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Showing posts with label NFIRS. Show all posts
Showing posts with label NFIRS. Show all posts

Friday, April 12, 2013

Fact Sheet: 2011 Combustible Dust Related Incidents, NFIRS Analysis


Fact Sheet: 2011 Combustible Dust Related Incidents, NFIRS Analysis from Combustible Dust Policy Institute



A Combustible Dust Policy Institute (CDPI) preliminary analysis of 2011 National Fire Incident Reporting System (NFIRS) incident data provided by the National Fire Data Center of the U.S. Fire Administration indicated over 500 combustible dust related incidents in manufacturing facilities where dust was the item first ignited. Near misses include incidents that did not result in any harm to personnel, the facility, process, or product. Analysis did not include the grain sector or coal-fired energy plants.

Additionally, the CDPI analysis does not include many incidents that were not reported by fire departments to the National Fire Data Center. As a result there are many more combustible dust related incidents that cannot be evaluated in determining whether the incident was a near miss or not. 

Special thanks to the nation's Fire Departments, NFIC State Program Managers, and the National Fire Data Center at the U.S. Fire Administration in sharing this valuable Information.  

Casual Pathways Between Near Misses and Catastrophic Events 
Excellent article by Carsten Busch from Norway, highlighting Common Cause Hypothesis (CCH) which also pertains to near misses and catastrophic combustible dust related incidents. In the current OSHA ComDust rulemaking process and recently reintroduced proposed combustible dust bill H.R. 691, incidents resulting in property/content loss (30% NFIRS analysis) yet no casualties (approximately 95%) are considered near misses. Yet the casual pathways (ignition sources, dust management strategies, etc.) for the consequences of all combustible dust related incidents are all the same. 

The true definition of a "near miss" is an incident not resulting in any harm to personnel, the facility, process, or product. So why are near misses ignored in accounting for combustible dust related fire and explosion hazards in protection of the workplace in the OSHA ComDust rulemaking process and recently reintroduced proposed combustible dust bill H.R. 691?

Report on preliminary findings of a study of incident reporting systems for near misses in non­medical domains. This can also apply to combustible dust related incidents/accidents where NFIRS data provides a multitude of information in developing barriers for the prevention of future accidents.

Near Misses in Non­-medical Domains
"Consequently, the same patterns of causes of failure and their relations precede both adverse events and near misses." Sounds familiar with ComDust related incidents at facilities whether it was flash fire, dust explosion, or layer fire? They all have casual pathways of improperly managed ignition sources and fuel sources. A written fire prevention plan (FPP) addresses these casual pathways initially at the organizational level. The next step would be implementation at the technical and operational level.

"We defined a near miss as any event that could have had adverse consequences but did not and was indistinguishable from fully fledged adverse events in all but outcome." Note: National Fire Incident Reporting System (NFIRS) was not included in the report of near misses in non­medical domains. 

U.S. Chemical Safety Board (CSB): Near Misses.
Dust Explosion Hazard Awareness / Imperial Sugar Management and Workers
(Page 54 .pdf) "The CSB concluded that the small events and “near-misses” caused company management, and the managers and workers at both the Port Wentworth, Georgia, and Gramercy, Louisiana, facilities to lose sight of the ongoing and significant hazards posed by accumulated sugar dust in the packing buildings."

CSB Key Findings: Imperial Sugar Refinery
Page 48 .pdf)  # 4 "Company management and the managers and workers at both the Port Wentworth, Georgia, and Gramercy, Louisiana, refineries did not recognize the significant hazard posed by sugar dust, despite the continuing history of “near-misses’”

Hoeganaes
(Page 14 ,pdf) "Operators and mechanics reported being involved in multiple flash fires during their employment at the Gallatin facility. At the time of the incidents, many were aware that the iron dust could burn or smolder. However, they were not trained to understand the potentially severe hazard when accumulated dust is dispersed in air. Rarely would operators report the minor flash fires and “near-misses” that periodically occurred."

