Welcome Aboard the Combustible Dust Policy Institute site! In 2012, a preliminary analysis of 2011 NFIRS data indicated 500+ combustible dust related fires and explosions in many sectors throughout the United States with the majority of incidents "near misses." The primary goal of this site concerning the complex subject of combustible dust is to bring forth a situational awareness to global stakeholders, which hopefully will lessen the occurrence and reduce the severity of future accidents.
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.
Figure 7. Percent Combustible Dust Related Violations Distributions
The recent status report on the OSHA combustible dust National Emphasis Program (NEP) provides helpful insight into recent targeted enforcement and inspection activities. It does get a bit bewildering in deciphering all the calculus when the numbers do not add up.
For example in Figure 6 the total combustible dust related violations is 2,214. Yet according to the introductory paragraph concerning enforcement findings, there was more than 4,900 violations. So which is it 2,214 or 4,900?
Many facility managers and owners attempting to manage the risk in addition to being regulatory compliant might just find themselves at the other end of a citation if not careful. For example, the NEP status report provides information on Violations Related to Combustible Dust Hazards:
"Under the NEP, the Hazard Communication standard is the standard most frequently cited with respect to combustible dust related hazards, followed by the housekeeping standard"
Yet there is no mention of violationsin regards to powered industrial trucks in Figure 7. In contrast, review Figure 6 in the status report you'll note it's the third most frequent type of violation. So are you using an explosion-proof industrial powered truck (fork-lift)at you facility if there is combustible dust present?
Better check that factory nameplate for either DY, EE, or EX depending on the Hazardous Location Division 1 or 2. It could be the defining difference between a costly fineor not.
"The U.S. Department of Occupational Safety and Health Administration (OSHA) has revealed the preliminary top 10 most-frequent workplace safety violations for 2009 as part of a presentation at the NSC's annual Congress & Expo. The number of top 10 violations has increased almost 30 percent over the same time period in 2008."
Powered Industrial Trucks is 8th on the list.
8. Powered Industrial Trucks - 2,993 violations
Each year, tens of thousands of injuries related to powered industrial trucks (PIT), or forklifts, occur in US workplaces. Many employees are injured when lift trucks are inadvertently driven off loading docks, lifts fall between docks and an unsecured trailer, they are struck by a lift truck, or when they fall while on elevated pallets and tines.
Many stakeholders were anxious to hear the Chemical Safety Board (CSB) key findings and recommendations in the September 24, 2009 release of the final investigation report on the catastrophic dust explosion at Imperial Sugar Refinery. The CSB made five key recommendations with included adherence to NFPA combustible dust standards, comprehensive housekeeping, hazard communication training, emergency response, and that Imperial Sugar implement corrective actions in accordance with best engineering practices referenced in the NFPA standards. These recommendations were not solely directed at Imperial Sugar but the entire industrial sector that handles combustible particulate solids, which generate combustible dust. Yet CSB left out a key recommendation that workers don flame resistant clothing in the protection from flash fire severe burn injuries.
CSB Dust Hazard Study In 2006 CSB concluded a Dust Hazard Study following a series of catastrophic high consequence dust explosions that occurred in 2003. The important safety recommendations of the study were forwarded to OSHA, which provided the agency a foundation in the formulation of the 2007 and 2008 reissued Combustible Dust National Emphasis Program (NEP). Additionally, following the Imperial Sugar Refinery explosion, the House Education and Labor Committee drafted a combustible dust bill utilizing the CSB Dust Hazard Study recommendations as the framework of the bill. Currently OSHA is drafting a general industry combustible dust regulation, which also is utilizing the CSB Dust Hazard Study recommendations as guidance.
All the recommendations from the Chemical Safety Board prompting action addressing combustible dust hazards in the industrial workplace is great and long overdue yet many layers of protection have been overlooked in the recommendations. This was especially evident when the data from the Dust Hazard Study only recognizes that 281 incidents occurred from 1980-2005, when in reality the incidents are ten times that many. For example, in 2008, the Combustible Dust Policy Institute discovered through media accounts, there were over 150 incidents in the manufacturing, non-manufacturing, and utility sectors. Probability of occurrence is an important element in obtaining an understanding of the complex issue of combustible dust.
