Scorecard: Combustible Dust Explosions/Fires March 2008

March was a busy period for combustible dust explosions and fires at manufacturing facilities totaling 14 incidents, which included seven combustible dust explosions at wood, food, metal, power generation, and feed industries. In contrast, at grain facilities there was four combustible dust related incidents, which included one explosion. Luckily there were no fatalities and limited to one injury. The negative economic impact to the local communities has been the most damaging aspect of these preventable and predictable accidents.

Most troubling is the repeatable combustible dust related explosions and fires that have occurred in 20% of the incidents. For instance, a metal finishing facility in Michigan had combustible dust fires occur in their dust collectors twice within one week. In the second fire, employees emptied all 18 of their fire extinguishers to quench the flames.

Hazardous Communication
The majority of the workforce, management, and owners have no idea of the combustible nature of combustible particulate solids when combustible dusts are generated during the manufacturing process. Combustible dusts forming an explosive atmosphere can be equated to flammable vapors that occur in a transfer operations between petroleum barges and a refinery during a marine transfer of flammable liquids. For example, when the transfer hose is connected or disconnected from the barge, flammable vapors are present from the flammable liquids, which generates a potential explosive atmosphere.

Petroleum refinery operators have material safety data sheets which inform the workers of the flash points of the flammable liquids they are working with. In contrast, industries that handle wood, metal, feed, plastic, and other solids have no information in their material safety data sheets concerning the minimum ignition temperatures and minimum explosive concentrations of the combustible dusts that are generated from the combustible particulate solids they are handling.

Explosive Atmospheres
Explosive atmospheres are just as easily formed when working with combustible particulate solids as when handling flammable liquids. In both instances combustible dusts and flammable vapors are generated creating a hazardous environment. Preventive and mitigative measures must be instituted to protect the worker, facility, and community from catastrophic events that could occur if proper administrative and technical measures are not followed.

Currently it's safer to work in a chemical or petroleum plant as the petrochemical industry is already aware of the hazards and follows proper procedures. In contrast general industry has no comprehensive procedures in the safe handling of combustible particulate solids and the combustible dusts that are formed in the manufacturing process.

This is where the disconnect is over the last eight weeks with the nationwide 27 combustible dust related explosions and fires since the tragic Imperial Sugar Refinery combustible dust explosion in February. There would be public outrage if there were 7 refinery and chemical plant explosions over the month of March. But no outrage at all with the combustilbe dust explosions.

Trade Associations
Its time for all trade associations in general industry to create preventative and mitigative technical and administrative procedures concerning combustible dust hazards. This information can be shared collaboratively with it's association members in the prevention of future accidents.

For instance, material safety data sheets can be amended in providing fire and explosive hazards of combustible dusts. On the company level this would prove costly, whereas on the larger association level the costs can be reduced in amending material safety data sheets with a collaborative effort between its association members that handle the same raw materials in the manufacturing process.

Ignition Sensitivity
Additionally, at the trade association level, testing can be proactively instituted in determining the ignition sensitivities and explosive severity of the combustible dusts that are generated in the manufacturing process of combustible particulate solids. The current reactive measure that OSHA has in it's National Emphasis Program for combustible dusts does not provide industry with proper proactive preventive and mitigative measures.

Due to budget constraints, there are a limited number of OSHA inspectors in collecting samples and sending obtained dusts to the OSHA Salt Lake Testing Facility. Who is going to pay for these very expensive tests? What about the time in between when the facility might have an inspector arrive? Where is the protection in between ? The clock is ticking and only more preventable and predictable combustible dust related explosions and fires will occur until industry moves proactively.

Georgia Combustible Dust Fire Ends Shift Work

Over the weekend at Quality Carpet Cushion on the northern outskirts of Lafayette, Georgia as the evening crew were beginning their shift, a combustible dust related fire flared up adjacent to machinery that chops and shreds recycled foam in the manufacture of bonded polyurethane carpet padding. Dozens of firefighters from surrounding communities responded to the four alarm fire and finally where able to quench the billowing inferno 20 hours later the following day according to news reports.

