Combustible Dust Explosions and Fires-ATEX

Defining ‘world-class’ safety

2016-02-23T08:58:00.001-06:00

From Safety+Health Magazine

Defining ‘world-class’ safety

What does the phrase mean, and how can organizations achieve world-class status?

Kyle W. Morrison

February 21, 2016

Key points

According to some experts, “world class” can be considered a catch-all phrase to describe how positive a safety culture is, and where an organization stands when compared to others in their industry.
Other safety practitioners describe world-class safety as measurable achievement.
Another expert says world-class safety is not an award or championship, and requires a sustained effort.

Additional resource

Read more about 'world-class' safety from The Campbell Institute.

To be considered “world class” is to be among the best. But what does it mean to have a world-class safety program? How can the status be achieved, and what weight does the phrase “world class” carry?

As Safety+Health found out when pursuing these questions, the answers are complex.

“I think the term is used very loosely. Everyone has their own definition,” said Tony Sykes, an Indianapolis-based health, safety and environmental consultant for Eli Lilly and Co.

Some, like Kevin Feeman – a total safety culture facilitator for a Union Pacific facility in Carson, CA – believe “world class” is “too ambiguous, too subjective and too meaningless.” Instead, Feeman said, organizations should “work toward your unified, success-oriented goals.”

Still, other experts who spoke with S+H pointed out a number of characteristics that could make up the backbone of world-class safety.

Defining the term

Megan Raines is the global director – safety and training at Dresser-Rand, a Houston-based oil and gas industry product manufacturer that recently was acquired by Siemens. Raines believes the path to
world-class safety is one that moves toward zero incidents and includes continuous improvement. “No organization is ever going to be perfect,” she said. “A world-class organization is one where you never think you’re good enough.”

Her viewpoint is similar to that of Sykes, who said that when speaking with senior management, he avoids using the term “world-class safety” too often – focusing instead on whether the organization is at the top of its game.

“What we want to drive toward is being the best we’re capable of, and being able to measure what ‘good’ is,” he said.

Sykes said “world-class safety” can be useful as a catch-all phrase for achieving a certain safety status, and being able to measure that status.

To a degree, world-class safety is used in a very generic sense, and world-class performance can be measured in a number of ways, according to Jim Johnson. Johnson is the former vice president of workplace safety initiatives for the National Safety Council and current vice president, partnerships, for DEKRA Insight.

Johnson believes most people understand that the term is reserved for organizations that have distinguished themselves through their safety performance and have evidence to support it.

A measureable achievement

Some stakeholders describe world-class safety as a measurable achievement, as opposed to receiving an award – or a sports team winning a championship.

“I don’t think it’s like winning the World Series. I think it’s a compilation of characteristics that define a company,” said Mike White. White is a member of the World Class Team – a group of safety
professionals who work to further the goals of the Campbell Institute of the National Safety Council. (For more information on the Campbell Institute, visit www.thecampbellinstitute.org.) He worked for four decades at General Motors, most recently as director of global safety programs.

Leadership, and how well safety is integrated into business operations, can help define whether an organization is world class, White said. (See “World-class safety management”.)

These characteristics can be measured and used to evaluate safety performance. According to Bill Bozzo, a consultant who recently retired as the vice president of environment, safety, health and sustainability for DM Petroleum in New Orleans, measurements can include employee engagement, training, involvement of safety committees and injury rates. These leading and lagging metrics can then be used to mathematically assess where an organization stands compared with others.

One tool to perform these calculations is the DuPont Bradley Curve, which assigns a value to companies’ performances and charts it. Companies are then plotted on the chart, which features a curve sloping down to the right. The far right of the curve – the lowest point in the curve – denotes a belief in zero injuries as an achievable goal, as well as an organization with teams of employees taking ownership and responsibility for safety. An organization on the far right of the curve, according to Sykes, whose company uses the DuPont Bradley Curve, signifies a relative safety culture strength score of at least 80 percent that aligns with low recordables and is among the best benchmark

companies that have participated in the past. This could be considered the tipping point as to whether an organization has achieved world-class safety status, he said.

World-class safety in and of itself may not be an award or dependent on such recognition, but some awards can be used as evidence of an organization having achieved world-class status. The Robert W. Campbell Award, given out by the Campbell Institute, is cited by some safety professionals as one example.

According to Johnson, the Campbell Institute identifies past winners as world class, and the award is reserved for companies with performance metrics and other indicators that set them apart from the majority of employers.

These measures aren’t based on profits or size because world class isn’t limited to multi-billion-dollar global companies, Johnson added. Small, family-owned businesses can and do achieve a reputation for having world-class safety.

“When it comes to a world-class level of performance for safety and health, industry doesn’t matter, the size doesn’t matter,” he said. “Any organization can achieve that standard by enhancing the right culture and committing to sustainable management systems for health and safety.”

Losing it

Achieving world-class safety is no guarantee of maintaining that status, stakeholders say.

According to Bozzo, an organization that wants to be considered world class must remain at the cutting edge of safety. He cautioned that what is cutting edge today could become commonplace tomorrow, and maintaining status quo could lead to falling behind organizations that are pushing
the envelope.

Culture plays an important role in determining world-class safety, Johnson said, because it creates the environment for systems to achieve excellence. He added that it can take years to get the right safety
culture in place, but loss of it can occur overnight (e.g., a change in leadership with reduced focus on safety).

Although most organizations capable of achieving world-class status have a strong safety culture with the appropriate processes in place to recognize and minimize risks, Sykes cautioned that culture still could decay if the organization rests on its laurels.

Johnson agreed.
“If a company has a culture that tends to believe in their own success, they may not hear the messages on opportunities to improve,” he said.

Bozzo speculated that some organizations may fall into a trap – they believe they’re “already there,” so they don’t need to push for continuous safety improvement. What those organizations should be
saying, he said, is “We need to do this because we’re world class.”

Although injuries, illnesses and deaths could indicate that a company has fallen from its world-class status, several stakeholders who spoke with S +H suggested that this isn’t always the case.

“Black swan” events – occurrences that exist but are rare – are unexpected. How an organization reacts to them helps define its integrity and world-class status, according to Bozzo.

Dresser-Rand experienced this in 2011 when a worker died on the job. It was the company’s first – and to date only – on-the-job fatality since being incorporated, Raines said. “You take it as a learning moment,” she said. “We took it extremely seriously and we really learned a lot from it, and put in policies and processes to ensure that would never happen again.”

A timely response to incidents, learning from them and working to minimize the possibility of another incident is what world-class companies do, Bozzo said. Such employers also take these steps with full disclosure and share their knowledge. Not only is this knowledge shared internally, but world-class companies share their bad experiences and solutions with others – both in and outside their peer groups, he added.

Injury rates alone don’t always paint the picture. If an organization has low rates one year and high rates the next, Sykes said, that company likely did not have world-class safety in the first place.

“You didn’t have all the elements in place and your system decayed,” he said. What may be the case in this situation was the company had a positive safety climate the first year, but that was not a reflection of the company’s overall safety culture. (Climate can be described as the measurement of safety in the short term, while culture is a sustained safety effort.)

World-class safety management

According to the National Safety Council, five characteristics help determine whether a safety management system is “world class”:

Leadership – The management of an organization must lead by example to help drive employee engagement.
Integrated systems approach – Integrating safety processes
into all business functions and structures can result in safety becoming
embedded in how an organization does business.
Performance measurement – Both leading and lagging indicators must be used to promote and monitor continuous improvement of the management system.
Alignment to core organizational initiatives – Through
visioning, strategic planning and budgeting, safety can become aligned
with all other objectives, strategies and values in an organization.
Corporate citizenship and off-the-job safety – Through
initiatives, world- class organizations extend their safety efforts to
both the community and employees outside of work.

Achievement

Further highlighting a key difference between winning an award and obtaining world-class safety, Bozzo described world-class safety as a journey, not a destination or goal. An award is static – becoming world class is a mindset, he said.

Although an organization can decide to go on this journey, Bozzo warned that it should not declare itself “world class.”

Sykes agreed that the term carries more weight when coming from others, but said sometimes an organization knows itself better than anyone else. However, he stressed that any company must be able to show its methods of measuring its performance to back up a world-class safety claim. Without evidence, such a claim would not be taken seriously.

Employers need to be able to show what sets their group above other entities, Raines said, and outside recognition and robust internal procedures both provide evidence as to whether an organization is truly world class.

In Raines’ opinion, Dresser-Rand meets these criteria. “It is not even a priority for us. It’s a value,” she said of safety. “It’s critical all the time.”

In addition to recognition from clients and outside groups, Raines cites Dresser-Rand’s uniform global disciplined processes that surpass regulatory requirements, employee engagement with a successful stop-work authority program, and strong leadership where the highest-level individuals are held accountable for their commitment to safety.

Becoming a world-class safety company does not necessarily mean it will sell more product, White said, but it can help drive its overall performance.

Bozzo suggested something similar. “World class has to do with how well you recognize your business and what the risks are in your businesses, and how effective you are at controlling that,” he said. “World class is all about doing it well.”

Have Your Say...CSB ComDust Recommendation Hearing (July 25 1:30 PM EDT)

2013-07-24T11:00:00.000-05:00

Ask and comment now, email comments@csb.gov Questions and comments to be read aloud at the meeting. To listen to the meeting via telephone, please use the following number and participant code: Access Number: 1-800-920-7487 Participant Code: 44665662#

Beginning at Thursday July 25 1:30 p.m. EDT, the Board will consider and vote on the status designations of four recommendations to OSHA related to the issuance of a general industry standard for combustible dusts:

Recommendation No. 2006-1-H-R1, issued pursuant to the CSB's Combustible Dust Study.
Recommendation No. 2008-5-I-GA-R11, issued pursuant to the CSB's Imperial Sugar Investigation Report.
Recommendation Nos. 2011-4-I-TN-R1 and R2, issued pursuant to the CSB's Hoeganaes Case Study.

At the conclusion of the meeting CSB Board Members are expected to designate an OSHA general industry standard for combustible dust as the CSB's first “Most Wanted Chemical Safety Improvement” issue.

