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)

Chadron, Nebraska Grain Elevator Catches Fire

via rapidcityjournal.com

The Chadron grain elevator is one of 19 that the company operates in five states. These facilities must adhere to the OSHA Grain Facility Standard in the prevention of fires and explosions. No matter how many layers of protection are instituted only the probability and severity can be minimized.

In the current OSHA Combustible Dust proposed rulemaking process, the agency intends to prevent all explosions and fires in the manufacturing sector. How can this be done when fuel loads and potential ignition sources are constantly present during the production process both in the grain industry and manufacturing sector?

Posted via web from ComDust

Ethanol Plant Dust Explosions and Fires

Like a small tremor on the San Andreas fault line of the West Coast as a precursor to the big one, the recent explosion at the ethanol plant in Hastings, Nebraska provides a similar warning. In less than a year over a dozen combustible dust related fires and explosions have occurred at ethanol facilities throughout the Midwest. The importance of donning proper PPE such as flame resistant clothing (FRC) in such a work environment takes on added dimension with now learning the workers T-shirts were set on fire from the blast. A week prior to the Hastings explosion, according to media accounts, an ethanol plant in Casselton, North Dakota experienced a minor fire in the dust collection bin.

Ethanol plants have complex explosion and fire hazards not found in other manufacturing national industries (NAICS) where the attributes of a grain handling facility is combined with a chemical plant in the production of ethyl alcohol. Subsequently, these process facilities must follow stringent regulatory guidelines according to the OSHA Process Safety Management Standard (PSM) and EPA Risk Management Program (RMP). Additionally, combustible dust hazards are addressed in the OSHA Grain Facility Standard.

The confusing aspect of identifying in which area OSHA regulates this national industry besides the OSHA PSM standard is that SIC 2046 for Wet Corn Milling and SIC 2869 for Ethyl Alcohol Manufacturing is not listed as SIC's regulated in the OSHA Grain Facility Standard. In contrast, NAICS 311221 Wet Corn Milling is listed as a D-1 NAICS in the OSHA Dust NEP.

With the multitude of regulatory control measures protecting workers, the environment, and the public; accidents still happen. The question arises can the current high incident rate be minimized? In less than a year six ethanol plant explosions have occurred in Michigan, Arizona Minnesota, Kansas, Wisconsin, and Nebraska with ensuing injuries in 50% of these incidents.

So what is an unacceptable accident and injury rate before stakeholders reassess current administrative and best engineering control measures? All the proper administrative and best engineering control measures seem to be in place in the prevention and mitigation of fires and explosions. Yet the incidents are exponentially higher than any other national industry(NAICS) in the manufacturing sector. Hazard awareness through a multitude of educational programs is an excellent measure in addressing this issue.

For instance, ethanol trade associations such as the Renewable Fuel Association (RFA) has an proactive safety program addressing many of the hazards in ethanol production. Additionally, the RFA works collectively with the University of Illinois Fire Service in providing industry with educational programs that prevent future incidents.

Recently, Kirkwood Community College in Cedar Rapids, Iowa was awarded a $174,978 OSHA Susan Harwood Training Grant in hosting a 2 ½-hour awareness-level combustible dust safety course addressing grain dust and other organic dusts such as sugar, flour and paper. The training will provide 150 courses in 14 Midwestern states for 3,000 employers and employees primarily in the agriculture, food processing and fiber sectors with a focus on grain elevators and ethanol bio-refineries. Training is a great administrative approach in providing hazard awareness. But what about the current best engineering control measures and are they adequate?

With the current progression of incidents, this unique national industry with a primary NAICS 325193 Ethyl Alcohol Manufacturing and secondary NAICS 311211 Wet Corn Milling is quite similiar to tectonic plates shifting, one upon the other, and its only a matter of time before another event occurs in the seismic proportion of the 2007 Steamboat, Iowa explosion, causing millions of dollars in damage in addition to potential fatalities and injuries.

Overall, in the majority of these recent ethanol plant incidents, life safety, structural integrity and mission continuity objectives of the NFPA combustible dust standards have been maintained. This is an excellent example illustrating that combustible dust related explosions cannot be totally prevented only the severity reduced. The task now is to somehow reduce the probability.

