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Wednesday, December 21, 2011

NFPA's Guy Colonna details new committee structure for combustible dust ...



This is a great interview with Guy Colonna with the NFPA. He explains the NFPA's document structure for combustible dust.


There are eight NFPA documents that specifically address dust....and all of them address two hazards -- fires and explosions. Guy Colonna, head of NFPA's Industrial and Chemical Engineering Division, talks about a new committee structure that's in the works for NFPA's combustible dust documents.

Friday, December 16, 2011

"View your business as the market's most trusted, valued, and prized provider, advisor, and source: What you do is for a greater good, and you're truly being selfless in your business goal to serve the client better and more fully than any other competitor does." - Jay Abraham

Tuesday, October 25, 2011

Workplace Safety Toolkit

Workplace Safety Toolkit

Workplace Safety Is No AccidentAn Employer's Online Toolkit to Protect stakeholders.
Safety begins with corporate culture. This site is an excellent resource for your plant safety and health program.
It contains worksheets, checklists and information on a host of subjects related to health and safety including:

Foundational concepts such as Safety Policy, Job Descriptions, Safety Committees.

Concepts and Applications about how and why accidents happen, framework for safety culture, OSHA Fact Sheet and checklist, accident analysis and reporting.

And other Concerns and Issues such as ADA Compliance, pathogens, building maintenance, confined spaces, construction, drug free workplace, electrical safety, emergency action planning, ergonomics, fleet safety, food safety, hazardous and toxic substances, housekeeping, lockout/tagout, mold and mildew, off site assignments, portable power tools, PPE, security, workplace stress, and workplace violence.

Make sure and check it out. This site has the tools you need to help promote your safety culture, and keep your personnel safe.



Tuesday, October 18, 2011

Is Your Woodworking Plant OSHA Safe?


From the Woodworking Network blog, a good article on OSHA press releases in which wood products firms have been cited for serious, repeat and/or willful safety and health violations.

What is your corporate safety culture like?

Only serious "continuous significant improvement", and benchmarking best engineering practices to your health and safety program will prevent these type OSHA violations and citations.  Ignorance and negligence of current NFPA Standards for combustible dust, dust collection and other safety practices is what causes OSHA to have to police your business.

Like Rich in this article, I shake my head every time I read one of these stories or press releases, and it is almost a daily occurrence.  The shame is that many of the events in these stories could have been prevented!

My business is in the field of combustible dust, and helping protect process conveying systems, and dust collection systems from fires and explosions. My primary focus is in prevention, and providing and applying fire and explosion prevention and protection systems. Our purpose is helping our clients and customers prevent process fires and explosions - "Saving Production - Saving Lives!"

From my point of view, business should be able to police itself, and has a moral obligation to protect its most valuable asset - human capitol, and not just employees, but all stakeholders who come onto your property.  Because of negligence by a few, now OSHA has to police our manufacturing community.

This is the kind of stuff that keeps me up at night. I have actually had plant managers tell me they would rather have their plant burn down rather than invest in appropriate safety systems to protect their production, people, and reputation!  I have seen the catastrophic effects and loss of life as a result of this type attitude toward safety. To me this type attitude is willful negligence.  Safety systems and procedures aren't an empty expense to your business, but part of your production systems, a valuable asset to help keep you in business, and your people safe. They are insurance.

My goal is to leave the the process industries safer then when I started.  Let me help you protect your process from fires and explosions. We are here to help.

-Jeff Nichols

Is Your Woodworking Plant OSHA Safe?

By Rich Christianson | 08/07/2011 2:00:00 AM
I don't think that owners and managers of woodworking businesses lie awake at night thinking of ways to make their plants more dangerous for their employees. Yet, it is also apparent that some woodworking business owners and managers could do more to make their shops a safer work environment.

This is why I shake my head every time I see an OSHA press release in which a wood products firm has been cited for serious, repeat and/or willful safety and health violations. Are managers of these plants that callous or is OSHA simply overzealous?

Considering the long list of potential hazards in a typical woodworking operation -- machine guarding; wood dust as both respiratory and combustible dust issues, noise pollution, eye safety, VOC emissions from finishes and adhesives, etc. -- it's almost impossible not to imagine that on any given day, any wood operation could be cited by an OSHA inspector for one or more health and safety violations. And the preceding list doesn't even include administrative requirements such as maintaining Material Safety Data Sheets on file, developing a hazardous communications program and providing workers with regular safety training.

Callous or Picked on?My head is still shaking after posting an OSHA press release about Northeastern Wisconsin Wood Products of Pound, Wi, which was recently cited for 18 alleged health and safety citations, including 13 willful violations, which OSHA defines as "one committed with intentional knowing or voluntary disregard for the law's requirements, or with plain indifference to worker safety and health."