Meeting Agenda http://www.csb.gov/assets/1/7/72513_Meeting_Agenda.pdf

Live Demonstrations at Combustible Dust Testing Lab July 25 New Jersey

2013-07-12T14:30:00.000-05:00

Live Demonstrations at Combustible Dust Testing Lab in conjunction with Two-Day combustible dust workshop July 25-26 North Cinnaminson, New Jersey.

Course objectives- the combustible dust hazard workshop will provide the basic knowledge in identifying, evaluating, and controlling combustible dust hazards. Topics include recognizing fire and explosion hazards, ignition sources in operations, isolation engineering controls, laboratory testing for ignition and explosive severity, best industry practices and administrative controls for prevention, and conducting a facility hazard assessment. Who should attend: management, health and safety, and maintenance personnel in industries with combustible dust hazards including food, grain, wood, pulp, paper, plastics, pharmaceutical, rubber, metals and fossil fuel power generation.

Information

Two -Day Workshop July 25 & 26, 2013

One-Day Workshop July 25 includes tour and live demonstrations in combustible dust testing laboratory

EMSL Analytical Combustible Dust Testing Options:

Initial Dust CharacterizationThe most important information determined in this stage are Percent Combustible Dust. This is the percentage of the sample that has the potential to be combustible when it is dry and fine enough to pass through a 40 mesh sieve (less than 420 μm in size). The testing includes:
- Percent through 40 Mesh Screen
- Percent Moisture Content
- Percent Combustible Material (calculated)
- Percent Combustible Dust (calculated)

Go – No Go Testing (Explosive Screening) – ASTM E1226This is an economical and practical way to determine if the dust in the sample has the potential to be explosive. Testing consists of exposing the fine dust in the sample to low energy igniters inside the 20-Liter Siwek explosion chamber and determine the explosion over pressure. If the dust is not found to be an explosive threat, the analysis can be aborted to avoid unnecessary fees. If the sample turns out to be explosive on the screen testing, the more comprehensive analyses listed below should be conducted.

Explosion Severity (Kst, Pmax, [dP/dt]max) – ASTM E1226This testing provides an indication of the severity of the dust explosion by determining the deflagration parameters. The larger the value of Kst, the more severe the explosion is. For this test, the dust is suspended and ignited in the Siwek chamber and the maximum pressureand the rate of pressure rise are measured.

Minimum Explosion Concentration (MEC) – ASTME1515MEC is the minimum concentration for explosivity of a combustible dust cloud. It is determined by suspending the dust in the Siwek Chamber.

Minimum Ignition Energy (MIE) – ASTM E2019MIE is the electrical energy discharged from a capacitor, just sufficient to produce the ignition of the most ignitable mixture of air and dust. It is determined by suspending the dust in a Hartmann Lucite explosion chamber.

Minimum Ignition Temperature Test (MIT) – ASTM E1491 (dust cloud)ASTM E2021 (dust layer)This test method covers the minimum temperature at which a dust cloud will autoignite when exposed to air and heated in a furnace at atmospheric pressure. It is determined by introducing the dust into a BAM oven. As an alternative, the minimum temperature of self-ignition of dust layer can be measured using a hot plate set-up.

Class II TestingThis level of testing involves a number of parameters that determine if the sampled dust is considered a Class II hazardous material. Class II locations are defined as locations with combustible dust having Ignition Sensitivity (I.S.) greater than or equal to 0.2 or Explosion Severity (E.S.) greater than or equal to 0.5. I.S. is calculated from MIT, MIE, and MEC for the sample normalized to Pittsburg coal dust, whereas E.S. is calculated from Pmax and[dP/dt]max for the sample, also normalized to Pittsburg coal dust.

Resistivity Testing (for metal dust in particular)The resistivity testing is particularly important for metal dust. The electrical nature of the dust is one criteria to determine if it is necessary to take special precaution with regard to electrical insulation of the equipment operating in a location with Class II dust.

View Other Fire Investigation Testing - Fire, Smoke, Char, Ash, Soot, Accelerants
FREE Combustible Dust Poster for Environmental Professionals
Download 8.5 X 11 PDF

Webinar: Combustible Dust: From Sparks to Fires to Explosions

2013-07-08T12:51:00.000-05:00

Over 500+ combustible dust related incidents in 2011 according to U.S Fire Administration (Department of Homeland Security) NFIRS reports. Find out more with free webinar ON DEMAND

Since the 2009 introduction of OSHA’s proposed combustible dust rulemaking following the 2008 Imperial Sugar Refinery catastrophic dust explosion, a regulation has not been finalized. In the interim, Congress has acted with the February 2013 reintroduction of a proposed combustible dust bill, “Worker Protection Against Combustible Dust Explosions and Fires Act (H.R. 691),” which directs OSHA to immediately publish an interim combustible dust regulation.

A problem arises in both the proposed OSHA combustible dust rulemaking process and reintroduced combustible dust bill in that neither acknowledges the multitude of “near miss” combustible dust related fires, precursors to catastrophic dust explosions and flash fires. In 2013 a preliminary analysis by the Combustible Dust Policy Institute (CDPI) of National Fire Incident Reporting System (NFIRS) 2011 data provided by the National Fire Data Center at the U.S. Fire Administration indicated over 500 combustible dust related incidents. The majority of these incidents are “near miss” fires in the manufacturing and non-manufacturing sectors with dust, item first ignited.

This webinar will provide valuable information on how partnering with the nation’s fire service assists facility owners, managers, and OHS professionals in identifying combustible dust hazards, preventing incidents, and reducing liability. The presenters will discuss the fire service’s response to the prevalence of repeatable “near miss” combustible dust-related fires occurring throughout U.S. industry.

REGISTER

Vacuum Collection Systems Designed for Explosive Dust Atmospheres

2013-05-16T05:31:00.000-05:00

When milling, machining, polishing, grinding, or drilling materials such as Titanium, Magnesium, Aluminum, Iron Oxides, Stainless Steel, and Carbon Fiber, manufacturers must address the inherent explosion and fire hazards associated with the combustible dust generated by these materials.

NFPA 484 Annex // A.3.3.6.1 Combustible Metal Dust.*

3.3.6.1* Combustible Metal Dust. “A combustible particulate metal that presents a fire or explosion hazard when suspended in air or the process specific oxidizing medium over a range of concentrations, regardless of particle size or shape.”

An overall system solution must address the process requirements, materials, and the volumes processed. All equipment in contact with hazardous / combustible dusts must be constructed in compliance with HazLoc Class II disciplines, and applicable N.F.P.A., A.N.S.I., and A.S.M.E. standards. Customized systems are usually application specific and sized appropriately for the collection, conveyance, and control of the materials, ratios, and anticipated volumes of debris to be recovered.

A basic understanding of the issues and solutions as relate to current developments in systems configurations, and best industry practices requires an explanation as to how catastrophic events occur. In the interest of enhanced worker and plant safety we will also review what can be done to prevent them.

FIRE:

Direct:

Combustible dust related fires occur in all cases as a result of combustible materials being exposed to an ignition source. This can occur either during or subsequent to machining when materials are within ignition sensitivity levels capable of supporting a deflagration.

During Transfer:

When being transferred for collection, combustible dusts can also impact duct work elbows and other constrained joints and as a result of high speed impact create a spark moving the ignition source toward a collection point. Non-grounded components accumulating an electrostatic charge, exposure to electrical motors or other spark producing equipment can also provide an ignition source.

Collected:

If an ember or spark is eventually transferred to a collection location and maintains ignition energy it can initiate a further transfer of the ignition to additional materials in the process stream.

Accumulated Residuals:

Layers of dust which have accumulated over time have also been documented as transmitting an initial deflagration to secondary areas. In a worst case scenario if suspended as a dust cloud, explosions are easily generated as the deflagration gains rapid expansion due to the increase of combustibles.

EXPLOSION:

Suspension:

Dust explosions occur when combustible materials are suspended in an air/fuel concentration consistent with rapid ignition transmission. If the initial deflagration generates even a primary explosion, the associated shock waves will dislodge any dusts which have accumulated over time on overhead beams, walls, duct work, machinery, or collection vents. When these materials are dislodged from their resting place, they become airborne and in the presence of the initial flame front ignition source presented by the initial deflagration, they will contribute to an even much larger secondary catastrophic explosion. Incidents reported in recent years here in the U.S. have documented multiple deaths, injuries, and significant property destruction.

COMINGLED MATERIALS:

S.D.S. (SAFETY DATA SHEETS) seldom refer to the inherent danger of finite dust particles generated during machining processes. They fall short by NOT expressing the M.I.E. (Minimum Ignition Energy) and minimum ignition temperature (MIT) thresholds and seldom address the issue of reactivity with other materials. In some industries such as aerospace, there are usually several materials in a waste stream. As an example, drilling and assembling aircraft structures will generate carbon fiber, titanium, aluminum, and stainless steel in varying combinations. These comingled materials lead to secondary handling issue that S.D.S. specifications don’t address. Using one collection system for recovering different materials from diverse operations should be evaluated by sample testing to determine if a volatile combination of materials with lower MIE than each by themselves may be present.

HOUSEKEEPING:

Housekeeping, provides increased worker and plant safety but usually adds to the overall cost of manufacturing operating expenditures. Safely removing accumulated combustible dusts requires specialized equipment and in some cases access can only be achieved if entire production areas are shut-down. As a result, cleaning activities are not performed as frequently as they should be thus increasing the risks associated with accumulated combustible dusts. To minimize personal risks, efforts should include materials safety awareness, safe handling protocols and training. For example, using plant compressed air to “blow-off” debris from recessed areas should be avoided as the resultant dust in suspension could easily propagate an explosion under the right conditions.

TESTING:

When dealing with any of the debris generated within the production waste stream, one of the first steps must include combustible dust testing of the materials for explosive severity and ignition sensitivity as they would be generated in the work environment. Sample collection(s) and submittal to an independent laboratory for testing under N.F.P.A. Code 68 is essential. Data received from such test results is mandatory when designing fire prevention and explosion protection equipment and process systems with sufficient capacities to safely accommodate subsequent collection, conveyance, and containment of the materials being recovered.

