Combustible Dust NEP-Not All There?

Had to read it twice...maybe I initially misread it between the lines. No, No... it all there but not all there. Over half the states in the union are not required to participate in OSHA's Combustible Dust National Emphasis Program (NEP)

VI. Federal Program Change. EFFECTIVE DATE: October 18, 2007
...State plan participation in this national emphasis effort is strongly encouraged but is not required. State response/notice of intent regarding this directive is required....

Learn something new everyday. So how is the nation fully covered by the current effort that OSHA is projecting in protecting the health and safety of workers in regards to the hazards of combustible dusts? Especially when only half the nation's workplace is covered. Last time I checked, there were fifty stars in the blue union of the American Flag.

Combustible Particulate Solids vs. Dust Confusion

Hopefully the confusion in terminology regarding combustible particulate solids and combustible dusts will be cleared up prior to the House Education and Labor Committee hearing on Wednesday morning concerning the ‘‘Combustible Dust Explosion and Fire Prevention Act of 2008’’. With so many important policymakers being initially introduced to this complex acronym induced topic, it behooves the champions of the cause to get it right the first time out of the box.

First off, lets all understand and be in complete agreement that combustible dusts are a subset of combustible particulate solids (CPS). In its raw form combustible dusts did not arrive at the facility rear loading docks. Instead combustible particulate solids were trucked in. Thats where the Material Safety Data Sheets (MSDS) enter the picture, since these documents communicate the potential hazards of handling combustible particulate solids. which in their initial packaged state are mostly not hazardous at all.

For instance, after the facility receives the combustible particulate solids, the solid is then transformed into a finished product. During the production phase, which can include such activities as shipping, handling, conveying, mixing, pulverizing, etc. It's during this phase that combustible dusts are generated and a potential hazardous atmosphere can develop when minimum explosive concentrations (MEC) are partnered with a minimum ignition energy (MIE) to produce a potential explosion or fire.

Hope that clears up the confusion. Since prior to today and until reading several times over NFPA 654, I really couldn't of won the Wheel of Fortune either, if asked to compare and contrast the two.

Combustible Dust Mill Fire 3/07/08

Another preventable combustible wood dust fire occurred in our nation's lumbering region in Pittsfield, Maine this morning at Hancock Lumber. Luckily no one was injured, only economic property damage and disruption to mill operations.

From the company's website, the business has a rich history which began operation in 1848 as a small logging operation in Casco, Maine. The first sawmill went into operation in the 1880s.

Today, Hancock Lumber operates three sawmills in Maine (Casco, Pittsfield and Bethel) and is the largest producer of Eastern White Pine in the United States. Hancock "Made in Maine" pine products are shipped nationwide.(1)

"...Crews from several towns used a ladder truck and other equipment to fight the fire, which appeared to be located in a system of pipes that moves byproducts of the milling process..."

Then Chemical Safety Board determined that lumber and wood product industries account for 15 percent of combustible dust incidents. Additionally, wood material accounted for the largest percentage of combustible dust incidents.

a planer striking a rock or piece of metal likely shot a spark into the wood shavings chute, a metal tube about 4 feet in diameter, while employees worked. A fan that draws the shavings up into the chute provided enough oxygen for the spark to ignite the shavings,

After the conclusion of a Combustible Dust Hazards study, the report was submitted to OSHA in 2006 with a half a dozen recommendations to prevent such incidents. The primary recommendation was to implement a comprehensive combustible dust standard which also incorporated National Fire Protection Association combustible dust codes. So far OSHA has failed to act.

On another front, combustible dust related explosions and fires occur with alarming regularity and the tragic Dixie Crystal refinery explosion is not an isolated incident . Already 12 such incidents have occurred in the United States since the sugar refinery explosion. An Act of Congress will soon bring protection to industry and the nation's workforce

Congressmen Miller and Barrow are on the right track in holding a House Education and Labor committee hearing on 12 March 2008 with the Combustible Dust Explosion and Fire Prevention Act of 2008, which they have recently drafted and are working on having the bill appear on the House Floor.

Pittsfield lumber mill hit by fire
Google Map of Combustible Dust Fires and Explosions

Down Under Combustible Dust Fire

It appears that combustible dust fires and explosions are not limited to the United States as this news release from Australia informs us here on the other side of the equator.

Fire crews are confident they have extinguished a fire in recycled milk powder at the Fonterra Milk processing plant at Darnum in West Gippsland. Fire investigators believed it was caused by spontaneous combustion in a four storey high hopper.



Example: 40 pounds of powdered milk meets up with his buddies at the fire triangle. Their partner, confinement, was not feeling well and decided to stay inside.

Since the Dixie Crystal sugar refinery explosion in Georgia last month, there has been quite a bit of dialog between a diverse group of stakeholders which includes government legislators, enforcement agencies, and labor unions concerning what preventive measures should be taken to prevent future incidents. So far there has been no word from business organizations concerning impending costly preventive legislation in preventing future catastrophic dust explosions.

