Déjà vu Firefighters Killed & Injured in Repeatable Deadly Silo Explosions

Diagram. Aerial view of incident scene after 1997 explosion

Is anyone out there reading these accident reports prepared by the United States Fire Administration (1997) and NIOSH (2003)? Doesn't appear anyone is especially with the multitude of catastrophic incidents mirrored after each other like reruns on the television.

Time is way overdue for firefighting training on the practical aspects of combating combustible dust related fires. We already know about the physicochemical properties of combustible dust with the wealth of literature out there. Now is the time to get down dirty out on the training fire ground.

A real concern is in these two accident reports is continued mention of oxygen-limiting silos. This is incorrect as they were no longer oxygen-limiting silos but instead modified oxygen-limiting silos. Big difference between the two. Adding water to the top of any silo in conjunction with simultaneously opening access doors at the bottom and poking around with smoldering contents is wrought with danger. Do you feel lucky?

U.S. Fire Administration Fire Investigations Program:

The U.S. Fire Administration develops reports on selected major fires throughout the country. The fires usually involve multiple deaths or a large loss of property. But the primary criterion for deciding to do a report is whether it will result in significant “lessons learned.” In some cases these lessons bring to light new knowledge about fire--the effect of building construction or contents, human behavior in fire, etc...

 

Resources:

Industrial Silo Fire and Explosion1997 USFA
NIOSH LODD Report 2004

NIOSH Accident Report Catastrophic Coal Storage Silo Explosion

"Do not use water or traditional fire fighting foam; however, micelle encapsulator fire extinguishing agent, such as F-500, should be used. NFPA 1620, Standard for Pre-Incident Planning can be used to establish a pre-incident plan for silos within their jurisdiction so as to minimize the risk to emergency responders" NIOSH Accident Report 

Coal storage silo after explosion
(NIOSH photo)

Excellent job NIOSH sharing this educational accident report with the public providing valuable seven recommendations This will assist immensely in minimizing the severity of future combustible dust related accidents. CDPI encourages additional items in future recommendations regarding fire service emergency response to combustible dust related incidents throughout the manufacturing and non-manufacturing sectors:

 

Item #1: Fire departments should review, revise and enforce standard operating guidelines (SOGs) for structural fire fighting addressing responding to all combustible dust related incidents.

Item #2 Fire departments should train officers and fire fighters on the hazards associated with different types of processes handling and processing combustible particulate solids (CPS) and the appropriate fire fighting tactics.

Item #3: Fire departments should ensure that pre-emergency planning is completed for all processes handling and processing combustible particulate solids (CPS) within fire department jurisdictions. For example, a topic not yet addressed in NFPA 1620 Chapter 8.4, Special Hazard Considerations –combustible dust.

Item #4: Fire departments should ensure that a separate Incident Safety Officer, independent from the Incident Commander, is appointed at each structure fire and is knowledgeable of combustible dust related fire and explosion hazards.

Item #5: Municipalities should consider requiring that placards with hazard warnings and appropriate fire fighting guidelines be placed on buildings, bulk storage enclosures, air material separators, or other process equipment where the is a danger of a combustible dust deflagrations. Example: Hazard Warning Sign - Danger Explosive atmosphere

It is essential the fire service be acknowledged as a valuable and essential stakeholder in addressing combustible dust related fire and explosion workplace hazards. NIOSH and OSHA must work in a collaborative nature which must welcome the inclusion of the US Fire Administration. 

On the other side of the coin the NIOSH accident report missed the boat when not including all high risk occupancies that handle, manufacture, process, combustible particulate solids. Solely limiting the recommendations to silos ignores the big picture of combustible dust related fire and explosion hazards the fire service is exposed to on a daily basis.

For example, over 70% of the recommendations in this recent NIOSH report were copied and pasted from an earlier accident report " Volunteer Assistant Fire Chief Dies at a 2010 Silo Fire/Explosion - New York" It is this type of future NIOSH recommendation that will finally include the fire service as a vital stakeholder in the current OSHA combustible dust rulemaking process. Do we have to wait for another firefighter fatality to finally get it right?

