ComDust Alert #1 -Demolition Work Combustible Dust Hazard

Fire crews called to Hoover plant

Over the past year the Combustible Dust Policy Institute has observed through media accounts, numerous preventable combustible dust fires occurring at facilities where demolition work is conducted. Contractors must be informed by plant owners when working adjacent to process equipment such as ducting and bulk storage enclosures. A dilemma exists when the plant is sold and then vacant. How does the appropriate parties obtain the essential risk assessment information?

Prior to demolition work starting, a thorough risk assessment must be performed by all stakeholders, which identifies, evaluates, and controls the risk. Either the combustible dust hazard must be eliminated or managed appropriately. Most contractors are not aware of combustible dust hazards while conducting their work at manufacturing facilities. This presents a serious problem when heat sources from grinding and cutting tools adjacent to fuel sources complete the fire triangle.

Another possible solution in preventing future combustible dust related fires during demolition work is through an education effort involving area safety councils across the nation working proactively with their construction and manufacturing sector membership. Until some form of proactive situational awareness measure is implemented these incidents will continue.

Combustible Dust Explosion Inspection Training

The Illinois Safety Council is hosting several Combustible Dust Explosion Inspection Seminars at the University of Illinois in Naperville, Illinois on October 30 and November 20, 2008. Joseph Howicz, who has served for over 30 years as an OSHA Compliance Officer and OSHA Instructor in addition to John Newquist, OSHA's Region V Assistant Regional Administrator for Cooperative and State Programs will be speakers at the seminars.

Topics will include preventing and mitigating explosions, OSHA Combustible Dust NEP, OSHA Inspection Details, and a review of the important NFPA 654 Combustible Dust standard. Naperville is a short drive from Chicago's O'Hara Airport. Attendees who complete the one day program will receive Certificates of Completion (CEU) from the University of Illinois.

Registration and Application .pdf

Returning After Ike

For nearly a week the communication infrastructure throughout Galveston County has been down as the result of Hurricane Ike that cut a devastating path beginning at the eastern tip of Galveston Island and continuing northward up the Houston Ship Channel. Slowly electrical and Internet services are being restored throughout the area.

Today was the first day that the Combustible Dust Policy Institute, located in the eye of the hurricane in Santa Fe, Texas, has been able to get back to business when electrical power was restored by the hardworking crews and contractors of Center Point Energy . Luckily the 110 mph winds did not cause any major damage here on Sandy Lane, just plenty of frayed nerves and thankful that our prayers were answered that the storm didn't turn into a Cat 3.

Prior to tracking combustible dust fires and explosions in the manufacturing sector, Google Maps were also utilized to track maritime vessel traffic in the Houston-Texas City-Galveston area. Just thought I'd provide visitors here on this site a link to a birds-eye view of shipping traffic waiting to enter the local ports. Currently the Houston Ship Channel has reopened with restrictions and as soon as all the navigational aids are restored global trade will return back to normal here in this neck of the woods.

Google Map Shipping Traffic
Ike Aftermath Satellite Pictures

Blow Down ComDust Housekeeping Safety

http://www.edsonleader.com/ArticleDisplay.aspx?e=1200382

Make sure you safely vacuum areas of high dust build-up prior to a blow down. Unfortunately this sawmill experienced a fire when dust ignited during a blow down. On the positive side, the plant was saved from extensive damage when the fire sprinkler system activated. NFPA 654 and 664 are excellent resources with chapters that outline housekeeping procedures prior to blow downs.

Suppression System Successfully Extinguishes Fire

Here is a success story in regards to a recent fire at a textile mill in Pennsylvania. A news account in the Republican-Herald reported that the automatic fire alarm alerted the local Pine Grove, Pennsylvania fire department and upon their arrival the fire was extinguished by the factory’s fire-suppression system.

"Pine Grove Fire Chief Dave Sattizahn said a heat buildup of more than 300 degrees started the fire.“Lint or something got caught up in there,” he said. “I’m not exactly sure what yet. I don’t know if it was blocked. These things happen. It’s a common thing in the fabric industry."

The fire occurred in the duct work connected to a process machine. Guilford Performance Textiles is a global leader in textile and fabric finishing for over six decades. Additionally, the company is leading by example with the proactive mitigative fire protection measures that management has instituted in the plant with fire detection and suppression systems that reduced the severity of the recent incident.

Ignition and fuel sources are an inherent aspect at manufacturing facilities and fires unfortunately will continue to occur. It's through a comprehensive process hazard analysis that the likelihood and severity of incidents can be minimized. Plant managers and owners throughout the manufacturing sector can learn from this incident in minimizing the risk at their plant.

Guliford is listed as NAICS: 313312-Textile and Fabric Finishing Mills and not found in the OSHA Combustible Dust NEP where only 16% manufacturing sector NAICS are targeted for OSHA inspections with an emphasis on dust. Additionally, more than 50% of the 90+ combustible related fires and explosions in the last seven months are not listed in the NEP either. Relying solely on the OSHA Dust NEP as a solution does not address the complex combustible dust issue.

Even if your facility does have a NAICS that is listed in the NEP the chance of an OSHA inspection with a dust emphasis is very slim. For example of the over 2,000 NAICS 313311 Broadwoven Fabric Finishing Mills, 4%(29) had a facility inspection within the last twelve months by a CHSO and only 0ne of these was with an emphais for combustible dust. There are many more recent examples like this, which the Combustible Dust Policy Institute has discovered through research of incidents provided through news accounts.