The 13 willful violations cited against Northeastern Wisconsin Wood Products, including failure to provide workers with ear and eye protection;; lack of machine guards and guard rails; and accumulations of combustible dust;, carry penalties totaling $360,000 in proposed fines.

What makes this case particulary disconcerting is that OSHA had cited this firm for violations as early as 2006 and again in a follow-up inspection in 2007. In May 2010 the company was issued a secretary of labor petition for summary enforcement and granted 30 days to work with a Wisconsin state consultation service to abate the violations. According to OSHA, the consultation service fired the client "due to a lack of cooperation by the company."

When OSHA inspectors returned to the plant in January of this year, they identified the 18 violations, many of which OSHA noted were for the same safety and health issues it had originally written the company up for in 2006.

Incredible. Five years after being told where it was deficient in employee health and safety and many of the same problems continued to persist.

Adding insult to injury, OSHA this time also cited the company for a repeat safety violation carrying a proposed penalty of $7,920 for failing to provide potable water for drinking, plus three serious violations for failing to periodically inspect energy control procedures, use group lockout devices and train employees in electrical safety.

I would hope that Northeastern Wood Product managers have answers to explain their apparent disregard or inability to correct the deficiencies pointed out by OSHA inspectors.

'Worst Case Scenario'Northeastern Wood Products is hardly alone and as bad as it seems, another wood product company's predicament stands out in my mind as "the worst case scenario."

You may recall reading Woodworking Network's report about Phenix Lumber of Phenix City, AL, which was fined $1.9 million by OSHA willful violations in June "for egregious and other safety violations, including exposing employees to amputation and fall hazards." OSHA said while investigating the report of an employee who lost a finger in Phenix Lumber's planer mill, it learned of a second employee who had lost part of his hand working in the mill.

In citing Phenix Lumber for 24 willful violating, OSHA noted that the company had been been cited 77 times by the safety agency for serious safety and health violations since 2007, including for machine guard and lock-out/tag-out problems that if corrected might have prevented the amputation injuries.

The $1.9 million in proposed penalties was lumped on top of $439,400 in OSHA fines that Phenix Lumber received for relative to a fatal forklift injury and the case of a worker who was critically injured in a debarker machine accident.

Phenix Lumber issued a statement that it "has continued to significantly improve its safety and health program especially over the past year. Specifically, it has continued to revise its safety policies and procedures and to address OSHA concerns, has trained and retrained all of its employees and managers including the OSHA 10-hour safety training course, has provided additional personal protective equipment to all its employees and is providing weekly safety talks to all employees."

Maybe if Phenix Lumber had "continued to significantly improve its safety and health program" beginning after the initial OSHA violations in 2007, one or more of the tragedies at its plant would have been averted.

The bottom line is that while OSHA has a relatively small inspection crew, and many wood shops never see hide nor hair of an OSHA inspector, an OSHA inspection is just an accident or whistle from a disgruntled current or ex-employee away. And once a company is on OSHA's radar it remains there for years to come. Just ask the managers at Northeastern Wisconsin Wood Products and Phenix Lumber.

As the old saying goes, "Safety is no accident." Be sure to do regular audits of your operation to be OSHA safe, including meeting all of the record and reporting requirements. It's a huge task, but one that when done should help you sleep better.

Read more of Rich Christianson's blogs.

Sunday, October 16, 2011

So you want to build a biomass plant?

So you want to build a biomass plant? - TimberBuySell.com - the portal for timber, logs and woody biomass

In this article from TimberBuySell.com, Paul Janz with Ausenco Sandwell in Vancouver, BC gives you a quick overview of all the complexities involved.

A Beginners Guide to the Project Development Process

With the current emphasis on producing `green energy from biomass and the subsequent government grants and subsidies available to promote the idea, a lot of well-meaning but inexperienced entrepreneurs are promoting the construction of plants that will process biomass into one form or another.

There are some basic steps that all projects go through, from concept to start-up, whether the `builder is new to the process or whether it is a company with a well formulated plan for development. Following is a brief description of the project development process.

Friday, October 14, 2011

Dust explosions explained | Characteristics, ignition and effects

Dust explosions explained | Characteristics, ignition and effects

From the Dust Explosion Info website a great article on characteristics of explosions,  explosion concentrations, ignition of dust clouds, and the effects of explosions.

This website is an excellent starting point for those wanting to know more about explosions, the physical characteristics of an explosion, the necessary conditions for an explosion to occur, potential ignition sources, dust explosion statistics, flammability, risk assessment, dust explosion prevention and protection, standards, and hazardous area classification.

