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Wednesday, September 22, 2010

OSHA Regulatory Update is Not Good News for Employers

From Manufacturing & Technology eJournal http://www.mfrtech.com
And Gary W. Auman, Esq.

Pending OSHA legislation makes the employer responsible to make sure employees comply.  It does not place any responsibility on the employees for utilizing their training and equipment. Without such a change the pending legislation will make it almost impossible for a company to avoid OSHA enforcement, no matter how conscientious and safe it is.


OSHA Regulatory Update is Not Good News for Employers
Pending Legislation Does Not Place Any Responsibility on the Employees for Utilizing Their Training and Equipment

In an effort to pass OSHA legislation in 2010, the House recently attached portions of the Protecting America’s Workers Act to the Robert C. Byrd Miner Safety and Health Act of 2010. This action got the OSHA legislation out of committee and ready for a vote on the floor of the House. This legislation is not good news for employers.

Other key points in this article:

  • Bill addresses whistleblower protection.
  • Provide a private cause of action for the employee against the employer if OSHA decided there was not sufficient evidence for it to proceed to court with the employee’s complaint.
  • Creates rights in victims of industrial accidents that result in an OSHA investigation.
  • Require an employer to take immediate abatement action upon receiving the citations, even if the employer intended to file a notice of contest (NOC).
  • A major portion of the new legislation addresses new penalties. 
  • One of the most significant changes in the penalty area is the increase in criminal penalties for willful violations involving a fatality and creating a new category for criminal penalties involving a willful violation resulting in a serious injury.
  • Nothing in the legislation that would relieve employers of full responsibility for the actions of employees on the job.

Saturday, September 18, 2010

Risk Management 101 for Small Business Owners

Good article from American Express Small Business.

Here are some of the highlights:

Risk is an inherent part of being in business.  It can be managed and its adverse outcomes can be mitigated.  The greatest challenge for small business owners is to find the proper balance between peace of mind and profitability.
Take these steps to put an initial risk management plan into place at your company:

First: identify risks
Some risks are common to most or all businesses.  Others are very specific to your business and only you as the owner can know them.  The best way to approach this is to use a standard risks checklist as a start and then add to it based on your specific expertise.  The Small Business Administration provides a Small Business Insurance and Risk Management guide which addresses potential risks. 

Second: determine your company’s vulnerability for each risk
Vulnerability is a function of probability – what are the odds that a particular risk will materialize- and cost – how much does your company stand to lose as a result.


Third: prepare contingency plans
Contingency planning goes beyond just buying insurance.  There are many ways to manage risks.
An effective risk management plan is comprehensive and creative. It goes beyond insurance.

Fourth: Acquire the right types of insurance
Insurance, however, should not be forgotten or minimized!  It is a central part of risk management.

Fifth: Monitor and adapt as needed
Risk management plans should be reviewed and updated regularly.


Reckless leaders take reckless risks; prudent leaders take calculated risks.  Risk management is the “calculator.”

Wednesday, September 15, 2010

If my dust collector is small enough can I keep it inside?

This is another type of question we hear frequently.  Related to a previous post about how to upgrade and protect older dust collectors.  "If my dust collector is small enough can I keep it inside?"

From our friends at Powder Bulk Solids, the "Ask the Expert" Blog, and Shawn McCorkle with Oseco, a question about keeping smaller dust collectors inside and avoiding mitigation:

Explosion Venting/Suppression Q&A

  If I keep the air/material separator under 8 ft. 3 in., can I avoid explosive mitigation?

Answered July 26th, 2010 by Expert: Shawn McCorkle
This is a tricky question. NFPA 654 (7.13.1.2) requires that protection be provided for air material separators that have an explosion hazard. Section 7.13.1.1 requires that air-material separators shall be located outdoors unless it is has explosion protection per 7.1.2.1 (venting through duct, suppression, innerting, containment, flameless venting) or if the volume is less than 8 cubic feet. Therefore it can be located indoors but still must be protected. The problem is that the volume is too small to vent or suppress. So the way I would interpret it is that it would have to be built to contain or innerted. I think that the best solution is to direct this question to NFPA 654 for a clarification.
_________________________________________


This was a very interesting Question. In our business, the business of helping to protect industrial conveying and dust collection systems from fires and explosions, this question comes up often, "How can mitigation be avoided?"
There is no simple answer.  I would first review the process, and in some cases challenge the motive of the question.  Presumably people want to avoid mitigation due to cost factors.  I would submit that mitigation of risk is less costly than loss of life or other injury to personnel, production, or company reputation.  These factors must be included in your decision making process.
  
However, having said that, realize that many factors affect the operation of an air-material-separator, and many factors affect mitigation. Some of these factors include size, volume, strength and location of the vessel, along with combustibility characteristics of the material, air-to-fuel ratios, existing safety systems, applicable current regulations and standards, etc.  You can reduce risk, and you can reduce probability. Consider mitigation as insurance.

These are all factors to be considered within Process Safety Management. - Jeff Nichols

Monday, September 13, 2010

Potential hazards of airborne contaminants

From our friends at Powder Bulk Solids, and the "Ask the Expert" blog, and Rob Williamson at Dantherm, a question about the potential hazards or airborne contaminants and dust collection.


Dust Collection & Pollution Control Q&A

  Question: What are the potential hazards of the airborne contaminants that are removed by dust collection?

