$3 million Combustible Dust Related Fire Unreported

How can a $3 million fire that destroyed a historic furniture factory in Salt Lake City, Utah four years ago be unreported in the Chemical Safety Board Combustible Dust Hazard Study? An excerpt from a news account states:

"Local fire officials suspect that the fire started in the dust collector at the 120-year-old factory owned by Jeffrey Cobabe and Associates."

Hundreds of Incidents not Reported
The troubling aspect of the incomplete CSB Dust Hazard study that was submitted to OSHA in 2006 is that public policy concerning worker health and safety was formulated in the OSHA Combustible Dust National Emphasis Program (NEP) directive. Additionally, in March 2008 the House Education and Labor Committee introduced to Congress (H.R.5522) The Worker Protection Against Combustible Dust Explosion and Fires, also utilizing the CSB Dust Hazard study as the guidance and foundation in the drafted bill.

Since the Imperial Sugar Refinery dust explosion, dozens of training classes at industry conferences hosted throughout the nation have been providing industry stakeholders with information on combustible dust hazards. Yet these training seminars also make continuing reference to the CSB dust study in addition to the OSHA Combustible NEP, which unfortunately omits hundreds of manufacturing sub-sectors (NAICS). This training is fine and much needed in the industry. A problem arises when plant owners and managers are not obtaining the complete picture of the magnitude and depth of combustible dust hazards.

The Chemical Safety Board is not to blame. This agency is the finest accident investigation agency in federal government and has provided the industry with crucial information in preventing future accidents. With a limited budget these dedicated professionals are on the front lines investigating catastrophic accidents finding the root cause. What the agency isn't, is a research organization like the Bureau of Labor Statistics

OSHA Dust NEP NAICS

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Get the Knack of the NAICS
Referring to the above destructive fire where a dust collector was involved in just one example of the hundreds of NAICS and tens of thousand of manufacturing plants not listed in the OSHA Combustible Dust NEP, where only 68 out of a 427 manufacturing NAICS are referenced in Appendix D-1 & D-2. Just because your facility is not one of the 68 NAICS listed in the NEP, don't for a second believe you have a free pass and all is fine and dandy.

If the process stream handles combustible particulate solids that generates combustible dust of any sort, then you are sitting on a bottle rocket waiting to go off when all the factors of ignition, heat, fuel, suspension, and confinement all come together in the rare moment. We all know what a vapor cloud explosion can do in the refinery sector. The same devastating overpressure effects occur with a dust explosion in the manufacturing sector. In fact, unbelievably for many combustible dusts, the deflagration index or explosion severity (Kst) is much higher.

Explosion Ventilation Panels in Action

Last weeks combustible dust explosion at a evaporated dairy product manufacturing plant in Visalia, California is an excellent example how explosion ventilation panels reduce the severity of combustible dust explosions. Fatalities, injuries, and adverse economic damage can be minimized when manufacturing process facilities initiate a thorough process hazard analysis and follow the guidelines in the NFPA combustible dust standards, which address the objectives of life safety, structural integrity, and mission continuity through preventative and mitigative control measures.

OSHA's continuing proactive efforts in ensuring that manufacturing facilities have minimized the occurrence and reduced the severity of combustible dust hazards in the workplace is best illustrated when reviewing an inspection report and General Duty Clause citation ($6,400) completed several months earlier at similar evaporated dairy product manufacturing plant (NAICS 311514) in Wisconsin.

General Duty Clause Citation(excerpt)
1.Protein dryer were located inside a building lacked explosion venting.
2.Storage bin, located inside the building, did not have explosion venting.
3.Pneumatic Conveyor did not have spark detectors

AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS to comply with National Fire Protection Agency (NFPA) Chapter 61 Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2008 edition; NFPA 69 "Standard on Explosion Prevention Systems" 2008 edition; NFPA 654 "Standard for the Prevention of fire and Dust Explosion from the Manufacturing, Processing and Handling of Combustible Particulate Solids" 2006 edition

Industry Leader
Hopefully the Wisconsin facility has taken immediate action on the key items which the OSHA inspector cited in the report. Other manufacturing facilities can learn from the recent explosion that occurred in California, where explosion ventilation panels effectively reduced the risk to life and property. California Dairies is an industry leader in the evaporated dairy product manufacturing sector and should be commended for the preventative and mitigative control measures that management instituted in addressing combustible dust hazards.

