Combustible Dust Explosions and Fires-ATEX

British Columbia Combustible Dust Hazards Awareness Workshops

messinabout@earthlink.net (John Astad) — Sun, 13 May 2012 17:23:00 +0000

Workplace combustible dust related fires and explosions occur with alarming regularity in the global grain, mining, forestry and manufacturing sectors. Although the majority of incidents do not result in fatalities, injuries, or property damage, historically many of these non-consequential incidents have been precursors to catastrophic events.

The complex topic of combustible dust hazards recently came to the forefront in British Columbia when WorkSafeBC issued a directive order for all sawmills to conduct a comprehensive risk assessment resulting in an effective dust control program.

In conjunction with FireWise Consulting Ltd., John Astad, Director and Research Analyst from the Combustible Dust Policy Institute (CDPI) will be presenting a series of one day Combustible Dust Hazards Awareness Workshops throughout British Columbia. The goal of the CDPI is to minimize the severity and reduce the occurrence of combustible dust related fires and explosions through research of combustible dust related incidents. For more information on the CDPI view brochure here.

The Combustible Dust Hazards Awareness Workshop will provide stakeholders with the knowledge to minimize the probability of occurrence and severity of consequence of future combustible dust related incidents. In addition the workshop will assist stakeholders in developing a comprehensive dust control program as noted in the revised WorkSafeBC OHS Guidelines. Key aspects of the workshop are identifying, evaluating, and controlling combustible dust hazards in addition to providing guidance in conducting facility inspections and risk assessments.

Facility owners and managers concerns in reducing the probability of a catastrophic secondary dust explosion include good housekeeping, employee training, maintenance, and management of ignition sources. Prevention of future incidents begins with awareness of the problem and a robust hazard mitigation framework which consists of a facility risk assessment, written combustible dust program, and hazard communication.

This combustible dust workshop will discuss the importance of these topics and more in addition to the BC Fire Code referencing the National Fire Protection Association (NFPA) combustible dust standards. NFPA best industry practices include engineering controls for deflagration suppression, deflagration isolation, and explosion venting in the mitigation of combustible dust explosions. The NFPA 664 Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities provides excellent guidance in this area and is a key resource for the workshop. Click here for a detailed course outline.

COURSE DETAILS

June 11, 2012 Prince George

June 12, 2012 Williams Lake

June 14, 2012 Vernon

June 18, 2012 Port Alberni

June 19, 2012 Township of Langley

Time: 0800 to 1600
Registration Fee: $149.00 plus tax (includes lunch)

Register on-line by clicking on the FireWise Consulting Registrations link or register by mail, e-mail or fax by printing and filling out the form at the following link: Registration Form

GAO Report Results: OSHA and NIOSH Need to Work Together

messinabout@earthlink.net (John Astad) — Thu, 10 May 2012 17:41:00 +0000

Occupational health and safety should not solely be inspection, enforcement, and rulemaking. Regarding combustible dust workplace fire and explosion hazards, outreach, education, training, and research is essential. All these elements are included in the OSH Act. The enlightening GAO report sheds light on the fact that the OSH Act is not being adhered to. I encourage all EHS professionals to read the OSH Act, Sections 20, 21, 22 http://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=oshact

Solely relying on a regulation in providing a warm and fuzzy feeling is not the complete solution. A prime example, would be the multitude of grain elevator explosions following the OSHA Grain Facility Standard http://www.osha.gov/dea/lookback/grainhandlingfinalreport.html
So now we have reached a point where X fatalities is not acceptable but Y fatalities is acceptable. OSHA does not have the resources to be everywhere at once. The time has now come in the 21st century where the paradigm must change to shared responsibility engaging all stakeholders.

In contrast, "Clinical Professor of Environmental and Occupational Health Michael Silverstein claimed that OSHA and NIOSH have been working together for the past 40 years"
Then why hasn't NIOSH been a primary stakeholder in the OSHA Combustible Dust rulemaking?
Full Committee Hearing - Time Takes Its Toll: Delays in OSHA’s Standard-Setting Process and the Impact on Worker Safety http://www.help.senate.gov/hearings/hearing/?id=a23b4eec-5056-9502-5d4a-c00679b2215c

Maybe this GAO report will open dialogue on establishing and coordinating local, state, and federal standardization, interoperability, compatibility, and responder health and safety to prepare for, train and respond to, mitigate, and recover from any incident by identifying requirements for an all-hazards incident response which includes OSHA, NIOSH, and US Fire Administration? http://www.cdc.gov/niosh/nas/ppt/QUADCharts11/ZBCS_FY11_QC.htm

The InterAgency Board (IAB) is a voluntary collaborative panel of emergency preparedness and response practitioners from a wide array of professional disciplines that represent all levels of government and the voluntary sector. The IAB provides a structured forum for the exchange of ideas among operational, technical, and support organizations to improve national preparedness and promote interoperability and compatibility among local, state, and federal response communities.https://iab.gov/mvv.aspx

Doesn't catastrophic ComDust related fires and explosions in the workplace warrant federal standardization, interoperability, and compatibility?

GAO Report: WORKPLACE SAFETY AND HEALTH, Multiple Challenges Lengthen OSHA’s Standard Setting http://www.help.senate.gov/imo/media/doc/Moran.pdf

"Improve coordination with other agencies: Experts and agency officials noted that OSHA has not fully leveraged available expertise at other federal agencies, especially NIOSH, in developing and issuing its standards. OSHA officials said the agency considers NIOSH’s input on an ad hoc basis but OSHA staff do not routinely work closely with NIOSH staff to analyze risks of occupational hazards. "

"However, OSHA can coordinate more routinely with NIOSH on risk assessments and other analyses required to support the need for standards, saving OSHA time and expense. In our report being released today, we recommend that OSHA and NIOSH more consistently collaborate on researching occupational hazards so that OSHA can more effectively leverage NIOSH expertise in its standard-setting process. Both agencies agreed with this recommendation."