A PRO-ACTIVE SOLUTION: COLLECT – CONTROL – CONTAIN

Central Vacuum System

Current systems have incorporated both high volume air flow AND high vacuum to optimize collection efficiencies and transfer capabilities of heavy combustible dusts. The ability to collect and control the transfer of any debris or dust is related directly to the volume, size, weight, specific gravity, and surface area of the material to be addressed. Vacuum in itself provides no means to act upon any material unless there is substantial air volume available to generate the motive force behind transfer. Dust collectors generally rely upon large volumes of air flow and as a result impart minimal vacuum on materials to maintain their velocities in collection ducts.

Collect dust as it is being generated.

Hazardous dust migration in many cases has been eliminated by using specialized high volume – high vacuum / dust recovery systems to collect debris simultaneous to generation further containing the recovered materials and minimizing the burden of house-keeping. Within the aerospace industry, complete recovery of drill chips and dust at the work piece is currently in use on several projects and in automotive applications, debris recovery has been accomplished within assembly and machining operations with the same process.

Control dust during transfer:

The recovery of combustible particulate solids must assure that air/material ratios never approach critical M.E.C. (Minimal Explosive Concentrations) which could support ignition resulting in a deflagration which could travel either up or down stream of the event. M.E.C. ratios vary based on materials and process requirements, however the speed at which materials are transferred and the separation of these materials by excessive air volumes provides a means to isolate one particle from the next. High volume rate transfer also maintains the materials in suspension which minimizes their contact with duct work thus reducing the build-up of fines, clogs, static, and sparks

Contain dust for safe disposal:

Many terms apply to the initial separation of the combustible dusts from the recovering air stream such as Vortex, Centrifugal, or Gate type systems. Initial contact between recovered dusts and the receiving receptacle act to slow the materials in the air stream such that heavy materials drop out of the airstream before contact with any filtering media. General dust collectors employ filter “bag-house” configurations with high pressure air jets to back flush the filters on occasion to maintain collection capabilities as the finer materials in these type systems have a tendency to migrate into the filter media. Rotary valves or gates at the bottom of the recovery receptacles allow recovered materials to be collected for disposal.

SYSTEM FEATURES:

Items which may have been considered as “OPTIONAL” in the past should be considered as MINIMAL requirements in systems collecting and conveying combustible dusts in compliance to HazLoc Class II. Terminology may differ between industries and suppliers however the intent to which these are applied remains consistent with providing safety in the work place.

Specifically best industry practices include:

Grounding – and incorporating non-spark producing elements, materials, motors, switches

Spark / Heat detection – includes multiple high temperature rise sensors

Explosion detection – detect first pressure wave of an initial explosion ( see isolation below )

Explosion venting – pressure relief and / or rupture disk, vents explosion toward a safe area

Flame / Fire / Deflagration Suppression – appropriate to the material(s) being encountered

Flameless venting – prevents flame travel beyond location of occurrence

Isolation-Explosion gates – prevents flame travel “up-stream” or to other process areas

Minimized debris contained for safe daily removal

Plant personnel education, awareness and training

Author: J. Byron Walker is Director for Systems Design and Engineering @ TECH TRANS UNLIMITEDCORP. He has over 35 years of experience in Robotics and automation systems integration working in the automotive, aerospace, and electronics industries. He holds patents in finite parts cleaning technologies and is responsible for providing total systems solutions for the safe recovery and transfer of Hazardous Materials to which this article is directed.

Wisconsin Combustible Dust Hazard Awareness Seminar, May 16

2013-05-01T09:29:00.002-05:00

Full-day Combustible Dust Hazard Awareness Seminar. May 16, 2013, Northcentral Technical College, Wausau, Wisconsin. Workplace combustible dust related fires and explosions occur with alarming regularity throughout the global grain, mining, manufacturing and non-manufacturing sectors. Historically, many of these non-consequential incidents have escalated into catastrophic events. Subsequently, this educational seminar will provide stakeholders with the basic knowledge and skills in minimizing the probability of occurrence and severity of consequence of future combustible dust related incidents in addition to maintaining OSHA regulatory compliance.

Seminar agenda will include:

• Introduction to OSHA Regulations and NFPA Combustible Dust Standards

• Identifying combustible dust hazards

• Evaluating combustible dust hazards

• Administrative and engineering control measures

• Facility inspection and risk assessment

Date: May 16, 2013

Time: 9:00 a.m. - 5:00 p.m.

Location: NTC Wausau Campus

Price: $50

Media Must Cease in Referring West, Texas Facility as a Fertilizer Plant

2013-04-22T20:07:00.001-05:00

Fertilizer Plants Defined 101 from Combustible Dust Policy Institute

Quite alarming when nation-wide stakeholders don't believe they have anything in the magnitude of the West, Texas facility such as a fertilizer manufacturer yet have establishments supplying fertilizers to farmer end-users

Don't kid yourself folks, West Fertilizer was not a fertilizer manufacturer either, as the media incorrectly portrays in many instances. The Texas establishment supplied custom blended fertilizer to farmers in the area as a retail establishment in addition to operating a grain handling facility, yet exempt under the OSHA Process Safety Management (PSM) Standard, while handling a Highly Hazardous Chemical (anhydrous ammonia).

The media incorrectly labels the facility as a fertilizer plant. So a bakery that customs mixes flour and sugar is a flour mill or sugar refinery? As a result of this inaccurate information many stakeholders don't believe they have potential fire and explosion hazards in their backyard.

This is a dangerous trend where safety professionals must educate the media on the facts before others incorrectly believe no hazards exist. Unfortunately Texas authorities did not learn from the Magnablend catastrophe especially in regards to Local Emergency Planning Committees (LEPC).

NAICS 42451: Grain and Field Bean Merchant Wholesalers, in addition to West Fertilizer covered under EPA RMP handling anhydrous ammonia with OSHA PSM exemption.

Total number of facilities: 82
Number of deregistered facilities: 10
Number of processes that could reach off-site: 82
Total pounds of toxic chemicals in processes: 28,355,310
Total pounds of flammable chemicals in processes: 0
Number of 5-year accidents: 4
Number of deaths from 5-year accidents: 0
Number of injuries from 5-year accidents: 4
Amount of property damage from 5-year accidents: $0

NAICS 424910, Farm Supplies Merchant Wholesalers, additional establishments in USA under EPA RMP handling anhydrous ammonia with OSHA PSM exemption

Total number of facilities: 3,645
Number of deregistered facilities: 601
Number of processes that could reach off-site: 3,738
Total pounds of toxic chemicals in processes: 6,728,564,906
Total pounds of flammable chemicals in processes: 392,870
Number of 5-year accidents: 138
Number of deaths from 5-year accidents: 3
Number of injuries from 5-year accidents: 191
Amount of property damage from 5-year accidents: $209,774

NAICS 493130, Farm Product Warehousing and Storage. in addition to West Fertilizer covered under EPA RMP handling anhydrous ammonia

Total number of facilities: 260
Number of deregistered facilities: 121
Number of processes that could reach off-site: 267
Total pounds of toxic chemicals in processes: 101,485,227
Total pounds of flammable chemicals in processes: 72,000
Number of 5-year accidents: 5
Number of deaths from 5-year accidents: 0
Number of injuries from 5-year accidents: 4
Amount of property damage from 5-year accidents: $0

RMP was last updated on RTK Net with a set of EPA data made on May 30, 2012

TIER II Reporting To SEPC and LEPC's

Tier II in conjunction with LEPC' is a key element where many chemicals are not triggered with thresholds in the EPA/RMP or OSHA/PSM programs. In contrast, TIER II when used as intended by the LEPC's engages the necessary hazard awareness on the other side of the fence-line throughout the community in preventing, planning and preparing for future accidents.

What is a Texas Tier Two Report?
"Two types of thresholds that determine whether a hazardous chemical will be included on the Texas Tier Two Report:

#1. There are very low thresholds for any of the listed EPA Extremely Hazardous Substances (500 pounds or the Threshold Planning Quantity in pounds for the specific listed chemical, whichever amount is less).

#2. For all other "generally hazardous chemicals" products which require a Safety Data Sheet (SDS)under the federal Occupational Safety and Health Administration's (OSHA's) Hazard Communication Standard], the threshold for reporting is 10,000 pounds."

LIST OF LISTS
• EPCRA Section 302 Extremely Hazardous Substances
• CERCLA Hazardous Substances
• EPCRA Section 313 Toxic Chemicals
• CAA 112(r) Regulated Chemicals For Accidental Release Prevention

"This consolidated chemical list includes chemicals subject to reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA), also known as Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and chemicals listed under section 112(r) of the Clean Air Act (CAA).

This consolidated list has been prepared to help firms handling chemicals determine whether they need to submit reports under sections 302 and 313 of EPCRA and determine if releases of chemicals are reportable under CERCLA and section 304 of EPCRA. It will also help firms determine whether they will be subject to accident prevention regulations under CAA section 112(r)"

3rd IND EX Safety Congress Nuremberg, Germany April 24-25

2013-04-17T21:09:00.000-05:00

Nuremberg Castle
Photo Credit: Vitold Muratov

Industrial explosion protection IND EX Safety Congress in conjunction with POWTECH 2013 International Trade Fair for Mechanical Processing Technologies and Instrumentation.For instance, at POWTECH 2011: 704 exhibitors from 73 countries, 15,498 trade visitors (including TechnoPharm)

Two days of explosion protection session topics which also includes live dust explosions (outdoors) at the Nürnberg Convention Center. IND EX, the German based Association of Experts for Explosion Safety, organizes this two day extravaganza. Keynote Speaker: Dr. Bert Reichert -Nürnberg Hospital for Burn Traumas- "Fatal consequences of insufficient safety concepts - burn and explosion traumas to the human body."

Sessions chaired by Dr.-Ing. Johannes Lottermann, Dipl.-Ing. Richard Siwek, and Stefan Penno

Presentation topics include:

Dust explosion in a Fiber Board Factory

Protection of Mixers and Blenders against explosions

Combustion of Biomass - Influence of material specifications on explosion protection measures

Are we sure that certified safety systems are really safe?

