Monday, June 29, 2009

Fire Prevention Plans: Don't Get Burned

Fire Prevention Plans: Don't Get Burned There are some 100,000 workplace fires every year in the United States, resulting in losses in the billions of dollars. And the human toll is high as well. The National Safety Council estimates that fires and burns account for 3 percent of all occupational fatalities.

Friday, June 26, 2009

OSHA instructions for responding to a significant event

OSHA's instructions for responding to a significant event
Hi All...found this while doing some research for an article. Not sure if it's been updated since (1991), but interesting stuff. Rachel Brutosky
Public Relations Coordinator at Nilfisk-Advance America.

Monday, June 15, 2009

Take More Action to Prevent Dust Explosions

Take More Action to Prevent Dust Explosions
One year after 14 workers died in an explosion at Imperial Sugar, combustible dust fires and explosions continue to occur at U.S. businesses. OSHA has not begun rulemaking on a comprehensive combustible dust standard, as recommended by the Chemical Safety Board in 2006. More needs to be done, according to CSB Chairman John Bresland. That's the safety message for February 4, 2009.

It only takes a Millisecond

The explosion at the ConAgra Foods plant in Garner, NC, shows again the vulnerability of operations to catastrophic events and their highly undesirable consequences. Ensure that your operations not only pursue workplace safety excellence but also properly address process related safety excellence...

Sunday, June 7, 2009

About the CSB

PSM for Dust Hazards

PSM Oriented Towards Dust Hazards?
Posted by John Astad on May 29, 2009 at 10:23pm
Request Sent! View John Astad's blog
A process safety management (PSM) oriented program that addresses combustible dust hazards in the manufacturing, non-manufacturing, and utility sectors needs to be implemented as it is in the chemical and refinery sectors.
The main problem, is a disconnect concerning wood, food, paper, textiles, etc. process streams as not being considered like the 136 highly hazardous chemicals (HHC) as outlined in OSHA's Process Safety Management regulation (29 CFR 1910.119).OSHA National Emphasis Programs (NEP)Last year, the OSHA Combustible Dust National Emphasis Program (NEP) became effective four months after the Petroleum Refinery Process Safety Management (PSM) National Emphasi... There is a vast difference in the two OSHA NEP's with the goal of protecting the nations workforce and outlying communities from the harmful effects of industrial fires, explosions, and toxic releases.
In reviewing the background information for the Refinery PSM NEP, its disturbing when comparing and contrasting fatalities and catastrophes(FAT/CAT) between refineries and facilities that handle combustible particulate solids that generates combustible dust. For instance, on pg. 4 the Refinery NEP states:"According to OSHA’s IMIS database, since May 1992, 36 fatality/catastrophe (FAT/CAT) incidents related to HHC releases in the refining industry have occurred. These incidents included 52 employee deaths and 250 employee injuries, 98 of these injuries required hospitalization."Fatalities and Catastrophes (FAT/CAT)Over the same fifteen year period, according to the results of the Chemical Safety Board Dust Hazard Investigation, there were over 95 fatalities and hundreds of injuries as the result of over 160 combustible dust related fires and explosions in the manufacturing, non-manufacturing , and utility sectors. Basically there are three times as many fatalities and catastrophes (FAT/CAT) in sectors that generate combustible dust than in the refinery sector.
Yet Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) and administrative control measures to protect the manufacturing workplace are dismally lacking. So is the rapidly diminishing manufacturing sector that provides a base for our national economic security even worth protecting? It doesn't seem so with the obvious inattention thats been misdirected elsewhere, to supposedly more urgent aspects of workplace occupational health and safety.
Highly Hazardous Chemicals (HHC)Combustible dusts have similar explosion severity (Pmax, Kst) effects as flammable liquids, gases, and vapors concerning destructive overpressure, thermal radiation, and ensuing projectiles. Facilities that maintain processes with over 10,000 pounds of flammable liquids and gases must consider these products as highly hazardous chemicals (HHC) as outlined in the OSHA's Process Safety Management regulation (29 CFR 1910.119).
So if combustible dusts have similar devastating explosive effects causing fatalities and catastrophes (FAT/CAT) like flammable liquids and gases, why aren't they listed as a highly hazardous chemicals(HHC)?
Wood, food, textiles, paper and many other seemingly harmless materials in manufacturing process streams are not considered toxic, reactive, or corrosive like the over 130 highly hazardous chemicals (1910.119 App A) under the Process Safety Management program. It's their combustible and explosive characteristics that need to be addressed as it is for flammable liquids and gases HHC (highly hazardous chemicals) in the OSHA PSM standards.
Recognizing the hazards of combustible dust is the first step through a process hazard analysis which is the foundation in lessening the occurrence and reducing the severity of future combustible dust related fires and explosions.
Once the hazards are identified and evaluated control measures can be implemented in similar fashion as outlined in the OSHA Process Safety Management program. A few of the measures in the current PSM with debatable input to a possible Combustible Dust PSM include:Operating ProceduresFor instance, the implementation written operating procedures addressing operating limits with consequences of deviation with steps to follow to correct deviations such as high operating temperatures. These operating procedures must include safety and health considerations concerning quality control for raw materials and control of dust emissions.
Additionally, precautions necessary to prevent combustible dust related fires and explosions, which also includes engineering controls, administrative controls, and personal protective equipment.Contractor ParticipationA process safety management program would also require contractor participlation.
Over the past year a large percentage of combustible dust related fires have involved contractors conducting hot work adjacent to process equipment. A Combustible Dust PSM would properly and proactively inform contract employers of the known potential combustible dust fire, explosion hazards related to the contractor’s work and the process. This would lessen the occurrence of future incidents.
Mechanical Integrity (MI)Mechanical integrity (MI) issues in a Combustible Dust PSM, would address the potential ignition sources that cause combustible dust related fires and explosions at facilities. For instance duct work, dust collectors, dryers, mixers, blenders, ovens, bulk storage enclosures are reoccurring problem areas concerning combustible dust related fires and explosions.
The refinery sector Mechanical Integrity PSM program addresses pressure vessels and storage tanks, piping, relief and vent systems and devices, and emergency shutdown systems controls. In contrast the manufacturing sector has bulk storage enclosures (silos, bins), pneumatic conveying duct systems, air material separators (dust collectors), in addition to relief and venting with explosion ventilation panels in reducing the severity of dust explosions.

