Do you know about the "FM Global Property Loss Prevention Data Sheet 7-76"?

OSHA has many standards regarding combustible dust and many refer to other standards and documents by outside groups or organizations. One such document is the "FM Global Property Loss Prevention Data Sheet 7-76". This document addresses the prevention and mitigation of combustible dust explosion and fire. It is also a property loss and prevention data sheet. FM Global provides comprehensive global commercial and industrial property insurance, engineering-driven underwriting and risk management solutions, property loss prevention research and , claims handling.

With a wide variety of safety requirements the FM Global Property Loss Prevention Data Sheet 7-76 covers such things as building explosion hazards, dust collectors, ducting,silos,

and many other items regarding dust explosion and fire. The detail of specific recommendations makes the document a useful resource for the prevention of dust explosions. One specific issue is fugitive dust in a room or building. The dust must have a enclosure separate from the surrounding building. Explosion resistant materials must be used and no open holes or openings in which a fire or explosion could pass through. All explosion venting devices must be inspected periodically to prevent impairment. Such possible impairments as corrosion, improper painted movable parts, icing, snow, obstruction, and equipment that is located near the venting device.

To view the complete document FM Global Property Loss Prevention Data Sheet 7-76.

FM Global website.

OSHA website.

Research actual equipment and venting devises for combustible dust and air pollution control.

Exploring the Congressional H.R.691 - Worker Protection Against Combustible Dust Explosions and Fires Act of 2013

The H.R.691 - Worker Protection Against Combustible Dust Explosions and Fires Act of 2013 was referred to the subcommittee on Workforce Protections in Congress on 4-23-2013.  While the important urgency of worker safety regarding combustible dust is growing everyday, Congressional members have not brought the bill H.R.691 to a roll call.  Mr. George Miller of California  Mr. Barrow of Georgia introduced the bill and have faced lobbying groups and other obstacles slowing the bills chances of passage.  

The bill will require the Secretary of Labor to issue an interim occupational safety and health standard regarding worker exposure to combustible dust, and for other purposes.  After extended research Congress found that an emergency exists concerning worker exposure to combustible dust explosions and fires, and there is a significant risk of death or severe injury to workers employed at facilities where combustible dusts are present.

   The CSB recommended that the Occupational Safety and Health Administration (OSHA) issue a standard designed to prevent combustible dust fires and explosions in general industry, based on current National Fire Protection Association (NFPA) dust explosion standards.  The recommendation was released in November.
             
After 3 catastrophic dust explosions that killed 14 workers in 2003, the Chemical Safety and Hazard Investigation Board (CSB) issued a report in November 2006.  The report identified 281 combustible dust incidents between 1980 and 2005 that killed 119 workers and injured 718. ``Combustible dust explosions are a serious hazard in American industry'' according to The CSB.  A quarter of the explosions occurred at food industry facilities, including sugar plants.

To read the full: H.R.691 - Worker Protection Against Combustible Dust Explosions and Fires Act of 2013 bill.

To find out more about combustible dust safety: Is Your Factory Safe From A Dust Collector Explosion?

Article: Environmental, Health & Safety : Plant & Personnel Safety : Dust Explosions

The U.S. Occupational Safety and Health Admin. (OSHA) has flagged combustible dusts as a top issue since the Imperial Sugar Mill explosion in Port Wentworth, Georgia, that killed 14 employees and injured many others in February 2008. Combustible dust is, in fact, one of OSHA’s National Emphasis Programs (NEPs).  A recent article posted on Chemical Engineering explores the concerns of dust explosions regarding the environment,plant and personal health and safety.

Even though combustible dust is a top issue recognized by OSHA, the organization does not have it's own standards regarding combustible dust hazards in place or even on the table.  Currently combustible dust hazards fall under the General Duty Clause.  According to the Status Report on the Combustible Dust NEP, 11% of combustible-dust-related violations pertain to the General Duty Clause.

 Now this is where it gets confusing.  Though OSHA currently is without standards for combustible dusts, a National Emphasis Program established by OSHA and Congress gives OSHA the power to fine facilities that aren’t in compliance with relevant NF PA standards during routine inspections or inspections under the NEP.

You may read the full article that addresses combustible dust in the chemical industry and how the effects of non specific OSHA combustible standard is making compliance difficult.

Chemical Engineering Article:  Environmental, Health & Safety : Plant & Personnel Safety : Dust Explosions

Occupational Safety and Heath Administration

In depth Dust Collection Information

OSHA Firefighting Precautions at Facilities with Combustible Dust

Often the first responders are at an immediate disadvantage upon arriving at a combustible dust explosion and/or fire.  This week OSHA released a booklet outlining safety procedures for emergency responders who may experience fires and explosions caused by combustible dust.