This is only the tip of the iceberg of agencies not working together regarding workplace ComDust fire and explosion hazards. For example, OSHA has ignored the US Fire Administration in the ComDust Rulemaking process. When a ComDust related fire goes beyond the incipient stage, who you going to call to extinguish the fire?

Mountain Pine Beetle Infested Trees Moisture Content in Evaluating Fire & Explosion Hazards

messinabout@earthlink.net (John Astad) — Fri, 04 May 2012 19:22:00 +0000

Numerous MPB working papers were written for the Mountain Pine Beetle Initiative (MPBI) administered by the Canadian Forest Service. The MPBI began in 2002 and was a six-year package of programs with a total budget of $40 million.

Stakeholders will find a wealth of information in the numerous working papers such as moisture content in infested trees regarding time since death (tsd). The stages infested trees go through after the green stage include the red stage, where the tree shows characteristics of dying (i.e., red needles) in the stand for 2-4 years,and the grey-stage, where the tree has been dead in the stand for 5 or more years.

During the evaluation of moisture content (MC) it is important to understand that fiber saturation point (FSP) varies with tree species. FSP is when there is no longer any free water between the cell structures.(see page 18 .pdf) NFPA 664 defines deflagrable wood dust when the moisture content (wet basis) is less than 25% and the median particle size is less than 500 microns. Converting from dry-basis to wet-basis moisture content calculations.

A problem arises when the science is not applied when conducting a hazard evaluation of the fire and explosion properties of wood dust. When the raw material input changes from green wood with high moisture content to low moisture content MPB infested trees a management of change (MOC) is warranted.

For group members desiring additional info on MC here is a link to the OSHA ComDust NEP. Scroll down to Appendix E ,Combustible Dust Tests Conducted at SLTC

"Moisture in dust particles raises the ignition temperature of the dust because of the heat absorbed during heating and vaporization of the moisture. The moisture in the air surrounding a dust particle has no significant effect on the course of a deflagration once ignition has occurred.

There is however, a direct relationship between moisture content and minimum energy required for ignition, minimum explosive concentration, maximum pressure, and maximum rate of pressure rise. For example, the ignition temperature of cornstarch may increase as much as 122 Fahrenheit, with an increase of moisture content from 1.6 percent to 12.5 percent.

As a practical matter, however, moisture content cannot be considered an effective explosion preventive, since most ignition sources provide more than enough heat to vaporize the moisture and to ignite the dust. In order for moisture to prevent ignition of dust by common sources, the dust would have to be so damp that a cloud could not be formed." (Source: Fire Protection Handbook, 19th Edition).

An excellent resource concerning moisture content in MPB infested trees versus non-infested trees is the paper Moisture changes in lodgepole pine before and after attack by the mountain pine beetle by Dr Rob Reid who worked at the Forest Entomology and Pathology Branch, Department of Forestry, Calgary, Alberta. Dr. Reid conducted moisture content studies on MTB trees near Invermere, British Columbia, and Banff, Alberta, in the period 1955-1960.

The nine page .pdf has excellent figures and tables illustrating moisture content in MPB infested trees versus non-infested trees. Many of the scientific papers written were the result of the $40 million dollar Canadian Mountain Pine Beetle Initiative (MPBI) program (2002-2008) which reference Dr Reid's 1961 paper.

The problem we have now is that industry has not utilized the wealth of scientific data acquired in the Mountain Pine Beetle Initiative (MPBI) in assessing fire and explosion risk when these infested trees are processed.

Resources
NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities
Moisture content of lumber produced from dead western white pine and Lodgepole Pine trees.

Rate of deterioration, degrade and fall of trees killed by mountain pine beetle: A synthesis of the literature and experiential knowledge (2005)
Current knowledge of characteristics and utilization of post-mountain pine beetle wood in solid wood products

A wood and fibre quality-deterioration model for mountain pine beetle-killed trees by biogeoclimatic subzone
The mountain pine beetle : a synthesis of biology, management, and impacts on lodgepole pine (2006)

Understanding the WorkSafeBC Lakeland Mills inspection reports

messinabout@earthlink.net (John Astad) — Fri, 27 Apr 2012 14:58:00 +0000

Recently there has been extensive media coverage on the recently released WorkSafeBC Lakeland Mills inspection reports. Media accounts mention dust levels in the reports but fail to inform the public that the issue of dust was primarily respiratory health hazards of dust and not fire and explosion hazards of dust. There is a big difference. In many instances airborne levels of combustible dust can be indicative of engineering control measures such as local exhaust ventilation is not adequate or insufficient housekeeping.

Excerpts from Lakeland Mill Report

This inspection report focused on the MSI, Noise and Wood dust components of the provincial high risk strategy.

2/3/2009 page 33 Most processing saws and chipping heads are equipped with local exhaust ventilation, which appear to reduce accumulations of fine dust. No recent monitoring of exposure to wood dust has been conducted. Wood dust exposure will be further evaluated during subsequent inspections. This is an item that should be re-evaluated due to the changes in productivity that has occurred over recent years and the fact the majority of the wood being processed is dry beetle killed pine

SRO/OHO Barry Nakahara and I inspected this worksite as part of the high risk provincial strategy

5/27/2010 page 67 We confirmed that hearing tests are being done regularly. We discussed potential dust exposure and the need for appropriate respiratory protection for workers performing clean up of dusty areas. The employer has recently conducted air monitoring for dust and exposures relating to the end-spraying operation. These results were reviewed and no significant problems were noted.

OSO Darren Beattie and I conducted an inspection of this jobsite on February 6, 2012 to assess compliance with the Workers' Compensation Act and the Occupational Health & Safety Regulation. A separate inspection report will be issued by OSO Beattie summarizing his observations.

2/9/2012 Page 112 We discussed the wood dust observed throughout the mill. At the time of inspection, the airborne concentration appears to be below the exposure limit (Non-allergenic wood dust EL = 2.5 mg/m3) in the work areas visited. There are accumulations of piles of wood dust in various areas of the mill. We reviewed the requirement to prevent the accumulation of hazardous amounts of wood dust.

