Footprints to Disaster-Combustible Dust

Justin Clift, Industrial Market Specialist at Hazard Control Technologies shares with readers at the Industrial Fire Journal an educational article in understanding how to assess, evaluate, and control combustible dust hazards in the workplace. Justin has extensive experience in providing coal fired power plants the professional guidance in minimizing the probability and reducing the severity of combustible dust related fires and explosions. There are dozens of other national industries that also have combustible dust hazards and stakeholders can acquire a basic understanding in how combustible dust hazards develop so as to initiate preventative and mitigative measures using administrative controls and best engineering practices as outlined in the article.

Enlightening topics that are discussed in Justin's very thorough article are float dust, fugitive dust, fire department education on combustible dust hazards, and incident investigation follow-up of combustible dust incidents no matter how minor. Of extreme importance highlighted in the article is the explosive severity, where the Kst of combustible dust can change during the process while transferring from different stages during product movement. This problem is not just specific to the handling of coal but throughout all manufacturer sectors. Do you know the Kst of your raw products during the manufacturing process?

For additional questions specific to your facility or if your facility desires training courses, focusing on Fire Protection/Suppression/Prevention and Emergency Response contact Justin at Hazard Control Technologies

Resource
A blueprint for disaster Justin Clift Article in Industrial Fire Journal

Global Cooperation Needed Combustible Dust Hazards

Last month's fire that raged through the Paarl Print Factory in Paarl, South Africa that killed a 13 workers and seriously injured many more was reminiscent of fatalities and injuries that occur in the manufacturing sector here in the USA.

A press release issued by the Chemical, Energy, Paper, Printing, Wood and Allied Workers' Union (CEPPWAWU) spokesperson, Cedric Maluleke stated, "preliminary finding that the initial small fire in the cafeteria was propagated through the building by an ensuing dust explosion. This was fueled by paper dust that had accumulated on the open rafters of the building and which had been raised into the air by the shockwave."

The above description is a textbook example of a deflagration where the pressure wave moves at the speed of sound (768 mph) and a devastating fireball following shortly thereafter. Hopefully we can learn from our global trading partners in minimizing the severity and probability of future combustible dust incidents. Currently the OSHA Dust NEP has failed to list paper industries, like the above example, as a combustible dust hazard in the Appendix of the Dust NEP.

This is quite troubling especially when reviewing the Prerule abstract for the combustible dust rulemaking that the Dust NEP will be the foundation for the rulemaking process. Scary stuff. So who is the wizard behind the curtain at OSHA deciding which national industry (NAICS) has a combustible dust hazard or not? Over 50% of combustible dust incidents last year occurred in national industry's not listed in the Dust NEP.

Without acknowledgment that incidents are occuring in national industries not listed in the Dust NEP, stakeholders are unprepared in dealing with the hazards. The problem is intensified when OSHA Susan Harwood Grant Awardees of Combustible Dust Training also use the Dust NEP as the foundation for their training programs, which omits industries at high risk and types of materials (Did you Know?) that can create combustible dust hazards. Will it take an incident as catastrophic as the South African Paarl Print Factory for the wizard behind the curtain to wake up?

The USA is not the only stakeholder that is at loss with reality through lack of information. Especially when reading the press release from our South African trading partners that,"Dust explosions in industry are relatively rare. They are most often encountered in the coal mining industry and in the grain-handling and processing industries. Coal dust, grain dust and paper dust are inflammable and, when raised into the air, can explode."

So dust explosions are rare and most often only encountered in coal mining industry and in the grain-handling and processing industries ? I wish that were the case, but last year there were over 30 combustible dust related explosions in the manufacturing and non-manufactruing sectors here in the USA according to media reports.

Lessons learned from the tragic incident in South Africa and incidents here on our own shore is that before any rulemaking process can proceed in a manner that protects the workplace is to have an understanding of the the probability and severity of combustible dust related fires and explosions throughout the manufacturing, non-manufacturing and utility sectors.

The current Dust NEP formulated through the Chemical Safety Board recommendations is a start but stakeholders throughout industry still have a long way to go in order to protect the workplace from future fatalities and injuries when dust deflagrations occur.

Resources
Paarl Print plant fire disaster-Media Release

Combustible Dust Standards Task Group Forming

The Non-Ferrous Founders' Society (NFFS) is forming a task group in preparation for the lengthy OSHA combustible dust rulemaking process. Other national industries should also be forming task groups so as to provide the much needed input to OSHA during the comment period which includes stakeholder meetings that will be held in the future. The ANPRM will be published shortly in the Federal Register so stay tuned for further developments.

Are there other national industries (NAICS) forming Combustible Dust Standards Task Groups?

14th Annual VOSH Conference: Roanoke,Va

The Virginia Department of Labor and Industry will be hosting the 14th Annual Virginia Occupational Safety and Health Conference (VOSH) June 2-5 2009 at The Hotel Roanoke and Conference Center in Roanoke, Virginia, which is located at the western foot of the Blue Ridge Mountains in Roanoke Valley. Several dozen break-out sessions covering a diverse spectrum of topics on occupational health and safety will provide employers, employees, and health and safety professional the tools in developing a healthy and safer workplace.

Attendees also look forward to the Thursday morning keynote address by Chemical Safety Board Member, the Honorable Gary L.Visscher with the topic, "Heading Towards the Future in Workplace Safety." Visscher was appointed to the U.S. Chemical Safety Board by President Bush on August 2, 2004. Prior to the CSB appointment he served from 2001 as Deputy Assistant Secretary of the Occupational Safety and Health Administration (OSHA).

