Occupational Safety and Health Administration
Stakeholder Meetings on Combustible DustWednesday, February 17, 2010
9:00am - Noon and 1:30pm - 4:30pmMarriott Perimeter Center
Register now as a participant or observer for the OSHA Combustible Dust Rulemaking Stakeholder Meeting to be held in Atlanta, Georgia . Federal Register Notice January 25, 2010
Posted via web from ComDust
Investigators also determined that the shop was constructed under building and fire codes that don't allow for work on hazardous materials such as natural gas.
That kind of work falls under an occupancy rating that generally requires encased lighting fixtures and gas monitoring equipment that could have prevented the fire,
Ignition after natural gas contacting an arcing fluorescent light. Electrical fixtures in the destroyed maintenance shop not rated for Hazardous (Classified) Locations (29 CFR 1910.307). State Fire Marshal made an informal tour in May 2008 and didn't observe HazLoc weakness nor at an earlier inspection in the 1990's. Say What?
This story sounds so familiar of state fire marshal's not recognizing combustible dust fire and explosion hazards (explosive atmospheres) as mentioned in the 2006 Chemical Safety Board's Dust Hazard Investigation.
Posted via web from ComDust
The absurdity of including the manufacturing sector in the OSHA General Industry Standards really hit home the other day while working the graveyard shift at the refinery. A co-worker and I were having a discussion concerning the Sub-Parts of the General Industry Standards in which housekeeping, hazardous communication, ventilation, and PPE have the same requirements for refinery workers as they do for restaurant/fast food workers. This is were I had a bit of difficulty in justifying to Steve that the occupational hazards that we are exposed to in our 12 hour shifts our similar to food service workers as outlined in the General Industry Standards.
So why does construction, agriculture, and the maritime trades have separate OSHA Standards, yet manufacturing doesn't? Each of these sectors have their own unique occupational hazards in the workplace. In 2007 there were 400 fatalities in the manufacturing sector. Leading cause of fatalities in 2007 were from contact with objects and equipment (140), transportation incidents (102), and falls (48).
In 2008, Bureau of Labor Statistics (BLS) reported 689,700 recordable injury or illness cases in manufacturing industries with more than half of these requiring days away from work, job transfer or restriction.. The nearly 14 million workers in this sector had the highest numbers and rates of occupational illnesses with more than 25% of these were hearing loss. So what is so general about this, to be referred as General Industry?
Manufacturing workers have specific risks to hazards that others in General Industry are not exposed to. Such as contact with machinery and equipment, physical exertion, repetitive motions causing musculoskeletal disorders, hazardous exposure to toxic substances, organic solvents, pesticides, dust, isocyanates, chemicals, aerosols, nanoparticles, carbon monoxide, explosions, structural failures, and noise. For example, manufacturing sector fatal work injuries involving fires and explosions was up 14 percent in 2008.
What other General Industry sectors are exposed to as much risk? All the above are specific hazards that are not general in nature and must be addressed accordingly so as to minimize fatalities, injuries, and illnesses. Utilizing these General Industry Standards, relics of the 1970's when the Rubik's Cube was cool and the drive-in movie was still in fashion is not the solution for the 21st Century.
An earlier post with the example of the Ventilation General Industry Standard that is mostly occupational hygiene in nature and not occupational safety concerning inherent fire and explosions hazards in the manufacturing sector is only the tip of the iceberg. Currently OSHA's answer to address this inadequacies is to develop separate standards for different fire and explosion hazards such as combustible dust. So whats next, a Vapor Cloud Explosion Standard.?
After-all, there are many, many more fatalities and injuries as the result of these sort of incidents such as the BP Texas City Refinery incident. It's quite evident that Process Safety Management (PSM) has not had stellar results. So lets have a Vapor Cloud Explosion Standard next. Of course this is not the appropriate solution but only further illustrates the absurdity of the manufacturing sector referred to as General Industry.
The appropriate and most obvious solution is to revise the current OSHA Standards to reflect current occupational hazards that workers are exposed to on a daily basis. Manufacturing is vital to the economic health and security of our nation, which had gross output of $4.5 trillion in 2005, and the most important sector of the U.S. economy in terms of total output (Bureau of Economic Analysis 20081). It's long overdue for manufacturing to be have it's own OSHA Standard like construction, agriculture, and the maritime sectors. Until then all stakeholders can expect additional red-tape and bureaucracy of separate standards included in the OSHA General Industry Standards. Is that the course desired?
Combustible Dust Pre-Conference Workshop at the 5th Annual Industrial Fire, Safety, and Security Conference-IFSS 2010 upstairs in the George R. Brown Convention Center in downtown Houston, Texas, February 2 2010 from 8:00 AM- 5:00 P.M. (Lunch Included) Topics will introduce attendees to the hazards of combustible dust fires and explosions in the manufacturing, non-manufacturing, and utility sectors. Stakeholders will acquire important information, which they can utilize in identifying, evaluating, and controlling combustible dust hazards. The educational workshop will assist stakeholders in minimizing and preventing combustible dust incidents in addition to achieving OSHA regulatory compliance.