Resource
Lakeland Mills inspection reports

Guidance WorkSafeBC Directive Order to Sawmill Employers

messinabout@earthlink.net (John Astad) — Fri, 27 Apr 2012 14:21:00 +0000

Now that the topic of workplace combustible fire and explosion hazards is out the open in British Columbia sawmills it is important for facility owners and managers to understand the steps in a risk assessment in developing engineering and administrative control measures. The missing link that has not been communicated to stakeholders is the importance of understanding the BC Fire Code which references NFPA 664 Standard for the Prevention of Fires and. Explosions in Wood Processing and Woodworking. Facilities. An excellent resource in understanding NFPA 664 is the 24 page .pdf document developed by the Wood Machinery Manufactures of America (WMMA).

The BC Fire Code references NFPA 664 Standard for the Prevention of Fires and. Explosions in Wood Processing and Woodworking. Facilities. For example, BC Fire Code (1998), Hazardous Processes & Operations (page 113 .pdf) Section Part 5.3. – Dust Producing Processes (page 115 .pdf)

Many don't realize that it is not WorkSafeBC which enforces the BC Fire Code but instead the Fire Commissioner ("Office") and the Office's jurisdiction over fire safety and fire protection in British Columbia. The Office is the senior authority having jurisdiction over fire safety and prevention in B.C. The Office administers the Fire Services Act and it regulations, and appoints and trains local assistants to the Fire Commissioner.

"where WorkSafeBC prevention officers observe what they believe to be a violation of the Fire Services Act or its regulations, prevention officers will notify the local assistant to the Fire Commissioner."

Solely relying on the WorkSafeBC regulation on combustible dust is not sufficient in undertaking a comprehensive risk assessment in addition to developing a combustible dust control program. An understanding of NFPA 664 as referenced in the BC Fire Code will assist immensely in conducting a safety review for combustible dust in sawmills.

To assist stakeholders WorkSafeBC published OHS Guideline G5.81 Combustible Dust-Sawmill Facilities (April 25, 2012) The recent guideline provides information on a Combustible Dust Program which includes elements of hazard mitigation; facility risk assessment, written combustible dust control program, and a hazardous communication program.

Update April 28, 2012 WorksafeBC Bulletin — Clean-up of hazardous combustible dust
"WorkSafeBC has prepared a simple one-page bulletin in safe cleaning procedures of combustible dust that protect workers."

Resources
WorkSafeBC Directive Order to Sawmill Employers
NFPA 664 Combustible Dusts – Overview (WMMA)
BC Fire Code (1998)
OHS Guideline Combustible Dust Sawmills

Relying on housekeeping as a first line of defense against explosion and fire is a false economy

messinabout@earthlink.net (John Astad) — Fri, 27 Apr 2012 11:08:00 +0000

Why going cheap on the dust collection & control system is short sighted...

We all know that our cars and trucks have air and oil filters to catch dust to avoid abrasive wear of the engine. We have seen news articles about how airborne dust is not good for jet engines - like when that Icelandic volcano erupted in 2010, or the Argentinean eruption in 2011.

So, why do so many industrial operations let their dust collection systems get plugged up and fail to perform? Assuming that they bother to install adequate dust controls in the first place?

One common complaint from the people who run foundries and factories is cost - buying a dust control system costs some serious coin, and too many operations try to go bottom dollar when they buy equipment.

Another issue is maintaining and cleaning the equipment - this requires technicians with some training, whereas handing a laborer a shovel or a broom is a good way to keep him busy when things are a bit slow for making product.

This is especially problematic when the dust in question is combustible.

I've lost track of the mills and factories I've consulted for who have had "snowdrifts" of dust piled up because they didn't have the right dust collection and control system, and instead relying on housekeeping to deal with the mess.

Fortunately, most of these operations were making steel or cement, and slag and rock dust don't burn or explode. They are abrasive however, and the dusts stick to exposed lubricated parts, like the cables of the hoist of an overhead crane, or the packing of a pillow-block bearing.

It's difficult to quantify how much service life get eaten up by the grit grinding away on the machinery, but a knowledgeable maintenance superintendent can do predictive maintenance for his/her own shop, and develop the trend data.

Things get more complicated when the dust has hazardous qualities, such as toxicity or flammability.

OSHA has a distinct preference for engineering controls of such dusts - it makes sense to control and confine the potential hazard, making the work environment safer.

When we look at some key fatal accidents, we find that the dust control systems were no longer working as designed or installed.

The Hayes Lemmerz explosion in Huntington, IN in 2003 was largely due to the inadequacy of their dust collection system which was leaking aluminum powder from its ductwork.

The rash of explosions and fires at Hoeganaes in Gallatin, TN in 2011 were exacerbated by the prevalence of combustible iron powder due to the lack of adequate function of the ageing dust control equipment.

The Imperial Sugar explosion in Port Wentworth, GA in 2008 was also largely due to inadequate dust controls.

When we look at the accident investigation photographs from these incidents, the prevalence of fugitive dust (dust which has escaped containment) is obvious - and frightening to a knowledgeable observer.

Housekeeping presents several problems as a means to control combustible dust. A major problem is that dust will deposit on any horizontal surface - like roof beams, conduits, and the top surfaces of machinery and internal enclosures (electrical & machinery rooms for example).

Then there is the issue of just how one goes about cleaning up the accumulated fugitive dusts. The CSB report on the explosion and fire at CTA Acoustics in Corbin, KY in February of 2003 shows that sweeping and blowing combustible dust can easily generate a combustible cloud, which can react with any ignition source.

Conventional industrial vacuum cleaners ("Shop Vacs") are not much better, since they lack specific grounding and venting to prevent internal explosion of the dust which they are sweeping up.

The recent sawmill explosions in British Columbia in January and February would appear to also be due to fugitive dust (final reports from the BC government are not yet available). The news reports indicate that the mills were operating with reduced staff, which would indicate that there were fewer employees available for maintenance and housekeeping.

Factor in a drier source of timber - beetle killed trees - and the possibilities for dust problems become all too real.