Trends in norms, guidelines vs. old school approaches from the past

The design of explosion proof Battery Rooms for solar driven boats and consequences for other applications in the field of renewable energy

Modeling of Dust Explosions to determine optimum protection when EN standards and codes are not relevant or considered too conservative

State of the art in explosion isolation

Of using a belt as well as additional suspenders: Explosion safety repeated unnecessarily

Explosion safety goes South America - about the ABNT + its standardization efforts in Brazil

Simplified explosion protection of filters - explosion venting, explosion isolation + improved separation all in one

CFD simulations of the 20 liter explosion vessel

Dispersion of two-phase jets from accidental releases in hydraulic pipes
Hydrogen Hazards

Fact Sheet: 2011 Combustible Dust Related Incidents, NFIRS Analysis

2013-04-12T16:27:00.001-05:00

Fact Sheet: 2011 Combustible Dust Related Incidents, NFIRS Analysis from Combustible Dust Policy Institute

A Combustible Dust Policy Institute (CDPI) preliminary analysis of 2011 National Fire Incident Reporting System (NFIRS) incident data provided by the National Fire Data Center of the U.S. Fire Administration indicated over 500 combustible dust related incidents in manufacturing facilities where dust was the item first ignited. Near misses include incidents that did not result in any harm to personnel, the facility, process, or product. Analysis did not include the grain sector or coal-fired energy plants.

Additionally, the CDPI analysis does not include many incidents that were not reported by fire departments to the National Fire Data Center. As a result there are many more combustible dust related incidents that cannot be evaluated in determining whether the incident was a near miss or not.

Special thanks to the nation's Fire Departments, NFIC State Program Managers, and the National Fire Data Center at the U.S. Fire Administration in sharing this valuable Information.

Casual Pathways Between Near Misses and Catastrophic Events

Excellent article by Carsten Busch from Norway, highlighting Common Cause Hypothesis (CCH) which also pertains to near misses and catastrophic combustible dust related incidents. In the current OSHA ComDust rulemaking process and recently reintroduced proposed combustible dust bill H.R. 691, incidents resulting in property/content loss (30% NFIRS analysis) yet no casualties (approximately 95%) are considered near misses. Yet the casual pathways (ignition sources, dust management strategies, etc.) for the consequences of all combustible dust related incidents are all the same.

The true definition of a "near miss" is an incident not resulting in any harm to personnel, the facility, process, or product. So why are near misses ignored in accounting for combustible dust related fire and explosion hazards in protection of the workplace in the OSHA ComDust rulemaking process and recently reintroduced proposed combustible dust bill H.R. 691?

Report on preliminary findings of a study of incident reporting systems for near misses in nonmedical domains. This can also apply to combustible dust related incidents/accidents where NFIRS data provides a multitude of information in developing barriers for the prevention of future accidents.

Near Misses in Non-medical Domains

"Consequently, the same patterns of causes of failure and their relations precede both adverse events and near misses." Sounds familiar with ComDust related incidents at facilities whether it was flash fire, dust explosion, or layer fire? They all have casual pathways of improperly managed ignition sources and fuel sources. A written fire prevention plan (FPP) addresses these casual pathways initially at the organizational level. The next step would be implementation at the technical and operational level.

"We defined a near miss as any event that could have had adverse consequences but did not and was indistinguishable from fully fledged adverse events in all but outcome." Note: National Fire Incident Reporting System (NFIRS) was not included in the report of near misses in nonmedical domains.

U.S. Chemical Safety Board (CSB): Near Misses.
Dust Explosion Hazard Awareness / Imperial Sugar Management and Workers
(Page 54 .pdf) "The CSB concluded that the small events and “near-misses” caused company management, and the managers and workers at both the Port Wentworth, Georgia, and Gramercy, Louisiana, facilities to lose sight of the ongoing and significant hazards posed by accumulated sugar dust in the packing buildings."

CSB Key Findings: Imperial Sugar Refinery
Page 48 .pdf) # 4 "Company management and the managers and workers at both the Port Wentworth, Georgia, and Gramercy, Louisiana, refineries did not recognize the significant hazard posed by sugar dust, despite the continuing history of “near-misses’”

Hoeganaes
(Page 14 ,pdf) "Operators and mechanics reported being involved in multiple flash fires during their employment at the Gallatin facility. At the time of the incidents, many were aware that the iron dust could burn or smolder. However, they were not trained to understand the potentially severe hazard when accumulated dust is dispersed in air. Rarely would operators report the minor flash fires and “near-misses” that periodically occurred."

(page 27 .pdf) CSB Recommendations to Hoeganaes 2011-4-I-TN-R9
"Develop and implement a “near-miss” reporting and investigation policy that includes the following at a minimum:"
• Ensure facility-wide worker participation in reporting all near-miss events and operational disruptions (such as significant iron powder accumulations, smoldering fires, or unsafe conditions or practices) that could result in worker injury.

• Ensure that the near-miss reporting program requires prompt investigations, as appropriate, and that results are promptly circulated throughout the Hoeganaes Corp.

• Establish roles and responsibilities for the management, execution, and resolution of all recommendations from near-miss investigations

• Ensure the near-miss program is operational at all times (e.g. nights, weekends, holiday shifts).

Conclusion

Near misses can no longer be ignored. It's very distressing that OSHA in the combustible dust rulemaking process in conjunction with the legislators in the reintroduction of the proposed combustible dust bill H.R. 691 have chosen to ignore 95% of combustible dust related incidents in manufacturing facilities, which do not result in personnel casualties. Yet these very same incidents, as history illustrates are precursors to catastrophe.

Explosion Relief Systems Free AIA Webinar May 1st

2013-04-02T12:11:00.001-05:00

“Explosion Relief Systems for Low Strength Enclosures”

Date : Wednesday the 1^tst of May 2013 @ 11am EST

C/S Explovent, a division of C/S Construction Specialties, is inviting you to join a free webinar about “Explosion relief systems for low strength enclosures”!

Introduction:

The issue of venting violent overpressures is a critical one for owners of facilities where potentially explosive atmospheres, materials, and processes exist including combustible dust. Recent statistics indicate that the average damage due to explosions in industrial establishments is approximately $3.4 million, compared to $210,000 for an average fire. The possibility of an explosion occurring must be seen as a real concern considering only three common elements must be in place for an event to occur: ignition source, a fuel, and confinement. As obvious as it sounds, even fine dust particles and a spark can create an explosive atmosphere. We might not think of this, but if something can burn, it can likely explode.

An explosion vent is designed to be the weakest part of the external structure. As the explosion vent experiences the pressure rise, it opens quickly allowing the rapidly expanding heated gases to be released to the outside. By doing so, the internal walls, floor, and ceiling are spared from the damaging overpressure experienced during a deflagration.

To successfully limit damage to the vented area, vent design and the pressure resistant structure must be in keeping with guideline authority recommendations. As such, C/S Explovent® explosion relief systems have been designed in accordance with the NFPA 68 Venting of Deflagrations guideline and Factory Mutual 1-44 Damage Limiting Construction document. Explovent® has been tested, approved, and labelled by Factory Mutual and tested and approved by the Canadian Center for Mineral and Energy Technology for explosion relief applications.

Participants will learn:

What explosion relief is
What industries have a true need for explosion venting products
Types of explosions & catalysts as they relate to the industry
Why explosion venting should be specified
Code drivers & their impact on today's specifiers
Overview of available explosion venting products

To register and get more details about this free webinar, just click on the link and follow the step!

About C/S Construction Specialties: For 60 years, Construction Specialties has been a leader in architectural specialty products, including : Acrovyn® Wall and Door Protection, Pedisystems® Entrance Flooring, Expansion Joint Covers, Cubicle Track and Curtains, Smoke and Explosion Venting Systems, Architectural Grilles, Architectural Louvers and Sun Controls. We have operations throughout the world and can provide C/S Products virtually anywhere. For a complete list of our international locations, visit www.c-sgroup.com.

This presentation is AIA Accredited

California Lower Rate of Combustible Dust Related Incidents Due to FPP?

2013-03-28T02:05:00.000-05:00

California Lower Rate of Combustible Dust Related Incidents Due to FPP? from Combustible Dust Policy Institute

How come California with more manufacturing facilities than any other state (approx. 40,000 establishments-U.S. Census Bureau-2010) yet has a lower rate of combustible dust related incidents than any other state? Could it be that they require fire prevention plans (FPP) for all facilities whereas other states don't? Shouldn't a state with the highest number of facilities also have the highest number of incidents? Quite interesting accidentally connecting the dots between combustible dust related incidents in a preliminary analysis of 2011 NFIRS data and fire prevention plans (FPP) 29 CFR 1910.39.

It’s back to school for us all after coming across this helpful resource with the University of California Riverside's Fire Prevention Plan (FPP) providing an excellent framework with FPP key elements as required by the California Code of Regulations (CCR) Title 8, Section 3221. The detailed FPP document includes a section on Fire Extinguishers where "all faculty and staff are annually provided the opportunity to receive hands-on training and experience in using portable fire extinguishers."

California is one of the approved State Plan States that went beyond minimum federal OSHA regulatory requirements concerning FPP's (Exemptions. 1910.157(b)(1)) For example, California facilities not requiring the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal are required to have a Fire Prevention Plan (CCR Title 8, Section 3221).

Whereas Federal OSHA states don’t require a Fire Prevention Plan (FPP) in this scenario unless the facility follows under one of these three host standards: Ethylene Oxide, 1910.104, Methylenedianiline, 1910.1050, and 1,3 Butadiene, 1910.105. Additionally FPP required where the written fire safety policy requiring the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal.

With a bit of imagination the University of California Riverside's Fire Prevention Plan (FPP) provides an excellent framework for a voluntary FPP’s which should include controlling ignition and fuel sources in the prevention of combustible dust fires and explosions. The U.S. Chemical Safety Board (CSB) did not make any FPP recommendations in the 2006 Dust Hazard Study. As a result OSHA has not recognized FPP in the 2008 Combustible Dust National Emphasis Program (NEP), 2009 Combustible Dust Advanced Notice of Proposed Rulemaking, 2011 OSHA Combustible Dust Expert Forum, nor on the OSHA Combustible Dust Hazards webpage. The Democrat Committee Education and the Workforce has acknowledged this error with the reintroduction of the proposed bill, "H.R. 691 Worker Protection Against Combustible Dust Explosions and Fires in the Workplace," where 40% of the requirements in the bill are from content in the OSHA Fire Prevention Plan (FPP) 29 CFR 1910.39.