(page 27 .pdf) CSB Recommendations to Hoeganaes 2011-4-I-TN-R9
"Develop and implement a “near-miss” reporting and investigation policy that includes the following at a minimum:"
• Ensure facility-wide worker participation in reporting all near-miss events and operational disruptions (such as significant iron powder accumulations, smoldering fires, or unsafe conditions or practices) that could result in worker injury.

• Ensure that the near-miss reporting program requires prompt investigations, as appropriate, and that results are promptly circulated throughout the Hoeganaes Corp.

• Establish roles and responsibilities for the management, execution, and resolution of all recommendations from near-miss investigations

• Ensure the near-miss program is operational at all times (e.g. nights, weekends, holiday shifts).  

Conclusion 
Near misses can no longer be ignored. It's very distressing that OSHA in the combustible dust rulemaking process in conjunction with the legislators in the reintroduction of the proposed combustible dust bill H.R. 691 have chosen to ignore 95% of combustible dust related incidents in manufacturing facilities, which do not result in personnel casualties. Yet these very same incidents, as history illustrates are precursors to catastrophe. 

 

Thursday, March 28, 2013

California Lower Rate of Combustible Dust Related Incidents Due to FPP?


How come California with more manufacturing facilities than any other state (approx. 40,000 establishments-U.S. Census Bureau-2010) yet has a lower rate of combustible dust related incidents than any other state? Could it be that they require fire prevention plans (FPP) for all facilities whereas other states don't? Shouldn't a state with the highest number of facilities also have the highest number of incidents? Quite interesting accidentally connecting the dots between combustible dust related incidents in a preliminary analysis of 2011 NFIRS data and fire prevention plans (FPP) 29 CFR 1910.39.

It’s back to school for us all after coming across this helpful resource with the University of California Riverside's Fire Prevention Plan (FPP) providing an excellent framework with FPP key elements as required by the California Code of Regulations (CCR) Title 8, Section 3221. The detailed FPP document includes a section on Fire Extinguishers where "all faculty and staff are annually provided the opportunity to receive hands-on training and experience in using portable fire extinguishers."

California is one of the approved State Plan States that went beyond minimum federal OSHA regulatory requirements concerning FPP's (Exemptions. 1910.157(b)(1))  For example, California facilities not requiring the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal are required to have a Fire Prevention Plan (CCR Title 8, Section 3221).

Whereas Federal OSHA states don’t require a Fire Prevention Plan (FPP) in this scenario unless the facility follows under one of these three host standards: Ethylene Oxide, 1910.104, Methylenedianiline, 1910.1050, and 1,3 Butadiene, 1910.105. Additionally FPP required where the written fire safety policy requiring the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal.

With a bit of imagination the University of California Riverside's Fire Prevention Plan (FPP) provides an excellent framework for a voluntary FPP’s which should include controlling ignition and fuel sources in the prevention of combustible dust fires and explosions. The U.S. Chemical Safety Board (CSB) did not make any FPP recommendations in the 2006 Dust Hazard Study. As a result OSHA has not recognized FPP in the 2008 Combustible Dust National Emphasis Program (NEP), 2009 Combustible Dust Advanced Notice of Proposed Rulemaking, 2011 OSHA Combustible Dust Expert Forum, nor on the OSHA Combustible Dust Hazards webpage. The Democrat Committee Education and the Workforce has acknowledged this error with the reintroduction of the proposed bill, "H.R. 691 Worker Protection Against Combustible Dust Explosions and Fires in the Workplace," where 40% of the requirements in the bill are from content in the OSHA Fire Prevention Plan (FPP) 29 CFR 1910.39.

Fire prevention plans (FPP) are an excellent administrative and procedural control measure in minimizing the probability of occurrence of future combustible dust related incidents by managing and controlling potential ignition and fuel sources. Without FPP's  combustible dust related incidents will continue to occur in an unabated manner. The majority of combustible dust related incidents are "near misses" precursors to catastrophe. As a result combustible dust hazards are primarily a fire issue and secondarily a potential explosion problem.