Company officials have yet to comment concerning the incident, yet the entire shell-shocked town of Lafayette is still trying to recover from the dismal Sunday where approximately 100 workers in the community depend on the plant for their livelihood. Luckily there were no injuries only an overwhelming negative economic impact on a small town community that is already feeling the ripples of a nationwide housing slump and no hope for the future since the facility was gutted out with fire and water damage.

Combustible dusts are generated from the grinding process of the combustible particulate solids of polyurethane which has a minimum ignition temperature close to the heat of a recently extinguished wooden matchstick . Inattentive housekeeping is a leading factor in combustible dust fires and explosions such as the tragic event that claimed 13 lives and over 50 injuries in Port Wentworth, Georgia nearly two months at the Imperial Sugar Refinery. Remove the fuel from the fire triangle and the possibility of a fire is also removed.

Removing the fuel factor is easier said than done. Especially when the workspace also becomes part of the manufacturing process; compounded with a process that grinds over 4 million pounds of combustible particulate solids (polyurethane) a month in suppling consumer demand for bonded carpet padding . With over two dozen nationwide facilities similar to Quality Carpet Cushion in the manufacturing of bonded polyurethane carpet padding, industry trade associations such as the Carpet Cushion Council and Alliance for the Polyurethanes Industry need to convene as a collaborative group to reevaluate the manufacturing process in the prevention and mitigation of future combustible dust incidents.

As it stands now everyone is on borrowed time, as LaFayette Public Safety Director Tommy Freeman succinctly stated:

In any manufacturing plant they have a buildup of dust and soot that floats around in the air and settles everywhere. Over time this accumulates. A simple fire under these circumstances can cause a flash-burn or -fire, because that dust is extremely flammable.........“The plant has had other fires in the past but were small and in different proximity,” Freeman said. He said all manufacturing plants have fires from time to time." Source: Walker County Messenger/Larry Brooks

In the meantime there won't be any shift work at the Quality Carpet Cushion for awhile.

Shift work, hard work, tired body
Blue-collar shirt and a baseball cap
Union made

He's hot, sweat drops, 'round the clock
Door never locks
And the noise never stops

Night or day
Work seven to three
Three to eleven
Eleven to seven

Shiftwork Lyrics by Kenny Chesney :

Resource: News Channel 9 Video

Grain Combustible Dust Explosions and Fires: 2008

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Combustible dust explosions and fires occurring in grain elevators and feed mills during 2008 throughout the United States. The OSHA grain facility combustible dust standard has reduced the the number of fatalities and injuries since prior to 1988 when the standard was implemented. Yet incidents still occur on a regular basis.

Also included on the Google Map are incidents in Canada and the United Kingdom.

OSHA’s Scorched Earth Campaign-Combustible Dusts

Last time Americans heard of a scorched earth campaign was nearly a century and a half ago toward the end of the Civil War when Union Major General William Tecumseh Sherman conducted his “Savannah Campaign’ and “March to the Sea” from Atlanta to the port of Savannah. In his wake, he burned everything to the ground except courthouses, churches, and dwellings. In the background of the procession, military bands played on, while his troops sang the chilling words “John Brown's soul goes marching on!"

Conflicting Campaigns

Fast forward into the twentieth-first century and another more productive campaign is happening across the nation’s heartland to the tune of a different song and that is the prevention of future preventable and predictable combustible dust related explosions and fires. At the forefront of this complex issue is OSHA’s conflicting scorched earth campaign in staunchly opposing labor’s desire in a comprehensive combustible dust standard in its health and safety regulations. In the meantime the nation’s economic industrial infrastructure is burning to the ground due to the alarming prevalence of combustible dust explosions and fires.

In the same southern maritime port of the Savannah River where General Sherman ended his “March to the Sea,” the United States suffered a horrific loss of lives and property with the explosion of the Georgia’s Imperial Sugar Refinery caused by combustible sugar dust. Fifteen months prior to the explosion, the Chemical Safety Board, an independent federal agency charged with investigating industrial chemical accidents to protect workers, the public, and the environment, made recommendations concerning the implementation of OSHA combustible dust standard, which OSHA failed to act on.

Scorched Infrastructure

So now the nation’s workforce is living under an OSHA ‘scorched earth” policy. Haunting recurrences of combustible dust explosion occurred yesterday in Dudley, North Carolina where a Georgia-Pacific wood processing plant experienced over $ 20,000 of damages when four of its dust collectors exploded causing a small fire in the main structure. Luckily there were no injuries.

