Probability of Occurrence

A recent dust explosion at a wood pellet mill in Germany drives home the point that global collaboration concerning combustible dust fires and explosion hazards in the workplace must be a central theme in managing the risk. Without the knowledge of probability of occurrence, a comprehensive process hazard analysis cannot be developed. The problem is in obtaining the incident data. Solely relying on news accounts will not provide global coverage. Especially when all global ComDust incidents are not reported as such.

A good start would be for the Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals to network with their prospective local professional associations, trade organizations, and governmental agencies. A network would enable stakeholders to share incident data, which could assist in managing the risk.

The recent OSHA ComDust ANPRM is an excellent example in obtaining an understanding of probability of occurrence, where in Table 1, national industries were listed that had previous combustible dust related fires and explosions. On an international perspective many manufacturing processes have similar process situations and process conditions. So just because a ComDust incident has not yet happened in one geographic region does not mean it will not happen in another global region with a similar manufacturing process.

A good example, are recent combustible dust explosions in Germany wood pellet mill and the earlier sugar silo explosion. Global manufacturers have similiar processes, which also includes the United States. OSHA in addition to acquiring information on probability of occurrence in the USA, which was illustrated in Table 1 of the combustible dust ANPRM, should also be aware of the global perspective. This global proactive situational awareness will assist all stakeholders in the proposed combustible dust rulemaking.

Dust Explosion Former Sugar Factory-Gross-Gerau, Germany

Dust explosion happened in Germany but it just as well could have occurred anywhere else. It's extremely important to understand that collecting data on global combustible dust related fires and explosions assists immensely in understanding the probability of occurrence and severity of consequence. Through lessons-learned, global trading partners can share information in the prevention and mitigation of future incidents in similar national industries.

OSHA did a great job in the preparation of the recent ANPRM proposed combustible dust rulemaking document in the introduction section, providing Table 1 illustrating national industries with a discernible probability of occurrence. Collecting incident data over a period of time assists in risk analysis. Especially in observing trends where incidents are occuring in specific national industries.

Last year, immediately after the Imperial Sugar incident I began collecting data from news accounts of combustible dust related fires and explosions in the United States. Subsequently, a week before the first combustible dust hearing was held by the House Committee on Education and Labor on March 12, 2008, over a dozen combustible dust related fires and explosions had occurred in the manufacturing sector, since the previous Imperial Sugar incident. The numbers just didn't add up? Especially with the CSB Dust Hazard Study reporting an average of 12 incidents annually.

Thinking geez, this is something that could help provide an enhanced awareness on the volatile subject. I eagerly contacted the House Committee on Education and Labor and offered to share this important incident data. Well things didn't work out. A staff member informed me that the the data couldn't be used at the Combustible Dust hearing , as congressional committee members would not find it acceptable, since it was coming from some guy in Texas on his computer. After hanging up the phone, the Combustible Dust Policy Institute went into action.

I'd like to thank the many friendships developed spanning the globe in supporting my combustible dust incident research efforts. Without your enthusiastic encouragement I don't think it would of been possible to continue such an endeavor with such intensity. Many times working 24-36 hours at a time in conjunction with 12 hour shifts with my regular job. Sort of a Dr. Jekyll/Mr. Hyde existence.

It's odd, nowadays unless one is represented by a million dollar lobby firm on K Street, then the voice of the average blue collar American working Joe on the street is worthless. That's the way things stand today in Washington, D.C. But the paradigm has changed. With the power of the Internet, one has the resources at hand as any Fortune 500 Corporation.. All it takes from there is a deep desire to seek the truth in what is reality in contrast to sometimes questionable governmental data and commercial mainstream media.

I encourage all Americans to go behind the scenes, like Toto did in the Wizard of Oz and pull the curtain back while the Wizard pulls the levers. Combustible dust is just a drop in the bucket in comparison to the myriad of social-economic issues that confront Americans, in which Congress and governmental agencies debate on a daily basis. Pick an issue that interests you and then go for it, researching topics that you hear about in the news.

Many news reports are solely commentary with supposedly facts and figures obtained from governmental press releases. After a few weeks of research, you just might find that the data in the governmental reports and mainstream media might not quite be reality. But once you do obtain information, start writing about the results of your research to share with others with similiar interests. Be sure to include hyperlinks of your sources in your content, so readers can obtain a fuller understanding of the subject.

Now with Web 2.0, utilizing Blogs, Twitter, Facebook, Linkedin, etc your story is effortlessly shared across international borders. Just remember content is king. So the more you post, the more the Google spider will find in keywords that will appear when potential visitors are seeking information on the subject in their searches.