Fire prevention plans (FPP) are an excellent administrative and procedural control measure in minimizing the probability of occurrence of future combustible dust related incidents by managing and controlling potential ignition and fuel sources. Without FPP's combustible dust related incidents will continue to occur in an unabated manner. The majority of combustible dust related incidents are "near misses" precursors to catastrophe. As a result combustible dust hazards are primarily a fire issue and secondarily a potential explosion problem.

Proposed Combustible Dust Bill Relationship to OSHA Regulations

2013-03-25T22:34:00.000-05:00

Proposed Combustible Dust Legislation H.R. 691,Worker Protection Against Combustible Dust Explosions and Fires Act of 2013. Presentation illustrates relationship of proposed combustible dust bill with OSHA regulations. Approximately 40% of the requirements are mirrored from content in the OSHA Fire Prevention Plan 1910.39 in addition to approximately 50% of content analogous to OSHA's Process Safety Management 1910.119 regulations.

Many of the NFPA combustible dust standards also include elements of Process Safety Management (PSM) such as management of change (MOC), accident investigations, contractor training, etc. Additionally elements in the requirements of the proposed bill include: Hazard Assessment 1910.132, Hazard Communication (HazCom) 1910.1200, Process Safety Management (PSM) 1910.119, Lock-out/Tag-out (LOTO)1910.147, and Hot Work 190.252.

The proposed reintroduced legislation fails to address in the "findings" the importance of training, education, outreach, inspections, and enforcement at the local jurisdictional level with the I-Codes such as the International Building Code and International Fire Code which reference the NFPA combustible dust standards. There exponentially more local building and fire inspectors conducting plan review, permit approval, and inspections than the limited resources of OSHA inspectors working out of distant area offices. Fires can never be effectively regulated at the federal level since fire prevention and protection is a local issue. A cohesive collaboration between local, state, and federal agencies would be a equitable solution in addressing the contentious and complex subject of combustible dust fire and explosion hazards in H-2 High-Hazard occupancies which appear to many as benign deflagration hazards with the continued occurrence of "near misses" throughout all sectors

YouTube video on slide #2 is Representative George Miller (D), Chairman of the Education and Labor Committee, making a statement during floor debate on HR 5522, the Worker Protection Against Combustible Dust Explosions and Fires Act, on April 30, 2008. The bill passed in the House of Representatives April 30, 2008, 6:56 p.m. with a 247/165 simple majority vote but was never passed by the Senate.

OSHA Fire Prevention Plans (FPP) & Hazard Assessments Ignored by Many

2013-03-23T14:47:00.000-05:00

Figure 6. Number of Combustible Dust Related Violations

Figure 6. "Number of Combustible Dust Related Violations" OSHA Status Report on Combustible Dust National Emphasis Program (NEP) does not even note any combustible dust related violations for "1910.39 Fire prevention plans." How odd especially with requirements of a written plan on proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard. In addition to procedures to control accumulations of flammable and combustible waste materials in conjunction with procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials.” I guess combustible dust is not considered a combustible waste material nor a hazardous material?

Congressional Proposed Interim Standard
Since OSHA 1910.39 Fire prevention plans have been ignored regarding combustible dust hazards they will now be included in the reintroduced combustible dust legislation "Worker Protection Against Combustible Dust Explosions and Fires Act of 2013," for an OSHA interim combustible dust standard. Elements in an interim standard will include:

(2)written program that includes provisions for hazardous dust inspection, testing, hot work, ignition control, and housekeeping, including the frequency and method or methods used to minimize accumulations of combustible dust on ledges, floors, equipment, and other exposed surfaces.

(3) Requirements for engineering controls, administrative controls, and operating procedures, including means to control fugitive dust emissions and ignition sources, and the safe use and maintenance of process equipment and dust collection systems and filters.

(4) Requirements for workplace inspection and housekeeping to prevent accumulation of combustible dust in places of employment in such depths that it can present explosion, deflagration, or other fire hazards, including safe methods of dust removal.

(6) Requirements to provide written safety and health information and annual training to managers and employees and their representatives, including housekeeping procedures, hot work procedures, preventive, predictive, and periodic maintenance procedures, common ignition sources, and lock-out, tag-out procedure.

NOTE: OSHA Fire Prevention Plans (FPP) only required if all of your employees evacuate immediately during a fire emergency (page 15 .pdf) or if one of these three host standards apply: CFR 1910.1047(h)(1)(iii): Ethylene Oxide, CFR 1910.1050(d)(1)(iii): Methylenedianiline, or CFR 1910.1051(j): 1,3-Butadiene.

Additionally no mention in the 2009 OSHA Status Report on Combustible Dust National Emphasis Program regarding combustible dust related violations in failure to have a certified written Hazard assessment 1910.132(d)(1) “The employer shall assess the workplace to determine if hazards are present, or are likely to be present...” Legislators did not forget that one either in the reintroduced combustible dust legislation with (1) Requirements for hazard assessment to identify, evaluate, and control combustible dust hazards.

OSHA Citations: Fire Prevention Plans (FPP) and Certified Hazard Assessments
Question is how can there be hundreds of combustible dust related incidents annually with over 500 in 2011 according to a CDPI preliminary analysis of NFIRS data, if the required OSHA written Fire Prevention Plans (FPP) and certified Hazard Assessments plans are adhered to? Is it just a paper chase and stakeholders doing nothing more than filing the required written plans in the office file cabinet?

Federal OSHA citations for the period October 2011 through September 2012 in the Lumber And Wood Products industries, (Except Furniture) there was no Federal OSHA citations for 1910.39 - Fire prevention plans (FPP). With the over 500 ComDust related incidents in 2011 according to a preliminary NFIRS analysis, the Lumber And Wood Products industries experienced over 16% of the incidents. How can there be so many incidents yet in the same vein FPP is adhered to regarding regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials?

This observation is not meant to solely pick on the Lumber And Wood Products as there are dozens of other diverse industries handling combustible particulate solids. For example out of the over 12,700 Federal OSHA citations at 2,419 facilities in the manufacturing sector from October 2011 through September 2012, only two (2) Federal OSHA citations for 1910.39 - Fire prevention plans (FPP) So the odds of receiving an OSHA citation for FPP in that time period was 0.016% out of the nearly 13,000 citations.

Conclusion
The problem is intensified when viewing the OSHA website on combustible dust hazards where, "Federal OSHA standards are mandatory; they include provisions that address certain aspects of combustible dust hazards. Some are industry-wide and others and industry-specific." No mention at all regarding certified written hazard assessment 1910.132(d)(1) nor any note of 1910.39 Fire prevention plans. Additionally, in the OSHA ComDust NEP numerous OSHA CPL's listed in the reference section yet CPL 2-1.037, Compliance Policy for Emergency Action Plans and Fire Prevention Plans excluded. Wouldn't it be prudent for all global stakeholders to implement the protections of hazard assessments and fire protection plans now instead of waiting for the results of proposed combustible dust legislation and regulations?

Building Signage Communicating Hazards Will Save Lives

2013-03-12T13:56:00.000-05:00

Truss Signage

International Fire Code (2012) Appendix J - Building Information Sign, provides excellent guidance in communicating high-hazard occupancies to fire crews responding to combustible dust related fires and explosions. Many fire departments are not aware of the inherent special risk of a HazMat nature when responding to these types of incidents. The situation is especially critical with lack of resources for many jurisdictions in conducting pre-site visits as outlined in NFPA 1620 Standard for Pre-Incident Planning.

“Truss signage,” is an excellent example currently implemented in numerous jurisdictions throughout the nation in preventing injures and fatalities of fire-fighters due to truss system failures. Similar signage as referenced in the International Fire Code (2012) and NFPA 704 will effectively communicate hazards to fire departments responding to facility combustible dust related incidents.

“Fire Chief did not receive an MSDS sheet from facility until the next day. Fire Chief added that if he had the MSDS sheet at the time of the incident his tactical decisions would have been different.” –excerpt accident report. This example illustrates if High-Hazard H-2 occupancy signage was affixed to the outside of buildings, fire crews would know upon arriving at the fireground that deflagration hazards are present. NFPA 704 signage produces similar results. A flammable vapor cloud explosion (VCE) is not much different than the severity of a wood dust deflagration as both involve damaging pressures waves followed by slower moving flame fronts of destructive flammable gases.

21st Century National Phenomena, Combustible Dust Fires and Explosions?

2013-03-02T16:58:00.000-06:00

Photo Credit: Sebastian Ritter

1973 Report of the President's Commission on Fire Prevention and Control "In pursuit of answers, the Commission has held hearings in five widely scattered cities, heard the testimony of more than 100 witnesses filling thousands of pages of transcript, and spent countless hours learning and deliberating in both formal and informal sessions.”

"In addition, special studies have been prepared by Commission staff and by a dozen experts from government and private groups exploring particular problems and their alternative solutions. Over 130 position papers were filed with the Commission advocating different approaches to the fire problem."

Fire and the Built Environment in Chapters 8-12 of the America Burning report notes fire hazards of Flammable Fabrics, Fireworks, Transport of Hazardous Materials, Aircraft Fire Safety, Marine Fire Safety, Motor Vehicle Safety, and Railroad Transportation Fire Safety. In contrast, combustible dust fire and explosion hazards were excluded from the report.

Fifteen years later, in 1987 a national workshop was held in Virginia on America Burning Revisited where again no reference to combustible dust fire and explosion hazards in the built environment. Ironically the OSHA Grain Handling Facilities Final Rule was published fours weeks after the national workshop on December 31, 1987.

Why is there a national disconnect between combustible dust related fires and catastrophic dust explosions? Eliminating combustible dust related fire hazards (heat, fuel, or oxygen) prevents a catastrophic combustible dust explosion or flash fire from even occurring. All five of the catastrophic combustible dust explosions the U.S. Chemical Safety Board (CSB) completed accident investigations on had a history of "near miss" non-consequential combustible dust related fires.

Inaccurate Data Distorts Complexities of Combustible Dust Hazards

2013-02-15T21:14:00.001-06:00

Columbia Graphophone of 1901.

