How can a $3 million fire that destroyed a historic furniture factory in Salt Lake City, Utah four years ago be unreported in the Chemical Safety Board Combustible Dust Hazard Study? An excerpt from a news account states:
"Local fire officials suspect that the fire started in the dust collector at the 120-year-old factory owned by Jeffrey Cobabe and Associates."
Hundreds of Incidents not Reported
The troubling aspect of the incomplete CSB Dust Hazard study that was submitted to OSHA in 2006 is that public policy concerning worker health and safety was formulated in the OSHA Combustible Dust National Emphasis Program (NEP) directive. Additionally, in March 2008 the House Education and Labor Committee introduced to Congress (H.R.5522) The Worker Protection Against Combustible Dust Explosion and Fires, also utilizing the CSB Dust Hazard study as the guidance and foundation in the drafted bill.
Since the Imperial Sugar Refinery dust explosion, dozens of training classes at industry conferences hosted throughout the nation have been providing industry stakeholders with information on combustible dust hazards. Yet these training seminars also make continuing reference to the CSB dust study in addition to the OSHA Combustible NEP, which unfortunately omits hundreds of manufacturing sub-sectors (NAICS). This training is fine and much needed in the industry. A problem arises when plant owners and managers are not obtaining the complete picture of the magnitude and depth of combustible dust hazards.
The Chemical Safety Board is not to blame. This agency is the finest accident investigation agency in federal government and has provided the industry with crucial information in preventing future accidents. With a limited budget these dedicated professionals are on the front lines investigating catastrophic accidents finding the root cause. What the agency isn't, is a research organization like the Bureau of Labor Statistics
Get the Knack of the NAICS
Referring to the above destructive fire where a dust collector was involved in just one example of the hundreds of NAICS and tens of thousand of manufacturing plants not listed in the OSHA Combustible Dust NEP, where only 68 out of a 427 manufacturing NAICS are referenced in Appendix D-1 & D-2. Just because your facility is not one of the 68 NAICS listed in the NEP, don't for a second believe you have a free pass and all is fine and dandy.
If the process stream handles combustible particulate solids that generates combustible dust of any sort, then you are sitting on a bottle rocket waiting to go off when all the factors of ignition, heat, fuel, suspension, and confinement all come together in the rare moment. We all know what a vapor cloud explosion can do in the refinery sector. The same devastating overpressure effects occur with a dust explosion in the manufacturing sector. In fact, unbelievably for many combustible dusts, the deflagration index or explosion severity (Kst) is much higher.
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