Wednesday, January 30, 2013

2011 Geographic Distribution Combustible Dust Related Incidents



Wisconsin
50
Ohio
40
North Carolina
30
Virginia
29
California
26
Georgia
24
Minnesota
22
Texas
22
Illinois
20


The Combustible Dust Policy Institute (CDPI) researched over 500 combustible dust related fires and explosions in manufacturing facilities utilizing 2011 National Fire Incident Reporting System (NFIRS) data provided by the U.S. Fire Administration's National Fire Data Center. All 50 states report NFIRS data with approximately 23,000 fire departments out of over 30,000 fire departments in the USA reporting NFIRS data each year which consists of about 75 percent of all fires occurring annually.

2011 NFIRS data  indicated combustible dust related fires and explosions occurring in 40 out of 50 states with nine states reporting over twenty incidents as indicated by the table above. Since NFIRS is a voluntary program not all fire departments in the USA report incidents where property damage occurred. Content loss is also noted in NFIRS data in addition to property loss.

"NFIRS distinguishes between “content” and “property” loss. Content loss includes loss to the contents of a structure due to damage by fire, smoke, water, and overhaul. Property loss includes losses to the structure itself or to the property itself. Total loss is the sum of the content loss and the property loss."

In the vast majority of over 500 incidents in 2011 no fatalities, injuries, nor property damage occurred, which is similar to the results of a confined structure fires defined by the U.S. Fire Administration. In contrast, two workplace fatalities and fourteen injuries occurred in nine states. Additionally, ten fire-fighters sustained injuries while responding to combustible dust related fires. The 2011 NFIRS injury and fatality data conflicts with the 2006 CSB Combustible Dust Hazard Study for the 1980-2005 time frame, where it was noted, "injuries and fatalities occurred in 71 percent of the incidents." In 2011, property damage occurred in 30 percent of incidents with damage of less than $5,000 in 56 percent of  incidents.

Combustible dust related incidents occurred in 20 of the 21 manufacturing subsectors in 2011. The food and chemical manufacturing subsectors experienced a total of nine incidents ( two food, seven chemical). In a following post additional information will be provided on a profile of affected industries and types of combustible dust involved in combustible dust related incidents during 2011.

Special thanks to the dedication and hard work of the local fire departments, state program managers, and staff at the National Fire Data Center at the U.S. Fire Administration in providing NFIRS data to end-users, "Fighting Fire with Facts." Without their continued efforts in identifying combustible dust related incidents, sharing this valuable information would not be possible.

Saturday, January 12, 2013

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. 

Thursday, November 29, 2012

Over 17,000 combustible dust related fires (1980-2005) USA

NFIRS Data From USFA

Extrapolating NFPA's Fire Analysis and Research Division estimates  from the report "Fires in U.S. Industrial and Manufacturing Facilities," provides in-depth insight into combustible dust related fire statistics in manufacturing facilities from the 2006-2010 period. Subsequently, the Combustible Dust Policy Institute noted over 17,000 combustible dust related fires in the twenty-five year period 1980-2005 while extrapolating the 2006-2010 data. Dust, fiber, or lint (including sawdust) was the item first ignited in 12% of 5,670 manufacturing facility fires/ (2006-2010) annual average. Data from the U.S. Fire Administration’s (USFA) National Fire Incident Reporting System (NFIRS) and the NFPA annual fire department experience survey was utilized in compiling NFPA Fire Analysis and Research Division estimates.

The educational NFPA report provides valuable insight into area of origin, heat source, factors contributing to ignition, and equipment involved in ignition (EII). For example, the leading factor contributing to ignition was mechanical failure or malfunction. Regarding heat sources, the leading factor was unclassified heat from powered equipment followed by radiated or conducted heat from operating equipment.


                                Manufacturing Facility Fires (2006) Source: NFIRS 5.0 USFA

To assist stakeholders in understanding the modules in the NFIRS reporting system here is a list of several elements regarding ignition with their pages from the NFIRS 5.0 Reference Guide. Note: This is a large file (9.7  mb) and may take considerable time to download on slower connections.