For instance, the OSHA Combustible Dust NEP lists several dozen manufacturing national industries (NAICS) that have the potential or have a high risk in experiencing combustible dust incidents. Yet over 50% of national industries that had combustible dust related fires and explosions in 2008 were not listed as target industries (NAICS). Not to be picking on the paper subsector but to use as an example to illustrate a point, it's national industries (NAICS)are absent from the Dust NEP. On a global perspective amongst our international trading partners, an April 2009 dust explosion at a South African paper printing plant resulted in 14 fatalities and dozen of injuries from burns. This incident highlights that paper dust has a high consequence and potential for combustible dust fires and explosions.
Importance of PPE Understanding probability of occurrence and severity of consequence is only one important aspect in addressing combustible dust hazards in the industrial workplace. Layers of protection are derived from administrative controls and best engineering practices with the final layer, personnel protection equipment (PPE). The Chemical Safety Board overlooked PPE in the recommendations following the key findings of the Imperial Sugar Refinery dust explosion. For instance the April 23, 2008 Chatham Emergency Management Agency, After Action Report mentions that 36 persons were injured and transported to Memorial hospital in Savannah, Ga; 14 of those were non life-threatening injuries. Eventually a total of 20 victims were relocated to the Joseph M. Still Burn Center at Doctors Hospital in Augusta, Georgia with life threatening burn injuries.
Traumatic Burn Injuries In a Burn Care Commentary time-line of the events following the dust explosion, the Joseph M. Still Burn Center highlights that the victims had," thermal burn injuries ranging from 5% Total Body Surface Area (TBSA) damage, treatable onsite and in area Emergency Departments, to 95% TBSA— critical burn damage that in most cases is not survivable." The Combustible Dust Policy Institute believes that if the workers had worn personnel protection equipment in the donning of flame resistant clothing (FRC), the Total Body Surface Area (TBSA) damage would of been less severe. Without FRC once a fireball makes contact with conventional clothing, the clothing ignites causing even more severe burns than the original flame.
A news account of a worker that succumbed to his burns at the Joseph M. Still Burn Center a week following the dust explosion indicated he had third degree burns on more than 80% of his body. Of the 20 workers that were admitted to the burn center, six (30%) did not survive due to the severity of their burn injuries. Malcolm Frazier, 47, of Savannah, a floor manager at the plant, with burns covering 85 percent of his body was the last one to succumb on August 22, 2008. Malcolm fought a brave fight hanging on for over seven months while his parents Richard and Hattie Frazier vigilantly stood by, encouraging him to persevere. Burn Injury Studies Chances of survival after life threatening burn injuries diminish rapidly in accordance with one's age group. In a 1991-1993 study conducted by the American Burn Association, results indicated Total Body Surface Area (TBSA) damage is a key survival factor for burn victims based on the age of the victim. For instance chances in survival of a victim in the 40-49 age group with over 75% TBSA is 30% versus 60% survivability for the 20-29 age group
Lawrence Manker Jr, 20, in the latter group was the last Imperial Sugar burn patient to be released from the burn center in October 2008. Lawrence, like Malcolm had burns to over 85% of his body. To assist the healing process, doctors medically induced him into a coma for six months so they could treat the severe burns. Studies have shown that burns to over 75% of the body can occur easily from the ignition and continued burning of conventional clothing versus workers that don FRC, which do not continue to burn when exposed to a flame source.
Flame Resistant Clothing in Industry Workers in industries such as the petroleum, petrochemical, and chemical sectors where flash fire hazards also are present, already are donning flame resistant clothing in adherence with the requirements of proper personnel protection equipment. There is a disconnect in the USA where many governmental agencies, legislative officials, trade associations, professional organizations, and numerous other stakeholders are not aware that a dust explosion is a propagating explosion like a vapor cloud explosion which occurred at the BP Texas City Refinery in 2005. Both explosions have the devastating effects of overpressure, thermal radiation, and ensuing projectiles.