Examples of prior combustible dust related incidents with firefighter injuries:

Firefighter suffers second-degree burns battling blaze at facility in  Monroe, OH (May 2012)  "While attempting to extinguish the fire, Fire Chief John Centers said “there was a dust explosion” that caused the three injuries.""

Three firefighters injured after fire at Lumber mill  in Gaston August 2011 "Firefighters were mopping up a fire that started in a powerhouse at the  Lumber mill when a pipe exploded on a walkway, injuring them. "

BURNSVILLE, Minn. Explosion at Black Dog powerplant injures firefighters (August 2010)
  "An Xcel spokesperson says the incident started as a smoldering fire in a coal hopper Firefighters were called, and were working the blaze when the explosion occurred around

Surgoinsville,TN firefighter injured in blast a Phipps Bend plant in TN (August 2009) (recycling newspaper to process oil absorbent pads) "a five-year veteran of the department, was standing near a storage bin where firefighters were cleaning up after attempting to extinguish burning fibers which had been ignited by sparks from a grinder, when an unexpected explosion occurred, according to Fire Chief Murlice Carpenter."

Six Stockton, California firefighters slightly hurt in plant explosion (Sept. 2008)  "Five firefighters were just inside the building and one just outside the building on stairs when the explosion occurred. The firefighter on the stairs was the firefighter who suffered the worst of the injuries."

Pella, Iowa (Nov 2005) Two firefighters are recovering today after two explosions company  "As firefighters tried to put out the fire, another explosion took place. " 

Resources: 
NIOSH Fatality Accident Report-fire in coal storage silo 
NIOSH Fire Fighter Fatality Investigation and Prevention Program
Presentation by Tim Merinar & Tom Hales (NIOSH/DSR) entitled "NIOSH Fire Fighter Fatality Investigation and Prevention" at public stakeholder meeting;  [PDF - 11.5 MB]

GAO Report Results: OSHA and NIOSH Need to Work Together

Occupational health and safety should not solely be inspection, enforcement, and rulemaking. Regarding combustible dust workplace fire and explosion hazards, outreach, education, training, and research is essential. All these elements are included in the OSH Act. The enlightening GAO report sheds light on the fact that the OSH Act is not being adhered to. I encourage all EHS professionals to read the OSH Act, Sections 20, 21, 22

Solely relying on a regulation in providing a warm and fuzzy feeling is not the complete solution. A prime example, would be the multitude of grain elevator explosions following the OSHA Grain Facility Standard  So now we have reached a point where X fatalities is not acceptable but Y fatalities is acceptable. OSHA does not have the resources to be everywhere at once. The time has now come in the 21st century where the paradigm must change to shared responsibility engaging all stakeholders.

In contrast,  "Clinical Professor of Environmental and Occupational Health Michael Silverstein claimed that OSHA and NIOSH have been working together for the past 40 years"
Then why  hasn't NIOSH been a primary stakeholder in the OSHA Combustible Dust rulemaking?
Full Committee Hearing - Time Takes Its Toll: Delays in OSHA’s Standard-Setting Process and the Impact on Worker Safety.
 
Maybe this GAO report will open dialogue on establishing and coordinating local, state, and federal standardization, interoperability, compatibility, and responder health and safety to prepare for, train and respond to, mitigate, and recover from any incident by identifying requirements for an all-hazards incident response which includes OSHA, NIOSH, and US Fire Administration?

"The InterAgency Board (IAB) is a voluntary collaborative panel of emergency preparedness and response practitioners from a wide array of professional disciplines that represent all levels of government and the voluntary sector. The IAB provides a structured forum for the exchange of ideas among operational, technical, and support organizations to improve national preparedness and promote interoperability and compatibility among local, state, and federal response communities."

Doesn't catastrophic ComDust related fires and explosions in the workplace warrant federal standardization, interoperability, and compatibility?

GAO Report: WORKPLACE SAFETY AND HEALTH, Multiple Challenges Lengthen OSHA’s Standard Setting.