The destructive fire at the Swany White flour mill in Minnesota in December of 2011 appears to be another example of fugitive dust catching fire - possibly due to a hot bearing on the ~100 year old milling and sifting equipment.

So, relying on housekeeping as a first line of defense against explosion and fire is a false economy - not only is there a greater risk to the workers workers, but the maintenance costs for machinery are higher, due to increased abrasion from dust getting into the moving parts of machinery.

Contributed by Eric Anderson
Vice President
Renewable Energy Technologies, Inc.
eanderson@eandersonventilation.com

Decade anniversary: Silo fire at Tire Recycling plant

messinabout@earthlink.net (John Astad) — Thu, 16 Feb 2012 19:38:00 +0000

NCNewsPress.com Article Feb 6, 2012
U.S. Fire Administration/Technical Report Series: Tire Recycling Facility Fire Nebraska City, Nebraska USFA-TR-145/January-February 2002

Excerpts from US Fire Administration report:

The Facility
The plant had been inspected by Nebraska State Fire Marshal’s Office on more than one occasion and had a history of poor housekeeping as well as a track record of poor equipment maintenance. There had previously been two fires at the site, as well as two fires at another EnTire facility, also located in Nebraska City.

The Incident
The explosion expelled chunks of rubber that were approximately two to four inches in diameter. Debris was hurled 300 to 400 feet away, damaging and destroying apparatus and equipment as well as injuring the thirteen firefighters

Investigation
The State Fire Marshal has determined that the probable cause was a faulty bearing in the stiff leg auger which carried the crumb rubber from the ground level to the top of the silos.

The bearing overheated igniting the rubber debris around the sugar base. A contributing factor was the poor housekeeping practices. No definite cause of the explosion has been identified,

Lessons Learned
Most local zoning and building codes do not adequately address facilities of this type. Traditionally, volunteer fire departments do not become involved in local zoning issues and often lack the resources to properly preplan target hazards.

The facility in this incident was not designed for its use, nor were there adequate safe guards built into the process since the complex already existed and was modified to accommodate this particular process.

Fire departments should become more proactive in the permitting and zoning process and should endeavor to ensure appropriate code enforcements in facilities of this type, whenever it is possible to do so.

How Fast Will the Fire Spread in Your Dust Layers Compared to Gunpowder (BZ 6)

messinabout@earthlink.net (John Astad) — Sun, 12 Feb 2012 18:47:00 +0000

A recent news account of a paper dust fire rapidly spreading a distance of 300 feet, brings to mind the importance of understanding the burning behavior of combustible dust layers.

It is time all stakeholders understand the burning behavior of their combustible dust through VDI 2263 lab test. Under elevated temperatures a layer of dust can escalate from a potentially non-spreading fire to a spreading fire. Example of BZ #'s : Salt (BZ 1) Gunpowder (BZ 6) Below are several files from BIA Report 13-97 "Combustion and explosion characteristics of dust":
(BZ 1-3 No Fire Spread)
(BZ 4-6 Fire Spread)

Index File

Information and Description File page 21/Combustion Test
Organic Products

Chemical Products

Inorganic Products

Miscellaneous Products

In the last file, group1_2.pdf , go to second page of material data in the last column on the right under combustibility test to find the BZ number (1-6) Note: The BZ numbers should only be used as a guideline since the dust at your facility will have unique and different characteristics of particle size, shape, moisture content, chemical composition, etc.

Another resource in locating BZ numbers is the Gestis-EX Dust database. Not all the dust samples in the database will have the BZ number. So you will have to search for several different samples in finding a BZ number to use as a guideline.

Revise Combustible Dust National Emphasis Program (NEP): Poll

messinabout@earthlink.net (John Astad) — Wed, 01 Feb 2012 15:45:00 +0000

Combustible dust related fires and explosions are occurring throughout the manufacturing and non-manufacturing sectors that are not specifically recognized in Appendix D-1 & D-2 of the OSHA Combustible Dust National Emphasis Program (NEP).
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=directives&p_id=3830

Recently a CSB recommendation in the Hoeganaes Case Study instructed OSHA to revise the Combustible Dust National Emphasis Program (NEP) to add industry codes for facilities that generate metal dusts (e.g., North American Industrial Classification System, NAICS, code 331111 Iron and Steel Mills, and other applicable codes not currently listed)..

What about the dozens of other NAICS having a history of combustible dust related fires and explosions that are not recognized in the ComDust NEP?

Occupy Combustible Dust Fires and Explosions :)

messinabout@earthlink.net (John Astad) — Tue, 31 Jan 2012 19:51:00 +0000

Remove Appendix D-1 and D-2 from OSHA Combustible Dust NEP and replace with all NAICS in the manufacturing and non-manufacturing sectors that handle, generate, and process combustible dust. "All or None"

Say no to anymore catastrophic combustible dust related fires and explosions and not just a select few of specific industries (NAICS).

9th International Symposium of Hazards, Prevention and Mitigation of Industrial Explosions-Poland

messinabout@earthlink.net (John Astad) — Mon, 30 Jan 2012 18:57:00 +0000

9^thInternational Symposium of Hazards, Prevention and Mitigation of Industrial Explosions (9^thISHPMIE) between 22 and 27 July 2012. Cracow, Poland

"Roots of the Symposium reach far into the past. ISHPMIE was founded in 1996 as a joined meeting of Dust Explosion Colloquia Baranow (1984). The first ISHPMIE was organized in 1996 in Bergen."

THE SCOPE OF THE CONFERENCE PROBLEMS IS AS FOLLOWS:

ignition;
flame propagation;
ases, dust, vapors explosiveness;
deflagrations and DDT;
detonations of gases, dusts, vapors;
kinetics of chemicals reactions;
formation of explosive mixtures in industrial conditions;
blast waves;
explosion prevention techniques and means;
explosion mitigation /protection techniques and means;
explosion risk assessment methods;
explosion/ consequences analysis;
case studies;
standards and regulations;
hydrogen safe

Special thanks to Dr. Bill Kauffman in sharing the event with the CDPI so other global stakeholders can be aware of International Symposium in Poland.