Reviewing the OSHA NEP's for combustible dust and Process Hazard Management (PSM), OSHA management recommends that CHSO's (inspectors) wear flame resistant clothing when conducting inspections at facilities where flash fire hazards are present. Ironically after over 55% of the victims from the Imperial Sugar explosion sustained life threatening burn injuries that were admitted to the Joseph M. Still Burn Center, the Chemical Safety Board does not include a sixth recommendation that flame resistant clothing be worn in potentially combustible dust explosive environments.
Conclusion The only reason I can think that this recommendation was not included was due to the current litigation with millions of dollars at stake in potential compensation of all the burn victim survivors and families of the deceased. CSB must maintain neutrality and maintain impartiality in not placing blame. Including this important yet vital recommendation would of enhanced the plaintiffs case and been a damaging blow to the defendants. In all fairness, Imperial Sugar Refinery employees are now wearing FRC's in addtion to state of the art best engineering practices that CEO John Sheptor has implemented in the reconstruction efforts since the February 7, 2008 explosion.
An OSHA combustible dust standard is long overdue for general industry. In the past six years there's only been a handful of dedicated career governmental employees and legislators directing this much needed occupational health and safety policy. Last Thursday at the Hilton Savannah Desoto on East Liberty Street was a monumental and historical event where the CSB provided much needed recommendations to Imperial Sugar and the entire industry.
These recommendations will validate OSHA's current combustible dust rulemaking process. But that is where the problem arises, especially when all layers of protections are lacking, but must be considered in preventing future fatalities, severe injuries, and devastating economic damage. Personnel protection equipment in FRC's is just as important as housekeeping, training , emergency response, and NFPA best engineering practices. We owe it to Imperial Sugar Refinery explosion victims, survivors and families to get it right in the combustible dust rulemaking process so as to prevent and minimize future catastrophic occurrences.
UPDATE 9/25/09-OSHA combustible dust regulation submitted to OMB for Review. On the fast track now following CSB Imperial Sugar Recommendations http://ow.ly/rkV8 Thanks Larry, for sharing
Last month's fire that raged through the Paarl Print Factory in Paarl, South Africa that killed a 13 workers and seriously injured many more was reminiscent of fatalities and injuries that occur in the manufacturing sector here in the USA.
A press release issued by the Chemical, Energy, Paper, Printing, Wood and Allied Workers' Union (CEPPWAWU) spokesperson, Cedric Maluleke stated, "preliminary finding that the initial small fire in the cafeteria was propagated through the building by an ensuing dust explosion. This was fueled by paper dust that had accumulated on the open rafters of the building and which had been raised into the air by the shockwave."
The above description is a textbook example of a deflagration where the pressure wave moves at the speed of sound (768 mph) and a devastating fireball following shortly thereafter. Hopefully we can learn from our global trading partners in minimizing the severity and probability of future combustible dust incidents. Currently the OSHA Dust NEP has failed to list paper industries, like the above example, as a combustible dust hazard in the Appendix of the Dust NEP.
This is quite troubling especially when reviewing the Prerule abstract for the combustible dust rulemaking that the Dust NEP will be the foundation for the rulemaking process. Scary stuff. So who is the wizard behind the curtain at OSHA deciding which national industry (NAICS) has a combustible dust hazard or not? Over 50% of combustible dust incidents last year occurred in national industry's not listed in the Dust NEP.
Without acknowledgment that incidents are occuring in national industries not listed in the Dust NEP, stakeholders are unprepared in dealing with the hazards. The problem is intensified when OSHA Susan Harwood Grant Awardees of Combustible Dust Training also use the Dust NEP as the foundation for their training programs, which omits industries at high risk and types of materials (Did you Know?) that can create combustible dust hazards. Will it take an incident as catastrophic as the South African Paarl Print Factory for the wizard behind the curtain to wake up?
The USA is not the only stakeholder that is at loss with reality through lack of information. Especially when reading the press release from our South African trading partners that,"Dust explosions in industry are relatively rare. They are most often encountered in the coal mining industry and in the grain-handling and processing industries. Coal dust, grain dust and paper dust are inflammable and, when raised into the air, can explode."