"Improve coordination with other agencies: Experts and agency officials noted that OSHA has not fully leveraged available expertise at other federal agencies, especially NIOSH, in developing and issuing its standards. OSHA officials said the agency considers NIOSH’s input on an ad hoc basis but OSHA staff do not routinely work closely with NIOSH staff to analyze risks of occupational hazards. "

"However, OSHA can coordinate more routinely with NIOSH on risk assessments and other analyses required to support the need for standards, saving OSHA time and expense. In our report being released today, we recommend that OSHA and NIOSH more consistently collaborate on researching occupational hazards so that OSHA can more effectively leverage NIOSH expertise in its standard-setting process. Both agencies agreed with this recommendation."

This is only the tip of the iceberg of agencies not working together regarding workplace ComDust fire and explosion hazards. For example, OSHA has ignored the US Fire Administration in the ComDust Rulemaking process. When a ComDust related fire goes beyond the incipient stage, who you going to call to extinguish the fire? 

Resources:
Multiple Challenges Lengthen OSHA's Standard Setting (GAO Report)

Legislators, More Regulation is the ComDust Cure

Why is it that legislators seem to think that passing more bills and regulations is the cure all? Problem with the combustible dust issue is that no one in Washington D.C. has all the facts and solely utilizing the Chemical Safety Board's Dust Hazard Study provides a false perception of the enormity and complexity of the issues both social and economical.

"Their bill would tell OSHA to issue - within 90 days - an interim standard. It would require better housekeeping, engineering controls, worker training and a written combustible-dust safety program."
Savannahnow.com-news article

For example, the CSB report states there were 281 ComDust incidents from 1980-2005, or an average of eleven incidents annually. In stark contrast, according to media accounts of ComDust related incidents since 2008 there have on an average 12 incidents a month. This would equate to approximately 4,000 ComDust incidents during the 1980-2005 timeframe.

Not understanding the depth of the issue is only part of the problem. For example FEMA/U.S. Fire Administration's, "National Fire Incident Reporting System 5.0 (NFIRS)" via local fire departments has failed to report and identify process situations, process conditions, and process materials regarding combustible dust related fires, precursors to catastrophic dust explosions.

If the local fire and explosions hazards can't be identified, then how can they be evaluated and controlled? Of course legislators at the national level seem to think legislation and regulation is the answer for a local/regional problem. That is the easy way out in attempting to solve a primarily fire life safety issue and secondarily an occupational safety issue.

The OSH ACT specifically states that to address workplace safety, issues of regulation, education, outreach, and research must be pursued. OSHA with its limited resources cannot do it all.

"by providing for research, information, education, and training in the field of occupational safety and health; and for other purposes."

What happened to NIOSH as the OSH ACT intended in getting involved with outreach/education regarding the combustible dust issue as it had done decades ago concerning coal mine dust explosions, prior to when the U.S Bureau of Mines (USBM) was transferred to NIOSH, Department of Energy (DOE), U.S. Geological Survey, and the Bureau of Land Management in 1995-97.

Let’s all grow up and stop singling out Imperial Sugar explosion as the problem. Currently Imperial Sugar is an industry leader in addressing ComDust fire and explosion hazards. What about the tens of thousands manufacturing facilities that have potential ComDust fire and explosion hazards? So now OSHA as Secretary of Labor states, "there's a new sheriff in town." So what we going to do, fine them all?

Outreach, training, research, and education through NIOSH and US Fire Administration are just a few examples in alternatives to more legislation and regulation. Question is, who has the vision in providing the leadership so all local, state, and federal agencies are working together in these tough economic times.