Luckily in this incident the explosion prevention equipment was functioning properly and only a fire ensued. Back in February 1980, a powdered milk mill in Minneapolis, Minnesota was not so lucky when the mill was destroyed by an explosion when an employee lowered a drop cord into a bin of powdered milk to see if it was empty. A conveyor was running at the bottom of the bin. The drop cord got caught in the conveyor and caused the explosion. The explosion spread throughout the steel bins and the warehouse causing 1 fatality and 8 injuries.

Source:ABC Gippsland

Fire in a tower of milk powder

Pre-Op Combustible Dust Legislation Hearing

It ought to be quite dicey at the House Education and Labor committee hearing next week covering the Combustible Dust Explosion and Fire Prevention Act of 2008 (H.R. 5522), which was introduced by Reps. George Miller and John Barrow (D-GA). There will definitely be an atmosphere of us against them between the Democrat and Republican committee members who represent conflicting interests of labor and business.

After viewing the web site opensecrets.org and comparing and contrasting the campaign contributors it became apparent as night and day that labor contributions represent the Democrats and business represents the Republicans of the committee. But who's representing the blue collar worker that is not part of any collective bargaining agreement?

The divisiveness is even more apparent between the House Education and Labor Committee when one sees that each party even has it's own web site for this specific committee. One for the Democrats and one for the Republicans . A striking quote on the Republicans website states:

"Under the Bush Administration, OSHA has made significant efforts to supplement traditional enforcement with cooperative partnerships,"

Cooperative partnerships, that basically means no irksome costly regulations and instead form voluntary industry alliances . This is the same tone that Edwin Foulke, the director of OSHA is touting as a the administration political appointee, which of course would be only natural. If this wasn't his position then he wouldn't have a job anymore and would be back practicing law in the Carolinas.

Most troubling in the preemptive hours before the committee hearing is the dissension across the aisles that partisan committee members have against one another from an event nearly two months ago concerning House passage of the S-Miner Bill H.R. 2768,, which Republicans claim rolls back mine safety reforms.

"...Over the strong objections of leading Republicans, academic experts, and the mining community, the U.S. House of Representatives today narrowly passed legislation that rewrites major mine safety legislation approved less than two years ago. Republicans objected to the S-MINER Act (H.R. 2768) because it halts the progress of bipartisan ..."



For an excellent preview of what to expect at next week's hearing concerning the atmosphere that will prevail. Then check out this video where we can listen to Rep Don Young (R-AK) speak on H.R. 2768, the S-Miner Act and its negative effect on energy. Just strike out Miner Act and add the Combustible Dust Explosion Act when you listen, then you'll be on the right trail.

When one takes an overall view of this impending legislation it would be advantageous to look at the legislative history of the grassroots movement that formed for the house passage of the S-Miner Bill in January 2008. For example, a lobby composed of 325 corporations with 1.6 million dollars of spending money represented by the National Mining Association was amazingly defeated by 95,000 miners represented by the United Miner Workers of America on a $20,000 in lobbying money in the first half of 2007. Hopefully, that sort of momentum will occur with the Combustible Dust Explosion and Fire Prevention Act of 2008 (H.R. 5522) that Congressman Miller and Barrow drafted for impending legislation.

Click on the Google Map for an enlarged view, The fire logos are preventable combustible dust related fires and explosions over the past two months. The red bubbles are representative of electoral districts where current Republican committee members sit on the House Education and Labor Committee. Just figure I'd illustrate how prevalent this issue is and how close it strikes to home with Dixie Crystal not being an isolated incident.

OSHA Launches Web Page on Combustible Dusts

In a press release today, OSHA announced that it has prepared a specific web page with information on the safety regulations that the work site is required be under compliance with concerning combustible dusts. Not anything new concerning content. Only that the areas OSHA is enforcing and conducting inspections is neatly organized. Other content includes the voluntary OSHA Safety and Health Information Bulletin (SHIB) 07-31-2005 and information on the Combustible Dust National Emphasis Program.

Hot Topics

• Combustible Dust National Emphasis Program. OSHA Instruction CPL 03-00-006, (2007, October 18).
• Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions. OSHA Safety and Health Information Bulletin (SHIB) 07-31-2005, (2005, July 31). Also available as a 21 KB PDF, 9 pages.

Additionally, a page is provided listing all the applicable aspects of OSHA General Industry standards that would apply to all workplaces even ones with combustible dust.

The best feature of the web page and my hats off to OSHA...thanks. Is the links to NFPA 654 and NFPA 454, where once you arrive at the NFPA site, you have the option of utilizing a reader to view the entire code book. Can't copy pages...you need to purchase for that.

There is a link to other resources, which could of expanded to include the very educational and informative CSB Combustible Dust Hazard Study that was completed in 2006. Instead the Chemical Safety Board link only goes to their news page.

Heh...you don't want to be in the news. We want to learn how to stay out of the news. Maybe if the OSHA webmaster is reading this he can fix this minor aberration.