Answered August 31st, 2010 by Expert: Rob Williamson
Dust collection removes airborne contaminants, such as dust, mist and fumes from the work environment. The airborne particles created by cutting, shaping and grinding are more than a nuisance, they can be a serious health hazard to both health and safety if not properly controlled. Here are some of the potential problems of which you should be concerned:
Respiratory effects are the primary health concern. Inhaling excessive dust, mist or fumes can cause nasal irritation and bleeding, inflammation of the sinuses, wheezing, prolonged colds and decreased lung function. You can also develop an allergy and asthma from repeated exposure to certain airborne contaminants.
Skin and eye effects are also possible. Dermatitis, an inflammation of the skin, can occur from repeated contact. Symptoms can include itching, redness or cracking of the skin. These contaminants can also cause eye irritation.
Certain airborne contaminants are known human carcinogens. Occupational exposure can cause cancer of the sinuses and nasal cavities.
__________

I would also add that in industrial processing these airborne contaminants in many cases are also combustible.  Proper dust collection system design, controls and housekeeping, as well as safety and protection systems are required.

Saturday, September 11, 2010

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

Another good article from our friends at Farr on OSHA REQUIREMENTS and MANUFACTURERS RESPONSIBILITIES for COMBUSTIBLE DUST , DUST COLLECTORS and dust collection systems.

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.

Friday, September 10, 2010

Just What Is Innovation?

From Chemical Info, and author Mike Collins, comes a good piece on innovation.

Here are a few hints:
Leadership, Change and Creativity
R&D and Experimentation
Procedures and Processes
Culture and Environment
Problems, Trends and Opportunities

He also has a few warning signs for you. Can you say "Outsourcing"?
 
BLOG: Just What Is Innovation?
If the innovation process goes offshore, America will lose much of its capacity to generate wealth, and that decline in long-term economic growth is assured … continue

Old but still functioning dust collectors need to be upgraded

This is a question, we hear frequently. 

From our friends at Powder & Bulk Solids "Ask The Experts Blog", an article by Dr. Mayer with Rembe answering the question about what the requirements are for old dust collectors:

Explosion Venting/Suppression Q&A

  We are a food processing company with an old but still functioning dust collector that needs to be upgraded and currently has no vent panels. We have been told that we need to move the dust collector outside in order to be in compliance with NFPA standards. Kst is somewhere around 150 bar m/sec or less. Is that our only option?

Answered September 9th, 2010 by Expert: Dr. Gerd Mayer
Not necessarily. You really have a number of options. Depending on distances, Preds and such, you might be able to duct and vent the collector to the outside with an explosion panel if your collector is close to an exterior wall. But you need to pay attention to the Pred of the collector and you may need to strengthen your collector (you mention it is old!) due to potential back pressure that will build up. Another option is to safely vent your dust collector with a flameless vent, designed to capture both the flame and pressure of a combustible dust explosion, should one occur. Or, as you mentioned, you might decide you want to move the dust collector outside to a “safe” location, away from the facility and away from areas where people might walk or gather or vehicles might park or be located.
_____

This is a good answer by Dr. Mayer.  Things that need to be considered are the size of the dust collector, age, strength, location, and proximity to an outside wall. To meet current NFPA 654 Standards you will also need to consider not only explosion venting, but also sprinkler or deluge, a Spark Detection System, Isolation, and if the collector is returning air back to the plant, you may also need to consider Spark Detection and an Abort Gate.  If you have questions in this area, we can help.

Tuesday, September 7, 2010

OSHA Issues Stern Warning to Grain Handling Facilities (Combustible Dust)

OSHA Issues Stern Warning to Grain Handling Facilities (Combustible Dust)

From Our friends at Nilfisk Industrial Vacuum Blog:

OSHA Issues Stern Warning to Grain Handling Facilities (Combustible Dust)

Following several safety violations in August, OSHA is sternly reminding grain handling facilities to comply with the proper safety and maintenance procedures, outlined in the Grain Handling Facility Standard.
At a recent press conference, David Michael, OSHA Administrator stated, “I am appalled at the outrageously reckless behavior of some operators of grain storage facilities. OSHA has investigated several cases involving worker entry into grain storage bins or elevators where we have found that the employer was aware of the hazard and OSHA standards but has failed to train or protect their workers. OSHA has aggressively pursued these cases and will continue to use our enforcement authority to the fullest extent possible…We will not tolerate noncompliance with our Grain Handling Facilities Standard, and we will take violations of these standards very seriously.”
And if that didn’t get people’s attention, The Wisconsin Agri-Service Association has notified it’s members of OSHA’s new local emphasis program for grain handlers, in which the agency will randomly select a cycle of 10 facilities at a time within each of the four Wisconsin area districts (WI, IL, OH) to inspect them for major hazard areas. The Local Emphasis Program will investigate hazards like engulfment, falls, combustible dust, and electrocution and focus on feed mills, ethanol plants, pet food manufacturers, grain elevators and warehouses.
For facilities looking to bulk up their maintenance efforts in response to OSHA’s strict message, our A17 EXP vacuum cleaner is a top choice among grain handling facilities. It’s an air-operated vacuum (often preferred) that’s ATEX-approved (Ex) for Zones 1, 2, 21 and 22. It’s also designed to meet the requirements for use in Class I, Group D, and Class II, Groups E, F, and G locations. More info on our website.
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