Currently a situational awareness is lacking nationwide that combustible dust poses a potentially explosive atmosphere the same as flammable gases, vapors, and mists. Are you aware of the dust hazards at your facility, which can result in OSHA citations?
Guests speakers: Tim Anderson, Owner, All Feed Processing and Packaging Inc "Regulatory Compliance Small Business Perspective"
Robert Zuiderveld, General Manager, Pyroban Corporation "Powered Industrial Equipment Operation in Potentially Explosion Hazardous Locations"
Bruce Gordon, Senior District Manager, Nilfisk , "Proper Housekeeping and Explosion-Proof Vacuums Hazardous Locations"
WHO ATTENDS IFSS Workshops and Seminars?
Attendees from across the United States converge at IFSS every year to meet with their peers - industrial emergency response and security leaders throughout the industrial and energy marketplace.
INDUSTRIAL FIRE, SAFETY & SECURITY Attendees Include:
FEDERAL/STATE/MUNICIPAL
By Joe Lederman
Throughout the greater part of the 20th century, a naturally-occurring mineral known as asbestos was utilized in a variety of applications. Due to its flame resistant, highly durable and inexpensive qualities, it became the ideal choice for manufacturers. Asbestos can appear in roof shingles, dry wall, attic insulation, popcorn ceilings and electrical wires.
The mineral was mixed into paint, combined with cellulose to make fiberboard and wallboard, mixed with cement to make siding shingles and formed into felt for use as roof felting and backings on vinyl flooring. Asbestos was even used in joint compound, which was used in dozens of different kinds of applications.
Hidden from the public for decades, exposure to asbestos can lead to the development of the mesothelioma disease, as well as many other health ailments that are extremely difficult to treat and diagnose. Due to these effects, it is recommended that men and women in the workplace receive proper information and tips to avoid any inhalation of asbestos. The use of asbestos became extremely prevalent in various industries which lead to many tradesmen being wrongfully exposed to airborne asbestos fibers.
Workers from practically all trades were involved with asbestos, even those that worked in the unlikeliest of professions. Asbestos was used in a variety of different products and was largely found in shipyards, power plants, chemical plants, factories, steel mills, building construction, and the telephone industry. Some of the occupations that commonly came in contact with asbestos include: asbestos textile mill, automobile production, building engineers, electrical workers, military personnel, custodians, pipefitters, railroad workers and firefighters.
Healthy Tips & Info
Asbestos exposure is easily prevented by taking simple precautions. Any home or building built before 1980 has a good chance of still containing asbestos. Even firehouses should be inspected for asbestos as many of them were constructed prior to any asbestos ban.
Licensed abatement contractors who remove asbestos, will be familiar with the regulations in protecting you and themselves from exposure to asbestos. They must wear protective equipment such as masks and gloves to avoid any exposure. The area is usually isolated from the rest of the house by shutting down ventilation systems and sealing them.
If you locate any suspected asbestos, most experts advise to leave it alone and un-disturbed. When asbestos is left alone, it is harmless. But if the material is disturbed or becomes damaged, millions of tiny fibers are released into the air where they can then be inhaled or ingested. If you encounter black or dark asphalt floor tiles, they may contain high levels of asbestos fibers.
These fibers become lodged in the tissue of organs (most often the lungs) and can eventually cause a number of illnesses such as malignant mesothelioma and asbestosis. Diagnosis of this asbestos-related lung illness is a difficult task due to a long latency period and many symptoms mimicking less serious ailments. A reported 2,000 to 3,000 mesothelioma cases are diagnosed every year in the United States alone, which averages out to three percent of the total cancer diagnoses. A patient’s prognosis can be affected by many factors, these include: age of diagnosis, treatment methods and cigarette smoking.
If you are or have worked in any of the listed trades and believe you have experienced asbestos exposure, it is important to receive regular screenings by physicians to identify a possible disease. It should be known asbestos exposure does not always lead to a disease, but because the latency periods associated with asbestos illnesses can last 20 to 50 years, a regular check up is advisable.
Resource
Asbestos.com
Reviewing the recent OSHA Combustible Dust NEP status report (Figure 6) illustrates that 90% of the citations for combustible dust arose from OSHA General Industry Standards. Approximately 10% of the citations were General Duty Clause citations where a majority of examples were for ventilation such as ductwork, dust collectors, and other aspects of the dust collection system used in ventilation. (pages 7-10 of 12 page .pdf)
The current OSHA General Industry Ventilation Standard 29 CFR 1910. 94 includes elements that address dust hazards in abrasive blasting, grinding, polishing, and buffing operations. Problem is, the Ventilation Standard originates more from an industrial hygiene viewpoint, where attention is directed towards respiratory hazards such as silica sand inhaled during blasting operations. What about combustible dust fire and explosion hazards from inadequate ventilation throughout the manufacturing sector?