So dust explosions are rare and most often only encounteredin coal mining industry and in the grain-handling and processing industries ? I wish that were the case, but last year there were over 30 combustible dust related explosions in the manufacturing and non-manufactruing sectors here in the USA according to media reports. Lessons learnedfrom the tragic incident in South Africa and incidents here on our own shore is that before any rulemaking process can proceed in a manner that protects the workplace is to have an understanding of the the probability and severity of combustible dust related fires and explosions throughout the manufacturing, non-manufacturing and utility sectors.
The current Dust NEP formulated through the Chemical Safety Board recommendations is a start but stakeholders throughout industry still have a long way to go in order to protect the workplace from future fatalities and injuries when dust deflagrations occur.
The Combustible Dust Policy Institute found through researching media accounts in 2008 that over 150+ combustible dust related fires and explosions occurred in the manufacturing, non-manufacturing and utility sectors in the United States. Over 30% of these incidents are repeats of prior fires and explosions that fire departments are responding to. Subsequently, these reoccurring incidents mostly go unnoticed by OSHA, unless there are at least three injuries or one fatality.
The current OSHA Combustible Dust National Emphasis Program (NEP) directive does not address the majority of national industries (NAICS) where incidents are frequently occurring. For example, over 60% of incidents in 2008 occurred in national industries not listed in Appendix D-1 and D-2 of the NEP.Too much emphasis and resources is being directed toward the OSHA Dust NEP, when the majority of incidents are occurring in national industries not referenced in the NEP.
To further complicate the situation, the Chemical Safety Board Combustible Dust Hazard Study did not include in the profile of affected industries, the Paper, Textile, and Non-Manufacturing subsectors as industries where a combustible dust hazard exists. For example, in 2008, over 22% of incidents occurred in these subsectors. Without this important information, OSHA did not include paper national industries in the NEP. Over 10% of combustible dust related incidents in 2008 occurred in paper national industries.
In contrast, over 7% of incidents in 2008 occurred in the rubber/plastics subsector, where these national industries were referenced 90% of the time in the OSHA Dust NEP. A NAICS listing in the NEP does not guarantee the probability of occurrence will be lessened. For instance, the national industry NAICS: 326150/Urethane and Other Foam Product Manufacturing, the U.S Census Bureau lists over 433 firms in the USA.In 2008, OSHA inspected 9% (37) of these facilities with only three inspected for an emphasis on combustible dust.
For 2008, media accounts of combustible dust related fires and explosions occurred in thirty-six states. The states with 10 more or more incidents included Ohio (12), Illinois (10), Maine (10), Pennsylvania (10), and Iowa (10). Injuries occurred in 12% of the incidents. Of the total incidents reported by the media in 2008, 20% were combustible dust explosions.
Reviewing the the grain sector, through media accounts, over 50 combustible dust related fires and explosions occurred in 2008 with over 30% (15) were dust explosions. The adverse economic impact from dust explosions in this sector was much greater than the economic impact from explosions in the manufacturing sector. A question does arise if it makes good sense to model the current pending combustible dust legislation after the OSHA Grain Facility Standard, when so many injuries and economic damage is occurring from dust explosions similar to what’s happening in the manufacturing sector?
This brief overview of combustible dust related incidents in 2008 will hopefully provide all stakeholders additional insight into the complexity of combustible dust hazards in the workplace. The current occupational health and safety regulatory framework does not currently address the magnitude of the problem that encompasses all the national industries where incidents are repeatedly occurring throughout the manufacturing and non-manufacturing sector.
A process safety management (PSM) oriented program that addresses combustible dust hazards in the manufacturing, non-manufacturing, and utility sectors needs to be implemented as it is in the chemical and refinery sectors. The main problem, is a disconnect concerning wood, food, paper, textiles, etc. process streams as not being considered like the 136 highly hazardous chemicals (HHC) as outlined in OSHA's Process Safety Management regulation (29 CFR 1910.119).