Implementing written procedures to maintain the integrity of the above process equipment would provide employees with an overview of the mechanical integrity process and the combustible dust hazards that have been identified in a prior process hazard analysis. Process equipment inspection, maintenance, and testing would also be a vital aspect in the MI at the facility where deficiencies can be addressed in a proactive manner.

Incident Investigation Reoccurring incidents of combustible dust related fires and explosions have been a common theme in the manufacturing sector over the past year. This year, over 30% of incidents are repeats of prior fires and explosions at facilities. In many instance a combustible dust fire is a precursor to a a rare event, the combustible dust explosion.
Without proper incident investigation by the facility, the exact cause of the fire goes unnoticed and the combustilbe dust hazard remains present for the next preventable and predictable incident. A Combustible Dust PSM would identify the chain of events and causes where corrective measures such as Recognized And Generally Accepted Good Engineering Practices (RAGAGEP) can be developed and appropriately implemented.

Conclusion: Do I feel lucky?
The above examples are just a few proactive measures that could be crucial aspects of a Combustible Dust PSM that is similar to the current PSM utilized for facilities which process highly hazardous chemicals (HHC). Other measures in the PSM include Hot Work Permits, Emergency Planning and Response, Management of Change, and Compliance Audits. Many of the areas are already covered in the National Fire Protections Association (NFPA) combustible dust standards.Until combustible dusts are recognized as having similar explosive severity characteristics as flammable liquids and gases (highly hazardous chemicals) of the current OSHA PSM, preventable and predictable combustible dust related fires and explosions will continue to occur. Hopefully on a bit of borrowed time the next rare event will not be in the magnitude of the recent Imperial Sugar Refinery dust explosion. Like in the 1971 Dirty Harry movie, Detective Inspector Harry Callahan played by Clint Eastwood asks, "You've got to ask yourself one question: 'Do I feel lucky?"

