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Showing posts with label National Fire Incident Reporting System. Show all posts
Showing posts with label National Fire Incident Reporting System. 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. 

 

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. 

Tuesday, November 27, 2012

Error in OSHA Combustible Dust; Advance Notice of Proposed Rulemaking

Reviewing the OSHA advance notice of proposed rulemaking (ANPR) creates quite a concern. For example in the second sentence of the "Summary" at the top of the page, "For the purposes of this notice, the term "combustible dust" includes all combustible particulate solids of any size, shape, or chemical composition that could present a fire or deflagration hazard when suspended in air or other oxidizing medium"

So for combustible dust to be hazard it must be suspended in air? What about smoldering layers of dust which also fire and explosion hazards? Before dust can be in suspension it first must be layered on horizontal surfaces. Personnel have been fatally and severely injured from smoldering dust initially not in suspension. Additionally facilities have burned to the ground due to layers of dust.

The problem of OSHA defining combustible dust solely in suspension became readily apparent when trade associations submitted comments in response to the ANPRM requesting their NAICS be removed from "Table 1--Industries Having at Least One Recorded Combustible Dust Incident Reported Since 1980," since combustible dust incidents at facilities they represented were dust layered fires and not in suspension. Was the Dust Incident table (page 43 .pdf) listing severity of consequences (Kst's) instead of NAICS, during a topic of discussion at the 2011 OSHA Combustible Dust Expert Forum a response to the turmoil of defining combustible dust solely in suspension?

There is no mention whatsoever in the OSHA Combustible Dust ANPRM about catastrophic combustible dust related fires as a result of layered dust not in suspension. In stark and awakening contrast, the NFPA Fire Analysis and Research Division prepared a report, "Fires in U.S. Industrial and Manufacturing Facilities" providing  insightful information regarding combustible dust related structure fires in manufacturing properties from 2006-2010. The NFPA report noted that shop tools and industrial equipment were involved in 29% of these structure fires. 


Most importantly dust, fiber, or lint (including sawdust) was the item first ignited in 12% of manufacturing facility incidents. This would equate to over 600 combustible dust related incidents annually. A vast and disturbingly revealing  difference from the 2006 CSB Dust Hazard Investigation Report identifying 281 combustible dust incidents from 1980-2005, or approximately 11 incidents annually. The educational NFPA report obtained fire incident data from the US Fire Administration's National Fire Incident Reporting System (NFIRS) data in conjunction with NFPA’s annual survey of U.S. fire departments. 

Its quite alarming where our global trading partners in the IECEx Scheme and European ATEX System recognize dust layers as a fire and explosion hazard yet here in the USA we do not recognize these immediate hazards in the current combustible dust rulemaking process. Continuing to proceed in solely defining combustible dust as a hazard in suspension and ignoring dust layers will have serious consequences in the future as experienced now and in the past. Is it time for a revision of the OSHA Combustible Dust; Advance Notice of Proposed Rulemaking in accordance with reality or should we continue while in error? 

On a side note, do you know the burning behavior of your dust? Additional information on burning behavior (VDI 2263). Currently OSHA nor CSB recognizes burning behavior in evaluating combustible dust fire and explosion workplace hazards.Unfortunately, we'll have to wait for another catastrophe before burning behavior is reconized like it is amongst our international trading partners.


Monday, January 17, 2011

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

Thursday, January 13, 2011

U.K Combustible Dust Fire with Metal Dust

“The fire was on the mezzanine floor in a hopper containing metal dust"
www.miltonkeynes.co.uk

OSHA needs to look at DSEAR and ATEX and include ComDust in the universe of potentially explosive atmospheres in the rulemaking process, which also includes flammable liquids, gases, vapors, and mists. Can't continue like the present situation in the USA with ComDust as a separate entity. Until then, the US Fire Administration will continue to ignore the fire and explosion hazards of ComDust with deficient incident reporting in the National Fire Incident Reporting System NFIRS 5.0

 

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