C/S Explovent Video-must see!

There are many sources where explosion ventilation panels can be acquired after a process hazard analysis is completed. For example, Construction Specialties is a global leader in providing explosion ventilation panels with it's field testable and ATEX 95 compliant C/S Explovent^® If your facility does not have explosion ventilation panels installed yet, then maybe it's time to include this important investment in the 2009 budget.

Resources

More details from Richard Cotta President and CEO of California Dairies 2:41 MP3
Example Milk Powder Process
Lessons Learned : Explosion in a Milk Powder Processing Plant
New Zealand Dairy Industry Spray Drying Plant-Dust Explosion Control

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.  

Flame Resistant Garments: Minimizing Combustible Dust Hazards

David Osbon here from UniFirst Corporation and just wanted to post to the blog to introduce myself to the network and talk about a few things related to Combustible Dust Explosions. Following the catastrophic events that took place in February in Port Wentworth, GA I have spent a great deal of time researching combustible dust and the hazards associated with dust. I will be the first to admit that prior to the February event I did not understand the devastating effect of these explosions. I do now - I have seen it first hand.

Minimizing the Risk
My background is technical in nature. Prior to my current employment I researched and developed flame resistant fabrics for the industrial sector (NFPA 70E Standard for Electrical Safety in the Workplace 2009 , Petrochem, Electric Utilities, etc). I have investigated many fatalities and in almost every case - the fatality was PREVENTABLE! In almost all cases EDUCATION and UTILIZATION of the appropriate Personal Protective Equipment (PPE) would have prevented or minimized the extent of the injuries associated with the accident.

Through all of the research I have conducted over the last several months, one of the main issues that I see as "lacking" in most of the CSB reports, the House of Representatives meeting (HR5522), and all of the OSHA NEP directive information is the utilization of PPE.

NFPA 2113 Flame-Resistant Garments
The OSHA directive CPL 03-00-008 Combustible Dust National Emphasis Program (Reissued) ,does make specific reference to General Duty Clause (OSHA 1910.132) citations if the hazard is present and the appropriate PPE is not utilized. The directive goes on to mention NFPA 2113 -Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire as a reference document for selection and care of FR garments. NFPA 2113 has a specific section that deals with combustible dust.

What I do not find is a specific section that requires the use of FR garments. As I have seen with the NFPA 70E market, the electric utility market, and the petrochem market - OSHA has generally left this area vague and has relied on the General Duty Clause as a "catch all" gray area to allow citations to be issued without having to write the requirement in to LAW!

After reviewing the LONG list of fines associated with the Port Wentworth event I did note approximately $249,000 in General Duty Clause violations. As information to the post - the Port Wentworth site is now outfitting ALL personnel in Flame Resistant garments to increase their overall level of protection.

Improved Technology
While flame resistant fabrics and garments will not eliminate ALL injuries associated with combustible dust hazards, I strongly believe that the use of these garments would have minimized some of the burn injuries. Fabric and garment technology has improved ten fold over the last 5 years. Garments are now lighter weight, more comfortable, more durable, and more protective than at anytime in the past.

We are in the beginning stages of working with NFPA on a new standard that would increase the awareness and use of protective garments in combustible dust situations.As well, a member of my team has just joined the ASTM committee that deals with combustible dust. I personally am active with ASTM F23 (Committee on PPE and Equipment) and F18 (electrical workers).

It is my hope that we can build a network of professionals that are experts on combustible dust that will be able to educate the public on the hazard and tools available to minimize burn injury. If we can save one life - this would all be worth it.

Combustible Dust Hazards Training-Strategic Alliances

Stakeholders across a wide spectrum of industry through education can minimize the occurrence and reduce the severity of combustible dust hazards that are inherent aspect of the manufacturing process. Strategic alliances of user groups, safety councils, OSHA regional offices, and industry leaders are vital in developing a situational proactive awareness in reducing fatalities, injuries, and adverse economic impact caused by combustible dust related fires and explosions.

OSHA Regional Training
MNOSHA (State OSHA Plan) which is part of the Minnesota Department of Labor and Industry consists of separate enforcement and consultation services. Through the Workplace Safety Consultation Division, MNOSHA has already presented two combustible dust training seminars in St. Paul and Cloquet and will be presenting the third seminar, " Preventing Combustible Dust Explosions," seminar November 19, 2008 in St. Cloud, MN. Seating is limited, call 651-284-5060 for additional information.