OSHA National Emphasis Programs (NEP) Last year, the OSHA Combustible Dust National Emphasis Program (NEP) became effective four months after the Petroleum Refinery Process Safety Management (PSM) National Emphasis Program (NEP). There is a vast difference in the two OSHA NEP's with the goal of protecting the nations workforce and outlying communities from the harmful effects of industrial fires, explosions, and toxic releases.
In reviewing the background information for the Refinery PSM NEP, its disturbing when comparing and contrasting fatalities and catastrophes(FAT/CAT) between refineries and facilities that handle combustible particulate solids that generates combustible dust. For instance, on pg. 4 the Refinery NEP states:
"According to OSHA’s IMIS database, since May 1992, 36 fatality/catastrophe (FAT/CAT) incidents related to HHC releases in the refining industry have occurred. These incidents included 52 employee deaths and 250 employee injuries, 98 of these injuries required hospitalization."
Fatalities and Catastrophes (FAT/CAT) Over the same fifteen year period, according to the results of the Chemical Safety Board Dust Hazard Investigation, there were over 95 fatalities and hundreds of injuries as the result of over 160 combustible dust related fires and explosions in the manufacturing, non-manufacturing , and utility sectors. Basically there are three times as many fatalities and catastrophes (FAT/CAT) in sectors that generate combustible dust than in the refinery sector.
Yet Recognized And Generally AcceptedGoodEngineering Practices (RAGAGEP) and administrative control measures to protect the manufacturing workplace are dismally lacking. So is the rapidly diminishing manufacturing sector that provides a base for our national economic security even worth protecting? It doesn't seem so with the obvious inattention thats been misdirected elsewhere, to supposedly more urgent aspects of workplace occupational health and safety.
Highly Hazardous Chemicals (HHC) Combustible dusts have similar explosion severity (Pmax, Kst) effects as flammable liquids, gases, and vapors concerning destructive overpressure, thermal radiation, and ensuing projectiles. Facilities that maintain processes with over 10,000 pounds of flammable liquids and gases must consider these products as highly hazardous chemicals (HHC) as outlined in the OSHA's Process Safety Management regulation (29 CFR 1910.119). So if combustible dusts have similar devastating explosive effects causing fatalities and catastrophes (FAT/CAT) like flammable liquids and gases, why aren't they listed as a highly hazardous chemicals(HHC)?
Wood, food, textiles, paper and many other seemingly harmless materials in manufacturing process streams are not considered toxic, reactive, or corrosive like the over 130 highly hazardous chemicals (1910.119 App A)under the Process Safety Management program. It's their combustible and explosive characteristics that need to be addressed as it is for flammable liquids and gases HHC (highly hazardous chemicals) in the OSHA PSM standards.
Recognizing the hazards of combustible dust is the first step through a process hazard analysis which is the foundation in lessening the occurrence and reducing the severity of future combustible dust related fires and explosions. Once the hazards are identified and evaluated control measures can be implemented in similar fashion as outlined in the OSHA Process Safety Management program. A few of the measures in the current PSM with debatable input to a possible Combustible Dust PSM include:
Operating Procedures For instance, the implementation written operating procedures addressing operating limits with consequences of deviation with steps to follow to correct deviations such as high operating temperatures. These operating procedures must include safety and health considerations concerning quality control for raw materials and control of dust emissions. Additionally, precautions necessary to prevent combustible dust related fires and explosions, which also includes engineering controls, administrative controls, and personal protective equipment.
Contractor Participation A process safety management program would also require contractor participlation. Over the past year a large percentage of combustible dust related fires have involved contractors conducting hot work adjacent to process equipment. A Combustible Dust PSM would properly and proactively inform contract employers of the known potential combustible dust fire, explosion hazards related to the contractor’s work and the process. This would lessen the occurrence of future incidents.
Mechanical Integrity (MI) Mechanical integrity (MI) issues in a Combustible Dust PSM, would address the potential ignition sources that cause combustible dust related fires and explosions at facilities. For instance duct work, dust collectors, dryers, mixers, blenders, ovens, bulk storage enclosures are reoccurring problem areas concerning combustible dust related fires and explosions.
