2011 Over 500 Combustible Dust Related Incidents in Manufacturing Sector

NFIRS Structure

National Fire Incident Reporting System (NFIRS) analysis #94 item first ignited and #700 manufacturing property use. NFIRS is a voluntary reporting system so many fire incidents are not reported to the National Fire Data Center of the U.S. Fire Administration in Maryland. If there is no incident report for the legal record, then it's as if the incident never happened. Thanks to the dedication of the local fire departments, state program managers of the the National Fire Information Council (NFIC), and the National Fire Data Center in providing this valuable incident data to stakeholders for further analysis and evaluation.

NFIRS analysis of 2011 manufacturing sector workplace combustible dust related incidents indicated 14 injuries and 2 fatalities. For all items first ignited at manufacturing facilities including dust, NFIRS data indicated a total of 115 workplace injuries and 15 fatalities. In addition to workplace injuries 10 firefighters sustained injuries responding to combustible dust related incidents at manufacturing properties in 2011.

Currently about 23,000 fire departments report NFIRS data to the National Fire Data Center each year out of approximately 30,145 fire departments. (Source: U.S. Fire Administration and NFPA). As a result solely utilizing NFIRS data is not conclusive and does not provide a total count of incidents, injuries, fatalities, and property damage. In contrast, NFPA conducts a National Survey of fire departments in the development of a scaling ratio in conjunction with NFIRS data which assists in filling the gaps of insufficient NFIRS data.

Stakeholders are highly encouraged to review the informative NFPA report "Fires in U.S. Industrial and Manufacturing Facilities (2006-2010) " provided by NFPA’s Fire Analysis and Research Division. For all types of fires the recent NFPA 2012 report noted an annual average of 22 fatalities and 300 injuries at industrial and manufacturing properties which also includes the utility, defense, agriculture, and mining sectors..

Evaluating NFIRS data stakeholders can observe emerging trends in NAICS, Area of Fire Origin, Heat Source, Type of Material First Ignited, Cause of Ignition, Factors Contributing to Ignition, Equipment Involved in Ignition (EII), Presence of Detectors, Presence of Automatic Extinguishing System, Casualties, Property Loss, etc. The next intermediate step in an evaluation is utilizing NFPA 550 Guide to the Fire Safety Concepts Tree then culminating with implementing control measures in the NFPA combustible dust standards, International Fire Code, and FM Global Property Loss Prevention Data Sheets.

The OSHA Combustible Dust; Advance notice of proposed rulemaking, Table 1--Industries Having at Least One Recorded Combustible Dust Incident Reported Since 1980  is misleading and not reality noting 422 combustible dust incidents in a 28 year time span or approximate average of 15 incidents annually. To fully understand the depth of the combustible dust problem in the workplace it is imperative the fire service be included in future dialogue regarding training, outreach, education, inspections, and enforcement.

Key stakeholders from the fire service having intimate knowledge of fire and explosion hazards in non-residential building structures include: International Association of Firefighters (IAFF), International Association of Fire Chiefs (IAFC), National Volunteer Fire Council (NVFC), National Association of State Fire Marshals (NASFM), and National Fire Information Council (NFIC).
 
Appropriately the contentious issue of combustible dust hazards in the workplace is primarily a fire hazard and secondarily an explosion hazard. Subsequently, the majority of combustible dust related incidents are non-consequential (near misses) fires with no injuries, fatalities, nor property damage. This results in a disturbing mindset of "normalization of deviation" where facility owners and managers falsely believe that since nothing bad has happened in the past then nothing bad will happen in the future. Initially addressing the fire hazards will eliminate the possibility of secondary catastrophic dust explosions or disastrous flash fires. 

Incident Type data element # 244 Dust explosion NFIRS

Area of Origin: 2006 NFIRS Combustible Dust Related Fire Analysis

Just recently an Incident Type data element #244 Dust explosion (no fire) was added to National Fire Incident Reporting System (NFIRS) (Page 3-24 .pdf). Many stakeholders are aware of combustible dust related fires with an Area of Origin in which NFIRS also recognizes service area data elements #52 Conduit, pipe, utility, or ventilation shaft, #55 Duct, Includes HVAC, cable, exhaust, and #58 Conveyors (pages 4-16 and 4-17 .pdf) In contrast, no recognition of dust collectors in Equipment Involved in Ignition (EII), Shop Tools and Industrial Equipment (pages 4-31 though 4-32) nor Area of Origin. A recent analysis of NFIRS 2006 data indicated pipes, ventilation shafts, ductwork, and conveyors as the area of origin in over 16% of combustible dust related fires in manufacturing sector service areas.

FM Global provides informative guidance in "Prevention and Mitigation of Combustible Dust Explosions and Fire," Property Loss Prevention Data Sheet No. 7-76, (page 38 .pdf) in Table 6 Loss by Equipment Type with dust collectors noted as the leading type of equipment involved in combustible dust incidents.

Here in the USA a problem arises with fire departments voluntarily reporting dust collector explosions or fires to the National Fire Data Center (NFDC) through National Fire Incident Reporting System (NFIRS). For instance, there's no specific data element to report dust collectors in NFIRS like for the data element #244 dust explosions. If the incident is not recorded then it is as if the incident never happened. NFIRS data is considered a legal document for reporting purposes

Is this acceptable to recognize data element #244 dust explosion in NFIRS yet ignore dust collectors? Sort off like a Catch-22 situation where many dust explosions and combustible dust related fires occur in dust collectors yet no adequate manner to report dust collector incidents comprehensively.