Currently MNOSHA is working on adopting the Federal OSHA Dust NEP, which is voluntary for the 22 states that have their own separate State OSHA Plan. An excerpt from the Novemeber 2, 2007 Minutes of the Occupational Safety and Health Advisory Council mentions MNOSHA's "Intent to Adopt Identical" combustible dust emphasis program as outlined in the Federal NEP. Hopefully in the future other State OSHA Plan states will follow the example that is being developed in Minnesota. In the meantime MNHA is hosting combustible dust seminars in a strategic alliance with BS&B Pressure Safety Management

User Group Training
Manufacturing and Energy Utility user groups are vital in addressing their membership concerning "best practices." The PRB Coal Users Group is actively addressing the hazards of combustible dust in coal fired energy plants. When referring to the Combustible Dust NEP in Appendix D-1, Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires. coal fired energy plants are noted as NAICS 221112, Fossil Fuel Electric Power Generation . The PRB Coal Users Group in conjunction with Power Magazine is offering a Webinar "Combustible Dust: Proactive approaches to managing combustible dust,"
on Tuesday, October 28, 2008 at 10AM Central.

Safety Council Training
The Illinois Safety Council (ISC) has hosted several combustible dust training seminars over the past several months. Working closely with John Newquist, OSHA's Region V Assistant Regional Administrator for State Cooperative Programs and Joe Howicz, CSP and Fire Protection Expert, ISC will host additional training at the University of Illinois October 30, 2008 and November 20, 2008 with the Combustible Dust Explosion Inspection Seminars.

Industry Training
Chilworth Technology, an industry leader in providing process safety services throughout the industry is offering several one-day combustible dust training courses "OSHA Dust Explosion Inspection Preparatory Training," during November and December in Georgia, New Jersey, and Illinois. Chilworth Technology offers a wide range of consulting services in preventing and mitigating combustible dust hazards.

Combustible Dust Policy Institute
It's important that all stakeholders with concerns of combustible dust hazards work together through strategic alliances in addressing the complex issue of combustible dust . The Combustible Dust Policy Institute serves as an informational gateway in providing a situational awareness throughout the manufacturing and utility sectors. Feedback and input is much appreciated and I welcome visitors to the Combustible Dust site in joining the professional combustible dust network on LinkedIn.

The mission of the Combustible Dust Policy Institute is to minimize the severity and reduce the occurrence of combustible dust related fires and explosions in the nation’s workplace. Through ongoing research of combustible dust related incidents, which identifies and evaluates risk, the Combustible Dust Policy Institute provides risk assessment information that a diverse spectrum of stakeholders utilize in effectively controlling combustible dust hazards. Assisting stakeholders in this endeavor, health and safety compliance is achieved in addition to reducing workplace fatalities, injuries, and adverse economic impact.

ComDust Alert #2 -Combine Harvester Combustible Dust Fires

I found an interesting article regarding combine harvester combustible dust hazards and would like to share it with everyone. It's really a combination of several stories that spans two continents, one under the equator for all you shellbacks and one above the equator here in the USA.

For instance, last week a news article from MPNnow (10/16/08) www.is.gd/4xV1 of a combine that caught fire in Farmington, N.Y., which was a total loss of $240,000. The farmer thinks that a spark from one of the blades ignited a layer of soybean dust inside the equipment. This sounds so familiar in the manufacturing sector where a spark travels through the duct work into the dust collector causing a fire or much worse an explosion.

Anyway, fast forward to an article today originating in Australia where harvesting of grain crops has begun and the Fire and Emergency Services Authority (FESA) is providing a warning :

"The machinery itself, I mean it's all metal so it can get hot and if there's any build up of dust on the equipment that does get hot, well then it can ignite very quickly and they'll lose a fairly expensive piece of equipment..."

These are excellent examples illustrating how hot surfaces cause combustible dust fires no matter if its in the manufacturing sector or farming sector. Until reading these articles originating from both sides of the Pacific Ocean I had no idea there was a combustible dust hazard on farm equipment. I wonder if all the global farmers operating those very expensive combine harvesters know about the combustible dust hazards?

10/13/08 Combine Fire-Argos, Indiana
10/6/08 Combine Fire - Elma, Iowa
1o/2/08 Combine Fire-Wallingford, Iowa