The refinery sector Mechanical Integrity PSM program addresses pressure vessels and storage tanks, piping, relief and vent systems and devices, and emergency shutdown systems controls. In contrast the manufacturing sector has bulk storage enclosures (silos, bins), pneumatic conveying duct systems, air material separators (dust collectors), in addition to relief and venting with explosion ventilation panels in reducing the severity of dust explosions.
Implementing written procedures to maintain the integrity of the above process equipment would provide employees with an overview of the mechanical integrity process and the combustible dust hazards that have been identified in a prior process hazard analysis. Process equipment inspection, maintenance, and testing would also be a vital aspect in the MI at the facility where deficiencies can be addressed in a proactive manner.
Incident Investigation Reoccurring incidents of combustible dust related fires and explosions have been a common theme in the manufacturing sector over the past year. This year, over 30% of incidents are repeats of prior fires and explosions at facilities. In many instance a combustible dust fire is a precursor to a a rare event, the combustible dust explosion.
Without proper incident investigation by the facility, the exact cause of the fire goes unnoticed and the combustilbe dust hazard remains present for the next preventable and predictable incident. A Combustible Dust PSM would identify the chain of events and causes where corrective measures such asRecognized And Generally AcceptedGoodEngineering Practices (RAGAGEP) can be developed and appropriately implemented.
Conclusion: Do I feel lucky? The above examples are just a few proactive measures that could be crucial aspects of a Combustible Dust PSM that is similar to the current PSM utilized for facilities which process highly hazardous chemicals (HHC). Other measures in the PSM include Hot Work Permits, Emergency Planning and Response, Management of Change, and Compliance Audits. Many of the areas are already covered in the National Fire Protections Association (NFPA) combustible dust standards.
Until combustible dusts are recognized as having similar explosive severity characteristics as flammable liquids and gases (highly hazardous chemicals) of the current OSHA PSM, preventable and predictable combustible dust related fires and explosions will continue to occur. Hopefully on a bit of borrowed time the next rare event will not be in the magnitude of the recent Imperial Sugar Refinery dust explosion. Like in the 1971 Dirty Harry movie, Detective Inspector Harry Callahan played by Clint Eastwood asks, "You've got to ask yourself one question: 'Do I feel lucky?"
The recent grain elevator explosion in Louisiana last week brought back stark memories of over three decades ago, in 1977, when a series of similar dust explosions occurred in grain elevators throughout the south, which resulted in dozens of workplace fatalities. Fortunately in the recent explosion no injuries or fatalities were reported, just a lot of frayed nerves from nearby residents with electrical service briefly interrupted along the Mississippi River.
30 Combustible Dust Explosions Over the past year, through media accounts, 30 combustible dust related explosions have occurred in the wood, food, chemical, metal, plastic, rubber, utility, and paper manufacturing sectors. On the western bank of the meandering Savannah River, workers weren't so lucky in escaping injuries or fatalities on the evening of February 7, 2008 when a catastrophic Imperial Sugar Refinery dust explosion occurred in Port Wentworth, Georgia. Subsequently, national media coverage created a much needed awareness concerning combustible dust hazards in the workplace.
Additionally, intense outrage amongst Democratic Congressional leaders responded with an emotionally drafted general industry combustible dust bill, which passed in the House, and now awaiting vote in the Senate. Results of the presidential election, with a potential shake-up of public policy concerning workplace health and safety will determine the future of the bill.
118+ Fires and Explosions Unfortunately this year, the Imperial Sugar dust explosion was not an isolated incident. For instance over the past year, through media accounts, 118+ combustible dust related fires and explosions have occurred in the manufacturing, utility, and non-manufacturing sectors.
Trying to make sense of it all and why even dust explodes is an exercise in science combined with business and public policy across the vast ocean of the public and private sectors. The on-going tug of war between the interests of big business and labor complicates the matter even further in arriving at a cost effective solution in preventing future fatalities, injuries, and adverse economic damage.