It's like a broken record going round and round for nearly a decade with inaccurate incident data distorting the complexities of workplace combustible dust hazards. Now the Democrat House Committee on Education and the Workforce has reintroduced a combustible dust bill (H.R. 691) utilizing the same inaccurate incident data (approximately 10 incidents annually) as OSHA utilized in the 2009 Combustible Dust Advanced Notice of Proposed Rulemaking ANPRM (page 2 .pdf Table 1).

CSB stated in a disclaimer from their 2006 Dust Hazard Study, "The combustible dust incidents included here are likely only a small sampling, as no federal or state agency keeps specific statistics on combustible dust incidents..." This is an inaccurate statement especially since local fire departments, state fire marshals, and the National Fire Data Center/U.S Fire Administration of the Department of Homeland Security collects specific data on combustible dust incidents in accordance with the Federal Fire Prevention and Control Act of 1974 with the National Fire Incident Reporting System (NFIRS). For instance NFIRS data element #94 (dust, fiber, or lint. Includes sawdust) as item first ignited is entered in the NFIRS Fire Module (page 104 .pdf) by local fire departments following a response to an incident.

The Combustible Dust Policy Institute (CDPI) conducted preliminary analysis of NFIRS 2006 and 2011 combustible dust related incident data and determined between 500-600 combustible dust related incidents occurring annually in manufacturing plants, not 10-15 annually as indicated in the 2009 OSHA Combustible Dust ANPRM published in the Federal Register and recent Democrat House Committee on Education and the Workforce press release.

If congressional and administrative policy makers cannot accurately identify the magnitude of the combustible dust problem then how can it be expected to comprehensively evaluate the situation so as to develop cost effective control measures in protecting the nation’s valued workforce?

Comparing the partial success of the OSHA Grain Facility Standard in mitigating and preventing grain explosions to non-grain facilities generating combustible dust is like comparing apples to oranges. There are tens of thousands of facilities in a multitude of sectors in addition to manufacturing with combustible dust fire and explosion hazards compared to the much smaller number of grain facilities.

There is no doubt a standard or regulation is needed either through legislative action or OSHA administrative action. It’s like pouring the concrete foundation for a house or high-rise, you need plenty of rebar so the foundation does not become unstable later on. Not acknowledging the magnitude of combustible dust incidents fails to identify the precursors to catastrophic combustible dust incidents. A misguided and not well thought out regulation will only provide a warm and fuzzy feeling with huge economic and fire safety implications.

Resources
NFPA Report: Fires in U.S. Industrial and Manufacturing Facilities
OSHA Combustible Dust Expert Forum (page 45 .pdf Dust Incidents Table)
The Many Uses of NFIRS Data

2011 Geographic Distribution Combustible Dust Related Incidents

2013-01-30T00:36:00.001-06:00

Wisconsin	50
Ohio	40
North Carolina	30
Virginia	29
California	26
Georgia	24
Minnesota	22
Texas	22
Illinois	20

The Combustible Dust Policy Institute (CDPI) researched over 500 combustible dust related fires and explosions in manufacturing facilities utilizing 2011 National Fire Incident Reporting System (NFIRS) data provided by the U.S. Fire Administration's National Fire Data Center. All 50 states report NFIRS data with approximately 23,000 fire departments out of over 30,000 fire departments in the USA reporting NFIRS data each year which consists of about 75 percent of all fires occurring annually.

2011 NFIRS data indicated combustible dust related fires and explosions occurring in 40 out of 50 states with nine states reporting over twenty incidents as indicated by the table above. Since NFIRS is a voluntary program not all fire departments in the USA report incidents where property damage occurred. Content loss is also noted in NFIRS data in addition to property loss.

"NFIRS distinguishes between “content” and “property” loss. Content loss includes loss to the contents of a structure due to damage by fire, smoke, water, and overhaul. Property loss includes losses to the structure itself or to the property itself. Total loss is the sum of the content loss and the property loss."

In the vast majority of over 500 incidents in 2011 no fatalities, injuries, nor property damage occurred, which is similar to the results of a confined structure fires defined by the U.S. Fire Administration. In contrast, two workplace fatalities and fourteen injuries occurred in nine states. Additionally, ten fire-fighters sustained injuries while responding to combustible dust related fires. The 2011 NFIRS injury and fatality data conflicts with the 2006 CSB Combustible Dust Hazard Study for the 1980-2005 time frame, where it was noted, "injuries and fatalities occurred in 71 percent of the incidents." In 2011, property damage occurred in 30 percent of incidents with damage of less than $5,000 in 56 percent of incidents.

Combustible dust related incidents occurred in 20 of the 21 manufacturing subsectors in 2011. The food and chemical manufacturing subsectors experienced a total of nine incidents ( two food, seven chemical). In a following post additional information will be provided on a profile of affected industries and types of combustible dust involved in combustible dust related incidents during 2011.

Special thanks to the dedication and hard work of the local fire departments, state program managers, and staff at the National Fire Data Center at the U.S. Fire Administration in providing NFIRS data to end-users, "Fighting Fire with Facts." Without their continued efforts in identifying combustible dust related incidents, sharing this valuable information would not be possible.

2011 Over 500 Combustible Dust Related Incidents in Manufacturing Sector

2013-01-12T15:26:00.000-06:00

NFIRS Structure

National Fire Incident Reporting System (NFIRS) analysis #94 item first ignited and #700 manufacturing property use. NFIRS is a voluntary reporting system so many fire incidents are not reported to the National Fire Data Center of the U.S. Fire Administration in Maryland. If there is no incident report for the legal record, then it's as if the incident never happened. Thanks to the dedication of the local fire departments, state program managers of the the National Fire Information Council (NFIC), and the National Fire Data Center in providing this valuable incident data to stakeholders for further analysis and evaluation.

NFIRS analysis of 2011 manufacturing sector workplace combustible dust related incidents indicated 14 injuries and 2 fatalities. For all items first ignited at manufacturing facilities including dust, NFIRS data indicated a total of 115 workplace injuries and 15 fatalities. In addition to workplace injuries 10 firefighters sustained injuries responding to combustible dust related incidents at manufacturing properties in 2011.

Currently about 23,000 fire departments report NFIRS data to the National Fire Data Center each year out of approximately 30,145 fire departments. (Source: U.S. Fire Administration and NFPA). As a result solely utilizing NFIRS data is not conclusive and does not provide a total count of incidents, injuries, fatalities, and property damage. In contrast, NFPA conducts a National Survey of fire departments in the development of a scaling ratio in conjunction with NFIRS data which assists in filling the gaps of insufficient NFIRS data.

Stakeholders are highly encouraged to review the informative NFPA report "Fires in U.S. Industrial and Manufacturing Facilities (2006-2010) " provided by NFPA’s Fire Analysis and Research Division. For all types of fires the recent NFPA 2012 report noted an annual average of 22 fatalities and 300 injuries at industrial and manufacturing properties which also includes the utility, defense, agriculture, and mining sectors..

Evaluating NFIRS data stakeholders can observe emerging trends in NAICS, Area of Fire Origin, Heat Source, Type of Material First Ignited, Cause of Ignition, Factors Contributing to Ignition, Equipment Involved in Ignition (EII), Presence of Detectors, Presence of Automatic Extinguishing System, Casualties, Property Loss, etc. The next intermediate step in an evaluation is utilizing NFPA 550 Guide to the Fire Safety Concepts Tree then culminating with implementing control measures in the NFPA combustible dust standards, International Fire Code, and FM Global Property Loss Prevention Data Sheets.

The OSHA Combustible Dust; Advance notice of proposed rulemaking, Table 1--Industries Having at Least One Recorded Combustible Dust Incident Reported Since 1980 is misleading and not reality noting 422 combustible dust incidents in a 28 year time span or approximate average of 15 incidents annually. To fully understand the depth of the combustible dust problem in the workplace it is imperative the fire service be included in future dialogue regarding training, outreach, education, inspections, and enforcement.

Key stakeholders from the fire service having intimate knowledge of fire and explosion hazards in non-residential building structures include: International Association of Firefighters (IAFF), International Association of Fire Chiefs (IAFC), National Volunteer Fire Council (NVFC), National Association of State Fire Marshals (NASFM), and National Fire Information Council (NFIC).

Appropriately the contentious issue of combustible dust hazards in the workplace is primarily a fire hazard and secondarily an explosion hazard. Subsequently, the majority of combustible dust related incidents are non-consequential (near misses) fires with no injuries, fatalities, nor property damage. This results in a disturbing mindset of "normalization of deviation" where facility owners and managers falsely believe that since nothing bad has happened in the past then nothing bad will happen in the future. Initially addressing the fire hazards will eliminate the possibility of secondary catastrophic dust explosions or disastrous flash fires.

Incident Type data element # 244 Dust explosion NFIRS

2012-12-21T15:11:00.003-06:00

Area of Origin: 2006 NFIRS Combustible Dust Related Fire Analysis

Just recently an Incident Type data element #244 Dust explosion (no fire) was added to National Fire Incident Reporting System (NFIRS) (Page 3-24 .pdf). Many stakeholders are aware of combustible dust related fires with an Area of Origin in which NFIRS also recognizes service area data elements #52 Conduit, pipe, utility, or ventilation shaft, #55 Duct, Includes HVAC, cable, exhaust, and #58 Conveyors (pages 4-16 and 4-17 .pdf) In contrast, no recognition of dust collectors in Equipment Involved in Ignition (EII), Shop Tools and Industrial Equipment (pages 4-31 though 4-32) nor Area of Origin. A recent analysis of NFIRS 2006 data indicated pipes, ventilation shafts, ductwork, and conveyors as the area of origin in over 16% of combustible dust related fires in manufacturing sector service areas.

FM Global provides informative guidance in "Prevention and Mitigation of Combustible Dust Explosions and Fire," Property Loss Prevention Data Sheet No. 7-76, (page 38 .pdf) in Table 6 Loss by Equipment Type with dust collectors noted as the leading type of equipment involved in combustible dust incidents.

Here in the USA a problem arises with fire departments voluntarily reporting dust collector explosions or fires to the National Fire Data Center (NFDC) through National Fire Incident Reporting System (NFIRS). For instance, there's no specific data element to report dust collectors in NFIRS like for the data element #244 dust explosions. If the incident is not recorded then it is as if the incident never happened. NFIRS data is considered a legal document for reporting purposes

Is this acceptable to recognize data element #244 dust explosion in NFIRS yet ignore dust collectors? Sort off like a Catch-22 situation where many dust explosions and combustible dust related fires occur in dust collectors yet no adequate manner to report dust collector incidents comprehensively.

