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.
Stakeholders in the manufacturing, non-manufacturing, and utility sectors are eagerly awaiting OSHA’s Advanced Notice of Proposed Rulemaking (ANPRM) in the Federal Register.Following the Chemical Safety Board’s recent key findings and recommendations on the Imperial Sugar Refinery dust explosion, OSHA submitted the combustible dust regulation for review to the Office of Management and Budget, a Cabinet-level office within the Executive Office of the President of the United States.On a state level and moving much faster than Federal actions, Georgia recently held a public hearing for their combustible dust regulation.
A diverse spectrum of the manufacturing sector attended a public hearing last week at the Fire Commissioners Hearing Room in Atlanta, Georgia where they submitted final comments to the Administrative Law Judge for consideration. Representatives of Georgia’s manufacturing sector are not opposed to fire and explosion safety in the workplace and have been working tirelessly with the Commissioners office in developing a consensus.
Since the Imperial Sugar Refinery explosion, stakeholders have worked closely with Georgia Insurance and Safety Fire Commissioner, John Oxendine, in developing a combustible dust regulation that will provide appropriate layers of protection in minimizing the probability and reducing the severity of future combustible dust related fires and explosions.
In contrast, a point of contention does arise within the manufacturing sector concerning the feasibility of a regulation during the nation’s economic recession. For instance, costly best engineering practices for combustible dust fire and explosion hazards is not required amongst many global trading partners and many argue this would result in a competitive disadvantage for Georgia businesses.
Georgia’s combustible dust rulemaking process has national significance in that stakeholders across a diverse spectrum of state manufacturing subsectors are also representative on a larger scale of national manufacturing subsectors. So could the comments and input to Georgia government officials be a precursor to future comments in the upcoming federal action during the OSHA combustible dust rulemaking process?
The Combustible Dust Policy Institute proposes a possible solution in alleviating economic concerns.This would initially include administrative control measures and safe working practices that would not put small businesses at a global competitive disadvantage.
For example, good housekeeping (CSB recommendation), OSHA hazard communication training, contractor participation (PSM), explosion protection documents (ATEX) and accident investigation (PSM) protocol would minimize the severity and likelihood of future incidents immensely.
Essential but costly, best engineering practices and inherent safety design, phased in over a period of several years in conjunction with the global economy rebounding is a viable option that needs further discussion.An excellent example of a phase-in- period occurred with the EU ATEX directives for potentially explosive atmospheres in the workplace.
In this podcast segment, Jeff Romine, a Corporate Safety Director for national flooring manufacturer, attended the Georgia public hearing on combustible dust and shares with listeners a first hand perspective of industry concerns that were presented to the Administrative Law Judge. These same concerns have a national significance in the Federal OSHA combustible dust rulemaking.
Mr. Romine has over 20 years of experience in consultation, auditing, safety, education and insurance, and is a Certified Safety Professional (CSP), Certified Professional Environmental Auditor (CPEA), and OSHA Outreach General Industry Trainer. Mr. Romine is currently serving as a Senior Corporate Safety Manager in the Risk Management Department for Shaw Industries one of the leading flooring manufactures in the United States, a Berkshire Hathaway Company. He lives in RinggoldGA with his wife Cindy, daughter Katie (Senior at the University of GA) and son Alex aka“AJ” (freshman at OglethorpeUniversity)
With the recent Chemical Safety Board accident investigation recommendations following the Imperial Sugar Refinery explosion, stakeholders in the manufacturing sector are even more pressed in addressing combustible dust hazards in the workplace. One of the five key recommendations was for stakeholders to develop training materials for employees and contractors on the hazards of combustible dust. That is easier said than done. There have been several excellent combustible dust training programs developed through the Susan Harwood Training Grant over the last two years.
The problem is gaining access to this safety training material that the taxpayers have already paid for. In contrast, the training videos on combustible dust that the North American Die Casting Association produced through the Susan Harwood Grant is easily accessible for free on YouTube. So far, haven't been so lucky on the web in viewing the training materials on combustible dust hazards that Georgia Tech Research Institute, Kirkwood Community College, and the Texas Engineering Extension Service developed from over $500, 000 in grant money through the 2008 Susan Harwood Program.
Training is definitely needed on combustible dust hazards in the workplace there is no arguing that. Over $448,000 was awarded to two recipients in 2009 to also develop combustible dust safety training. So how many times do we need to develop combustible dust safety training? Wouldn't once be enough? Seems like the combustible dust safety videos that the North American Die Casting Association has available for free is the direction that combustible dust hazard awareness program should be going. But what the heck if you got an extra couple $100, 000 in the kitty, then let's spread the love. Who said the nation was in the worst recession since the Great Depression?
Turning up stones always seems to get me in trouble, especially when I end up with more questions than answers. Sort of like when the CSB reported in their 2006 Combustible Dust Hazard Study that there was 281 combustible dust incidents from 1980-2005 or on an average 12/annually. Yet in 2008, after over a thousand hours of research I discovered in media reports over 150 ComDust incidents in the manufacturing, non-manufacturing and utility sectors. If only the CSB would have provided the disclaimer in their press releases concerning incident data, then the media, legislators, stakeholders, the public, and OSHA would have had a better idea of the complexity of the combustible dust issue.
CSB Combustible Dust Incident Data Disclaimer
"The combustible dust incidents included here 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. 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. " In regards to access to training materials that have already been developed through OSHA training grants the picture gets much larger than just combustible dust training which is a very small niche in occupational health and safety. Since 2003 there has been over $60, 000, 000 awarded to over 345 grantees. Yet only 14 or 4% of these training program materials are available on the OSHA web site. So where's the beef? What happened to the other 331 training program educational materials?