"The primary purpose of this document is to protect emergency responders from harm by giving them a framework for gathering the necessary information prior to an emergency and converting it into safe operating procedures.  In this document, emergency responders include firefighters, fire brigade members, hazardous materials teams, and others who might be called upon to respond when a fire or explosion occurs."states the OSHA booklet.

The booklet explains combustible dust explosions and how they occur.  Preparation that can be made before a response and precautions that can be made during an emergency response are detailed.  Another concern for first responders is the proper use of fire extinguishers, hose stream, equipment compatibility, and ventilation that are used.  The OSHA document details combustible dust and the reactions of usual fire fighting chemicals.  In some incidents the combination of explosive dust and water can escalate the incident resulting in injury or death.

Ventilation is a widely used practice by firefighters to remove heat and smoke, but can have catastrophic consequences when combustible dust is involved.  Actions such as appropriate power shutdown, safety procedures and normally used tools that can ignite combustible sources are addressed.

With more than 130 workers killed and 780 injured in combustible dust explosions since 1980, the booklet should immediately impact the safety concerns of emergency responders, workers and employers.

Links:
To download the complete booklet:  "OSHA Firefighting Precautions at Facilities with Combustible Dust".
To learn more about "Combustible Dust Collection"
Website: Occupational Safety and Health Administration

News Article: Charges Considered In Grain Elevator Blast

It seems that we are seeing and reading about combustible dust explosions weekly and even daily at times.  A recent article by Mike McGraw with the Kansas City Star revisited the deadly Bartlett Grain Elevator explosion of 2011 that killed four workers and two inspectors at the Atchison facility.    Federal prosecutors are now considering criminal charges against the grain operation owners.

This does not guarantee that criminal case will be filed.  Criminal charges in most workplace deaths are rare.   Many safety advocates contend that charges may avoid future deaths.  William Kauffman, a retired University of Michigan professor and aerospace engineer who has investigated grain elevator explosions for OSHA states “Criminal charges in these cases do change behavior.”  

Although Kansas is one of the leading states in grain elevator deaths, federal officials are not aware of such charges being brought before.  A statement released by the company reads  “Bartlett Grain has done everything in its power to learn the truth about this accident and we look forward to proving that the OSHA allegations are untrue and unfounded.”  According to research at Kansas State University, Kansas ranks third in the nation in grain dust explosions, with 64 since 1958.  Grain dust can be six times as explosive as black powder, often being ignited by overheated motors, misaligned conveyor belts, sparks or overheated bearings.   In 1987 OSHA revamped its regulations by reducing the amount of explosive grain dust in the elevators and by eliminating ignition points.  

OSHA can refer a matter to the local U.S. attorney for criminal prosecution, but the final decision to prosecute is up to U.S. attorney.  If federal prosecutors decide to take a criminal case and prove an employer “willfully” violated a safety standard that resulted in a worker’s death, the company can be fined up to $500,000.  The top company officials can also be sentenced up to six months in prison as a federal misdemeanor.

For more information click the links below.

To read the full article with video "Charges Considered In Grain Elevator Blast" 
Combustible dust testing information "Understanding Your Dust" 
OSHA "Prevention of Future Elevator Explosions"

Article: 10 Ways A Dust Collection System Can Contribute To Your Plant’s Sustainability

A dust collector is designed to clean a factory of dust and fumes, thus making it fundamentally green.  By designing a dust collection system properly you can contribute to sustainability in many additional ways. An article appearing in Green Manufacturer magazine titled "10 Ways a dust collection system can contribute to your plant’s sustainability" written by air pollution control expert John Dauber, gives an easy overview in helping increase and maintain sustainability.

Make sure that the dust collector is compliant with the new U.S. Environmental Protection Agency (EPA) and National Emission Standards for Hazardous Air Pollutants (NESHAP) Rule 6x regarding weld fumes and other airborne contaminants.   You can request a written guarantee from the equipment manager stating the dust collector meets the standards.  Size the collector properly for the application and area.  An undersized dust collector can result in high pressure drop, frequent filter changes, high energy usage, and a host of larger maintenance issues.

If you are being accountable for a  high standard of sustainability shouldn't you require your dust collector supplier to do the same.  You can request a sustainability report or other documentation as evidence of its green manufacturing initiatives.   The use of a VFD variable-frequency drive controls fan speed effectively and efficiently.

To read the full article and learn additional steps to consider for a truly sustainable dust collection system please visit Green Manufacturer Magazine.
You may also find more information regarding the EPA Standards here.

Article: From Dust To Death - Six tips to stop dust collector explosions

Preventing combustible dust explosions has been an industry concern for years.   Increasing the stress for emergency health and safety managers trying to find the correct solution and maintain that solution for the future as well.  With so many standards, regulations, and codes one can get easily overwhelmed.  A recent article in ISHN Magazine by industry experts Tony Supine and Mike Walters condense the tedious task into a few informative tips.   