Currently there are no immediate plans for changes to the NFIRS. In the meantime, the National Fire Data Center (NFDC) accepts suggestions for changes for review in the next version of NFIRS. Anyone is welcome to forward specific suggestions to NFDC in addition to supporting documentation. Please forward documentation requesting a dust collector data element be added to NFIRS to Brad Pabody, Chief, National Fire Data Center, United States Fire Administration (301) 447-1049 (Fax) or brad.pabody(@)dhs.gov Thanks.

Resources
NFIRS 5.0 Complete Reference Guide

Guidance on how to analyze NFIRS Version 5.0 fire data, refer to USFA’s National Fire Incident Reporting System Version 5.0 Fire Data Analysis Guidelines and Issues documentation.

Information about the methodologies used in analyzing NFIRS data, Chapter 1 of Fire in the United States 2003-2007 15th Edition.

Using NFIRS to compute national estimates in analyses, article on the National Fire Protection Association’s (NFPA) Web page “The National Estimates Approach to U.S. Fire Statistics” by Hall and Harwood.

· Details on the U.S. Fire Administration’s current fire data estimation methodology for all building (i.e., residential and nonresidential) fires and associated losses, review the “National Estimates Methodology for Building Fires and Losses” (August 2012).

Responding to Bulk Storage Combustible Dust Related Fires

2012-11-29T15:25:00.000-06:00

Firefighting Piercing Rod Kit

Justin Clift, Industrial Marker Manager from Hazard Control Technologies shares with readers in this article the intricacies in combating combustible dust related fires. Justin emphasizes these fires can be safely extinguished with the correct equipment and fire fighting agent while following a six-step hazard elimination procedure.

1) Understand, Assess & Identify Incident Hazards
2) Eliminate Secondary Dust Hazards
3) Eliminate Primary Dust Hazards
4) Eliminate Flash Fuel Hazards
5) Eliminate Smoldering Hazard
6) Eliminate Injuries

You must use the micelle encapsulating agent, F-500 and you may require a Piercing Rod Kit for deep seated hot spots (>10ft below surface). Foam caps the material trapping the combustible vapors and will not penetrate. For instance, water will not penetrate or saturate the material.

Deep Seated Fires

When a deep seated hot spot burns it dries out the material surrounding it forming a crust. As the temperature increases the crust becomes thicker and thicker. 95% of the time, the crust will adhere to the sides of the structure so attempting to run it out is not an suitable option. This crust will continue to slowly expand until the weight of the material above it causes it to collapse.

This collapse will typically result into a flash fire, which hits the structures ceiling adding confinement and triggering the primary explosion. The primary explosion disperses the float dust on surrounding structures and equipment, which contacts the primary explosion's flame front and triggers a catastrophic secondary explosion.

You can't flood the structure with water because water will not penetrate this crust. If enough water is applied, it's weight will allow it to penetrate the material but it still can't penetrate the hot spot's crust. Thus it runs off to the sides and starts washing away the foundation of the hot spot, causing it to collapse and triggering the chain of events as discussed above.

The root cause of the problem is a lack of knowledge on combustible dust related fires and explosions. Emergency Responders need to be rebooted for a lack of a better term. The actual fire or smoldering material is not their problem, their problem is the environment surrounding the fire and the nature of a deep seated hot spots.

Firefighters have the equipment and training to be very successful at extinguished fires, they can see. However, it's extremely difficult to fight a fire no one can see and if you can't see it then you can't confirm it's been extinguished and you can't let your guard down. Our Emergency Response Team knows to never trust a fire you can't see. It's not a safe scene until we have confirmed extinguishment to the best of our abilities and all material has been completely removed from the structure.

Presentation and Videos

If you’re interested, here is a hyperlink where you can download some videos and a presentation I delivered recently at Coal Industry Conference. Unfortunately, I can’t get the videos to link properly with the presentation but you can view them separately. The file is 482MB so it may take a couple of minutes to download completely. If you have any questions or problem with the hyperlink please feel free to contact me anytime.

The presentation is about preparing for the unexpected and discusses some lessons learned during a few recent Emergency Response Services HCTperformed. Procedures are important but just having a good playbook, doesn’t mean you’re ready to take the field. There is no shame in having a fire from time to time, it’s the nature of the coal and the inherent hazards of a power plant.

What is remorseful, is when a plant is ill-prepared and gets caught with their pants down which may jeopardize the health and safety of plant personnel and Emergency Responders. Plants must be prepared for the unexpected, they must have the proper procedures which are practiced, revised, and reviewed in effort to be prepared as possible. If a plant doesn’t properly prepare and practiced they shouldn’t be awestruck when they fall short of their expectations.

About the Author

Justin Clift is the Industrial Market Manager for Hazard Control Technologies, headquartered in Fayetteville, GA. He is originally from Ohio and transferred to Georgia to start working for HCT shortly after graduating from Ohio State University in 2005.

Justin Clift
Mr. Clift provides loss control solutions for the power industry, specializing in fire detection, suppression, and prevention. He also conducts class room training for emergency responders on the hazard of combustible dust and silo fire fighting through the use of piercing rods and a micelle encapsulating agent.

Justin has visited hundreds of industrial facilities and has first-hand experience extinguishing coal fires throughout the US, as HCT Emergency Response Team’s Incident Commander. He has also worked side by side with engineering and plant personnel, specifying upgrades to the plant’s fire protection system utilizing F-500 concentrate control systems.

Frequently Justin is asked to assist in the development of emergency response procedures, specifically applicable to the handling of a combustible dust. He is often called-upon to speak at industry meetings and events that focus on power generation and industrial safety, and on the hazards associated with combustible dust. Contact Information:Justin Clift , Industrial Marker Manager, Hazard Control Technologies C: 770-318-1805 O: 770-512-5112 E: jclift@hct-world.com

Over 17,000 combustible dust related fires (1980-2005) USA

2012-11-29T09:40:00.000-06:00

NFIRS Data From USFA

Extrapolating NFPA's Fire Analysis and Research Division estimates from the report "Fires in U.S. Industrial and Manufacturing Facilities," provides in-depth insight into combustible dust related fire statistics in manufacturing facilities from the 2006-2010 period. Subsequently, the Combustible Dust Policy Institute noted over 17,000 combustible dust related fires in the twenty-five year period 1980-2005 while extrapolating the 2006-2010 data. Dust, fiber, or lint (including sawdust) was the item first ignited in 12% of 5,670 manufacturing facility fires/ (2006-2010) annual average. Data from the U.S. Fire Administration’s (USFA) National Fire Incident Reporting System (NFIRS) and the NFPA annual fire department experience survey was utilized in compiling NFPA Fire Analysis and Research Division estimates.

The educational NFPA report provides valuable insight into area of origin, heat source, factors contributing to ignition, and equipment involved in ignition (EII). For example, the leading factor contributing to ignition was mechanical failure or malfunction. Regarding heat sources, the leading factor was unclassified heat from powered equipment followed by radiated or conducted heat from operating equipment.

Manufacturing Facility Fires (2006) Source: NFIRS 5.0 USFA

To assist stakeholders in understanding the modules in the NFIRS reporting system here is a list of several elements regarding ignition with their pages from the NFIRS 5.0 Reference Guide. Note: This is a large file (9.7 mb) and may take considerable time to download on slower connections.

Area of Fire Origin 4-13

Heat Source 4-17

Operating Equipment

Hot or Smoldering Object

Other Open Flame or Smoking Materials

Chemical, Natural Heat Sources

Heat Spread From Another Fire. Excludes operating equipment.

Other Heat Sources

Item First Ignited 4-19

Cause of Ignition 4-24

Factors Contributing to Ignition 4-25

Mechanical Failure, Malfunction

Electrical Failure, Malfunction
Design, Manufacturing, Installation Deficiency

Operational Deficiency

Equipment Involved in Ignition 4-29

Shop Tools and Industrial Equipment

Manufacturing establishments diminished from 373,000 (1990) to 332,000 (2007), a 11% decrease in manufacturing facilities. In a ten year trend of nonresidential fires (1992-2001) there was a 21% decease in fires. (page 119 .pdf)

Nonresidential Fires (1992-2001)

USFA and U.S. Census Bureau statistics depicting decreases in nonresidential fires and manufacturing establishments illustrates a higher number of annual fires in the 25 year period (1980-2005) than in the more recent (2006-2010) time-frame. As a result, the 680 combustible dust related fires annual average (2006-2010) would extrapolate into even more annual incidents from 1980-2005.

U.S. Bureau of Labor Statistics: Manufacturing Establishments (2001-2011)

Very Unusual Trend

U.S. Fire Administration: Fire Estimates. Manufacturing Fires Drop 38% (2007-2010) From 6,200 (2007) to 3,900 (2010), during the same period nonresidential fires drop 18%. U.S. Bureau of Labor Statistics indicated the number of manufacturing establishments dropped 7%. So has incidents of combustible dust related fires and explosions also dropped 38% in the 2007-2010 time frame?

About NFIRS
NFIRS is not representative of all fire incidents in the United States and is not a census of fire incidents or casualties. For example, NFIRS is a voluntary system, and it includes only those fire incidents reported to the system by fire departments that report to NFIRS. Also, not all States participate in NFIRS, and all fire departments that report to NFIRS within a State do not necessarily report all of their fire incidents. Additionally, some fire departments that report fire incidents do not report associated casualties. States and/or fire departments that report in one particular year may not report to NFIRS the following year.

Partial list of Federal Government organizations (page 12 .pdf) that use NFIRS: U.S. Consumer Product Safety Commission, Military Services (Air Force, Army, Coast Guard, Marines, Navy), U.S. Commerce Department, National Institute on Standards and Technology, Center for Fire, Research, U.S. Department of Transportation, National Highway Traffic Safety Administration, U.S. Congress, House Basic Research Subcommittee, U.S. Public Health Service, Centers for Disease Control and Prevention, U.S. Department of Justice, Federal Bureau of Investigation, U.S. Department of Housing and Urban Development, U.S. Department of Treasury, Bureau of Alcohol, Tobacco, and Firearms, Library of Congress, etc.

