive atmospheres generated daily in the workplace without precautionary preventative, mitigative, administrative, and technical control procedures.