At a recent combustible dust webinar last October, attendees to the educational event learned that about ten combustible dust incidents occurred annually from the early 1980s until 2005 in the U.S.A. This data was obtained from the Chemical Safety Board Dust Hazard Investigation that was completed in 2006, noting 281 ComDust incidents from 1980-2005.
Unfortunately, this is not reality in contrast to media reports that note over ten combustible dust incidents every month. Currently, OSHA is in the combustible dust rulemaking process utilizing this incomplete data from the CSB Dust Hazard Study. This presents a problem by not exposing the enormity and complexity of combustible dust related fires and explosions in the manufacturing, non-manufacturing, and utility sectors.
The problem is exasperated by the current OSHA Combustible Dust National Emphasis Program (NEP) that further lessens the magnitude of combustible dust incidents by solely listing certain national industries (NAICS) that have a potential for combustible dust incidents and excluding thousands of other manufacturing plants that do have a history of ComDust incidents not listed in the ComDust NEP. For example, in 2008 over 50% of facilities that had ComDust incidents were not listed in the Appendices D-1 and D-2 of the NEP.
If your facility generates combustible dust it doesn't matter whether OSHA acknowledges the hazard our not in the ComDust NEP. Bottom-line, you have a potential fire and explosion hazard that can cause grave burn injuries, fatalities, and severe property damage. Get your dust tested now or at least conduct a thorough process hazard analysis; identifying, evaluating, and hopefully controlling the hazard.
To learn more about combustible dust hazards be sure to check out the excellent Chemical Processing. com webinar moderated by Traci Purdum, Senior Editor/Digital Media. Presenters included Dr Vahid Ebadat Ph.D/Chilworth Technology, Inc., John Dauber, sales manager/Camfil Farr APC, Bob Korn, Director of Sales for Explosion Protection Products/Fike Corporation, and Guy Colonna, Division Manager, managing the Industrial and Chemical Engineering department for the National Fire Protection Association.
Resources
Google Map Dec 2010-Jan 2011 Combustible dust related fires and explosions
Dust Gets it's Due- By Seán Ottewell, Editor at Large-Chemical Processing.com
Saturday, January 15, 2011
Ten ComDust incidents per year...Say What?
Friday, January 14, 2011
Confined Structure Fires also Combustible Dust Related?
Just prior to the Christmas holiday a minor combustible dust related fire occurred in a dust collector at a Misc. Fabricated Metal Producing Manufacturing/NAICS 332999 facility in Wisconsin. These type of facilities are listed in Appendix D-2 of the OSHA ComDust NEP as Fabricated Metal Products, Not Elsewhere Classified with industries that may have Potential for Combustible Dust Explosions/Fires.
According to the news account:
The fire was extinguished and contained to the dust collector bag house. There was no fire extension into manufacturing plant.WQOW.Com
The incident begs the question was this a confined structure fire? Where as in similiar small fire incidents that are limited in scope, are confined to noncombustible containers, rarely result in serious injury or large content losses, and are expected to have no accompanying property losses due to flame damage. The news account mentions no fire extension into manufacturing plant nor injuries which resulted in an estimated $10,000 damage to dust collection bag house. Since dust collectors are constructed of metal they would be non-combustible.
In the U.S. Fire Administration/National Fire Data Center, Investigation of Confined Structure Fires, Topical Fire Research Series, the report noted 2002 NFIRS 5.0 data contain abbreviated reporting for slightly over 52,000 confined structure fire incidents—37% of structure fires.These incidents accounted for $26 million in combined losses, 3 deaths, and nearly 500 injuries. Most confined structure fires (77.5%) occurred on residential properties. It is the other 23% that we are concerned about in manufacturing non-residential properties.
There is a problem in this US Fire Administration reporting in that it does not formally consider dust collectors or other process equipment in the manufacturing sector that are non-combustible as confined structure fires. Instead, cooking fires, trash or rubbish fires, chimney fires, commercial compactor, fuel burners, and incinerators are used as data element descriptors in these type of fires.
This does present a problem since fire service professionals can't identify combustible dust fire hazards in the NFIRS 5.0 reporting system, then how can they assist stakeholders in evaluating and controlling combustible dust fire hazards. All combustible dust related fires are failed catastrophic combustible dust explosions. Time is way overdue for the FEMA/US Fire Administration's National Fire Data Center to review their fire reporting methodology that omits the dozens of minor combustible dust related fires that have a history of evolving into catastrophic dust explosions.
Combustible Dust Explosion Pharmaceutical Preparation Plant
A combustible dust explosion occurred at a pharmaceutical preparation plant in Iowa prior to the end of the 2010 a few weeks ago. Luckily there were no injuries or fatalities and damage was minor according to the news account.
"There were no injuries. The explosion blew out doors on the building and dust collectors, with additional minor damage."Eastern Iowa News Now
It appears the mention of doors blowing out in the dust collector might be referring to explosion ventilation panels. Being that the plant is involved in pharmaceutical preparation with a NAICS 325412, it is noted in the OSHA Combustible Dust NEP in Appendix D-1 as an Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires.
Over the past 12 months OSHA has been enforcing a myriad of regulations in addition to ComDust NEP emphasis in their site visits at pharmaceutical preparation facilities. The OSHA Integrated Management Information System also referred to as IMIS provides a helpful insight to these inspections.
An educational General Duty Clause citation for one Pharmaceutical Preparation Plant noted that "neither dust collector was equipped with deflagration venting panels directed to an unoccupied area or with a suppression system. The collectors were located inside an occupied area which employees entered to conduct maintenance on a daily basis."This is in contrast to the current incident where the dust collector was installed outside on the roof and appeared to have explosion vent panels.
