Expoquimia-Combustible Dust ATEX Seminars

Expoquimia, one of the largest Chemical Trade Fairs in the European Union will be held October 20-24 2008 in Barcelona, Spain. Professionals across a wide spectrum of the chemical industry will host technical seminars and lectures for attendees and participants.

Activities at Expoquimia include instrumental analysis, biomaterials, sensory chemistry, biotechnology, new solvents, purchase management, and combustible dust explosion protection/prevention educational tracks..

Stakeholders and professionals who are responsible for plant safety in regards to the hazards of combustible dust generated from combustible particulate solids will have an opportunity to attend the 4th International Industrial Safety Conference (Jornada de Seguridad Industrial Atex) part of the combustible dust educational track.

Xavier de Gea, Director of LPG Prevención y Protección de Explosiones and coordinator of the combustible dust track has organized two daily of sessions with the support of the European Safety Management Group. Utilization of coal for power generation is becoming an important and vital feedstock with the issue of tight oil supplies in the global market. Potential hazards of combustible dust coal explosions exist with the increase utilization of coal.

The first day of the 4th International Industrial Safety Conference will cover diverse topics that include engineering standards that are necessary while handling solid materials such as coal as outlined in the European Union ATEX directive. Area of interest will include:

• Risk analysis of Solid combustible


• Self combustion parameters on coal and biomass


• Coal grinding in the light of the new ATEX directive


• Explosion protection reclosing devices


• CO2 / N2 inerting as Preventive Explosion Protection at coal grinding

ATEX, or ATmosphères EXplosibles, originates from ATEX 94/95 is the regulatory technical requirements in the European Union that require manufacturing facilities to have specific equipment and protective systems that are located in explosive atmospheres such as combustible dust, flammable vapors, gases, and liquids.

Another aspect of the regulatory framework concerning combustible dust in the European Union is ATEX 137, which protect workers from the hazards of potential combustible dust explosions and fires in explosive environments. This would be analogous to OSHA protective standards that are currently being debated in Congress following the Imperial Sugar Refinery explosion.


Policymakers, regulators, legislators, trade associations, and safety professionals in the United States can learn from the EU ATEX in a manner that would assist in developing a comprehensive combustible dust program throughout the nation in preventing and mitigating future combustible dust incidents plaguing the nation's manufacturing sector.

Attending the 4th International Industrial Safety Conference at the Barcelona Expoquimia would be an ideal opportunity for all stakeholders in gaining an understanding of the complex issue of combustible dust, which is a problem afflicting all of our global trading partners. Book your flight and listen to some solutions before the combustible dust monster arrives for Halloween.

4th INTERNATIONAL INDUSTRIAL SAFETY CONFERENCES .pdf

Ethanol Plant Explosions Continue

http://www.wwmt.com/news/calhoun_1350736___article.html/county_explosion.html

With over 160 ethanol plants in operation and 43 plants under construction the hazards of explosions and fires are omnipresent. Since July 2007, six reported ethanol plant explosions and fires have taken place in the United States. Last week the Anderson Corp. plant in Sheridan Township, Michigan exploded in the dryer area causing injuries and damage to the building.

Last December the distillers grain dryer was destroyed at the Pine Lake Corn Processors facility in Steamboat, Rock Iowa causing millions of dollars in damage. Luckily no injuries or fatalities occurred. The contractors at the Princess Anne, Maryland GreenLight Biofuels biodiesel plant were not so lucky less than two months ago when one fatality and one injury occurred after an explosion while adding a methane line during hot work.

Production and refining of ethanol and biodiesel is a new industry and will require that the owners and operators implement the same safety production procedures as the petrochemical refining industry

The current learning curve is now proving to be very costly in human lives and adverse economic effects to the community.

Ethanol Plant Explosions and Fires Google Map

Bleak Picture of Plant Shutdowns

Here is an interesting snapshot of recent plant shutdowns in the United States. Many states have a web link that provides a listing of plant closings. The Worker Adjustment and Retraining Notification Act (WARN) offers protection to workers by requiring employers to provide notice 60 days in advance of covered plant closings and covered mass layoffs.