Thursday, June 4, 2009

Leading Indicators to Improve Safety Programs

Using Leading Indicators to Improve Your Safety Program
By Terrie S. Norris, CSP, ARM, CPSI
Terrie S. Norris is the risk control manager for Bickmore Risk Services & Consulting.
How are you measuring the success of your safety program? Many entities, whether private or public, use one or more of the following: OSHA incident rate, severity rates, claims per $100 in payroll, number of fatalities, average cost per claim, and/or experience modification. These are all great trailing indicators. The problem is that they are measures of failure. A loss must occur before a value can be established. An analysis of the losses may provide a focus for the entity’s safety and health or its liability programs, but it does not drive improvement.
A better equation for the improvement of safety, health, and liability performance is focused attention on leading indicators plus measured performance. Leading indicators are those that focus attention on activities that can contribute to improvement through the elimination or reduction of risk factors and changes in behavior. Leading indicator activities include: job task analysis, early return-to-work, incident investigation, supervisor safety coaching, evaluating safety performance as part of annual performance appraisals, evaluating claims management performance, conducting training, safety inspections, risk management program assessments, and conducting employee perception surveys. The status of these activities is an indication of an entity’s risk management performance.
The other part of the equation is measured performance. How do we know we are doing a better job if we do not measure what we do? We measure our trailing indicators, why not measure our leading indicators? Take safety inspections for example. If the expectations are measured, then the level of performance can be compared from one inspection to another. As an example, a company I worked for was very enthusiastic about golf, and we were very competitive about our scores. We set up our safety inspection program to reflect golf scoring. We used a checklist, but each item had a point value. Points were given for undesirable conditions or behaviors, and points were deducted for desirable conditions or behaviors; the goal was to have the lowest score. Here is an example of the point structure:
• plus 1 point – other than serious
• plus 2 points – serious
• plus 3 points – imminent danger
• plus double points for repeats from prior inspections
• minus points for desired status
The Plant Manager reviewed the results monthly at his staff meetings. This provided management attention to the conditions and safety behaviors within the plant department by department. Management’s attention drove the supervisors to ensure that corrective actions were implemented. Manager and supervisor attention led to improved conditions and the correction of unsafe behaviors. Improved conditions and behaviors resulted in a reduction in the number of loss incidents and near misses, thus improving the plant’s safety performance.
Similar focus can be applied to the overall risk management program. Many mistake this approach as a focus on compliance, but it is not. When assessing an entity’s management of risks, many of the activities and behaviors that drive good risk management go beyond compliance; compliance merely provides a base.
A comprehensive risk management assessment looks at all the risks and exposures and is not limited to workplace safety. Topic areas assessed include the practices involved in: OSHA compliance, early return-to-work, workers’ compensation claims management, emergency management and business continuity, liability claims management, contractual risk transfer, fleet safety and liability, and internal loss control. Public entities also include practices associated with: fire department, street and sidewalk management, sewer management, police department, parks and recreation, and playground management.
When making the assessment, points can be allocated for levels of compliance with regulations and best practices. The assessment measures completeness of: written programs and procedures, employee training, incident investigations, routine inspections, use of standardized forms, follow-up procedures, management oversight procedures, and safety performance appraisal.
Measuring performance of leading indicators provides entities with the ability to establish improvement plans based on SMART goals. Specific, measurable, attainable, realistic, and timely goals set a roadmap that eliminates confusion and sets expectations. Trailing indicators can still play a part in reporting program results. But leading indicators can drive a risk management program to improvement.
PoultryTech is published by the Agricultural Technology Research Program, Food Processing Technology Division of the Georgia Tech Research Institute.Agricultural Technology Research Program – GTRI/FPTD, Atlanta, GA 30332-0823Phone: (404) 894-3412 • FAX: (404) 894-8051Angela Colar - Editor -

Dust Characteristics and Venting

Collecting and Testing Dust
Knowing dust characteristics facilitates ventilation equipment selection
By Lee Morgan, Farr APC