Across the nation, informative training seminars are conducted for stakeholders on preventative and mitigative measures in reducing the likelihood of combustible dust related explosions and fires. During these very educational workshops, the most referenced document in addtion to the CSB Dust Hazard Study and NFPA combustible dust standards, is the OSHA Dust NEP.

This is fine if your facility has NAICS that is listed in the NEP. But what about the other 84% NAICS in the manufacturing sector. Of course not all of these handle combustible particulate solids that generate combustible dust. Yet over 50% of the manufacturing facilities that experienced combustible dust incidents in the last seven months had NAICS not listed in the NEP.

So are you going to gamble on a 50:50 chance that your plant won't have a troubling combustible dust related fire and explosion in the near future? Worrying about an OSHA inspection should be a secondary thought. As outlined in the NFPA combustible dust standards, the life safety, mission continuity, and structural integrity of the premises is of utmost importance.

The recent statistical data of incidents and OSHA inspection reveals the true story. If you are the majority and not the minority then don't fall under the false presumption that the OSHA Dust NEP will provide the answer. Take steps now as Guilford and many other facilities not listed in the NEP have already done.

Statistical NAICS reports of prior OSHA inspections and combustible dust related incidents are now available at the Combustible Dust Policy Institute, which are utilized in the process hazard analysis in determining the likelihood and severity of combustible dust incidents. Unfortunately, while thinking outside the box, the research in acquiring this data does not rely solely on the Combustible Dust NEP.

State OSHA Plans Absent

After seven months collecting data of over 90+ combustible dust related explosions and fires from media accounts, the questions arises if any trends are developing throughout the nation in the manufacturing sector? The most glaring trend is State OSHA participation of combustible dust inspections and enforcement is minimal.

Explosions are happening in nearly 20% of incidents and repeatable incidents over 30% . The dust collector is involved in over 40% of events, either from a spark traveling downstream through the duct work or ignition originating locally in the air material separator.

General Duty Clause
Reviewing over 4,500 OSHA inspection reports on the IMIS Database that CSHO's have completed in the last twelve months and comparing with all the NAICS in Appendix D-1/D-2 of the OSHA Combustible Dust National Emphasis Program (NEP) Directive, resulted in 24 combustible dust General Duty Clause citations.

None of the GDC combustible dust citations occurred in a locale with a State OSHA Plan. According to the OSHA Combustible Dust NEP, it's strictly voluntary for these states to conduct targeted NAICS inspections and enforcement for combustible dust violations as outlined in the NEP. This presents a huge problem and a distorted picture of actions concerning federal OSHA offices in conjunction with the overall Combustible Dust NEP program.

North Carolina leads the OSHA State Plans in conducting inspections with an emphasis on combustible dust at manufacturing facilities throughout the state. In contrast, CHSO's from Pennsylvania federal OSHA offices lead the nation issuing General Duty Clause citations for combustible dust.

Prior Dust Inspections
Additionally, the media and congressional leaders have absorbed the political spin of an independent governmental investigative agency that submitted recommendations to OSHA in 2006. An emotional knee jerk reaction to the recent Imperial Sugar Refinery dust explosion and prior catastrophic dust explosions in 2003 in conjunction with the CSB recommendations resulted in drafting a combustible dust bill that now awaits a vote in the Senate.

After several congressional hearings on combustible dust, the word out on the street is that OSHA is not doing it's job in enforcement and inspection activities concerning combustible dust. How can this be, especially when Federal OSHA offices have been citing facilities on combustible dust violations for many years prior to the Imperial Sugar Refinery explosion?

Two OSHA's
In contrast, according to media accounts, over 50% of combustible dust explosions in the last seven months have occurred in states with State OSHA Plans, where an organized proactive Combustible Dust NEP is absent. Basically, there are two different and totally separate OSHA's nationwide, which is divided amongst Federal and State offices. Collecting data of recent combustible dust incidents reinforces the fact of two separate OSHA entities.

Collective Cooperation
A comprehensive combustible dust regulation will not solve the problem of preventable combustible dust related explosions and fires. It's only through the combined efforts of State and Federal OSHA offices in conjunction with local fire inspectors where the complex combustible dust issue can be addressed properly.

OSHA does not have the personnel and financial resources to inspect more than 10% of manufacturing facilities in the nation. What about the other 90% ? Cooperation with state and local Authorities Having Jurisdiction (AHJ) is the direction all stakeholders should be championing in developing a proactive comprehensive combustible dust plan. Not a comprehensive combustible dust regulation with the absent financial backing.

Costly Dust Testing
Incident data illustrating State OSHA Plan inactivity does not truly represent the entire situation. For example, additional funding is needed for combustible dust testing in manufacturing facilities, which would enhance State OSHA inspection and enforcement activity. Laboratory testing at the OSHA Salt Lake Technical Center for ignition sensitivity and explosion severity is very expensive, costing thousands of dollars.

Why wasn't this crucial aspect of the combustible dust bill discussed during the several congressional hearings? Who is going to pay ? It all looks good on paper and makes one feel warm and fuzzy but the reality begins to sink in when viewing the data of what actually is occuring.

Google Map Web Links

State OSHA Plans

General Duty Clause Citations 9/07-9/08
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