1. NFPA Standards - Benefits and challenges. Should they be used as OSHA Standards or compliance alternatives?
2. Scope - What facilites and combustible dusts should be covered or not, and on what technical basis?
3. Economic Impact - Costs and benefits of proposed rules and regulatory approaches?
4. Hazard Mitigation - Where and how engineering and administrative controls are applied, methods of analysis?
5. Additional topics - questions, comments, topics.
12 Lessons learned from the OSHA Combustible Dust Stakeholder Meeting February 17, 2010 1:00pm Session:
1. The lack of participation by local and regional companies affected by the new OSHA Combustible Dust Standard, and other industry professionals is perplexing.
2. There is no deadline for creating the new OSHA Combustible Dust Standard.
3. Generally defining Combustible Dust industry wide is a very complex issue.
4. Existing NFPA and other Combustible Dust definitions typically rely on bulk density, i.e. a specific thickness of dust layer, without considering other combustibility features of the dust.
5. Protecting a dust collector from explosion is the same cost whether you have a small or large company.
6. Uniform testing standards are needed for certain protection devices.
7. There is not enough key front line employee participation in the standards development and implementation process, as these employee's generally have valuable input to process upset conditions and causes.
8. There needs to be a baseline prescriptive standard, but also performance based engineered standards because of the complexity of various dusts and industries.
9. Migrating dust must also be taken into consideration, not just the initial process dust.
10. Industry education is lacking. OSHA can help educate industry by collecting and disseminating combustible dust fire and explosion news.
11. OSHA can help educate industry by identifying system failures that contribute to citations.
12. Major keys to safety are containment of fugitive dust, housekeeping, and personal protection equipment and clothing.
Industries tell OSHA officials that regulating dust can be complex, expensive
The U. S. Department of Labor's Occupational Safety and Health Administration is holding the second of a series of roundtable discussions with industry volunteers as it considers drafting regulations. It started the process last year in response to congressional reaction to a dust explosion at Imperial Sugar's Port Wentworth mill near Savannah that killed 14 workers two years ago. Many of the victims were brought to Augusta for burn treatment.
Dorothy Dougherty, director of standards guidance at the agency, said there is no date set for when regulations would be drafted.
"We have to take our time," she said.
Most of the comments cautioned against applying too strict of a standard to every industry, from food processing to sand blasting to coal dust at neighborhood print shops.
"If I spill a gallon of gas in the middle of this room, we're all going to head for the exists. It I drop a bag of flour, we aren't," said Thomas Lawrence of RRS/Schrimer of Ballwin, Mo..
Cost estimates for compliance ranged from $2,000 to test dust for combustibility to as much as $30 million to upgrade a power plant.
Brian Edwards of Tucker, Ga.-based Conversion Technology warned that many costs are the same for specific machinery regardless of business size.
"If a company has to put in explosion-suppression equipment, it's going to cost the same whether it's a Fortune 100 company or a mom-and-pop shop, and that's hundreds of thousands of dollars," he said.
Grain Group Urges Exemptions for OSHA Dust Standard
NGFA expressly opposed harmonizing the grain-handling standard with any general industry combustible dust standard that may be developed. ...
|Atlanta Attorney Speaks During OSHA Meeting|
dBusinessNews Atlanta (press release)
As part of its rulemaking process for the proposed Combustible Dust Standard, the Occupational Safety & Health Administration has solicited comments from
|Industries tell OSHA officials that regulating dust can be complex ...|
Savannah Morning News
Attorney Howard Mavity, of the Atlanta firm Fisher & Phillips, said he often visits factories that generate combustible dust operated by his clients, ...
Here are the meeting notes from the December 14, 2009 Stakeholder meeting in Washington DC:
http://www.regulations.gov/search/Regs/home.html#docketDetail?R=OSHA-2009-0023Posted by Brian Edwards, PE, Conversion Technology, Inc.