Results of an internet search produced a MSDS for microcrystalline cellulose (MCC) Cellulose; flour cellulose which has combustible dust fire explosion hazards. For example in the Fire Fighting section it notes, "Fine dust dispersed in air in sufficient concentrations, and in the presence of an ignition source is a potential dust explosion hazard. For Cellulose: Minimum ignition temperature, dust cloud: 410C. Minimum explosible concentration: 0.045 g/l." This is helpful information so stakeholders can take proper administrative, PPE, and engineering control measures.
On a side note, another combustible dust related fire and explosion originated from the same company that occurred nearly two weeks prior to above incident, yet paper dust was the process material at a different facility instead of microcrystalline cellulose (MCC) according to the news account.
“Something caused the paper dust to explode. We don’t know what it was,” Battalion Chief Rick Palmer of the Portage Fire Department said. Palmer said the fire department has been called to explosions at the plant in the past, most recently about eight months ago. Small fires can develop wherever the dust settles in the plant following such an explosion, he said. “We just chase little fires all over the place,”Michigan Live.com
Stakeholders searching the OSHA Combustible Dust NEP will not find any paper industries that OSHA believes have More Frequent and/or High Consequence Combustible Dust Explosions/Fires or Potential for Combustible Dust Explosions/Fires. Don't know what the NAICS is for the facility that generated paper dust in the news account yet there is mention that the facility produces paper insulation. In either case whether or not a facility is listed in the OSHA ComDust NEP, if you generate ComDust then you need to identify, evaluate, and control the fire and explosion hazards.
Thursday, January 13, 2011
U.K Combustible Dust Fire with Metal Dust
OSHA needs to look at DSEAR and ATEX and include ComDust in the universe of potentially explosive atmospheres in the rulemaking process, which also includes flammable liquids, gases, vapors, and mists. Can't continue like the present situation in the USA with ComDust as a separate entity. Until then, the US Fire Administration will continue to ignore the fire and explosion hazards of ComDust with deficient incident reporting in the National Fire Incident Reporting System NFIRS 5.0
Process Upset Causes Combustible Dust Related Fire
Another minor combustible dust fire in the news with no injuries or fatalities. That is the good news..Yet stakeholders need to be aware that besides hot surfaces, arcs, sparks, static electricity, etc (process situations) that can ignite combustible dust, so can process upsets such as the case in this incident.
"combination of water and molten steel can cause a flash-up. That flash of fire likely set dust on fire, which then spread to a nearby storage room." (Watch the video)
WTOL-news article
OSHA is in the rulemaking process for a combustible dust regulation that is a continuum of the OSHA Combustible Dust National Emphasis Program (NEP). The primary problem with this approach, is that it solely notes specific national industries (NAICS) that supposedly have a high probability or high consequence or potential for combustible dust incidents and ignoring others with potential fire/explosion hazards. Now for the bad news.. According to media account, over 50% of combustible dust related fires and explosions occur in national industries (NAICS) not listed in the the OSHA ComDust NEP, such as the case with this incident
For example, the real eye opener concerning this minor incident, is that this facility is an iron and steel mill national industry (NAICS 331111), which is not acknowledged in the OSHA Dust NEP as having high probability/consequence or potential for combustible dust incidents. So if the tree fell in the forest and no one heard it, did it fall?
There are dozens of other national industries composed of thousands of facilities in the wood, paper, plastic, metal, chemical, and food manufacturing sectors not listed in the OSHA ComDust NEP that have regular occurring minor combustible related dust fires which don't get notice from many other stakeholders either. This attitude is attributed to normalization of deviation as what occurred in the events leading up to the 1986 Space Shuttle Challenger disaster. Same thing with a catastrophic dust explosion as it is a rare event also.
It is time to face reality and get with the program, understanding the ComDust fire/explosion problem is a process condition (equipment) issue and not solely a national industry (NAICS) subject. Whether an industry is listed in the OSHA ComDust NEP or not as a non-NEP NAICS, they all have similar process materials (combustible dust) and process situations (ignition sources). So how can we say that one national industry has high probability/consequence or potential for a combustible dust incident because it is listed yet another one doesn't because it is not listed in the NEP? Yet both industries generate combustible dust during the manufacturing process. This train of thought does not hold water as America is burning. Just remember that any minor combustible dust related fire is a failed catastrophic combustible dust explosion.
Posted via email from ComDust
Wednesday, January 12, 2011
Combustible Dust Fire Incident Reporting Deficiencies
A problem arises in the national fire reporting system where there are no data elements specifically identifying manufacturing process equipment involved in ignition of combustible dust. If process condition fire hazards can't be identified, then how can they be properly evaluated and controlled through administrative, PPE and best engineering practices?
"Stakeholders seeking control measures to minimize the probability and severity of combustible dust incidents should work more closely with the fire service."
ohsonline.com-article
Posted via email from ComDust
Resources:
1. National Fire Incident Reporting System (NFIRS 5.0) Complete Reference Guide
2. Report on Confined Structure Fires-February 2006, US Fire Administration
3. U.S. Industrial and Manufacturing Property Structure Fires, Oct. 2009, NFPA Fire Analysis and Research Division4. US Chemical Safety Board, Combustible Dust Hazard Investigation, Nov. 2006
5. NFPA 901 Standard Classifications for Incident Reporting and Fire Protection
RSS Feed Subscribe