Resources -OSH Act

• Section 20 - Research and Related Activities
• Section 21 - Training and Employee Education
• Section 22 - National Institute for Occupational Safety and Health

Multi-Agency Approach Combustible Dust Hazard Awareness

Trying to connect all the dots in seeking solutions to combustible dust hazard awareness is a never ending and exciting adventure. During the Christmas/New Years holiday period in-between working the graveyard shift at the refinery I came across the exciting NIOSH National Occupational Research Agenda (NORA), which has been an ongoing project with NIOSH since 1996. I'd like the thank Dr. Sidney C. Soderholm, PhD, /NIOSH/NORA Coordinator for accepting my comments concerning Draft National Manufacturing Agenda NIOSH Docket 184, past the 5:00 p.m., December 15, 2009 deadline. I wonder how many other stakeholders are unaware of the proposed Strategic Goals in the NIOSH National Manufacturing Agenda?

Industrial and Manufacturing Facilities Report
Yesterday David Slaw, a partner with management consulting firm D5 shared the excellent Industrial and Manufacturing Facilities Report Abstract (Oct 09), authored by Jennifer Flynn of NFPA´s Fire Protection Research Foundation. Data in the report was acquired from the U.S. Fire Administration's version 5.0 of the National Fire Incident Reporting System(NFIRS) in addition to the National Fire Protection Association’s (NFPA) annual fire department experience survey. Jennifer did an awesome job in transferring the data into Tables, where readers can easily interpret and assimilate the wealth of information.

The most impressive aspect of the report is that it assists in identifying areas of origin, heat sources, equipment involved, leading causes of structure fires, and item first ignited concerning potential combustible dust related fires. For example, concerning item that first ignited in Table 9: of the 7,330 annual average of incidents from 2003-2006, 10% were dust, fiber, lint, sawdust or excelsior was involved. The new word for the day is excelsior. From the list it is difficult to ascertain whether combustible dust was specifically involved.

In regards to Area of Origin in Table 8: Processing, manufacturing area, or workroom was the leading area of origin for these fires in 15% of the incidences. Furthermore, Table 5 illustrates that the leading causes of structure fires in industrial and manufacturing properties was shop tools and industrial equipment. Unfortunately, an annual average of 30% of civilian deaths and 45% of civilian fire injuries were from these leading causes.

Stakeholders can be extremely proactive concerning their combustible dust ignition control program at their facility after reviewing Table 7: by Heat Source, which assists in providing an idea of probability of occurrence. So do you know the minimum ignition temperature (MIT) of the combustible dust that is generated at your facility? The majority of MSDS's from the raw product manufacturer usually does not have this physical fire property. Might be the time to have your combustible dust tested at a testing facility

* 14% Unclassified heat from powered equipment
* 11% Radiated, conducted heat from operating equipment
* 10% Spark, ember or flame from operating equipment
* 8% Arcing

Following each of the ten tables in the report a "Note" states:
These are national estimates of fires reported to U.S. municipal fire departments and so exclude fires reported only to Federal or state agencies or industrial fire brigades...

Media Accounts-Fires and Explosions
Another excellent source of information concerning combustible dust related fires is from news accounts. This resource is especially helpful for events not captured in NFIRS. For example, in many combustible dust related fires and explosions, volunteer fire departments respond to these incidents. If there are no fatalities and minimal injuries, the incident is not noticed in any formal manner where the probability of occurrence could prove most useful in future risk analysis prevention and mitigation strategies.

A major problem in relying on news accounts is that reporters are not knowledgeable about basic process equipment in a combustible dust related fires or explosion at a manufacturing facility. So the event is solely reported as just another industrial fire with no details of areas of origin, heat sources, equipment involved, or the item that first ignited. NIOSH has addressed this issue in STRATEGIC GOAL 15 – Engage the media more effectively to raise awareness and improve safety and health in construction in the October 2008 NORA National Construction Agenda.

A recent story comes to mind where last month a fire occurred at a Massachusetts facility. The fire chief provided information to the reporter that a large machine, which is approximately 11 feet tall, four feet wide and four feet deep that collects fine metal shavings ignited. So how would this event be captured in any sort of reporting system? Many of the combustible dust related incidents that OSHA and CSB become aware of are through news accounts, not the NFIRS system.

Maybe a possible solution would be for occupational health and safety professionals to submit abstracts for presentations at future media conferences so as to educate reporters on the basics of process equipment that are susceptible and have a history of combustible dust related fires and explosions. That might alleviate reports of a large machine (dust collector) that ignited.