Employers are covered by WARN if they have 100 or more employees. A covered employer must give notice if an employment site (or one or more facilities or operating units within an employment site) will be shut down, and the shutdown will result in an employment loss (as defined later) for 50 or more employees during any 30-day period.

In many instances no warning of impending shutdown is provided if the company has less than 100 employees. With all the shutdowns occurring in the manufacturing sector the question arises of how a company can afford fire and explosion equipment in the prevention and mitigation combustible dust incidents.

The current combustible dust bill, HR 5522, Worker Protection Against Combustible Dust Explosions and Fires Act that is awaiting a hearing and vote in the Senate will require facilities that generate combustible dust to install fire and explosion prevention/mitigation equipment in accordance with the National Fire Protection Association combustible dust codes.

Congressional leaders that drafted the bill forgot to conduct a cost benefit analysis on the economic burden, which the legislation would impose on the manufacturing sector. In a recent article in the Washington Post (6/29/08), "5 Myths About the Death Of the American Factory,'' by Gilbert B. Kaplan, the author notes that in 2007, manufacturing jobs dropped below 14 million workers for the first time in over a half a century. This is a very disturbing trend and will only get worse as a barrel of oil approaches the $200 mark very soon.

Will a combustible dust bill also provide economic incentives like it does with the energy, agricultural, and other business sectors?

Plant Shutdowns 2008 Google Map

OSHA Combustible Dust Blame Game

Over the past year OSHA has constantly been negatively portrayed in the national headlines concerning workplace safety issues. Several weeks ago CBS 60 Minutes aired a segment, questioning whether current OSHA workplace health and safety regulations are adequate in protecting the nation's workforce from the hazards of combustible dust in the manufacturing sector.

Prior to this sensationalism in journalism , the House Education and Labor Committee through the leadership of Congressman George Miller (D-CA), drafted a crafty bill and held congressional hearings on combustible dust. Now after passage in the House, HR 5522, the Worker Protection Against Combustible Dust Explosions and Fires Act awaits hearings and a vote in the Senate and eventually the Presidents signature.

False Presumption
Through all the political hoopla and national media attention after the tragic sugar dust explosion at the Imperial Sugar Refinery on February 7, 2008 in Port Wentworth , Georgia many including the provider of content on this site have mistakenly concluded that OSHA is at fault in not providing sufficient combustible dust regulations. This is a false presumption when the facts of the complex combustible dust issue are revealed.

Its much easier for congressional leaders to place all the blame on OSHA instead of fully researching the cause and effect of combustible dust incidents. Unfortunately, the media picks up on this misinformation and political spin that is perpetuated in conjunction with the Imperial Sugar Refinery tragedy.

Local Issue not Federal
Hazards of combustible dust in the manufacturing sector is a municipal, state or regional issue, not a federal problem. Whenever there is a fire or explosion at a manufacturing facility with combustible dust involved, who are the first responders in extinguishing the fire? Of course, it's either the facility fire brigade or the local fire department.

What jurisdictional protections must be followed to ensure the life safety and structural integrity of commercial buildings is instituted and maintained? Yes, thats correct, building and fire codes. Since when has it been OSHA's responsibility to act as first responders to industrial fires and enforcement of fire codes?

Fire Codes
Currently states are either utilizing the International Code Council, International Fire Code (IFC) or the National Fire Protection Association, Uniform Fire Code(UFC) with references to the numerous NFPA combustible dust codes. Following the 2006 Dust Hazard Study, the Chemical Safety Board determined that many fire inspectors are not knowledgeable concerning the hazards of combustible dust that are referenced in the fire codes. Additionally, the CSB report discovered that the IFC or UFC fire codes adopted by several states had not been properly addressed in relation to combustible dust concerning commercial buildings.