Cursory Solution : Incomplete Data Of major concern is how can public policy be created in Congress with ensuing OSHA health and safety regulation's if the extent of the problem is not completely evaluated? Costly governmental studies were completed, which resulted in federal directives that only provide a cursory solution to the combustible dust problem. In the meantime our nation's infrastructure in the manufacturing base is at threat from continuing preventable combustible dust related fires and explosions.
For instance the OSHA Combustible Dust National Emphasis (NEP) program is not even required in nearly half of the states with State OSHA Plans (strictly voluntary). That's only the tip of the iceberg, especially over the past year, where explosions and fires are occurring at facilities with dozens of NAICS not listed in the NEP.
Food Manufacturing Reviewing the food sector, six out of the seven combustible dust explosions occurred in national food industries (NAICS) not listed in the NEP. With explosions occurring more than once at dehydrated food and evaporated diary product manufacturing plants. This is where a ComDust Hazard Alert goes out next, especially when these industries are not on the NEP radar. OSHA inspectors are actively inspecting these facilities as the following excerpt from a recent General Duty Clause (GDC) citation at a dehydrated food manufacturing plant in Wisconsin will illustrate:
"...The following C.O.W (cream of wheat) equipment did not have explosion/deflagration containment, suppression, inserting, or venting protection: a) Cooker room dust collector, approximately 375 cubic feet, was located inside the building lacking explosion venting. b) silo did not have explosion venting. d) pneumatic conveyor did not have spark detectors or propagation shut off devices to prevent explosion propagating forward or aft. "AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD..."
Overall, out of the 17 combustible dust related fires and explosion in the food sector, over 70% happened at facilities not listed in the OSHA Dust NEP. Are we seeing a trend here?
Paper Product Manufacturing A glance at the paper manufacturing sector which includes 16 national paper industries (NAICS), not one is listed in the OSHA Dust NEP. So how many explosions and fires this year? How about 11 fires and explosions, which included two dust explosions. It's like a snowball rolling down the hill as the plot gets bigger and bigger with four paper mill combustible dust related fires, three sanitary paper product manufacturing fires, and two combustible dust fires at corrugated solid and fiber box manufacturing plants.
Plastics/Rubber Product Manufacturing In all fairness the plastics and rubber manufacturing sector is well covered in the NEP. For example, seven combustible dust fires and explosions occurred this year which includes three explosions. There does need to be a reevaluation of whether these national plastic/rubber industries have a potential /D-2 or more frequent/D-1 history of combustible dust fires/explosions as outlined in appendix D-1 and D-2 of the NEP. All these explosions occurred in NAICS that were referenced in D-2 (potential for an incident). If incidents are reoccurring with explosions then wouldn't that move them from a potential/D-2 to a frequent/D-1 in the Appendix?
Conclusion Other sectors in wood, chemical, textile, machinery and metal national industries have their share of explosions and fires as depicted in the chart for incidents in 2008. Stakeholders with financial interests in all these manufacturing and non-manufacturing sectors must understand that the OSHA Combustible Dust NEP is solely a directive which provides guidelines for OSHA inspectors in conducting enforcement and inspection actions at facilities.
It should not be used as guidance in preventing and mitigating future incidents, while misinterpreting that since your facility is not a listed NAICS in the NEP, you are out of danger from the hazards of combustible dust. Over 50% of the combustible dust explosions this year were at facilities with NAICS (national industries) not listed in the NEP. Don't be a statistic. As soon as possible initiate a process hazard analysis which identifies, evaluates, and controls the inherent combustible dust hazards at your facility.
For additional information if your national industry has a history of potential or high occurrence of combustible dust related fires/explosions contact John Astad at the Combustible Dust Policy Institute.
After seven months collecting data of over 90+ combustible dust related explosions and fires from media accounts, the questions arises if any trends are developing throughout the nation in the manufacturing sector? The most glaring trend is State OSHA participation of combustible dust inspections and enforcement is minimal.
Explosions are happening in nearly 20% of incidents and repeatable incidents over 30% . The dust collector is involved in over 40% of events, either from a spark traveling downstream through the duct work or ignition originating locally in the air material separator.
