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.

Timeline: Recent Combustible Dust Explosions

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The most recent combustible dust explosion occurred on the same day that the House Education and Labor Committee was having a hearing on HR 5522, "The Combustible Dust Fire and Explosion Prevention Act of 2008".

Testifying were William Wright, Acting Chair of the Chemical Safety Board: Ed Foulke, OSHA; Tammy Miser (whose brother, Shawn Boone, was killed in a combustible dust explosion); David Sarvadi, representing the US Chamber of Commerce; and Amy Spencer of the National Fire Protection Association.

Up Close Imperial Sugar Explosion Update

Six weeks have passed now since the horrific Imperial Sugar Refinery combustible dust explosion that occurred in Port Wentworth, Georgia on the evening of February 7. Imperial Sugar CEO John Sheptor allowed reporters an up close view of the blast site while investigators took a break during the Easter weekend.

Today News Threes Alice Massimi and photojournalist Art Ottimo were able to get a close-up look at the destruction caused by this horrific incident.

Combustible dust explosions and fires are a regular occurrence at numerous manufacturing and processing facilities across the United States and the Imperial Sugar incident is not an isolated case. Already 20 combustible dust related fires and explosion have occurred since the explosion in Port Wentworth.

3/18/08 MUSKEGON COUNTY Muskegon firefighters responded at 1:52 a.m. to the plant at 1867 Huizenga, where they discovered the plant's "dust collector" had caught fire, said Fire Marshall Major Metcalf. It's unclear why the device -- located outside the plant -- malfunctioned

Combustible dust fires originating in dust collectors occur with regularity and without proper voluntary detection, isolation, ventilation, and suppression measures in conjunction with the regulatory good housekeeping requirements additional incidents, will continue.

Just abiding by current combustible dust industry standards and OSHA regulations is not enough as Imperial Sugar CEO John Sheptor suggests, with all good intentions

PORT WENTWORTH, GA (WTOC) 3/21/08 - "We will rebuild this facility to the best knowledge we have with regard to the management of combustible dust, whether that be a regulation or industrial standard and by all means we believe we were operating according to these codes and standards previously," he said.

Rebuilding the sugar plant in compliance to current OSHA combustibles dust regulations will only prolong the situation of the continual occurrence of more combustible dust explosions.Especially since abiding to National Fire Protection Association (NFPA)codes on combustible dust is only voluntary.

At a recent congressional hearing of the House Committee of Education and Labor concerning the introduction of the Combustible Dust Explosion and Fire Prevention Act (H.R. 5522), David Sarvadi a lobbyist and attorney representing United States Chamber of Commerce the world's nationwide largest not-for-profit business federation, of 3,000,000 businesses, didn't believe that a mandatory OSHA combustible dust standard, which includes NFPA combustible dust explosion preventative and mitigative measures was a good idea.

Meanwhile combustible dust explosions are still occuring

3/13/08 By TOM QUIGLEY The Express-Times HIGH BRIDGE,NJ Fire erupted Wednesday inside an enclosed dust collector in a metal-grinding room at the Custom Alloy plant on Washington Avenue, borough Fire Chief Jeffrey Smith said.

The severity of the situation is not just solely on the protection of workers in the workplace from the unknown dangers of seemingly harmless combustible particulate solids and the combustible dusts that are generated. But now our nation's firefighters are at risk when fighting a structure fires where unrecognized combustible dusts are generated and primary and secondary dust explosions can occur during the deflagration event.

And so the saga continues:

3/10/08 WCCO.com OAK PARK HEIGHTS, Minn. (AP) ― Xcel Energy is shutting down its King plant in Oak Park Heights after a fire and possible explosion in a building near the coal-fired plant.

This was the second combustible dust explosion of coal dust within three months at the same facility. Currently, Minnesota is under a voluntary state OSHA program and doesn't even have an emphasis program regarding combustible dusts. So how is it that future preventable and predictable combustible dust explosions and fires can be diminished if there is no nationwide mandatory protective standards?

Resources:

NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids

Google Map Combustible Dust Related Explosions and Fires

Spooner Explosion-Dust or Vapor?

The catastrophic Tuesday chemical plant explosion at the Cortec aerosol can filling facility in Spooner, Wisconsin is still a mystery to local, state, and federal investigators. Luckily, most of the workers were in the break room when the mysterious explosion destroyed the facility. Yet two injuries occurred with the burn victims still in the hospital.

Cortec is a global leader in corrosion protection technology with its proprietary vapor-phase corrosion inhibitors. VCIs are environmentally friendly organic chemicals that condense on metal surfaces, creating an invisible barrier to moisture. Products that are filled in aerosol cans include rust removers, rust preventers, biodegradable cleaners, and degreasers.

With hundreds of diverse corrosion protection products manufactured at their other facilities, Cortec provides corrosion protection products for over 70 countries in conjunction 500 local distributors. For instance, NASA uses the products’ on the space shuttle and the U.S. military has a multitude of uses for the products in the adverse conditions which it operates whether land, sea, or air.

Normally aerosol can filling can be a potentially dangerous operation in the manufacturing process. Yet Cortec has alleviated that hazardous aspect with its EcoAir aerosol can product which utilizes unique technology in the form of aerosol products that are powered by compressed air which is not flammable. So how did the facility explode if it doesn’t use liquefied petroleum gas (LPG), dimethyl ether (DME), difluoroethane (DFE), or butane as a aerosol propellant?

That’s the mystery. Additionally, newspapers have stated through witness accounts, that no one can recall smelling any vapor such as a flammable gas leak. Furthermore, a business owner across the street heard a primary explosion then a larger secondary explosion followed by the huge fire.

Is it possible that the vapor corrosion inhibitor (VCI) in a dust form, prior to filling the aerosol cans, had accumulated over a period of time on overhead surfaces and ledges unbeknownst to plant management and the workers? That’s the big question even with the aisles and passageways spotless through conscientious housekeeping yet a hidden danger could be lurking above.