Have Your Say...CSB ComDust Recommendation Hearing (July 25 1:30 PM EDT)

Ask and comment now, email comments@csb.gov Questions and comments to be read aloud at the meeting. To listen to the meeting via telephone, please use the following number and participant code: Access Number: 1-800-920-7487 Participant Code: 44665662#

Beginning at Thursday July 25 1:30 p.m. EDT, the Board will consider and vote on the status designations of four recommendations to OSHA related to the issuance of a general industry standard for combustible dusts:

Recommendation No. 2006-1-H-R1, issued pursuant to the CSB's Combustible Dust Study.
Recommendation No. 2008-5-I-GA-R11, issued pursuant to the CSB's Imperial Sugar Investigation Report.
Recommendation Nos. 2011-4-I-TN-R1 and R2, issued pursuant to the CSB's Hoeganaes Case Study.

At the conclusion of the meeting CSB Board Members are expected to designate an OSHA general industry standard for combustible dust as the CSB's first “Most Wanted Chemical Safety Improvement” issue.

Meeting Agenda http://www.csb.gov/assets/1/7/72513_Meeting_Agenda.pdf

OSHA Combustible Dust National Emphasis Program (NEP) a Dismal Failure

"Assistant Labor Secretary Jordan Barab says he believes it's too early to assess the effectiveness of the program." Too early to assess? So how many more catastrophes like Hoeganaes must occur before we figure out the Combustible Dust National Emphasis Program (NEP) is a dismal failure?

Since 2008, through researching media accounts of combustible dust related fires and explosions the Combustible Dust Policy Institute has determined that over 50% of incidents are occurring in specific industries (NAICS) not recognized in the OSHA ComDust NEP.

Subsequently, the CSB Hoeganaes Case Study recommendation "Revise the Combustible Dust National Emphasis Program (NEP) to add industry codes for facilities that generate metal dusts(e.g., North American Industrial Classification System, NAICS, code 331111 Iron and Steel Mills, and other applicable codes not currently listed)," is only the tip of the iceberg.

What about the dozens of other industries throughout the entire manufacturing and non-manufacturing sectors not recognized in the NEP having a history of combustible dust incidents? Let’s stop fooling around and attempting to segment specific industries while Rome is burning. If you have combustible dust at your facility then it does not matter what you’re NAICS specific industry classification is.

As retired University of Michigan Professor of Aeronautical Engineering Bill Kauffman stated in the article, "It's not rocket science," If you don't believe it then check for yourself in the next news account of a combustible dust related incident where the specific industry (NAICS) is not recognized in the ComDust NEP. If this isn't a failure then I don't know what is.