Currently there are no immediate plans for changes to the NFIRS. In the meantime, the National Fire Data Center (NFDC) accepts suggestions for changes for review in the next version of NFIRS. Anyone is welcome to forward specific suggestions to NFDC in addition to supporting documentation. Please forward documentation requesting a dust collector data element be added to NFIRS to Brad Pabody, Chief, National Fire Data Center, United States Fire Administration (301) 447-1049 (Fax) or brad.pabody(@)dhs.gov Thanks.

Resources
NFIRS 5.0 Complete Reference Guide 

Guidance on how to analyze NFIRS Version 5.0 fire data,  refer to USFA’s National Fire Incident Reporting System Version 5.0 Fire Data Analysis Guidelines and Issues documentation. 

     Information about the methodologies used in analyzing NFIRS data, Chapter 1 of Fire in the United States 2003-2007 15th Edition.

Using NFIRS to compute national estimates in  analyses,  article on the National Fire Protection Association’s (NFPA) Web page “The National Estimates Approach to U.S. Fire Statistics” by Hall and Harwood.

·         Details on the U.S. Fire Administration’s current fire data estimation methodology for all building (i.e., residential and nonresidential) fires and associated losses,  review the “National Estimates Methodology for Building Fires and Losses” (August 2012).

Responding to Bulk Storage Combustible Dust Related Fires

Firefighting Piercing Rod Kit

Justin Clift, Industrial Marker Manager from Hazard Control Technologies shares with readers in this article the intricacies in combating combustible dust related fires. Justin emphasizes these fires can be safely extinguished with the correct equipment and fire fighting agent while following a six-step hazard elimination procedure.

1) Understand, Assess & Identify Incident Hazards
2) Eliminate Secondary Dust Hazards
3) Eliminate Primary Dust Hazards
4) Eliminate Flash Fuel Hazards
5) Eliminate Smoldering Hazard
6) Eliminate Injuries

You must use the micelle encapsulating agent, F-500 and you may require a Piercing Rod Kit for deep seated hot spots (>10ft below surface). Foam caps the material trapping the combustible vapors and will not penetrate. For instance, water will not penetrate or saturate the material.

Deep Seated Fires

When a deep seated hot spot burns it dries out the material surrounding it forming a crust. As the temperature increases the crust becomes thicker and thicker. 95% of the time, the crust will adhere to the sides of the structure so attempting to run it out is not an suitable option. This crust will continue to slowly expand until the weight of the material above it causes it to collapse.

This collapse will typically result into a flash fire, which hits the structures ceiling adding confinement and triggering the primary explosion. The primary explosion disperses the float dust on surrounding structures and equipment, which contacts the primary explosion's flame front and triggers a catastrophic secondary explosion.

You can't flood the structure with water because water will not penetrate this crust. If enough water is applied, it's weight will allow it to penetrate the material but it still can't penetrate the hot spot's crust. Thus it runs off to the sides and starts washing away the foundation of the hot spot, causing it to collapse and triggering the chain of events as discussed above.

The root cause of the problem is a lack of knowledge on combustible dust related fires and explosions. Emergency Responders need to be rebooted for a lack of a better term. The actual fire or smoldering material is not their problem, their problem is the environment surrounding the fire and the nature of a deep seated hot spots.

Firefighters have the equipment and training to be very successful at extinguished fires, they can see. However, it's extremely difficult to fight a fire no one can see and if you can't see it then you can't confirm it's been extinguished and you can't let your guard down. Our Emergency Response Team knows to never trust a fire you can't see. It's not a safe scene until we have confirmed extinguishment to the best of our abilities and all material has been completely removed from the structure.

Presentation and Videos

If you’re interested, here is a hyperlink where you can download some videos and a presentation I delivered recently at Coal Industry Conference. Unfortunately, I can’t get the videos to link properly with the presentation but you can view them separately. The file is 482MB so it may take a couple of minutes to download completely. If you have any questions or problem with the hyperlink please feel free to contact me  anytime.

The presentation is about preparing for the unexpected and discusses some lessons learned during a few recent Emergency Response Services HCT performed. Procedures are important but just having a good playbook, doesn’t mean you’re ready to take the field. There is no shame in having a fire from time to time, it’s the nature of the coal and the inherent hazards of a power plant.

What is remorseful, is when a plant is ill-prepared and gets caught with their pants down which may jeopardize the health and safety of plant personnel and Emergency Responders. Plants must be prepared for the unexpected, they must have the proper procedures which are practiced, revised, and reviewed in effort to be prepared as possible. If a plant doesn’t properly prepare and practiced they shouldn’t be awestruck when they fall short of their expectations.

About the Author

Justin Clift is the Industrial Market Manager for Hazard Control Technologies, headquartered in Fayetteville, GA.  He is originally from Ohio and transferred to Georgia to start working for HCT shortly after graduating from Ohio State University in 2005.

Justin Clift

Mr. Clift provides loss control solutions for the power industry, specializing in fire detection, suppression, and prevention. He also conducts class room training for emergency responders on the hazard of combustible dust and silo fire fighting through the use of piercing rods and a micelle encapsulating agent.

Justin has visited hundreds of industrial facilities and has first-hand experience extinguishing coal fires throughout the US, as HCT Emergency Response Team’s Incident Commander. He has also worked side by side with engineering and plant personnel, specifying upgrades to the plant’s fire protection system utilizing F-500 concentrate control systems.

Frequently Justin is asked to assist in the development of emergency response procedures, specifically applicable to the handling of a combustible dust. He is often called-upon to speak at industry meetings and events that focus on power generation and industrial safety, and on the hazards associated with combustible dust. Contact Information: Justin Clift , Industrial Marker Manager, Hazard Control Technologies C: 770-318-1805 O: 770-512-5112 E: jclift@hct-world.com