General Duty Clause Reviewing over 4,500 OSHA inspection reports on the IMIS Database that CSHO's have completed in the last twelve months and comparing with all the NAICS in Appendix D-1/D-2 of the OSHA Combustible Dust National Emphasis Program (NEP) Directive, resulted in 24 combustible dust General Duty Clause citations.
None of the GDC combustible dust citations occurred in a locale with a State OSHA Plan. According to the OSHA Combustible Dust NEP, it's strictly voluntary for these states to conduct targeted NAICS inspections and enforcement for combustible dust violations as outlined in the NEP. This presents a huge problem and a distorted picture of actions concerning federal OSHA offices in conjunction with the overall Combustible Dust NEP program.
North Carolina leads the OSHA State Plans in conducting inspections with an emphasis on combustible dust at manufacturing facilities throughout the state. In contrast, CHSO's from Pennsylvania federal OSHA offices lead the nation issuing General Duty Clause citations for combustible dust.
Prior Dust Inspections Additionally, the media and congressional leaders have absorbed the political spin of an independent governmental investigative agency that submitted recommendations to OSHA in 2006. An emotional knee jerk reaction to the recent Imperial Sugar Refinery dust explosion and prior catastrophic dust explosions in 2003 in conjunction with the CSB recommendations resulted in drafting a combustible dust bill that now awaits a vote in the Senate.
After several congressional hearings on combustible dust, the word out on the street is that OSHA is not doing it's job in enforcement and inspection activities concerning combustible dust. How can this be, especially when Federal OSHA offices have been citing facilities on combustible dust violations for many years prior to the Imperial Sugar Refinery explosion?
Two OSHA's In contrast, according to media accounts, over 50% of combustible dust explosions in the last seven months have occurred in states with State OSHA Plans, where an organized proactive Combustible Dust NEP is absent. Basically, there are two different and totally separate OSHA's nationwide, which is divided amongst Federal and State offices. Collecting data of recent combustible dust incidents reinforces the fact of two separate OSHA entities.
Collective Cooperation A comprehensive combustible dust regulation will not solve the problem of preventable combustible dust related explosions and fires. It's only through the combined efforts of State and Federal OSHA offices in conjunction with local fire inspectors where the complex combustible dust issue can be addressed properly.
OSHA does not have the personnel and financial resources to inspect more than 10% of manufacturing facilities in the nation. What about the other 90% ? Cooperation with state and local Authorities Having Jurisdiction (AHJ) is the direction all stakeholders should be championing in developing a proactive comprehensive combustible dust plan. Not a comprehensive combustible dust regulation with the absent financial backing.
Costly Dust Testing Incident data illustrating State OSHA Plan inactivity does not truly represent the entire situation. For example, additional funding is needed for combustible dust testing in manufacturing facilities, which would enhance State OSHA inspection and enforcement activity. Laboratory testing at the OSHA Salt Lake Technical Center for ignition sensitivity and explosion severity is very expensive, costing thousands of dollars.
Why wasn't this crucial aspect of the combustible dust bill discussed during the several congressional hearings? Who is going to pay ? It all looks good on paper and makes one feel warm and fuzzy but the reality begins to sink in when viewing the data of what actually is occuring.
The information in http://dustexplosions.blogspot.com/ is not meant to be a substitute for the Code of Federal Regulations (CFR), Federal Register, and other OSHA documents, which should serve as the primary source of regulatory guidance. The information on this site should not be used in place of appropriate technical or legal advice related to your company's specific circumstances. Combustible Dust Policy Institute tries to provide quality information, but we make no claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained in or linked to this web site and its associated sites. Combustible Dust Policy Institute has no liability arising from or relating to the use, interpretation, or application of the information or its accuracy or inaccuracy. Copyright notice: All materials in this site are copyrighted by the Combustible Dust Policy Institute. No materials may be directly or indirectly published, posted to Internet and intranet distribution channels, broadcast, rewritten for broadcast or publication or redistributed in any medium without permission.
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