In 1998, both the Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) issued more stringent requirements relating to the use of respirators in plants. Though respirators are critical to shielding workers from ambient dust and fumes, they are not the total answer.
The new OSHA standard (29 CFR 1910.134) states that employers are expected to use engineering controls to protect workers from air contaminants and not rely on respirators alone. While respirators do a good job of protecting workers' lungs, they do nothing to safeguard machinery and process areas from contamination that may result in costly equipment failure, constant rework, or general cleaning nuisances.
The equipment currently used in fabricating plants has reached a new level of sophistication. High-definition plasma cutters, laser cutters, and other computerized systems are more sensitive than machinery was 10 or 20 years ago. If dust is not collected properly from laser tables, welding stations, and similar areas, a million-dollar investment can be ruined in no time.
A well-designed and maintained dust and fume collection system is needed to prevent such problems and keep facilities in compliance with current air-quality requirements. In some cases, a good dust collection and ventilation system can eliminate the need for personal respirators and the challenge of getting employees to wear them.
Despite the importance of dust collection, most equipment decisions are based solely on guesswork, on previous experience, or on general recommendations from suppliers. Finding the right dust collection system is a complex task affected by dozens of variables. The situation does not lend itself to guessing games.
Figure 1 - A dual-laser particle analyzer is used in bench testing to perform particle size analysis.
Fabricators often are unaware that dust and fume collection can be approached scientifically using dust sample testing as the basis for sound and accurate equipment selection.
Testing dust is beneficial in many ways. By identifying the dust characteristics properly, you can determine the right type of collector (such as baghouse or cartridge system) and filtration media for your needs and determine the size equipment you need for optimal energy savings and operational efficiency. By using the right equipment, you can minimize maintenance problems and reduce emissions while extending filter life.

Wednesday, June 3, 2009

Quote of the day

"Dont just do safety - promote it and progress it, so that at the end of your career the safety field is better and more effective than when you started."
James Ramsey - Embry-Riddle Aeronautical University

Explosion Venting Requirements for California

Clarifies Dust Explosion Venting Requirements for California

Jupiter, FL (OPENPRESS) June 9, 2009 -- Recent projects in California uncovered a concern that may be unique to that state. Since similar concerns had been raised in previous California projects international dust explosion protection leader, CV Technology was motivated to clarify dust explosion requirements specific to the state of California.During a recent risk analysis for dust explosion hazards at one of the largest food processing plants in California, several vessels that handle combustible dusts were found to be unprotected.
The client required verification of compliance with applicable NFPA Standards, and if shortfalls were found, the client required recommendations for rectification. In this particular facility all of the vessels requiring protection were indoors and it would be quite straight forward to protect them using explosion vents ducted to the outside.
Vessels needing protection in facilities such as this include storage silos, bins, hoppers, weigh scales, bucket elevators, and air material separators.The concern raised by the client had to do with California’s strict air quality standards. With almost certainty the client predicted that getting permits to allow explosion vents to be ducted to the outside of the buildings would be extremely difficult and time consuming to obtain, if they could be obtained at all. "It’s seemingly a counter intuitive circumstance that there would be any obstacle to installing NFPA compliant explosion vents", states Bill Stevenson, Vice President of Engineering for CV Technology. "Especially, in light of the recent dust explosion losses nationally, the attention this problem has received in the US Congress, and in the media as well as the OSHA Dust National Emphasis program."
A commitment was made to research this issue and report findings. CV Technology contacted the Sacramento Metropolitan Air Quality Management District ( and Cal OSHA ( in the Sacramento office. Representatives of both agencies relayed the following information:• No permitting is required for air quality purposes because properly designed and installed explosion vents do not emit anything to atmosphere during normal plant operations. • No permitting is required by Cal OSHA to install explosion vents in compliance with NFPA Standards. Quite the reverse, the lack of required venting is viewed as a non-compliance violation.
The Cal OSHA representative did caution that there may be local permitting requirements and that the local fire marshal should be contacted for any special local permits. The bottom line is that both agencies view explosion venting as necessary and are anxious for manufacturers to use them where necessary to ensure safety.
This information should surprise no one if it is remembered that explosion venting is the most reliable, cost effective, and practical means to provide pressure relief for vessels that might otherwise be vulnerable to explosion. Explosion vents are installed as a back stop for those rare cases where the elements necessary for explosion come together. This is almost always an unusual set of conditions. So, whereas the lack of proper explosion vents can result in catastrophic losses, their presence in normal conditions would go unnoticed. Properly designed and installed explosion vents neither pollute, nor require energy, and because they are passive, they are intrinsically safe. CV Technology provides strategic consulting to examine and assess the risk of dust explosion. In addition, CV Technology manufactures products that are designed to prevent or mitigate dust explosions. More information and detail is available on the corporate website:
###Professional Free Press Release News Wire