In regards to occupational health and safety I'm certain that the future in achieving a safe workplace throughout industry in a comprehensive manner can be enhanced immensely utilizing all the resources that the Internet offers. I'd like to thank my good friend Xavier De Gea, Director en LPG Prevención y protección Explosiones from Barcelona, Spain for sharing the recent sugar dust explosion news account, which assists in providing a global awareness of a very complex subject.

Resources
News Article/Dust Explosion -German version
Photo Credit (Photo: Torben Liedtke) to the photo gallery

OSHA Combustible Dust Advanced Notice of Proposed Rulemaking

https://docs.google.com/fileview?id=0BwXCwzOQ_F0wYTc1YmJmZTMtN2FhNC00YzNlLTk2NTgtOWQyNjJhNGQ1YjFh&hl=en

Here is link to the OSHA ANPRM (15 pages) on combustible dust that was published in the Federal Register today. There are some excellent points on accident investigation and fire-fighter hazard awareness, which seeks public comment in addition to many other important issues.

Hot Work Adjacent to Explosive Atmospheres

http://www.wiscnews.com/bdc/news/466035

Initially when reading the recent news account of a worker that ignited flammable vapors causing an explosion while using a hand grinder to cut bolts embedded in the floor, it had not donned on me the gravity of the situation. That was until Jeffrey C. Nichols, President, South East Fire Prevention, Inc sent me an email this morning reminding me it could also happen with combustible dust. That is true, combustible dust provides explosive atmospheres just like flammable gases, vapors, liquids, and mists.

In many instances combustible dust related fires and explosions have occurred due to hot work providing the ignition source. One news account mentions that there was a sign adjacent to work area, that the area was hazardous. The same sort of warning signage should also be in areas where combustible dust is generated. In the EU, the ATEX directives have a provision for such signage. In the USA an OSHA combustible dust rulemaking is in the process and hopefully a provision of warning signage in communicating the risk from combustible dust explosions or fires will be included in the combustible dust rulemaking.

It is essential that prior to any hot work being conducted that a job hazard analysis be conducted evalauting the risk from potential fires and explosion. This ensures that a hot work permit includes all the potential ignition and fuel sources in managing the risk.

OSHA Hazard Communication Standard is Broken

With the OSHA combustible dust regulation Advance Noticed of Proposed Rulemaking (ANPRM) due to be published in the Federal Register any day now,(tomorrow?) many stakeholders are eager to provide comments in the rulemaking process. Initially, immediately after the dust explosion at Imperial Sugar Refinery in Port Wentworth, Georgia many were ready to place blame including myself. But after a cooling down period of a few weeks analyzing the situation it became readily apparent the combustible dust issue was a very complex topic.

It was the catastrophic Imperial Sugar explosion that galvanized Congress, the media, OSHA, and many other stakeholders into action. Sort of like the 9/11 of occupational health and safety. But instead of a threat from outside, the threat upon the nation’s manufacturing workforce was inside with insidious combustible dust.

The Chemical Safety Board became a major player in the accident investigation. Two years earlier, the CSB an independent governmental agency completed an informative Dust Hazard Study investigation in 2006 on combustible dust related fires and explosions in the industrial sector, following a series of dust explosions in 2003.

Many of the key recommendations that CSB presented in the 118 page report have already moved forward. Such as combustible dust hazard awareness training at the OSHA Training Institute (OTI), a Combustible Dust NEP, communicate to the United Nations the need to amend the Globally Harmonized System (GHS) to address combustible dust hazards, and issue a combustible dust standard based on the NFPA combustible dust standards. The most important recommendation and most misunderstood and overlooked is to revise the OSHA Hazard Communication Standard (HCS) (1910.1200) in the prevention and mitigation of fire and explosion hazards that combustible dust presents in the nations’ workplace.

Material Safety Data Sheets
Hazard communication through the utilization of Material Safety Data Sheets (MSDS) in providing the workforce with vital information on the ignition sensitivity and explosion severity of combustible dust is crucial in managing the risk. Without specific information on the fire and explosion physical properties of combustible dust, workers and plant management are at risk in inadvertently providing an ignition source in completing the fire triangle or explosion pentagon.

During the research that CSB conducted for the Dust Hazard Study they discovered after reviewing 140 MSDS’s across a wide spectrum of industry that none of the data sheets had the physical properties of ignition sensitivity and explosion severity (physical data parameters, such as Kst MIE, MEC, and MIT). Oh really? Well that should not come as a big surprise since the raw product manufacturers who prepares the MSDS’s usually have no idea of the specific process conditions or situations that reconstitute their raw product during the manufacturing process into final products that also generates combustible (explosive) dust.