Identifying Facility NAICS: OSHA Combustible Dust NEP

messinabout@earthlink.net (John Astad) — Sun, 29 Jan 2012 19:33:00 +0000

Many stakeholders are not aware if a facility is identified in the OSHA Combustible Dust National Emphasis Program NEP) for targeted inspections. Here are a few helpful steps to assist in obtaining the NAICS six digit designation then comparing with the NAICS in Appendix D-1 and D-2 of the OSHA ComDust NEP.

Step 1

Go to the OSHA Integrated Management Information System (IMIS) database and type the facility name in the Establishment Search

Here is an example of a facility already entered in IMIS:

Hoeganaes Corp
Gallatin, TN

SIC: 3399/Primary Metal Products, Not Elsewhere Classified

NAICS: 331111/Iron and Steel Mills

If the OSHA IMIS search does not populate a facility then an alternative would be to use the EPA Envirofacts search tool

Acquiring a NAICS at times can be frustrating and very time consuming since the above search methods will not always be successful. If the Standard Industrial Classification (SIC) is known, that will assist in determining the NAICS. For example type the SIC in the Google search box.

Google Search: SIC: 3399

The first hit at the top of the web page should be the Reference for Business website where the NAICS are found.

Step 2

Once the facility NAICS is obtained the next step is comparing the NAICS six digit designation with the NAICS in Appendix D-1 and D-2 of the OSHA ComDust NEP

Combustible Dust National Emphasis Program (Reissued) Page 35-37 D-1 and D-2

(html version) OSHA ComDust NEP

Next time you read a news account of a combustible dust related fire or explosion use the above exercise to determine if the facility is recognized in the OSHA NEP for targeted inspections. Don’t be surprised if the NAICS is not specified in D-1 or D-2 of the ComDust NEP.

There are many elements in the NEP that have successfully educated stakeholders in identifying, evaluating, and controlling the hazard. Yet when fatalities and serious injuries occur in NAICS not recognized in the NEP this presents a serious problem. One more fatality or injury as a result of a workplace combustible dust related fire or explosion is not acceptable. The workplace is reaching a point of, “Occupy Combustible Dust Fires and Explosions.”

Update: NAICS Exercise: Chocolate and Confectionery Manufacturing from Cacao Beans
January 29, 2012 Workers burned at chocolate factory. Use steps above to determine if facility NAICS is recognized in OSHA Combustible Dust NEP.

November 29, 2007 Explosion Valencia, CA
May 20, 2001 Chocolate Factory Blast Chicago, IL

Example General Duty Clause Citation at Chocolate Factory 06/03/2009

OSHA Combustible Dust National Emphasis Program (NEP) a Dismal Failure

messinabout@earthlink.net (John Astad) — Sat, 28 Jan 2012 18:23:00 +0000

"Assistant Labor Secretary Jordan Barab says he believes it's too early to assess the effectiveness of the program." Too early to assess? So how many more catastrophes like Hoeganaes must occur before we figure out the Combustible Dust National Emphasis Program (NEP) is a dismal failure?

Since 2008, through researching media accounts of combustible dust related fires and explosions the Combustible Dust Policy Institute has determined that over 50% of incidents are occurring in specific industries (NAICS) not recognized in the OSHA ComDust NEP.

Subsequently, the CSB Hoeganaes Case Study recommendation "Revise the Combustible Dust National Emphasis Program (NEP) to add industry codes for facilities that generate metal dusts(e.g., North American Industrial Classification System, NAICS, code 331111 Iron and Steel Mills, and other applicable codes not currently listed)," is only the tip of the iceberg.

What about the dozens of other industries throughout the entire manufacturing and non-manufacturing sectors not recognized in the NEP having a history of combustible dust incidents? Let’s stop fooling around and attempting to segment specific industries while Rome is burning. If you have combustible dust at your facility then it does not matter what you’re NAICS specific industry classification is.

As retired University of Michigan Professor of Aeronautical Engineering Bill Kauffman stated in the article, "It's not rocket science," If you don't believe it then check for yourself in the next news account of a combustible dust related incident where the specific industry (NAICS) is not recognized in the ComDust NEP. If this isn't a failure then I don't know what is.

Mystery of Airborne Combustible Dust Concentrations

messinabout@earthlink.net (John Astad) — Fri, 27 Jan 2012 21:55:00 +0000

So at what threshold should airborne concentrations of combustible dust trigger a concern for combustible dust related fires and explosions? Mention of industrial hygiene issues is reminiscent of the 2011 Foxconn catastrophic dust explosion in China, where initially workers complained of high levels of aluminum dust respiratory exposure during polishing operations.

Confusion still exists according to media accounts of the high airborne dust levels discovered in the WorkSafeBC inspections at the British Columbia, Canada facility a few weeks prior to Fridays catastrophic explosion. These high levels were for airborne concentrations in regards to respiratory exposure not combustible dust explosive concentration levels. Explosive airborne dust concentrations would require approximately 30,000 times more than the concentration found in the inspections depending on moisture content and particle size. For example, the highest airborne concentration was 5.9 milligrams/cubic meter, which was 2 times over the acceptable threshold of 2.5 milligrams/cubic meter, according to WorkSafeBC inspection reports released to the media.

To put this into perspective we must ask what exactly is 2.5 milligrams? Well if you put a pesky mosquito on a laboratory scale that would be your answer. Of course mosquitoes are not processed in sawmills, lumber is. But this does provide a general idea of 2.5 milligrams of mass. Alternately, using the mass of wooden toothpick provides better idea of how high suspended dust concentrations would be in one cubic meter of volume, such as the volume of a huge glass fish tank.

So here is the math. On an average, a wooden toothpick weighs approx. 100 milligrams on a laboratory scale. Now dissect the toothpick into 40 parts, which would equate to each of the forty toothpick parts weighing the same as a 2.5 milligram mosquito.