Area of Fire Origin 4-13


Heat Source  4-17
Operating Equipment
Hot or Smoldering Object
Other Open Flame or Smoking Materials
Chemical, Natural Heat Sources
Heat Spread From Another Fire. Excludes operating equipment.
            Other Heat Sources
Item First Ignited 4-19
Cause of Ignition 4-24
Factors Contributing to Ignition 4-25
Mechanical Failure, Malfunction
Electrical Failure, Malfunction
Design, Manufacturing, Installation Deficiency
Operational Deficiency
Equipment Involved in Ignition 4-29
Shop Tools and Industrial Equipment

Manufacturing establishments diminished from 373,000 (1990) to 332,000 (2007), a 11% decrease in manufacturing facilities. In a ten year trend of nonresidential fires (1992-2001) there was a 21% decease in fires. (page 119 .pdf)
Nonresidential Fires (1992-2001)
USFA and U.S. Census Bureau statistics depicting decreases in nonresidential fires and manufacturing establishments illustrates a higher number of annual fires in the 25 year period (1980-2005) than in the more recent (2006-2010) time-frame. As a result, the 680 combustible dust related fires annual average (2006-2010) would extrapolate into even more annual incidents from 1980-2005.
U.S. Bureau of Labor Statistics: Manufacturing Establishments (2001-2011)
Very Unusual Trend

U.S. Fire Administration: Fire Estimates. Manufacturing Fires Drop 38% (2007-2010) From 6,200 (2007) to 3,900 (2010), during the same period nonresidential fires drop 18%. U.S. Bureau of Labor Statistics indicated the number of manufacturing establishments dropped 7%. So has incidents of combustible dust related fires and explosions also dropped 38% in the 2007-2010 time frame?

About NFIRS
NFIRS is not representative of all fire incidents in the United States and is not a census of fire incidents or casualties. For example,  NFIRS is a voluntary system, and it includes only those fire incidents reported to the system by fire departments that report to NFIRS. Also, not all States participate in NFIRS, and all fire departments that report to NFIRS within a State do not necessarily report all of their fire incidents. Additionally, some fire departments that report fire incidents do not report associated casualties. States and/or fire departments that report in one particular year may not report to NFIRS the following year.

Partial list of Federal Government organizations (page 12 .pdf) that use NFIRS: U.S. Consumer Product Safety Commission, Military Services (Air Force, Army, Coast Guard, Marines, Navy), U.S. Commerce Department, National Institute on Standards and Technology, Center for Fire, Research, U.S. Department of Transportation, National Highway Traffic Safety Administration, U.S. Congress, House Basic Research Subcommittee, U.S. Public Health Service, Centers for Disease Control and Prevention, U.S. Department of Justice, Federal Bureau of Investigation, U.S. Department of Housing and Urban Development, U.S. Department of Treasury, Bureau of Alcohol, Tobacco, and Firearms, Library of Congress, etc.
  • NFIRS is the world's largest, national, annual database of fire incident information.
  • 50 states and the District of Columbia report NFIRS data.
  • 37 fire departments with a population protected of over 500,000 participate in the NFIRS.
  • About 23,000 fire departments report in the NFIRS each year.
  • The NFIRS database comprises 75 percent of all reported fires that occur annually.

Like many of the above governmental organizations, why didn’t the OSHA Directorates use NFIRS fire incident data when developing the OSHA Combustible Dust ANPRM for the rulemaking process? Only relying on incomplete CSB incident data (281 incidents 1980-2005) does not provide stakeholders enough information so as to understand the complexities and magnitude of the combustible dust fire problem in the USA manufacturing sector. As a result of solely using CSB incident data, the definition of combustible dust is explicitly in “suspension” and ignores layered combustible dust related fires (dust not in suspension). So what do you think, should we continue to ignore combustible dust related fires not in suspension?

Resources:

NFPA's "Fires in U.S. Industrial and Manufacturing Facilities"
NFIRS Reporting Form
Uses of NFIRS
NFIRS 5.0 Reference Guide 
Nonresidential Building Fires (USFA) page 75 Mfg. Buildings
Nonresidential Fire Trend 2006-2010
OSHA Combustible Dust; Advance notice of proposed rulemaking

 

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