Yet unfortunately several years earlier, 35 miles up the road on January 19, 2003 the West Pharmaceutical Services plant in Kinston, North Carolina was not so lucky when it was scorched to the earth from a preventable combustible dust explosion, resulting in 6 fatalities and 38 injuries. Luck can only go so far with combustible dusts where many substances of wood, metal, plastic, food, coal, chemicals, and pharmaceuticals have minimum ignitions energies (MIE) less than gunpowder at the millijoule level.

One Size Fits All

And that’s where the problem lays, OSHA’s position that a “one size fits all” combustible dust health and safety standard will not work due to the diversity of raw materials involved in the manufacturing process. The public should not be mislead by this position regarding a very complex subject of dust cloud formation and ignition processes in addition to flame propagation and blast waves generated by burning dust clouds.

OSHA’s upper management, in which Edwin Foulke is the leader, is still under the false assumption that combustible dusts ignite due to diverse flash points. This could be further from the truth. For example, there is no such thing as flash points like in flammable liquids and vapors when regulating combustible dusts. Instead the physical and fire properties include minimum ignition temperature (MIT), minimum explosive concentration (MEC), minimum ignition energy (MIE), and deflagration indexes (Kst)

Combustible Dust Properties

Most combustible dusts have a minimum ignition temperature (MIT) of less than 932 degree Fahrenheit (500 C), which is the temperature of a match that has been immediately extinguished. Regarding deflagration indexes (Kst) or explosive properties, which is the amount of pressure rising over a period of time there are four classes: no explosion, weak, strong and very strong. Sugar dust as in the Imperial Sugar Refinery explosion has a weak Kst index as does the polyethylene plastic dust that was involved in the West Pharmaceutical dust explosion.

The subject of combustible dusts is a fascinating science wrought with new terms unfamiliar to most people in contrast to flammable liquids and vapors which are regulated in accordance with their flash points and hazardous classes. Combustible dusts can be understood at the same level if the analogy is used between flash points in vapors generated from flammable liquids in comparison to minimum ignition temperatures for combustible dusts generated from combustible particulate solids.

National Emphasis Program
OSHA’s “scorched earth” policy in regards to combustible dust is intensified when misleading proclamations are made in leading global and national publications such as the USA Today Op/Ed column where OSHA Director Edwin Foulke states “last fall OSHA initiated a nationwide program to increase inspections in high-risk workplaces.” This could be further from the truth as there is no nationwide national emphasis program for combustible dusts.

For instance 26 states have approved state plans, Connecticut, New Jersey, New York and Virgin Islands plans cover public sector (State & local government) employment only. Which translates into fine print that State plan participation in the combustible dust national emphasis effort is strongly encouraged but is not required. Additionally, State response/notice of intent regarding this directive is required. So far none of the 23 states have an emphasis program for combustible dusts. In all fairness, Michigan, Indiana, Virginia, and Tennessee are in the process of adopting at state emphasis combustible dust program.

Reoccurring Dust Explosions

In the meantime over the last seven weeks since the catastrophic Imperial Sugar Refinery combustible dust explosion there have been over two dozen combustible dust related fires and explosions across the nation spanning from the Pacific to the Atlantic . These predictable and preventable events have ranged in a diverse set of industries and institutions such as food, wood, metal, textile, and rubber industries. In addition to an Xcel coal power plant in Minnesota and Sheboygan Falls High School in Wisconsin. Even General Tecumseh Sherman’s scorched earth policy “March to the Sea,” had not ranged this far in proportion in such a short amount of time.

It should not take an act of Congress like the proposed bill, “HR 5522, The Combustible Dust Fire and Explosion Prevention Act of 2008" that the House Education and Labor Committee held a hearing on March 12, 2008 to provide stimulus for OSHA to act. Instead sound and persuasive leadership is needed at the Department of Labor, where industry, labor, and governmental leaders can reach a comprehensive agreement in providing the health and safety protection that the country now desperately needs.