Now take three of those individual 2.5 milligram toothpick parts and grind them up to the consistency of sawdust. This would provide about total 7.5 milligrams of mass, a little over the 5.9 milligrams of the high airborne dust level that inspectors found in a cubic meter during the prior facility inspection.

So one must ask, is approx. 1/10 of wooden toothpick sawdust explosive in a cubic meter volume of air? The basis of a combustible dust explosive atmosphere is that the minimum explosive concentration (MEC) must be sufficient to have ignition while in suspension when combined with the fire triangle.Think of MEC analogous to the lower flammable/explosive level LFL/LEL of a flammable vapor or gas.

In contrast a minimum explosive concentration (MEC) of sawdust depending on moisture content and particle size is approximately 300 wooden toothpicks, weighing approximately 30 grams or 30 grams/cubic meter.Hope this helps obtaining insight in the difference between airborne respiratory hazards (milligrams) in contrast to airborne explosive concentrations (grams) of combustible dust. Of extreme importance is to ensure horizontal layers of dusts do not become airborne where a safe respiratory concentration can escalate rapidly into a minimum explosive concentration (MEC). Good housekeeping is key in this respect.

Full Report: Explosion of DeBruce Grain Elevator, Wichita, Kansas; June 8, 1998

messinabout@earthlink.net (John Astad) — Thu, 26 Jan 2012 19:42:00 +0000

Global Incident Awareness Can Save Lives

messinabout@earthlink.net (John Astad) — Fri, 28 Jan 2011 21:08:00 +0000

Two strikingly similiar pictures, two different countries, yet the explosive effects in these storage tanks were basically the same in the liquor pulping recovery process. In both catastrophic incidents fatalities occurred at corrugated packaging manufacturing facilities. The incident in France happened this month and the other in Wisconsin back in 2008, which the Chemical Safety Board is currently investigating. As a result of the Wisconsin incident CSB issued a March 2010 Safety Bulletin on Hazards of Welding and other Hot Work.

Christian Bourdon, the contract worker from Saint-Aubin, France died unnecessarily in the hospital as a result of injuries sustained from the explosion while doing hot work on the storage tank. Don't know if Christian or others in the global workforce had a chance to read the educational CSB bulletin. Incident investigations determining root cause and safety bulletins are great if the information is being received by OHS professionals then passed on to the workforce. Yet it is difficult to understand why repeatable catastrophic incidents are occurring when information is abundant concerning the hazards. Providing examples of these two incidents is even harder to grasp since the manufacturing and storage process were the same.

It is unacceptable that life-saving information resides securely within national borders when occupational health and safety is a global concern. In contrast global financial markets send and receive data real-time. So is the value of the buck of more importance than human life?

Resources
Paper & Pulp Mill Process Magnetrol International

Legislators, More Regulation is the ComDust Cure

messinabout@earthlink.net (John Astad) — Mon, 17 Jan 2011 07:49:00 +0000

Why is it that legislators seem to think that passing more bills and regulations is the cure all? Problem with the combustible dust issue is that no one in Washington D.C. has all the facts and solely utilizing the Chemical Safety Board's Dust Hazard Study provides a false perception of the enormity and complexity of the issues both social and economical.

"Their bill would tell OSHA to issue - within 90 days - an interim standard. It would require better housekeeping, engineering controls, worker training and a written combustible-dust safety program."
Savannahnow.com-news article

For example, the CSB report states there were 281 ComDust incidents from 1980-2005, or an average of eleven incidents annually. In stark contrast, according to media accounts of ComDust related incidents since 2008 there have on an average 12 incidents a month. This would equate to approximately 4,000 ComDust incidents during the 1980-2005 timeframe.

Not understanding the depth of the issue is only part of the problem. For example FEMA/U.S. Fire Administration's, "National Fire Incident Reporting System 5.0 (NFIRS)" via local fire departments has failed to report and identify process situations, process conditions, and process materials regarding combustible dust related fires, precursors to catastrophic dust explosions.

If the local fire and explosions hazards can't be identified, then how can they be evaluated and controlled? Of course legislators at the national level seem to think legislation and regulation is the answer for a local/regional problem. That is the easy way out in attempting to solve a primarily fire life safety issue and secondarily an occupational safety issue.

The OSH ACT specifically states that to address workplace safety, issues of regulation, education, outreach, and research must be pursued. OSHA with its limited resources cannot do it all.

"by providing for research, information, education, and training in the field of occupational safety and health; and for other purposes."

What happened to NIOSH as the OSH ACT intended in getting involved with outreach/education regarding the combustible dust issue as it had done decades ago concerning coal mine dust explosions, prior to when the U.S Bureau of Mines (USBM) was transferred to NIOSH, Department of Energy (DOE), U.S. Geological Survey, and the Bureau of Land Management in 1995-97.

Let’s all grow up and stop singling out Imperial Sugar explosion as the problem. Currently Imperial Sugar is an industry leader in addressing ComDust fire and explosion hazards. What about the tens of thousands manufacturing facilities that have potential ComDust fire and explosion hazards? So now OSHA as Secretary of Labor states, "there's a new sheriff in town." So what we going to do, fine them all?

Outreach, training, research, and education through NIOSH and US Fire Administration are just a few examples in alternatives to more legislation and regulation. Question is, who has the vision in providing the leadership so all local, state, and federal agencies are working together in these tough economic times.

Resources -OSH Act

Ten ComDust incidents per year...Say What?

messinabout@earthlink.net (John Astad) — Sat, 15 Jan 2011 06:28:00 +0000

At a recent combustible dust webinar last October, attendees to the educational event learned that about ten combustible dust incidents occurred annually from the early 1980s until 2005 in the U.S.A. This data was obtained from the Chemical Safety Board Dust Hazard Investigation that was completed in 2006, noting 281 ComDust incidents from 1980-2005.

Unfortunately, this is not reality in contrast to media reports that note over ten combustible dust incidents every month. Currently, OSHA is in the combustible dust rulemaking process utilizing this incomplete data from the CSB Dust Hazard Study. This presents a problem by not exposing the enormity and complexity of combustible dust related fires and explosions in the manufacturing, non-manufacturing, and utility sectors.