Standard of Care
So is the fire code issue an OSHA problem? As enforcement action, OSHA currently utilizes the General Duty Clause for manufacturing facilities that violate workplace health and safety standards concerning combustible dust hazards. These standards in addition to current OSHA regulations include nationally recognized standards of care that is recognized by industry consensus through the American National Standards Institute (ANSI). Many of these standards of care include NFPA 484 (metal dust), NFPA 664 (wood dust), NFPA 61 (agricultural/food dust), NFPA 654 (combustible particulate solids), and NFPA 120 (coal dust).

Conclusion
The combustible dust bill, HR 5522, the Worker Protection Against Combustible Dust Explosions and Fires Act is redundant, which will require OSHA to incorporate the NFPA combustible dust codes that already are part of state fires codes. Furthermore, OSHA does not have enough financial resources and inspectors to inspect local manufacturing facilities with regularity like local jurisdictions do.

Georgia has taken the lead in requiring manufacturing facilities that generate combustible dust to register with the state. This action is similar to the European Union combustible dust ATEX directive requiring explosion protection document submittal from manufacturing facilities. Workplace protection from the hazards of combustible dust need not be controlled at the federal level.

Instead of the question,"Would combustible dust explosions occur if an OSHA comprehensive combustible dust standard was instituted?" The appropiate question would be, "Would combustible dust explosions occur if current fire codes followed the references to the NFPA combustible dust codes?"

Government Safety Data Underreported

Last week the House Committee on Education and Labor convened a hearing on OSHA's underreporting of on-the-job injuries and illnesses. This was old news concerning the underreporting by governmental agencies. Crucial data concerning workplace safety is vital in promulgating policy and regulations to protect the worker. OSHA should not be singled out in problems collecting data. The Chemical Safety Board, an independent governmental investigative agency is also underreporting and undercounting safety data in the 2006 release of the Combustible Dust Hazard Study.

Chemical Safety Board Underreporting
Specifically, the Chemical Safety Board provided to the public and OSHA accident data from 1980-2005, which included 281 combustible dust fires and explosions. The disclaimer in the report states : the combustible dust incidents included are likely only a small sampling, as no federal or state agency keeps specific statistics on combustible dust incidents, nor does any single data source provide a comprehensive collection of all these incidents, nor does any single data source provide a comprehensive collection of all these incidents

Furthermore, information about small combustible dust incidents and near-misses is also generally unavailable. For instance, because incidents that cause no fatalities, significant injuries, or major fires may not be recorded in the OSHA and fire incident databases, the true extent of the problem is likely understated. Due to these limitations, the CSB does not represent the incident data as complete or error-free, and other compilations of dust explosion data are available.

Fact or Fiction
So how can policy be developed concerning general combustible dust standards if policymakers and legislators have no idea of the extent of the problem? A small sampling is just that, a sample. The problem of only relying on a sampling has been exasperated in the last four months since the Imperial Sugar Refinery explosion, where Congress and the national media is utilizing the CSB incomplete data as fact.

Nowadays, since the conclusion of the 2006 CSB Dust Hazard Study, information concerning recent combustible dust incidents can easily be found with a Google search on the Internet, through numerous online news reports. Yet the CSB still persists in undercounting combustible dust incidents and releasing this information to Congress and the media.

For example, in recent incomplete data provided to Congress, the CSB has reported an additional 70 combustible dust explosions and fires since the 1980-2005 period, for a total of 350 combustible dust fires and explosions in the last 28 years. This equates to one incident a month which is disjointed and skewed from the actual extent of combustible dust incidents that are occurring. For example, in the last four months over 50 combustible dust fires and explosions have taken place in the manufacturing sector.

Conclusion
The Chemical Safety Board is a governmental accident investigative agency and not a research agency. Over the past decade CSB has performed a superb job with it's limited resources in finding the root cause of chemical plant accidents, fatalities, and injuries. At the completion of it's investigations CSB provides free educational videos on lessons learned and investigative reports in the prevention of future incidents.

Daily intensive research concerning where and when combustible dust incidents are occurring in the nation's manufacturing sector is not the job function of CSB. Instead of all the political posturing that is now occurring in Congress concerning the passage of a comprehensive general combustible dust bill, more attention needs to be directed in seeking accurate information concerning the entire scope of industry combustible dust incidents.

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.