NFIRS is the world's largest, national, annual database of fire incident information.
50 states and the District of Columbia report NFIRS data.
37 fire departments with a population protected of over 500,000 participate in the NFIRS.
About 23,000 fire departments report in the NFIRS each year.
The NFIRS database comprises 75 percent of all reported fires that occur annually.

Like many of the above governmental organizations, why didn’t the OSHA Directorates use NFIRS fire incident data when developing the OSHA Combustible Dust ANPRM for the rulemaking process? Only relying on incomplete CSB incident data (281 incidents 1980-2005) does not provide stakeholders enough information so as to understand the complexities and magnitude of the combustible dust fire problem in the USA manufacturing sector. As a result of solely using CSB incident data, the definition of combustible dust is explicitly in “suspension” and ignores layered combustible dust related fires (dust not in suspension). So what do you think, should we continue to ignore combustible dust related fires not in suspension?

Resources:
NFPA's "Fires in U.S. Industrial and Manufacturing Facilities"
NFIRS Reporting Form
Uses of NFIRS
NFIRS 5.0 Reference Guide
Nonresidential Building Fires (USFA) page 75 Mfg. Buildings
Nonresidential Fire Trend 2006-2010
OSHA Combustible Dust; Advance notice of proposed rulemaking

Error in OSHA Combustible Dust; Advance Notice of Proposed Rulemaking

2012-11-27T14:02:00.000-06:00

Reviewing the OSHA advance notice of proposed rulemaking (ANPR) creates quite a concern. For example in the second sentence of the "Summary" at the top of the page, "For the purposes of this notice, the term "combustible dust" includes all combustible particulate solids of any size, shape, or chemical composition that could present a fire or deflagration hazard when suspended in air or other oxidizing medium"

So for combustible dust to be hazard it must be suspended in air? What about smoldering layers of dust which also fire and explosion hazards? Before dust can be in suspension it first must be layered on horizontal surfaces. Personnel have been fatally and severely injured from smoldering dust initially not in suspension. Additionally facilities have burned to the ground due to layers of dust.

The problem of OSHA defining combustible dust solely in suspension became readily apparent when trade associations submitted comments in response to the ANPRM requesting their NAICS be removed from "Table 1--Industries Having at Least One Recorded Combustible Dust Incident Reported Since 1980," since combustible dust incidents at facilities they represented were dust layered fires and not in suspension. Was the Dust Incident table (page 43 .pdf) listing severity of consequences (Kst's) instead of NAICS, during a topic of discussion at the 2011 OSHA Combustible Dust Expert Forum a response to the turmoil of defining combustible dust solely in suspension?

There is no mention whatsoever in the OSHA Combustible Dust ANPRM about catastrophic combustible dust related fires as a result of layered dust not in suspension. In stark and awakening contrast, the NFPA Fire Analysis and Research Division prepared a report, "Fires in U.S. Industrial and Manufacturing Facilities" providing insightful information regarding combustible dust related structure fires in manufacturing properties from 2006-2010. The NFPA report noted that shop tools and industrial equipment were involved in 29% of these structure fires.

Most importantly dust, fiber, or lint (including sawdust) was the item first ignited in 12% of manufacturing facility incidents. This would equate to over 600 combustible dust related incidents annually. A vast and disturbingly revealing difference from the 2006 CSB Dust Hazard Investigation Report identifying 281 combustible dust incidents from 1980-2005, or approximately 11 incidents annually. The educational NFPA report obtained fire incident data from the US Fire Administration's National Fire Incident Reporting System (NFIRS) data in conjunction with NFPA’s annual survey of U.S. fire departments.

Its quite alarming where our global trading partners in the IECEx Scheme and European ATEX System recognize dust layers as a fire and explosion hazard yet here in the USA we do not recognize these immediate hazards in the current combustible dust rulemaking process. Continuing to proceed in solely defining combustible dust as a hazard in suspension and ignoring dust layers will have serious consequences in the future as experienced now and in the past. Is it time for a revision of the OSHA Combustible Dust; Advance Notice of Proposed Rulemaking in accordance with reality or should we continue while in error?

On a side note, do you know the burning behavior of your dust? Additional information on burning behavior (VDI 2263). Currently OSHA nor CSB recognizes burning behavior in evaluating combustible dust fire and explosion workplace hazards.Unfortunately, we'll have to wait for another catastrophe before burning behavior is reconized like it is amongst our international trading partners.

OSHA NEP Conflicting with Fire Service Combustible Dust Fire Response

2012-11-26T03:57:00.000-06:00

Wheel Alignment or New Tire?

Earlier this year a combustible dust fire and explosion at a North Carolina fiber recovery facility resulting in four injuries has safety professionals scratching their heads and wondering why OSHA continues to ignore the multitude of manufacturing sub-sectors (NAICS) in the OSHA Combustible Dust National Emphasis Program ((NEP). For instance, the fiber recovery facility is classified as NAICS: 322299, All Other Converted Paper Product Mfg. (515 establishments in 2007) which is not recognized in Appendix D-1 nor D-2 of the OSHA NEP as an industry that may have potential for combustible dust explosions or fires.

There are many more NAICS not recognized in Appendix D-1 or D-2 where combustible dust fires and explosions have occurred since the NEP was reissued in 2008. Continuing on the misguided approach of targeted inspections for a select few of NAICS while not recognizing a multitude of others is a path wrought with undesirable consequences. There is a commonality of process equipment, effective ignition sources, and potentially explosive atmospheres amongst all global manufacturing sub-sectors processing and handling combustible dust. Its not a matter of if, but when a combustible dust related incident will occur. Solely relying on a NAICS conflicts with reality in conjunction with fire service response to the multitude of repeatable combustible dust fires and explosions regardless of whether a NAICS is listed in the NEP or not.

Deputy Chief Greg Blackburn of the Ronda Fire Department put it more succinctly following the March 2012 fiber recovery facility incident, "It's happened before. It's not uncommon, this kind of situation," he said. On a larger scale the same can be said as we observe continually from nationwide news accounts similar views following fire service response to combustible dust related fires and explosions of NAICS not recognized in the OSHA ComDust NEP.

For how much longer will the ComDust NEP continue to be a static document? Its already been over a half a decade since initially issued October 17, 2007. Will stakeholders have to wait for another tragic combustible dust catastrophe where the U.S. Chemical Safety Board will investigate providing key recommendations for root and contributing cause that we already know about? Continuing to ignore the fire service as a welcome partner in the combustible dust rule-making process fails to acknowledge the root of all catastrophic events. This would be in the form of all the prior non-consequential combustible dust events the fire service is responding to repeatedly.

We have it all backwards right now with all the focus on catastrophic dust explosions while ignoring the multitude of non-consequential combustible dust related fires. For instance, say your car is traveling down the freeway and you get a tire blowout due to a worn out tire treads. So you go to the tire shop for a new tire and the repair person notices your wheel alignment is off. Not having correct wheel alignment will cause your tires to wear improperly resulting in tires rapidly wearing down at the treads.

New Tire or Wheel Alignment?

So what you going to do purchase a new tire and continue your highway travel or get a wheel alignment before purchasing a new tire? Having a tire blowout on the highway at high speed is analogous to a potential catastrophic event. A wheel alignment is just like addressing the fires in minimizing the probability of a tire blowout while traveling on the highway. So is it time for a realignment? What do you think?

Déjà vu Firefighters Killed & Injured in Repeatable Deadly Silo Explosions

2012-11-25T02:52:00.000-06:00

Diagram. Aerial view of incident scene after 1997 explosion

Is anyone out there reading these accident reports prepared by the United States Fire Administration (1997) and NIOSH (2003)? Doesn't appear anyone is especially with the multitude of catastrophic incidents mirrored after each other like reruns on the television.

Time is way overdue for firefighting training on the practical aspects of combating combustible dust related fires. We already know about the physicochemical properties of combustible dust with the wealth of literature out there. Now is the time to get down dirty out on the training fire ground.

A real concern is in these two accident reports is continued mention of oxygen-limiting silos. This is incorrect as they were no longer oxygen-limiting silos but instead modified oxygen-limiting silos. Big difference between the two. Adding water to the top of any silo in conjunction with simultaneously opening access doors at the bottom and poking around with smoldering contents is wrought with danger. Do you feel lucky?

U.S. Fire Administration Fire Investigations Program:
The U.S. Fire Administration develops reports on selected major fires throughout the country. The fires usually involve multiple deaths or a large loss of property. But the primary criterion for deciding to do a report is whether it will result in significant “lessons learned.” In some cases these lessons bring to light new knowledge about fire--the effect of building construction or contents, human behavior in fire, etc...

Resources:

Industrial Silo Fire and Explosion1997 USFA
NIOSH LODD Report 2004

Management in Russia Factories Receives Prison Punishment, Combustible Dust Deaths

2012-11-23T11:16:00.001-06:00

(Bryansk. Russia) "Feed Processing Facility operated without a special license, worn-out equipment continued to operate where there was no dust collection. Resulting in October 23, 2011 explosion killing two workers. A September 2011 order to eliminate the violations to the company's management was issued yet ignored. The criminal case was opened under Part 2 of Article 143 of the Criminal Code (violation of safety regulations and other safety rules that resulted in the death of a person)." Best industry practices in feed processing facilities can be found in NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities.

(Udmurtia, Russia) In another incident (1/2/2012). "Director at furniture factory, two workers killed and two injured, faces up to five years in prison. Charged under Part 2 of Art. 219 of the Criminal Code, (violation of fire safety, by a person, which was responsible for their implementation, if it resulted in the death of the person.). Fire was caused by a spark that causing combustible dust deposits paints and explosion. The reasons stated was for violation of fire safety: where in the shop cleaning was not carried out - on the floor, walls and furniture lacquers site (paint shop) accumulated dust deposits paints. According to experts, the cause of fire was a violation of the process for dismantling the ventilation ducts." Best industry practices in furniture factories can be found in. NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities.

From the following excerpts of the Russia news stories you'll need to use Google Translate to read the complete account when translating from Russian to your specific language.Copy and paste the URL into the Google Translate box for language translation.