The problem is exasperated by the current OSHA Combustible Dust National Emphasis Program (NEP) that further lessens the magnitude of combustible dust incidents by solely listing certain national industries (NAICS) that have a potential for combustible dust incidents and excluding thousands of other manufacturing plants that do have a history of ComDust incidents not listed in the ComDust NEP. For example, in 2008 over 50% of facilities that had ComDust incidents were not listed in the Appendices D-1 and D-2 of the NEP.

If your facility generates combustible dust it doesn't matter whether OSHA acknowledges the hazard our not in the ComDust NEP. Bottom-line, you have a potential fire and explosion hazard that can cause grave burn injuries, fatalities, and severe property damage. Get your dust tested now or at least conduct a thorough process hazard analysis; identifying, evaluating, and hopefully controlling the hazard.

To learn more about combustible dust hazards be sure to check out the excellent Chemical Processing. com webinar moderated by Traci Purdum, Senior Editor/Digital Media. Presenters included Dr Vahid Ebadat Ph.D/Chilworth Technology, Inc., John Dauber, sales manager/Camfil Farr APC, Bob Korn, Director of Sales for Explosion Protection Products/Fike Corporation, and Guy Colonna, Division Manager, managing the Industrial and Chemical Engineering department for the National Fire Protection Association.

Resources
Google Map Dec 2010-Jan 2011 Combustible dust related fires and explosions
Dust Gets it's Due- By Seán Ottewell, Editor at Large-Chemical Processing.com

Confined Structure Fires also Combustible Dust Related?

messinabout@earthlink.net (John Astad) — Sat, 15 Jan 2011 03:08:00 +0000

Just prior to the Christmas holiday a minor combustible dust related fire occurred in a dust collector at a Misc. Fabricated Metal Producing Manufacturing/NAICS 332999 facility in Wisconsin. These type of facilities are listed in Appendix D-2 of the OSHA ComDust NEP as Fabricated Metal Products, Not Elsewhere Classified with industries that may have Potential for Combustible Dust Explosions/Fires.

According to the news account:

The fire was extinguished and contained to the dust collector bag house. There was no fire extension into manufacturing plant.

WQOW.Com

The incident begs the question was this a confined structure fire? Where as in similiar small fire incidents that are limited in scope, are confined to noncombustible containers, rarely result in serious injury or large content losses, and are expected to have no accompanying property losses due to flame damage. The news account mentions no fire extension into manufacturing plant nor injuries which resulted in an estimated $10,000 damage to dust collection bag house. Since dust collectors are constructed of metal they would be non-combustible.

In the U.S. Fire Administration/National Fire Data Center, Investigation of Confined Structure Fires, Topical Fire Research Series, the report noted 2002 NFIRS 5.0 data contain abbreviated reporting for slightly over 52,000 confined structure fire incidents—37% of structure fires.These incidents accounted for $26 million in combined losses, 3 deaths, and nearly 500 injuries. Most confined structure fires (77.5%) occurred on residential properties. It is the other 23% that we are concerned about in manufacturing non-residential properties.

There is a problem in this US Fire Administration reporting in that it does not formally consider dust collectors or other process equipment in the manufacturing sector that are non-combustible as confined structure fires. Instead, cooking fires, trash or rubbish fires, chimney fires, commercial compactor, fuel burners, and incinerators are used as data element descriptors in these type of fires.

This does present a problem since fire service professionals can't identify combustible dust fire hazards in the NFIRS 5.0 reporting system, then how can they assist stakeholders in evaluating and controlling combustible dust fire hazards. All combustible dust related fires are failed catastrophic combustible dust explosions. Time is way overdue for the FEMA/US Fire Administration's National Fire Data Center to review their fire reporting methodology that omits the dozens of minor combustible dust related fires that have a history of evolving into catastrophic dust explosions.

Combustible Dust Explosion Pharmaceutical Preparation Plant

messinabout@earthlink.net (John Astad) — Sat, 15 Jan 2011 01:22:00 +0000

A combustible dust explosion occurred at a pharmaceutical preparation plant in Iowa prior to the end of the 2010 a few weeks ago. Luckily there were no injuries or fatalities and damage was minor according to the news account.

"There were no injuries. The explosion blew out doors on the building and dust collectors, with additional minor damage."

Eastern Iowa News Now

It appears the mention of doors blowing out in the dust collector might be referring to explosion ventilation panels. Being that the plant is involved in pharmaceutical preparation with a NAICS 325412, it is noted in the OSHA Combustible Dust NEP in Appendix D-1 as an Industries with More Frequent and/or High Consequence Combustible Dust Explosions/Fires.

Over the past 12 months OSHA has been enforcing a myriad of regulations in addition to ComDust NEP emphasis in their site visits at pharmaceutical preparation facilities. The OSHA Integrated Management Information System also referred to as IMIS provides a helpful insight to these inspections.

An educational General Duty Clause citation for one Pharmaceutical Preparation Plant noted that "neither dust collector was equipped with deflagration venting panels directed to an unoccupied area or with a suppression system. The collectors were located inside an occupied area which employees entered to conduct maintenance on a daily basis."This is in contrast to the current incident where the dust collector was installed outside on the roof and appeared to have explosion vent panels.

Results of an internet search produced a MSDS for microcrystalline cellulose (MCC) Cellulose; flour cellulose which has combustible dust fire explosion hazards. For example in the Fire Fighting section it notes, "Fine dust dispersed in air in sufficient concentrations, and in the presence of an ignition source is a potential dust explosion hazard. For Cellulose: Minimum ignition temperature, dust cloud: 410C. Minimum explosible concentration: 0.045 g/l." This is helpful information so stakeholders can take proper administrative, PPE, and engineering control measures.

On a side note, another combustible dust related fire and explosion originated from the same company that occurred nearly two weeks prior to above incident, yet paper dust was the process material at a different facility instead of microcrystalline cellulose (MCC) according to the news account.

