Conclusion
Not everyone agrees on the best way to tackle combustible dust issues. Some concur with the CSB position that OSHA needs to accelerate efforts to produce and enforce its own standard, citing a long-standing precedent with the grain industry.
Explosions in grain bins used to be one of the biggest safety problems in the U.S. In 1987, following a series of deadly explosions, OSHA promulgated a Grain Handling Facilities Standard that remains in effect today. This standard has yielded major improvements in combustible dust safety in these facilities. According to OSHA, “The lessons learned in the grain industry can be applied to other industries producing, generating, or using combustible dust.” Others argue that more stringent and perhaps consolidated dust standards from the NPFA, diligently enforced by OSHA and local authorities, would be preferable to a separate OSHA standard.
What everyone does seem to acknowledge is that more drastic action is necessary to prevent combustible dust tragedies from continuing to occur. Until such action is mandated, a certain degree of self-regulation is called for. Managers of industrial facilities can choose to be part of the problem or part of the solution. By following the guidelines in this article, and securing the help of engineering consultants and equipment suppliers with a proven track record in combustible dust applications and performance-based solutions, you can minimize risk factors and maximize combustible dust safety in your facility.
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This series of blog posts come from the free white paper w to Make Sure Your Dust Collection System Complies with Combustible Dust Standards by Tony Supine and Mike Walters of Camfil APC. (Download full white paper as PDF here.) Tony Supine has held numerous positions with Camfil APC including research and development manager, technical director and currently plant manager. Mike Walters, a registered Professional Engineer with 30 years’ experience in air pollution control and dust collection systems, is a senior engineer with the company. Camfil APC is a leading manufacturer of dust collection equipment and part of Camfil, the largest air filter manufacturer in the world. The authors can be reached at (800) 479-6801 or (870)933-8048; email filterman@farrapc.com; website www.camfilapc.com.
References
National Fire Protection Association (NFPA), 1 Batterymarch Park, Quincy, MA 02169; www.nfpa.org.• NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities (2013)
• NFPA 68: Standard on Explosion Protection by Deflagration Venting (2013)
• NFPA 69: Standard on Explosion Prevention Systems (2008)
• NFPA 484: Standard for Combustible Metals (2012)
• NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing and handling of Combustible Particulate Solids (2013)
• NFPA 664 – Standard for the Prevention of Fire and Explosions in Wood Processing and Woodworking Facilities (2012)
Occupational Safety & Health Administration (OSHA), 200 Constitution Avenue, Washington, DC 20210; www.osha.gov.
• OSHA Combustible Dust National Emphasis Program (Reissued) – Directive Number: CPL 03-00-008; effective date March 11, 2008.
• OSHA Combustible Dust Standards, July 2008. U.S. Chemical Safety and Hazard Investigation Board (CSB), 2175 K. Street, NW, Suite 400, Washington, DC 20037;
www.csb.gov.
The Library of Congress, 101 Independence Ave, SE, Washington, DC 20540; http://beta.congress.gov/: H.R. 691: Worker Protection Against Combustible Dust Explosions and Fires Act of 2013.
OSHA Law Update, a Hazard Communication, Epstein Becker Green, 1227 25th Street, NW, Suite 700, Washington, DC 20037; http://www.oshalawupdate.com : “2011 Rundown of OSHA’s Combustible Dust National Emphasis Program and Rulemaking”, Amanda R. Strainis-Walker and Eric J. Conn; December 29, 2011.
ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA, 19428; www.astm.org; “ASTM E 1226-10,
Standard Test Method for Explosibility of Dust Clouds”, 2010.
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