Safety Forecast for the 21st Century

Safety Forecast for the 21st Century
May 24th, 2009 by Dr. Saraf
The 20th century was a time of great technological change that forever transformed how we live and work – changes that necessitated the birth and development of the field of Process Safety Management. The early years saw the evolution of mechanization into assembly lines and true industrialization. Lack of access to South American nitrate during World War I, led to the creation of the synthetic chemical industry. World War II fostered increased industrial growth and sophistication. By the 1960s, we were building computers and beginning our race to the moon. Industries grew becoming increasingly sophisticated and reliant on automated systems. The 1970s brought the creation of the US EPA and OSHA. The 1980s witnessed one of the greatest tragedies in the last century – an estimated 4,000 people died in the 1984 Bhopal accident. Since then, the process safety community has evolved in its approaches and methodologies to better manage risks.
But what have we, as process safety professionals, learned from the experiences of the 20th century? How can we use that learning to make the process industry safer in the 21st Century?
20th Century Accident DataBased on data from Lee’s Loss Prevention Handbook, 551 incidents occurred during the 81 years from 1911-1995.
Out of these 551 incidents, 270 (49%) resulted in a zero fatalities
374 (68%) of the accidents resulted in less than four fatalities
18 incidents (3% of 551) resulted in 100 or more fatalities
A more elegant way to analyze the accident data is to construct a fN curve, where f is the cumulative frequency of incidents leading to N or more fatalities.
In this fN curve,
The first point represents the 281 incidents that resulted in one or more fatalities.
The last point is the Bhopal accident, which is estimated to have resulted in 4,000 fatalities
Based on the 20th century fN curve, we observe
In the 1911-1995 time frame there were 100 incidents that resulted in 10 or more fatalities – an average of 1.2 incidents per year in which 10 or more people were killed.
There were 18 incidents (3%) in which more than 100 people died – an average of 1 incident every six years.
There were 3 incidents (0.54%) in which more than 1,000 died – an average of 1 incident every 28 years.
Prognosis for the 21st Century
How will the fN curve look for the 21st century? Without a crystal ball, a simplistic prediction is that the 21st century curve will be identical to the 20th century. So should we expect 551 process incidents again by 2099?
As technology progresses, clearly it will impact the fN curve.Based on my experience, I’m going to propose a Saraf fN curve predicting fatalities in the process industry for the 21st century.
Here are my predictions regarding the safety performance of the process industry in our current century:
There will be a drop in incidents that result in 1-10 fatalities because of increased hard hat safety requirements and awareness among workers due to better access to hazard communication and training.
In the last century, 18 incidents resulted in 100 or more fatalities. This number will decrease in the 21st century as risk mitigation measures for high consequence incidents become more reliable.
I believe the frequency of incidents that result in 10-20 fatalities will remain comparable. Such incidents are typically a result of human error, siting issues, proximity to community, poor plant design, and maintenance/inspection programs. Based on my understanding, I do not envision elimination of these key safety issues within a matter of a few decades. Zero incident plants are not a reality.
Final Word
Every decade in the 21st century, the process industry will witness an incident that will result in at least 10 fatalities.

Tuesday, June 2, 2009

Footprints to Disaster - Combustible Dust

Footprints to Disaster-Combustible Dust
posted by (John Astad) at Combustible Dust Explosions and Fires-ATEX - 4 hours ago
Justin Clift, Industrial Market Specialist at Hazard Control Technologiesshares with readers at the Industrial Fire Journal an educational article in understanding how to assess, evaluate, and control comb...