“Something caused the paper dust to explode. We don’t know what it was,” Battalion Chief Rick Palmer of the Portage Fire Department said. Palmer said the fire department has been called to explosions at the plant in the past, most recently about eight months ago. Small fires can develop wherever the dust settles in the plant following such an explosion, he said. “We just chase little fires all over the place,”

Michigan Live.com

Stakeholders searching the OSHA Combustible Dust NEP will not find any paper industries that OSHA believes have More Frequent and/or High Consequence Combustible Dust Explosions/Fires or Potential for Combustible Dust Explosions/Fires. Don't know what the NAICS is for the facility that generated paper dust in the news account yet there is mention that the facility produces paper insulation. In either case whether or not a facility is listed in the OSHA ComDust NEP, if you generate ComDust then you need to identify, evaluate, and control the fire and explosion hazards.

U.K Combustible Dust Fire with Metal Dust

messinabout@earthlink.net (John Astad) — Fri, 14 Jan 2011 03:36:00 +0000

“The fire was on the mezzanine floor in a hopper containing metal dust"
www.miltonkeynes.co.uk

OSHA needs to look at DSEAR and ATEX and include ComDust in the universe of potentially explosive atmospheres in the rulemaking process, which also includes flammable liquids, gases, vapors, and mists. Can't continue like the present situation in the USA with ComDust as a separate entity. Until then, the US Fire Administration will continue to ignore the fire and explosion hazards of ComDust with deficient incident reporting in the National Fire Incident Reporting System NFIRS 5.0

Process Upset Causes Combustible Dust Related Fire

messinabout@earthlink.net (John Astad) — Fri, 14 Jan 2011 02:19:00 +0000

Another minor combustible dust fire in the news with no injuries or fatalities. That is the good news..Yet stakeholders need to be aware that besides hot surfaces, arcs, sparks, static electricity, etc (process situations) that can ignite combustible dust, so can process upsets such as the case in this incident.

"combination of water and molten steel can cause a flash-up. That flash of fire likely set dust on fire, which then spread to a nearby storage room." (Watch the video)

WTOL-news article

OSHA is in the rulemaking process for a combustible dust regulation that is a continuum of the OSHA Combustible Dust National Emphasis Program (NEP). The primary problem with this approach, is that it solely notes specific national industries (NAICS) that supposedly have a high probability or high consequence or potential for combustible dust incidents and ignoring others with potential fire/explosion hazards. Now for the bad news.. According to media account, over 50% of combustible dust related fires and explosions occur in national industries (NAICS) not listed in the the OSHA ComDust NEP, such as the case with this incident

For example, the real eye opener concerning this minor incident, is that this facility is an iron and steel mill national industry (NAICS 331111), which is not acknowledged in the OSHA Dust NEP as having high probability/consequence or potential for combustible dust incidents. So if the tree fell in the forest and no one heard it, did it fall?

There are dozens of other national industries composed of thousands of facilities in the wood, paper, plastic, metal, chemical, and food manufacturing sectors not listed in the OSHA ComDust NEP that have regular occurring minor combustible related dust fires which don't get notice from many other stakeholders either. This attitude is attributed to normalization of deviation as what occurred in the events leading up to the 1986 Space Shuttle Challenger disaster. Same thing with a catastrophic dust explosion as it is a rare event also.

It is time to face reality and get with the program, understanding the ComDust fire/explosion problem is a process condition (equipment) issue and not solely a national industry (NAICS) subject. Whether an industry is listed in the OSHA ComDust NEP or not as a non-NEP NAICS, they all have similar process materials (combustible dust) and process situations (ignition sources). So how can we say that one national industry has high probability/consequence or potential for a combustible dust incident because it is listed yet another one doesn't because it is not listed in the NEP? Yet both industries generate combustible dust during the manufacturing process. This train of thought does not hold water as America is burning. Just remember that any minor combustible dust related fire is a failed catastrophic combustible dust explosion.

Posted via email from ComDust

Combustible Dust Fire Incident Reporting Deficiencies

messinabout@earthlink.net (John Astad) — Thu, 13 Jan 2011 02:56:00 +0000

A problem arises in the national fire reporting system where there are no data elements specifically identifying manufacturing process equipment involved in ignition of combustible dust. If process condition fire hazards can't be identified, then how can they be properly evaluated and controlled through administrative, PPE and best engineering practices?

"Stakeholders seeking control measures to minimize the probability and severity of combustible dust incidents should work more closely with the fire service."

ohsonline.com-article

Posted via email from ComDust

Resources:

1. National Fire Incident Reporting System (NFIRS 5.0) Complete Reference Guide

2. Report on Confined Structure Fires-February 2006, US Fire Administration

3. U.S. Industrial and Manufacturing Property Structure Fires, Oct. 2009, NFPA Fire Analysis and Research Division

4. US Chemical Safety Board, Combustible Dust Hazard Investigation, Nov. 2006

5. NFPA 901 Standard Classifications for Incident Reporting and Fire Protection

Biofuel Fires and Explosions-Google Maps

messinabout@earthlink.net (John Astad) — Wed, 12 Jan 2011 16:48:00 +0000

Google Maps

Ethanol Plant Fires and Explosions

Biodiesel Plant Fires and Explosions

Maps Compiled by John Astad, Director/Research Analyst, Combustible Dust Policy Institute

Combine Harvester Combustible Dust Fires

messinabout@earthlink.net (John Astad) — Wed, 12 Jan 2011 10:37:00 +0000

Informative article on the results of a research study on combustible dust related fires occurring in combine harvesters in the agricultural sector. The harvester diesel engine creates high temperatures resulting in very hot surfaces that can easily ignite the build-up of combustible dust that has low minimum ignition temperatures (MIT).
Stock & Land/Fairfax Media

The entire manufacturing sector can learn from this study as the process situations (ignition sources) of hot surfaces and static electricity can ignite combustible dust at facilities just like that do on a combine harvester. Good housekeeping is essential in minimizing the probability of occurrence in either case.

Posted via email from ComDust