This overview is not meant to place blame on the ethanol industry which is actively striving to reduce incident rates. Hopefully the information from tracking and researching these incidents will provide stakeholders an enhanced awareness concerning trends that have been developing. With this information possible preventative and mitigative strategies can be devised in minimizing the occurrence of another tremor.

Resources:
Incident Google Map
RMP Facilities
Dry Mill Ethanol Industry .pdf
ETHANOL DRY MILLING: MODEL DESCRIPTION
Feed and Grain Products .pdf

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Grain Facility ComDust Fires and Explosions

Since the Destrehan, Louisiana grain elevator explosion two weeks ago that put the ADM/Growmark's largest export terminal in Louisiana out of service, through media accounts, eight additional grain facility combustible dust related fires and explosions occurred throughout the nation. The financial damage from these events has totaled over $200,000 and luckily no injuries.

So is the OSHA grain facility standard working? It is not possible for OSHA with limited resources to inspect thousands of these grain handling facilities ensuring workplace safety compliance. Will it take a dust explosion in the magnitude of the catastrophic Imperial Sugar Refinery explosion this year to finally address the situation with additional governmental accident investigations, congressional hearings, and costly studies.

The clock is ticking and there is no time to waste. Combustible dust related fires and explosions in the grain handling facility or manufacturing, utility, and non-manufacturing sectors all have the same devastating effects.

The current combustible dust bill (H.R. 5522) awaiting a vote in the Senate needs to be reevaluated with provisions for all combustible dust related explosions and fires. Lets get our eggs all in one basket instead of the chaos that has engulfed the nation's workplace concerning combustible dust hazards.

Over 155 Dust Explosions/Fires 2008

Is the OSHA grain facility standard working? Luckily workers escaped injury at the Destrehan, Louisiana grain elevator explosion early Thursday morning. Since the beginning of 2008, through media accounts, an alarming tally of 13 grain facility combustible dust related explosions have occurred throughout the United States. Dust explosions and fires have plagued a wide swath of industry whether it be in manufacturing or the grain sectors.

Grain and Manufacturing Sectors
Fast rewind, over two decades ago after a rash of 1977 grain silo explosions that caused dozens of fatalities and resulted in the OSHA Grain Facility Standard , which outlined measures in protecting the workforce from combustible grain dust explosions and fires. But still, fires and explosions continue to occur resulting in numerous fatalities and injuries.

Immediately after the February 7, 2008 catastrophic Imperial Sugar Refinery dust explosion in Port Wentworth, Georgia , congressional leaders drafted a combustible dust bill that outlined provisions in protecting the manufacturing sector workforce from the hazards of combustible dust explosions and fires. The bill currently sits very bored, and stretched out, yawning waiting for action in Senate chambers after passing in the House by a mostly Democrat roll call.

Kick Like a Mule
Why does there have to be two separate OSHA regulations concerning combustible dust explosions and fires ? One for the grain sector and one proposed for the manufacturing sector? An explosion is an explosion just like a mule is a mule. Just different colors and a different sort of swag of the tail but the same powerful kick as any muleskinner can tell you.

The effects of any explosion whether it be a physical or chemical explosion entail damaging effects of overpressure, thermal radiation, and ensuing projectiles. Dust explosions are quite similar to vapor cloud explosions (VCE) that occur when flammable gases or vapors are suspended in air combined with the essential flammable limit (LFL-UFL) and joining their buddy, an ignition source.

Amazingly, the maximum pressures (Pmax) that develop in milliseconds, with the energy release of a dust or vapor cloud explosion in general are quite similar, around 7 Bar (1 bar = 14.5 psi) or 100 psi. Around 3 psi is enough to knock many commercial buildings down such as with aluminum siding

In 2008, through media accounts, the Combustible Dust Policy Institute has noted over 155 combustible dust related explosions and fires in the combined grain and manufacturing sectors. Dust explosions that result in adverse economic impact, fatalities and injuries do not differentiate between a grain elevator or dust collector inside a manufacturing process facility.

References

Crowl, D. A. (2003). Gases and Vapors. In Understanding Explosions (p. 17). Wiley-AIChE.
Crowl, D. (2003). Appendix E Combustion Data For Dust Clouds. In  Understanding Explosions  (p.
191). New York, New York: Wiley-AIChE.