Pertinent Legal Authority
In the recent OSHA Hazard Communication Proposed Rule concerning global harmonization there is quite an interesting discourse on the subject in the section VI. Pertinent Legal Authority.

“chemical manufacturers and importers tend to have greater knowledge and scientific expertise with respect to the composition of the chemicals they make or import. See 48 FR 53306, 53322. Therefore, they are usually in the best position to assess the inherent hazards associated with them.”

How can upstream raw product manufacturers in the life-cycle be in a better position to know the particle size distribution, particle size, moisture content, etc in determining the explosion severity and ignition sensitivity in managing the risk? But then immediately after that position statement a conflicting view.

“However, it is the downstream users and their employees who tend to have the best information about the means and methods of exposure, and are therefore usually in the best position to determine the risk arising from the use of the chemical in their workplaces. See 48 FR 53295–96, 53307; 59 FR 6132”

So which is it? The raw product manufacturers or the downstream users in the best position in providing the essential physical properties of probability of occurrence and severity of consequence in the MSDS’s? Now it all makes sense that 80% of combustible dust incidents that occurred in 2008, according to media accounts were combustible dust related fires. The majority of downstream users had no idea of the ignition sensitivity and they still don’t.

Warm and Fuzzy Feeling
So an OSHA combustible dust standard is going to make things all warm and fuzzy? A quick fix? Sure it’s much easier to implement a regulation; after all we don’t have enough regulations inundating the business community already. The steeper road to follow would be to fix the broken OSHA Hazard Communication Standard, the heart of the problem in identifying, evaluating, and communicating the risk.

It’s troubling that the OSHA combustible dust standard rulemaking process is based on the Chemical Safety Board’s 2006 Dust Hazard investigation, which does not provide policy makers with all the facts. Another excerpt from VI. Pertinent Legal Authority, states:

Development of a combustible dust standard under the OSH Act should be based upon research, demonstrations, experiments, and such other information as may be appropriate. In addition to the attainment of the highest degree of health and safety protection for the employee, other considerations shall be the latest available scientific data in the field, the feasibility of standards, and experience gained under this and other health and safety laws. Whenever practicable, the standard promulgated shall be expressed in terms of objective criteria and of the performance desired. 29 U.S.C. 655(b)(5).

The data from research that the CSB presented to OSHA is incomplete and does not take into account a full risk analysis of probability of occurrence and severity of consequence throughout the manufacturing sector For example, up to the week prior to the March 12, 2008 congressional committee hearing on combustible dust, over a dozen combustible dust related fires and explosions occurred in the four weeks immediately after the February 7, 2008, Imperial Sugar dust explosion. Yet the CSB Dust Hazard Study stated in the incident data, which they provided to OSHA, Congress, media, and the public, an average of 12 combustible dust incidents annually occurred from 1980-2005, or 281 total.

OSHA ComDust Enforcement Activity
It seems every other week; we read another media account of OSHA combustible dust enforcement and inspections activities that includes costly citations that an employer received due to combustible dust hazards. So will an OSHA combustible dust standard make things better and remedy the significant risk with even more combustible dust citations? Again referring to the proposed HAZCOM rule section in the Federal Register: VI. Pertinent Legal Authority

Where, however, OSHA is confronted with two feasible methods of reducing risk to the appropriate level, OSHA must chose the cheaper method. Id. at 513 n.32; International Union, UAW v. OSHA, 37 F.3d 665, 668 (D.C. Cir. 1994).

Conclusion
Addressing the deficiencies in the current HAZCOM standard would be more appropriate in addition to more feasible. Doesn’t make sense to put the cart before the horse when the hazards have yet to acknowledged in the MSDS’s. It’s a revised OSHA Hazard Communication Standard that is needed not a combustible dust standard. No one was demanding an OSHA flammable gas, liquid, and vapor standard after the nearly two dozen such incidents that CSB has investigated since 2003.

Resources
Flammable Liquid and Gas Fires/Explosions since 2003-CSB

Minimizing the Severity of Consequence

http://www.inmaricopa.com/NEWS/NewsArticleDetails.aspx?ArticleID=6798&&mid1=390

Early morning fire and explosion at Pinal Energy ethanol plant. This is an excellent example of NFPA combustible dust standards best engineering practices minimizing the severity of consequence of combustible dust related fires and explosions. In reality, combustible dust explosions cannot be totally prevented, only the probability of occurrence reduced and the severity of consequence minimized.