Reviewing the NFPA 654 standard will give you information on how to design a safe dust collection system.  It will also guide you to other NFPA standards regarding deflagration venting, explosion protection where venting is not possible, as well as standards for specific types of combustible dust and industries.   The NFPA has incorporated performance-based options, since 1995 using calculations in its standards for explosion protection equipment.   Since 2006 the NFPA has been allowing real world destructive test data to be used in place of the calculations data, as long as adequate testing has been proven.   Although often overlooked, real world data is permissible and your dust collection supplier may help you with cost savings and from over engineering,  all while not compromising safety.  

A hazard analysis is required to determine the level of fire and explosion protection required.  Testing the dust to determine the KST rating and Pmax by ASTM E 1226-10 standard needs to be established.  Quality is often overruled by a low price.   Is the value what it seems?  As documented a low-end dust collector will most likely need replacing after an explosion, where as a high quality gauge collector often only requires replacing only the explosion vent and filter cartridges.   High quality compliant equipment is reassurance and an investment in the future.   Keeping a clean facility is another key element in preventing dust explosions.  Hazardous levels of dust accumulation are the most common of all OSHA violations, often ending with fines.  The NFPA definition of hazardous surface dust is now 1/64 inch or 0.4mm in depth.   Staying alert of any changing conditions that can contribute to potential explosive problems should be normal practice.

You can read the full article here From Dust To Death - Six tips to stop dust collector explosions.

Article: How Well Do You Know Your Dust?

In my last post we explored an OSHA bulletin that highlighted the hazards associated with combustible dust. This week I would like to expand on how to determine the explosibility and physical properties of the actual dust. It is one thing to collect the dust but what exactly are you collecting?

While knowing your dust has always been good practice, it is rapidly becoming a necessity in today's regulatory climate. OSHA has identified and contacted 30,000 companies considered to be at risk of explosion from combustible dusts. The importance of dust testing has changed and the implications have become even more significant over the past few years.

Full article can be read here: How Well Do You Know Your Dust?

OSHA Bulletin - Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions

Recently the US Chemical Safety Board has called on the Occupational Health and Safety Administration to develop and publish a combustible dust standard that includes coverage for metal dusts by the end of 2012. As of today no such standard exists. OSHA Bulletin labeled "Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions" is not a standard or regulation. The purpose of the bulletin is to highlight the hazards associated with combustible dust. Work practices and guidelines that reduce the potential for a combustible dust explosion, or that reduce the danger to employees if such an explosion occurs, and training to protect employees from such hazards.

The bulletin covers accidents that occurred, elements needed for a combustible dust explosion, how to access for combustible dust, dust control, and education of management and employees. It's important to know what OSHA has in place currently and hopefully this will help prevent combustable dust incidents until the standards are released.

You can view the CSB video titled, Combustible Dust: An Insidious Hazard, at http://www.farrapc.com/comply/.

What are the biggest misconceptions manufacturers have relative to their OSHA responsibilities related to combustible dust?

The biggest misconception among manufacturers is that OSHA is just presenting them with a guideline, not with something they have to do. The fact is, OSHA is beefing up enforcement of safety measures on several fronts, and combustible dust has become one of the top priorities since the agency re-issued its National Emphasis Program (NEP) on this topic in March 2008.

Under the OSHA NEP, manufacturers are required to follow applicable NFPA standards including the revamped NFPA 68 Standard on Explosion Protection by Deflagration Venting, which provides mandatory requirements for dust collection applications involving explosive dusts. Sometimes other safety standards such as Factory Mutual may be applied instead, but these are no less stringent than NFPA and all are treated as legal code by nearly every town and county in the U.S.

For additional information, read the article, Five Ways New Explosion Venting Requirements For Dust Collectors Affect You. The article can be downloaded as a PDF.

In The News: OSHA Inspections/Citations for Combustible Dust Hazards

OSHA compliance officers have identified 3,662 violations where employees may be exposed to potential combustible dust hazards on the job. This report comes after the agency conducted 813 inspections at companies during the last 16 months. These visits are part of OSHA's ongoing National Emphasis Program (NEP) that it says is designed to reduce workers' exposure to combustible dust hazards.

OSHA also sent out a letter to over 30,000 facilities last year to bring attention to this issue. Did you receive one? If so, they have identified your company as being in an industry that faces this deadly hazard. If not, make sure you are not putting yourself, your business and your employees at risk anyway. OSHA wants to help and offers a free, confidential on-site consultation through a program designed for small companies (250 or less employees). There are some helpful insights and links regarding combustible dust (ComDust) Enforcement/Inspections here.

UPDATE (6/22/09 1:10pm):
Case in point: Serious citations issued to whey processing plant in Wisconsin. View the OSHA Inspection Detail.