On Tuesday, June 2, pre-conference events will include an OSHA General Industry 10-Hour Course in addition to an OSHA Construction 10-Hour Course. Instructors from the Virginia Department of Labor and Industry, BECO Construction, Thor, Inc., Southern Air, and Western Refining Yorktown, Inc will be teaching these classes. Course fee is $55.oo

Wednesday, June 3 the VOSH Conference kicks off with Lunch and Conference Opening remarks by C. Ray Davenport, Commissioner of the Virginia Department of Labor and Industry and Jennifer S. Wester, Director of Cooperative Programs. Following lunch, nearly 50 hourly training break-out sessions will continue for two days until adjournment at noon Friday, June 5, 2009

Employers in the Commonwealth of Virginia will not want to miss the Wednesday and Thursday morning breakout sessions that Anna E. Jolly, JD, CHMM, will be presenting on, "Workers’ Compensation vs OSHA Recordkeeping Requirements." Ms. Jolly in addition to being an industrial hygienist is Vice President at Circle Safety and Health Consultants, a full service Occupational Safety and Health consulting company.

Combustible dust hazards topics will also be included at the VOSH conference with presentations that provide insight and potential solutions in minimizing the probability of incidents occuring at facilities. Currently OSHA is in the Prerule stage in developing a general industry comprehensive combustible dust standard and stakeholders must begin developing potential cost effective risk management solutions so as to provide input to OSHA during the comment period of the lengthy OSHA rulemaking process.

Subsequently, the combustible dust sessions will provide an overview of national industries (NAICS) experiencing combustible dust incidents not listed in the Dust NEP in addition to helpful insight and possible cost effective administrative control measures that are also utilized in the OSHA Process Safety Management (PSM) standard where deflagration hazards also exist with vapor cloud explosions.

On-site fee for the VOSH Conference is $290.00. Major contributors to the VOSH conference include:
• Virginia State Association Of Occupational Health Nurses
• Colonial and Tidewater chapters of the American Society of Safety Engineers
• Central and Tidewater VA sections of the American Industrial Hygiene Association
• Virginia AFL-CIO

Resource
VOSH Conference Brochure

Tank Battery Explosion from 200 yards away

Regular Speed of Video

David Drummond says,
"While shooting some ENG/stock footage last night of a tank battery fire near Lamesa, TX that was ignited by lightning, an explosion took place that sent a foot and half long, 4" diameter pipe valve from 200 yards away arcing directly into the front of my storm chase vehicle causing extensive damage.

This is closer than you EVER want to be to an explosion!

Firefighters from Lamesa and Andrews, TX fought to keep the fire down and the tanks cooled off for an hour before it finally exploded. Miraculously, all managed to escape without injury!

Video aired today on NBC, CBS, ABC, CNN, TWC"

Videographer: David Drummond



Resources
STATter 911 (slow motion of explosion)
Firefighter gives detailed account

OSHA Combustible Dust Prerule Agenda

Celeste Monforton, DrPH, MPH Assistant Research Professor in the Department of Environmental and Occupational Health at the George Washington University and contributor of the public health blog, "The Pump Handle," has provided readers an excellent overview of Labor Secretary Hilda Solis's Regulatory Plan in her recent post with a discussion of the inner workings of the current Unified Agenda of Regulatory and Deregulatory actions, which includes Prerules of combustible dust and occupational exposure to silica, beryllium, and diacetyl.

According to the combustible dust prerule, the Advance Notice of Proposed Rulemaking is planned in August 2009 (no exact date yet) with stakeholder meetings sometime in December 2009.

It’s very troubling reading the Combustible Dust rulemaking abstract to learn that OSHA will be using information gathered from the reissued Combustible Dust NEP as the agency considers future rulemaking. This document does not provide a clear picture of reality. Especially considering that over 50% of combustible dust related fires and explosions in 2008, though media accounts, occurred in national industires (NAICS), not referenced in this outdated NEP.

Furthermore the 281 combustible dust incidents obtained from the CSB Dust Hazard Study does not address the thousands of incidents that have occurred over the past three decades. A sound occupational safety policy in protecting the workplace can only be formulated when stakeholders fully understand the probability of occurrence in addition to the severity. The CSB study was a great start but much more needs to be done in evaluating the hazard appropriately.

An OSHA comprehensive combustible dust standard is much needed but lets not get all warm and fuzzy by a quick fix like what has previously occurred decades ago with the OSHA Grain Facility Standard in which there was over 50 combustible dust related fires and explosions in 2008. Not counting the rare Feb. 7, 2008 Imperial Sugar Refinery incident, there was more economic damage and workplace injuries in the grain facility sector in 2008 than in the manufacturing sector from combustible dust related fires and explosions.

With such a complex subject as combustible dust spread across hundreds of national industries (NAICS), a negotiated rulemaking process like which occurred with cranes might be a viable option in addition to incorporating a hybrid process safety management (PSM) venue into the rulemaking process.

Resources
Agency Rule List - Spring 2009 (Select Dept of Labor in Dropdown)
Introduction to the Unified Agenda (must read ! )
OSHA-Reg-Agenda-Combustible-Dust (1910.307 Hazard Communication ???
OSHA's Regulatory Agenda and Guidance Projects-OSHA ASSE Presentation

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