Global Alternative

An excellent alternative to the conflicting points of view between the stakeholders would be to review programs that our global trading and security partners have. For example, Australia, New Zealand, Europe, and the United Kingdom already have health and safety regulations concerning explosive atmospheres like combustible dusts.

The European Union has instituted ATEX 95 equipment directive 94/9/EC and ATEX 137 workplace directive 99/92/EC. The unusual ATEX acronym is derived from French: Appareils destinés à être utilisés en ATmosphères EXplosibles .The United Kingdom with guidance from ATEX 95, has implemented the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) which require employers to control the risks to safety from fire and explosions.

Additionally, down under, Australia and New Zealand and doing the same with a phase in program spread out over the years like the United States did for the 2002 Homeland Security Act. After a period of six years and billions of dollars government and industry are completing the last aspects of homeland security with the controversial Transportation Worker Identification Credential (TWIC). Instead of protecting from a threat on the outside with the Homeland Security Act., the OSH Act with a comprehensive combustible dust standard can protect from the scorched earth occurring within.

Photo Credit: U.S. National Archives and Records Administration

North Carolina Combustible Dust Explosions and Fires

Michigan Combustible Dust Fires Reoccurring

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How can there be two combustible dust fires in succession within one week like has recently occurred in Muskegon, Michigan at the metal finishing facility of Port City Industrial Finishing Inc? In last Tuesday’s incident the dust collector/silo sustained $120,000 of fire damage and yesterday courageous and heroic fast-acting employees emptied all 18 fire extinguishers in quenching another combustible dust fire in the vicinity of a dust collector/air handling unit inside the building.

Michigan Scorecard

Michigan is high on the national scorecard of a continual succession of preventable and predictable combustible dust explosions and fires. Of a 7.0 earthquake magnitude on the scale of the recent tragic Imperial Sugar Refinery explosion, the Ford Rouge plant in Dearborn, Michigan experienced a coal dust explosion nearly two decades ago on February 1, 1991, causing 6 fatalities and 30 injuries after the dust had settled.

Two short years would pass when on May 25, 2001 another fireball and combustible dust explosion would erupt in the state at a Georgia Pacific particle-board plant in Gaylord, Michigan. In this incident there were 15 injuries of which nearly half of them where from six firefighters who were extinguishing hot spots from the earlier fire when another combustible dust explosion erupted.

2001 Not a Good Year

Four months later on September 21, 2001 as investigators were still analyzing and writing their accidents reports on the Georgia-Pacific explosion another combustible dust explosion occurred at a Wayland, Michigan milk processing plant, which resulted in two injuries and minor damage to the facility.

2001 was not a good year for the nation or Michigan either concerning explosions that seemed to come out from nowhere. The New Year in 2002 fared no better and even before the dismal anniversary of the catastrophic coal dust explosion at the Ford Rouge Plant had turned its pages on the calendar another coal dust explosion raised its nasty head on January 16, 2002 on the banks of Lake Superior in Marquette, Michigan.

At an electric services plant, a coal-fired boiler was being brought on-line where the coal feeding system had not been purged properly and an excessive amount of coal dust left in the system ignited, causing an explosion and leaving a fatality in its wake. The dragon had spoken and was not to be ignored.

National Problem

The last six years have been dormant in comparison to earthquakes’ with several combustible dust fires spread out through 2003 and 2004 with no fatalities or injuries, synoymonous to tremors and warning signs. It’s now when a facility such as Port City Industrial Finishing, where two combustible fires occur in succession within a week that notice occurs. In retrospect, Michigan only had nine combustible dust incidents from 1989-2004 leaving 7 fatalities and 59 injuries.

Michigan is not being singled out in the scheme that the dragon has planned out. Since he lashed his ugly tail upon the serene western bank of the Savannah River at the Dixie Crystal sugar refinery in Port Wentworth, Georgia over two dozen combustible dust explosions and fires have occurred throughout the nation.

So how many more fatalities and injuries must occur before the issue is addressed and a mandatory OSHA comprehensive combustible dust standard is implemented utilizing National Fire Protection Association combustible dust codes?

Quaker Oats Blows It's Top

http://www.gazetteonline.com/apps/pbcs.dll/article?AID=/20080324/NEWS/233198211/1006/news

Around sunrise as hearty Iowans were beginning their workday with the freezing and brisk morning commute in downtown Cedar Rapids, Iowa a dust explosion rocked the eight floor of the prominent Quaker Oats facility, which has been a landmark on the east bank on the Cedar River for over a century.