In many instances previous training programs over the past seven years for the same subject are being developed over and over again. So how many times does the identical subject need to be redeveloped and where is the oversight? Web based information, Power Point Presentations, on-line training materials, module interactive courses, computerized training videos, web based photo libraries, and macro-media presentation modules are a few examples of training materials that has been developed, yet there is no public access.
Having these excellent educational materials that has already been developed, readily available on the web for the entire workforce would assist in providing the much needed educational resources in reducing workplace fatalities, injuries, and economic disruption. Hopefully OSHA will eventually realize the immense power of the web through social networking utilizing Facebook, Twitter, YouTube, Blogs, etc so as to reach the millions of workers who search for content on their iPhones, Blackberries, and personnel computers. Already many Fortune 500 companies use these resources in selling their products and services. So whats wrong with a new paradigm in selling occupational health and safety to the nation's workforce?
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
Great idea with fire department in Germany conducting drills working closely with manufacturing sector management preparing for a combustible dust related fire or explosion occurrence. When was the last time your facility had a fire drill working closely with the local fire department? "Know Before You Go"
Dust explosion in a carpentry operation - post by comdust
Zum Glück handelte es sich nur um eine Übung am Dienstag,
"Fortunately it was just an exercise on Tuesday" This is a great idea with fire department conducting fire drills at manufacturing facilities that generate combustible dust - post by comdust
Spänebunker als Sammelbecken für die Absauganlage.
"Chip Bunker as reservoirs for the exhaust." One area where the combustible dust explosion hazard exists - post by comdust
Während der gesamten Übung wurde zudem erstmals das Verhalten der Feuerwehrleute digital festgehalten, sodass bei der anschließenden Manöverkritik im Gerätehaus die Bilder eine wertvolle Hilfe bei der Bewertung der Übung waren.
"Throughout the exercise was also the first time the behavior of the firefighters digitally recorded, so when the subsequent maneuvers Tool criticism in the pictures is a valuable aid in the evaluation of the exercise were." - post by comdust
Just as in the Netherlands, combustible dust hazards exist in schools here in the USA that have vocational training in their metal, wood, and auto workshops
Inspections also revealed that vocational schools are largely ignorant of the risk of wood dust explosions.
Same situation in the USA. Combustible dust hazards is a global issue of concern throughout many sectors that a majority of stakeholders are not aware of. - post by comdust
According to de Groot, a funding shortage caused the dangerous situations in these schools.
Funding is a big issue with the initial combustible dust testing for ignition sensitivity and explosion severity. - post by comdust
This is a very misleading OSHA Region 5 News Release]. There never was any repeat OSHA citations by the Eau Claire, WI Area OSHA Office for this newly acquired facility. The OSHA inspection took place less than 60 days after acquisition from SPF North America, a pet flavor and ingredient mfg. Additionally none of the citations resulted from many of the same safety and health hazards cited in the most recent inspections. Since there wasn't any recent inspections at the Milk Specialties Whitehall, WI facility
Four repeat violations with penalties totaling $21,800
These repeats are not from this Whitehall, Wi facility. Milk Specialties operates five other manufacturing plants in Wisconsin and Minnesota - post by comdust
citations resulting from many of the same safety and health hazards cited in the most recent inspection.
Very misleading. There was never any repeat citations by OSHA at the Whitehall, WI facility. The facility was purchased from SPF North America in October 2008 and the OSHA inspection took place less than 60 days later. - post by comdust
Dr. Wang Jiaqi, Institute of Animal Science, Chinese Academy of Agricultural Sciences
Update 6/24/09 The Other Half of the Story
Manufacturing facilities with multi-sites should be aware that if a facility currently receiving a citation and has received an OSHA citation at another site within three years for the same violation will be considered as a repeat citation. Here is an excerpt from Andy Purvin a member of the Online Safety Community that describes the situation
John, I ran into this a lot at my previous employer. OSHA says since the company has a large enough communications network, relaying information between plants wouldn't be a hardship. Therefore, since they could have "learned" from the previous inspection citations, it technically IS repeat violations.
I argued similar points to yours, but lost. Companies that have multi-site designation are going to be held accountable to update all plants on Regulatory Activity. To combat this, at my current company, when OSHA "visited" one of our locations, I communicated the results to all and confirmed corrective actions had taken place at EVERY location to avoid repeat violations.
Here is additional helpful info thatBryan HaywoodCEO & President, SAFTENG.net LLC shares with his comment on "repeat violations" at the LinkedIn Combustible Dust Policy Institute Group discussion:
"Although I can not speak to the question of "new ownership" I can state that a repeat citation can be issued to the facility if a different plant within the company that falls within Federal OSHA and NOT a state plan, has been cited for the same violation. The cited repeat violation does NOT have to have occurred at the same facility...just a facility within the company that falls under Federal OSHA, as I think was this case. You mentioned a MN facility and MN is a state plan, which means citations at the MN facility can NOT be used to issue repeats at a plant under Federal OSHA.
The change in ownership brings a new twist to OSHA's repeat citation policy. Basically, it is a new owner (e.g. new employer) and thus this new owner/employer can not be cited for the previous owners errors. Will be interesting to see if the business challenges these citations and if so if the OSHRC will vacate the citations.
Here is a link to OSHA's repeat citation policy for those interested in how FAR REACHING this policy can be.
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.
RSS Feed Subscribe