Case Study on All-Feed Processing and Packaging

Let's do a case study on All-Feed Processing and Packaging Inc as it relates to new growing and changing OSHA standards

Galva Illinois Production Plant

First focus - "if it can happen to me it can / will happen to you" which of the regulations are common to us all.

Second focus - what is the chance for compliance and what would TOTAL compliance look like.

Join in on the discussion in the Combustible Dust Policy Institute group.

Resources

OSHA News Release-$500,000 in fines against All-Feed
All-Feed OSHA Citations

Note:

For the record, the Citations posted are from an inspection that started on 07/2008 and ended 01/2009. They have since re-inspected All-Feed again which is referenced in "OSHA News Release-$500,000 in fines against All-Feed " the results of which have not been posted on the OSHA website (this inspection ended on 10/02/2009).

Both inspections lasted just shy of 6 months.

OSHA State Plan States-Heads up

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=16665

Interesting topic. Sort of a coincidence. Just recently heard a interesting story from a facility owner where OSHA combustible dust enforcement/inspection activities is stronger in one OSHA state plan state in contrast to weak in another state plan state across state lines. So Facility A is implementing costly best engineering practices to manage the combustible dust fire and explosion risk. Whereas Facility B, across state lines has minimal layers of protection.

This is all sort of like Déjà vu, when last year with a post on this subject," State Dust Emphasis Programs Voluntary," in regards to addressing combustible dust hazards.

Adoption ComDust NEP State Plan States

OSHA Combustible Dust ANPRM Discussions

With the recent posting in the Federal Register of the OSHA combustible dust proposed ruling ANPRM, the complex subject of combustible dust has come to the forefront as a workplace health and safety issue. I encourage all stakeholders to join the Combustible Dust Policy Institute Group discussions where many topics concerning managing the risk are discussed amongst business owners and fire/explosion safety experts. Your input in the discussions is extremely valuable in providing a framework of general consensus so as to develop comprehensive input during the OSHA ComDust ANPRM comment period.

The group is open to everyone and all ComDust group members look forward to your input. Thanks

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OSHA Underground
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Published by a group of health and safety industry experts

Written by five health and safety industry insiders, OSHA Underground is the “virtual watercooler” for all things OSHA. The bloggers don’t hold back on what they think about proposed regulations, safety violations, hazardous conditions, the failures of OSHA, and more.

Eliminating Significant Risk of Combustible Dust

Immediately following the preliminary release of the OSHA combustible dust Advanced Notice of Proposed Rulemaking (ANPRM) it became apparent that the issue would be contentious issue between opponents and proponents of the proposed combustible dust regulation. This was most evident with U. S. Labor Secretary, Hilda L. Solis's statement, "It's time for workers to stop dying in preventable combustible dust explosions."

The problem is, that no matter how stringent or how many regulations are implemented, primary dust explosions will continue to occur. Only the probability and severity is reduced. I believe what the Secretary meant to say, "It's time for workers to stop dying in preventable secondary combustible dust explosions."

Secondary Dust Explosions
Secondary devastating dust explosions are preventable when the fuel load is removed through good housekeeping as outlined in the OSHA general industry regulations. All the catastrophic dust explosions that the Chemical Safety Board has investigated were attributed to poor housekeeping where the pressure wave from the primary explosion suspended dust resting on horizontal surfaces into the path of the following flame/reaction front (fireball).

In contrast, implementing best engineering practices as referenced in the NFPA combustible dust standards will minimize the occurrence and reduce the severity of consequence of primary explosions. Without best engineering practices, there is the potential for injuries, fatalities, and economic damage adjacent to the process equipment from primary explosions. Yet no where near the magnitude of a secondary explosion where the entire facility experiences horrific structural integrity damage in addition to a terrible breach of life safety.

OSH Act
In regards to the proposed regulation that the Chemical Safety Board recommended to OSHA as a result of the 2006 CSB Dust Hazard Investigation. The OSH Act requires that before promulgating any occupational standard, OSHA must demonstrate based on substantial evidence in the record as a whole that the proposed standard will substantially reduce a significant risk of material harm. Well if good housekeeping that is already referenced in the OSHA general industry standards is followed then the significant risk of material harm would be substantially reduced.

So why a separate combustible dust standard for preventing catastrophic dust explosions, when the fuel load is removed according to good housekeeping? All the best engineering practices in the world as outlined in the NFPA combustible dust standards are irrelevant if the facility has layers of combustible dust waiting for a process upset and ignition source.

The Facts Please
It doesn't seem to matter anymore if critical analysis is entered into the equation for an equitable solution between labor and business interests. The line was drawn in the sand with the OSHA News Release this past April which stated, "since 1980 more than 130 workers have been killed and more than 780 injured in combustible dust explosions." Not true.

For example, in the CSB Dust Hazard Study, the data indicated that the injuries and fatalities were attributed to combustible dust fires and explosions, not solely explosions. Severe burn injuries from the fireball of a dust fire or dust explosion have severe consequences. I don't know why the combustible dust related fires are being ignored. Especially when over 80% of incidents in 2008 were fires.

Acknowledge Explosive Atmosphere
Between the mainstream media following the lead with inaccurate data from governmental press releases in conjunction with statements from political appointees, one would think the entire manufacturing sector is going up in smoke with mass casualties from dust explosions. This is not the case and totally opposite from the facts.

Any loss of life or injury from a workplace accident is one to many. But there must be some balance into how much industry is to be regulated with special regulations. When already many OSHA general industry regulations are in place and all that is needed is a revision with the wording "combustible dust." and the acknowledgment that combustible dust poses an potentially explosive atmosphere.

More than About Dust
Initially when I started the ComDust research project 20 months ago it was solely about dust. But now it has evolved into more than that. With questions arising, in how can incomplete governmental data and inaccurate press releases be utilized in formulating public opinion through the mainstream media?

But if governmental agencies can do it with combustible dust issue then it can be done with more pressing issues that effects millions of Americans. It's been an interesting and fascinating lesson in how governmental policy is formulated. Combustible dust really doesn't even come up on the radar with the myriad of other issues that effect a majority of Americans more directly on a daily basis.

I still have a firm belief in President Abraham Lincoln's view as he stated in the November 19, 1863, Gettysburg Address, "...and that government of the people, by the people, for the people..." I guess what President Lincoln was trying to get across is that we are the government and the government is us. It hasn't seemed that way for a long time in Washington D.C., with the Republicans pitted against the Democrats with a winner take all scenario in a majority of issues. In contrast to a consensus with a half way point were each party gives away a few concessions in order to come to an equitable solution.

Bitter Feud
In the case of the proposed combustible dust regulation, I don't see any half way point. It will be contentious bitter feud between labor and business interests. Sound critical analysis of managing significant risk will go to the wayside. This is evident already from the sparse Republican agreement with the ComDust bill that was passed in the House of Representatives last year to the recent public statements by the Department of Labor that they will give no quarter to business interests.

I can't take sides with either group since my main interest is providing and sharing with stakeholders a proactive situational awareness on combustible dust related fire and explosion hazards in the workplace. In the meantime, it's been an interesting lesson in government 101.

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.