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.
Friday, November 7, 2008
Grain Facility ComDust Fires and Explosions
Tuesday, November 4, 2008
Combustible Dust Explosions 2008
The recent grain elevator explosion in Louisiana last week brought back stark memories of over three decades ago, in 1977, when a series of similar dust explosions occurred in grain elevators throughout the south, which resulted in dozens of workplace fatalities. Fortunately in the recent explosion no injuries or fatalities were reported, just a lot of frayed nerves from nearby residents with electrical service briefly interrupted along the Mississippi River.30 Combustible Dust Explosions
Over the past year, through media accounts, 30 combustible dust related explosions have occurred in the wood, food, chemical, metal, plastic, rubber, utility, and paper manufacturing sectors. On the western bank of the meandering Savannah River, workers weren't so lucky in escaping injuries or fatalities on the evening of February 7, 2008 when a catastrophic Imperial Sugar Refinery dust explosion occurred in Port Wentworth, Georgia. Subsequently, national media coverage created a much needed awareness concerning combustible dust hazards in the workplace.
Additionally, intense outrage amongst Democratic Congressional leaders responded with an emotionally drafted general industry combustible dust bill, which passed in the House, and now awaiting vote in the Senate. Results of the presidential election, with a potential shake-up of public policy concerning workplace health and safety will determine the future of the bill.
118+ Fires and Explosions
Unfortunately this year, the Imperial Sugar dust explosion was not an isolated incident. For instance over the past year, through media accounts, 118+ combustible dust related fires and explosions have occurred in the manufacturing, utility, and non-manufacturing sectors.
Trying to make sense of it all and why even dust explodes is an exercise in science combined with business and public policy across the vast ocean of the public and private sectors. The on-going tug of war between the interests of big business and labor complicates the matter even further in arriving at a cost effective solution in preventing future fatalities, injuries, and adverse economic damage.
Cursory Solution : Incomplete Data
Of major concern is how can public policy be created in Congress with ensuing OSHA health and safety regulation's if the extent of the problem is not completely evaluated? Costly governmental studies were completed, which resulted in federal directives that only provide a cursory solution to the combustible dust problem. In the meantime our nation's infrastructure in the manufacturing base is at threat from continuing preventable combustible dust related fires and explosions.
For instance the OSHA Combustible Dust National Emphasis (NEP) program is not even required in nearly half of the states with State OSHA Plans (strictly voluntary). That's only the tip of the iceberg, especially over the past year, where explosions and fires are occurring at facilities with dozens of NAICS not listed in the NEP.
Food Manufacturing
Reviewing the food sector, six out of the seven combustible dust explosions occurred in national food industries (NAICS) not listed in the NEP. With explosions occurring more than once at dehydrated food and evaporated diary product manufacturing plants. This is where a ComDust Hazard Alert goes out next, especially when these industries are not on the NEP radar. OSHA inspectors are actively inspecting these facilities as the following excerpt from a recent General Duty Clause (GDC) citation at a dehydrated food manufacturing plant in Wisconsin will illustrate:
"...The following C.O.W (cream of wheat) equipment did not have explosion/deflagration containment, suppression, inserting, or venting protection: a) Cooker room dust collector, approximately 375 cubic feet, was located inside the building lacking explosion venting. b) silo did not have explosion venting. d) pneumatic conveyor did not have spark detectors or propagation shut off devices to prevent explosion propagating forward or aft. "AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD..."
Overall, out of the 17 combustible dust related fires and explosion in the food sector, over 70% happened at facilities not listed in the OSHA Dust NEP. Are we seeing a trend here?
Paper Product Manufacturing
A glance at the paper manufacturing sector which includes 16 national paper industries (NAICS), not one is listed in the OSHA Dust NEP. So how many explosions and fires this year? How about 11 fires and explosions, which included two dust explosions. It's like a snowball rolling down the hill as the plot gets bigger and bigger with four paper mill combustible dust related fires, three sanitary paper product manufacturing fires, and two combustible dust fires at corrugated solid and fiber box manufacturing plants.
Plastics/Rubber Product Manufacturing
In all fairness the plastics and rubber manufacturing sector is well covered in the NEP. For example, seven combustible dust fires and explosions occurred this year which includes three explosions. There does need to be a reevaluation of whether these national plastic/rubber industries have a potential /D-2 or more frequent/D-1 history of combustible dust fires/explosions as outlined in appendix D-1 and D-2 of the NEP. All these explosions occurred in NAICS that were referenced in D-2 (potential for an incident). If incidents are reoccurring with explosions then wouldn't that move them from a potential/D-2 to a frequent/D-1 in the Appendix?
Conclusion
Other sectors in wood, chemical, textile, machinery and metal national industries have their share of explosions and fires as depicted in the chart for incidents in 2008. Stakeholders with financial interests in all these manufacturing and non-manufacturing sectors must understand that the OSHA Combustible Dust NEP is solely a directive which provides guidelines for OSHA inspectors in conducting enforcement and inspection actions at facilities.
It should not be used as guidance in preventing and mitigating future incidents, while misinterpreting that since your facility is not a listed NAICS in the NEP, you are out of danger from the hazards of combustible dust. Over 50% of the combustible dust explosions this year were at facilities with NAICS (national industries) not listed in the NEP. Don't be a statistic. As soon as possible initiate a process hazard analysis which identifies, evaluates, and controls the inherent combustible dust hazards at your facility.
For additional information if your national industry has a history of potential or high occurrence of combustible dust related fires/explosions contact John Astad at the Combustible Dust Policy Institute.
Saturday, November 1, 2008
$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
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
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.
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
Example Milk Powder Process
Lessons Learned : Explosion in a Milk Powder Processing Plant
New Zealand Dairy Industry Spray Drying Plant-Dust Explosion Control
Thursday, October 30, 2008
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.
Wednesday, October 29, 2008
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 (
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.
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