Local Exhaust Ventilation
A key aspect in the fire triangle in reducing the possibility of a combustible dust fire or explosion is to remove the combustible dust fuel load. Good housekeeping alone will not completely remove the dust fuel load in most manufacturing processes, so dilution ventilation or local exhaust ventilation (LEV) must be utilized. Local exhaust ventilation (LEV) is the most effective in reducing explosive combustible dust concentrations.
Local exhaust ventilation (LEV) includes four major components: exhaust hood, ductwork, fan/ motor, and dust collector. The system must be properly designed and maintained so as to prevent and mitigate possible combustible dust related fires and explosions. Many of the combustible dust related fires occur or progress into the ventilation system. So it is extremely important that spark detection/flame suppression, abort gates, and explosion ventilation be incorporated in the industrial ventilation system.
General Industry Standards
The OSHA General Industry Ventilation Standard 1910.94(a)(2)(iii), does note that for abrasive blasting, the principles set forth in the National Fire Protection Association Explosion Venting Guide, NFPA 68-1954 be adhered to. What about other manufacturing processes where flammable or explosive dust mixtures may be present? There is a disconnect in many other General Industry Standards in not addressing combustible dust hazards such as in Hazard Communication, Housekeeping, and PPE. It's odd that Powered Industrial Trucks and Hazardous (Classified) Locations General Industry Standards address combustible dust, yet the majority of other General Industry Standards do not.
A proposed separate combustible dust standard does not address the antiquated OSHA General Industry Standards where many of the standards are from an industrial hygiene standpoint that fails to comprehensively address fire and explosion hazards concerning occupational safety. The Ventilation Standards in the maritime, construction, and general industry is an excellent example of this weakness.
For example, ventilation fire hazards in spray finishing are addressed in regards to solvent vapor there is the requirement 1910.94(c)(6)(ii) to dilute solvent vapor to at least 25 percent of the lower explosive limit of the solvent being sprayed. What about minimum explosive concentrations (MEC)/lower explosive limit (LEL) for combustible dust that is captured in the industrial ventilation system that are also possible fire and explosion hazards thoughout the manufacturing sector?
Potentially Explosive Atmosphere
Until OSHA recognizes that combustible dust is a potentially explosive atmosphere like in the above example for solvent vapors there will be a weakness in the Ventilation Standards that is mostly directed towards industrial hygiene. An excellent example where our international trading partners do understand that combustible dust poses an explosive atmosphere like flammable vapors, gases, and mists is the U.K DSEAR and EU ATEX Directives
OSHA cannot continue to address Industrial Ventilation as the most important engineering controls solely from an industrial hygiene standpoint. Industrial safety is just as important and must be on the flip side of the coin. The OSHA Salt Lake Technical Center(SLTC), which edited the informative and educational OSHA Ventilation Health and Safety Topics page should know better. Especially when SLTC is conducting all the testing for combustible dust ignition sensitivity and explosion severity.
U.S. Bureau of Mines
Over two decades ago Martin Marietta Laboratories and Marcom Associates, Inc. under contract from the U.S. Bureau of Mines (USBM closed in 1995 and transferred to NIOSH in 1996), prepared an excellent 220 page document, "Dust Control Handbook For Mineral Processing." The educational content was mostly centered on respiratory hazards concerning industrial hygiene in the mineral processing industry.
Many of the excellent chapters are applicable to the design and maintenance of industrial ventilation so as to minimize combustible dust fire hazards. In addition to the resource being located on the OSHA Safety and Health Topic Silica, Crystalline pages it should be cross-referenced on the OSHA Safety and Health Topic Ventilation Additional Information page.
Conclusion
In conclusion from reviewing the OSHA Combustible Dust NEP status report it appears that too much emphasis is being directed toward the General Duty Clause. Especially when over 30 percent of the report provides examples of General Duty Clause combustible dust citations where a majority of these citations are for industrial ventilation issues. What the ComDust NEP status report failed to emphasize, was the 90% of citations arose from General Industry Standards. Powered Industrial Trucks was not even included in Figure 7 of the report. Many of these antiquated General Industry Standards have not come to terms with combustible dust fire and explosion hazards from an industrial safety standpoint.
A separate combustible dust standard will provide many with a warm and fuzzy feeling but does not address an alternative regulatory approach in revising the current General Industry Standards so as to comprehensively come to terms with the 21st century occupational safety fire and explosion hazards in the workplace.
Resources
Designing Dust Collection Systems by Gary Q. Johnson-Workplace Exposure Solutions
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