Good Housekeeping – Minimize Accumulation of Combustible Dust
Cleanliness in the workplace may be subjective among your employees. OSHA requires good housekeeping, as 29 CFR 1910.22 indicates, “All places of employment, passages, store rooms and service rooms shall be kept clean, orderly, and in a sanitary condition.”
However, if your organization contains combustible dust hazards, one of the best methods to avoid the potential for a combustible dust explosion is to enforce good housekeeping rules. This is not subjective. NFPA 654 warns that a dust layer >1/32 of an inch accumulated on surface areas of at least 5 percent of a room’s floor area presents a significant explosion hazard. The Chemical Safety Board found that the West Pharmaceutical explosion in Kinston, NC in 2003 was caused by dust accumulations primarily under ¼ inch.Materials that may form combustible dust include metals (such as aluminum and magnesium), wood, coal, plastics, biosolids, sugar, paper, soap, dried blood, and certain textiles. Since 1980, more than 130 workers have been killed and more than 780 injured in combustible dust explosions.
OSHA has not only identified a National Emphasis Program on combustible to educate employers of combustible dust hazards, it recently announced that an Advanced Notice of Proposed Rulemaking will be issued. Stay tuned for this regulatory agenda, and start evaluating your worksite for combustible dust hazards. Find more information here.
Finally, to all of you in the profession of protecting workers, happy North American Occupational Safety and Health week. Check out the safety posters created by children of members of the American Society of Safety Engineers!
From: NC State University Blog:

2008 Fire and Dust Explosions Overview

Tuesday, March 3, 2009

2008 Dust Explosions and Fires Overview

The Combustible Dust Policy Institute found through researching media accounts in 2008 that over 150+ combustible dust related fires and explosions occurred in the manufacturing, non-manufacturing and utility sectors in the United States. Over 30% of these incidents are repeats of prior fires and explosions that fire departments are responding to. Subsequently, these reoccurring incidents mostly go unnoticed by OSHA, unless there are at least three injuries or one fatality.
The current OSHA Combustible Dust National Emphasis Program (NEP) directive does not address the majority of national industries (NAICS) where incidents are frequently occurring. For example, over 60% of incidents in 2008 occurred in national industries not listed in Appendix D-1 and D-2 of the NEP. Too much emphasis and resources is being directed toward the OSHA Dust NEP, when the majority of incidents are occurring in national industries not referenced in the NEP.

To further complicate the situation, the Chemical Safety Board Combustible Dust Hazard Study did not include in the profile of affected industries, the Paper, Textile, and Non-Manufacturing subsectors as industries where a combustible dust hazard exists. For example, in 2008, over 22% of incidents occurred in these subsectors. Without this important information, OSHA did not include paper national industries in the NEP. Over 10% of combustible dust related incidents in 2008 occurred in paper national industries.
In contrast, over 7% of incidents in 2008 occurred in the rubber/plastics subsector, where these national industries were referenced 90% of the time in the OSHA Dust NEP. A NAICS listing in the NEP does not guarantee the probability of occurrence will be lessened. For instance, the national industry NAICS: 326150/Urethane and Other Foam Product Manufacturing, the U.S Census Bureau lists over 433 firms in the USA. In 2008, OSHA inspected 9% (37) of these facilities with only three inspected for an emphasis on combustible dust.

For 2008, media accounts of combustible dust related fires and explosions occurred in thirty-six states. The states with 10 more or more incidents included Ohio (12), Illinois (10), Maine (10), Pennsylvania (10), and Iowa (10). Injuries occurred in 12% of the incidents. Of the total incidents reported by the media in 2008, 20% were combustible dust explosions.
Reviewing the the grain sector, through media accounts, over 50 combustible dust related fires and explosions occurred in 2008 with over 30% (15) were dust explosions. The adverse economic impact from dust explosions in this sector was much greater than the economic impact from explosions in the manufacturing sector. A question does arise if it makes good sense to model the current pending combustible dust legislation after the OSHA Grain Facility Standard, when so many injuries and economic damage is occurring from dust explosions similar to what’s happening in the manufacturing sector?
This brief overview of combustible dust related incidents in 2008 will hopefully provide all stakeholders additional insight into the complexity of combustible dust hazards in the workplace. The current occupational health and safety regulatory framework does not currently address the magnitude of the problem that encompasses all the national industries where incidents are repeatedly occurring throughout the manufacturing and non-manufacturing sector.
Posted by John Astad Combustible Dust Policy Institute at 2:25 PM
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