Luckily no injuries occurred and it only brought back a brief stark reminder of a catastrophic dust explosion that occurred in Cedar Rapids, nearly a century ago on May 19, 1919 at the Douglas Starch Works, where a dust explosion leveled the building causing 48 fatalities. Prior to 1899 George Douglas was a partner with the principles of North Star Milling, the predecessor of Quaker Oats founded in 1873.

Smiley Face

The familiar friendly face on that red, white, and blue Quaker Oats box in our cupboard has a rich history and there is nothing happier in the morning than crunching on a bowl of Cap”n Crunch (Quaker Oats product) to get the day started. The risks involved in getting the thousands of happy faces started in the morning are another story.

Handling food products in the manufacturing process produces inherent dangers with the seemingly harmless combustible dusts that are generated in the workplace. So who would have thought something as harmless as sugar, like earlier last month at Imperial Sugar in Georgia, would have the explosive power of another 9/11?

City-State Not Immune

Iowa has not been immune to these dangers as there have been over a dozen dust explosions over the last twenty years in the state according to the 2006 Chemical Safety Board’s Combustible Dust Hazard Investigation. Since 1991, in Cedar Rapids, there have been six dust explosions at wet corn milling, starch, bakery mix, cereal, and animal by-product plants. Luckily, no injuries just a lot of broken glass and rattled nerves and time to think more about prevention in the future.

Cause’s and ignition sources range from fires, spontaneous combustion, sparks, hot metal, and unknown. Over half of dust explosions never end up in a determination of causes due to the destruction that is wracked on the facility. Yet static electricity would be a good place to start. Are the workers wearing anti-static clothing in addition to anti-static floor covering as found in many hospitals in preventing potential explosions?

Voluntary OSHA Compliance

Voluntary measures of anti-static clothing only go so far in prevention as it is not required at facilities that generate combustible dusts. Additionally the operating costs for companies would be exorbitant in the investment of anti-static flooring coverings, which would fiercely eat into quarterly earnings statements.

This is only the tip of the iceberg when it comes to voluntary standards that the National Fire Protection Association lists in their numerous fire codes in handling metal, food, plastics, rubber, coal, wood, and other combustible particulate solids that generate combustible dusts. For instance, there are many more issues in contrast to explosion prevention which leads to explosion mitigation and covers ventilation, isolation, and suppression of dust explosions in milliseconds.

Myth or Dream

That’s where the real big bucks enter into the picture. Think of it as an entire industry rising from the ashes like the mythological Phoenix where a cottage industry of explosion protection devices is installed at all facilities generating combustible dusts and the idea of a future dust explosion would be decreased immensely. But that is only a dream such as a myth.

Threat From Within

Since the Homeland Security Act was passed in 2002, billions of dollars have been spent by government and industry in providing protection from outside threats. But what about protection from inside the nation where worker fatalities, injuries, and devastating economic impact occurs on a regular basis?

A major concern is that the Occupational Health and Safety Act was passed nearly four decades ago and it has yet to live up to the lofty goals of aggressively attacking the continual occurrence of fatalities and injuries in the workplace. Instead there is a patchwork of voluntary compliance and alliances with industry.

Labor or Industry

This mode of operation was reinforced during the March 12, 2008 hearing at the House Committee of Education and Labor on the HR 5522 "The Combustible Dust Fire and Explosion Prevention Act of 2008.” Where industry and business through the voice of the powerful and omnipresent U.S, Chamber of Commerce, the world's largest not-for-profit business federation, representing 3,000,000 businesses reiterated their position that a OSHA comprehensive dust standard is not a viable action.

Until an OSHA comprehensive combustible dust standard in the protection of workers and the workplace is instituted more preventable and predictable dust explosions and fires will occur. Since the catastrophic explosion at Imperial Sugar six weeks ago resulting in 13 fatalities there has been nearly two dozen additional combustible dust incidents. Maybe the dust explosion at Quaker Oats will be wake up call for immediate action as the kindred spirits Douglas Starch Works and Imperial Sugar look on.