Multi-Agency Approach
It's time now in the 21st century that all stakeholders start thinking outside of the box beyond the traditional systems that we are all accustomed to in regards to occupational safety concerning fire and explosion hazards in the manufacturing sector. A multi-agency approach utilizing information technology can close the gaps between DOL/OSHA, DHHS/NIOSH, and DHS/FEMA/U.S Fire Administration.

A problem with this vision for the future is that the above governmental departments and agencies have their own agendas that do not necessarily dove-tail into each other. With OSHA, we hear in national headlines there is a new sheriff in town with enforcement, inspections, and citations the rule. Yet in stark contrast, NIOSH is proceeding aggressively with their exciting National Sector approach in research, information, education, training, and outreach. Then there is the U.S. Fire Administration with their innovative NFIRS in the middle of the two.

All of the above in three separate cabinets of the Executive Branch of the U.S Government. Attempting to put it all together will be like herding cats at a four day Fourth of July rodeo.

NIOSH and OSHA, Divergent Paths to OSH Act

It's time for OSHA and NIOSH to work together in a comprehensive collaborative effort instead of the divergent manner that has been occurring in the past. The OSH Act 1970 mandated that NIOSH would carry out the policy set forth in Section 2 - Congressional Findings and Purpose of the Act and to perform the functions of the Secretary of Health and Human Services under Section 20 - Research and Related Activities and Section 21 - Training and Employee Education of the Act.

NIOSH has been conducting an excellent job in research, education, and outreach, providing stakeholders in the nation's workplace with their excellent products. The problem is that many of their products cannot be found on the OSHA Safety and Health Topics Pages. Many businesses are not aware of NIOSH, which is federal agency responsible for conducting research and making recommendations for the prevention of work-related injury and illness. NIOSH is part of the Centers for Disease Control and Prevention (CDC) within the U.S. Department of Health and Human Services.

OSHA in addition to conducting enforcement and inspection activities in the workplace also has many excellent occupational health and safety products. In contrast many stakeholders are aware of OSHA activities through citations and their collaborative outreach programs and educational resources available on the OSHA website. The problem with the OSHA and NIOSH educational resources and products is that they are located on two different websites.

For example, viewing OSHA's Safety and Health Topics Pages., one of the first topics in the search drop-down menu is Agricultural Operations There are many excellent links to:

• What standards apply? OSHA Standards | Other Federal

• What are the hazards and possible solutions in agricultural operations?Ergonomics | Noise | Respiratory | Chemicals | Biologicals | More
• How do I evaluate agricultural hazards in the workplace?

• Where can I find safety and health programs in agricultural operations? Research and Education Centers | International Model Programs

• What additional information is available?

In contrast, when comparing the OSHA Safety and Health Topics Pages to the NIOSH Safety and Health Topic Agricultural Page, many subjects that NIOSH has determined are important concerning occupational health and safety cannot be found on the OSHA pages. All the educational resources from NIOSH and OSHA are excellent, but wouldn't it make sense to combine the wealth of information that is currently located on two different website into one location?

Agricultural topics is just one example where the discrepancy arises. What about the dozens of other topics where OSHA provides helpful information on their Topic pages Index in addition to the NIOSH A-Z Index. With the technology on the Internet, an IT manager can combine the two in a seamless easy to use manner. Lets bring the OSH Act back as the Congress intended nearly four decades ago with OSHA and NIOSH working together in unison.

OSHA Combustible Dust Rulemaking Comment Period

Docket ID: OSHA-2009-0023

Agency: OSHA

via regulations.gov

Have you provided comments yet concerning the OSHA Combustible Dust ANPRM? Submit electronically by the January 19, 2010 deadline. Participation by all stakeholders is needed. Still need input from the state and local fire protection service, insurance industry, NIOSH, U.S. Fire Administration, etc.

Enter OSHA-2009-0023 in the Keyword or ID search bar on http://www.regulations.gov Home Page. Or go directly to the Docket Folder.

Posted via web from ComDust