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

Combustible Dust Related Fire, One Million Dollar Loss

This is the sort of combustible dust related incident CBS 60 Minutes would not care to hear about when researching for their June 2008 segment on combustible dust, "The Danger of Combustible Dust,"

Combustible dust-related fires with no fatalities nor injuries would not fit into their programming, especially with the host inaccurately informing American viewers "Since 1980, there have been at least 350 such explosions in the U.S., killing 133 people and injuring hundreds more." Quite disturbing since we all know the 2006 U.S. Chemical Safety Board Combustible Dust Hazard Investigation Report included both combustible dust fires and explosions from the 1980-2005 timeframe.

Seems almost like yesterday, with the 60 Minutes Executive Producer calling here to Texas from New York City inquiring if I knew of any facilities destroyed from dust explosions immediately following the Feb. 7, 2008 catastrophic Imperial Sugar Refinery explosion where he could send a CBS film crew to.

I said no, I didn’t know of any facilities destroyed by dust explosions but did know of a facility destroyed by combustible dust related fire like in this unfortunate Boca Raton, Florida  Cabinetry Shop incident  Mainstream sensationalistic networking doesn’t want to hear about mundane fires. Instead they need explosions causing death and destruction to wake up couch potatoes viewing the boob tube on Sunday evening.

Alas, the stage was set for the following next half decade where the drama would unfold. Where now even OSHA stating in prior  press releases, all incidents are dust explosions. But after all if 60 Minutes says it is so, must be fact, as all us baby boomers from a long ago era use to believe. If stakeholders don’t acknowledge the initial root of catastrophic dust explosions is fires (fire triangle on steroids) we’ll never identify the root of this systemic global problem.

California ComDustX Record Outstanding

How can one state that has over 13% of the nation's 333,460 manufacturing establishments, according to U.S Census Bureau 2005 data, maintain such a superb record of minimal combustible dust incidents? Across the board in the food, metal, wood, chemical, plastics/rubber, and textile industries, California has stayed off the radar with no incidents over the last two months. Either ComDust incidents are not being reported by the local press or industry must have a instituted a phenomenal preventive and mitigative combustible dust safety program.

Currently California has four times as many manufacturing facilities (44,825) than 84% of the 50 states in the union. Over the past 10 weeks since the Imperial Sugar Refinery explosion there has been over 30 combustible dust related fires and explosions occurring across a wide spectrum of industries throughout the United States from coast to coast. The revealing aspect is in over 45% of these incidents, California has the leading number of establishments in the following distinct industries were incidents have occurred in other states. Yet none in California.

How can this be? The math doesn't compute, since it seems if you have the leading number of industries, then shouldn't the state lead in ComDust incidents?

• Breakfast Cereal Manufacturing
• Dog and Cat Food Manufacturing
• Dry, Condensed, and Evaporated Dairy Product Manufacturing

• Cut Stock, Resawing Lumber, and Planing
• Other Millwork (including Flooring
• Institutional Furniture Manufacturing
• Nonupholstered Wood Household Furniture Manufacturing

• Electroplating, Plating, Polishing, Anodizing, and Coloring

• Nonwoven Fabric Mills
• Thread Mills

• Dental Equipment and Supplies Manufacturing

• Adhesive Manufacturing
• Urethane and Other Foam Product (except Polystyrene) Manufacturing

Currently, the Combustible Dust Policy Institute is reviewing governmental historical data from various agencies in the determination of abnormal trends in specific industries and locales where combustible dust incidents occur. The results will assist in managing resources where ComDustX hot spots occur and strategically direct stakeholders in an efficient manner in conjunction with lowering operating costs.

For instance, in the wet corn milling industry (NAICS) 311221, the Chemical Safety Board Combustible Dust Hazard Study collected data on 21 ComDust incidents from the period 1980-2005 in this industry. The wet corn milling industry has 66 establishments nationwide, employing nearly 9,000 workers in this food manufacturing subsector according to governmental data from 2005.

Iowa, the leading state with 12 establishments had 5 of the 21 incidents during the above noted period. In contrast, Illinois with 4 wet corn milling facilities had 7 incidents (33%) of the 21 incidents. Why does one state with three times as many establishments as the other, have 30% less occurrences of ComDustX incidents?

States with good records of low incident rates could possibly collaborate with high incident rate states in the reduction of future ComDustX incidents. A central clearing house could be developed across a wide spectrum of industries in facilitating future administrative controls. Regulations are only a temporary fix unless communication is maintained between industry stakeholders when dealing with the complex subject of combustible dust.