Wednesday, October 12, 2011

OSHA Should Beware of Combustible Trust

Combustible Trust
From Material Handling and Logistics and the MHL.com blog, is an interesting piece on why OSHA removed powered industrial trucks from the latest Combustible Dust status report in the rulemaking process.

OSHA Should Beware of Combustible Trust
Tom Andel
September 9th, 2011

That old line about the sliding scale of untruths—lies, damn lies and statistics—is fun to use when someone quotes a number to support their argument. How many times have you read an article that debunks a widely-believed statistic? A few years ago chocolate was bad for you. Too much sugar, caffeine and empty calories. Now the conventional wisdom is that chocolate is good for you. Its antioxidants will help you live to 150. That’s if you don’t get killed in an industrial dust explosion first.
That was another popular belief a couple years ago—that lift trucks were involved in many of the combustibe dust violations found by OSHA inspectors. That stat was reported in a status report OSHA published in 2009 on its Combustible Dust National Emphasis Program.

“Employers were cited for violations of personal protective equipment, electrical equipment for hazardous (classified) locations, first aid, powered industrial trucks, and fire extinguisher standards during these inspections,” the report stated. It documented this with a chart showing Powered Industrial Trucks responsible for 236 violations—third behind hazardous chemicals and Housekeeping.
Recently, John Astad, an expert on the hazards of combustible dust whom I’ve quoted in previous blogs, e-mailed me a new version of this report. It had the same chart, but the industrial trucks category was missing. He was concerned that, whether this were a mistaken or an intentional omission on OSHA’s part, that it could lower a user’s guard about the dangers of using spark-ignited engines in dusty environments and leave them vulnerable to citations.
Astad is sensitive to irregularities in OSHA stats, citing one in particular which states that 90% of combustible dust related incidents result in injuries or fatalities. This is diametrically opposed to his own research done in 2008 where he found that fewer than 10% of ComDust related incidents resulted in injuries or fatalities.
I checked with my source at OSHA, and after a little investigation, here’s what he found out about that chart from which the industrial trucks category was removed:
“After reviewing the data on which the bar chart was based, it was concluded that powered industrial trucks were involved in not 236 violations, but only 24 violations,” he told me. “In other words, 212 of the 236 combustible dust related violations attributed to powered industrial trucks had nothing to do with combustible dust. This error was rectified in our revision, in May of 2010.”
I share this with you as a reminder to keep that salt shaker handy next time you’re being fed statistics. Numbers go down easier with large grains of salt.

Monday, October 10, 2011

System Safety Skeptic - Lessons Learned

System Safety Skeptic - Lessons Learned

"Effective system safety efforts require learning from failure"

From Terry Hardy and the "System Safety Skeptic" Blog, an article on the lessons learned from the chemical explosion at the 1999 Y-12 Plant in Oak Ridge, TN.

Lesson Learned: Analyses after accidents often show that clues existed before the mishap occurred. Such clues frequently take the form of anomalies observed during the life cycle of a project. An anomaly is an apparent problem or failure that occurs during verification or operation and affects a system, a subsystem, a process, support equipment, or facilities. Anomaly or problem reporting and corrective action, therefore, can play an important role in system safety analyses. An effective anomaly report and corrective action process not only allows for the reporting of problems, but also implements a closed-loop process for finding and fixing the root cause of a problem. In the case of this accident, if the near misses had been properly reported and analyzed, this accident may have been prevented.

Wednesday, September 21, 2011

Explosions, fires kill 47% more workers in 2010

Explosions, fires kill 47% more workers in 2010

From Woodworking.com and Woodworking Network, an article based on the U.S. Bureau of Labor Statistics' National Census of Fatal Occupational Injuries, shows 47% rise in fire and explosion deaths in 2010.


WASHINGTON — Work-related fatalities resulting from fires and explosions increased dramatically from 113 in 2009 to 187 in 2010 -- the highest count since 2003, according to the U.S. Bureau of Labor Statistics' National Census of Fatal Occupational Injuries.
This 47% rise in fire and explosion deaths stands out from the rest of the report which indicated that job-related deaths held steady from 2009 to 2010. In fact, four fewer workers died on the job in 2010 than in 2009, 4,547 compared to 4,551 respectively.
The Occupational Safety and Health Administration is continuing to study the potential of developing a combustible dust standard that could impact the woodworking and other industries.
The top five causes of work-related deaths are:
  • Transportation incidents, 1,766;
  • Assaults and violent acts, including homicides, 888;
  • Contact with objects and equipment, including getting caught in equipment or struck by projectile, 732;
  • Falls, 635; and
  • Exposure to harmful substances or environments, 409.
Three hundred and 20 deaths occurred in manufacturing compared to 768 in mining, 751 in construction, and 586 in agriculture and forestry.
View the Bureau of Labor Statistics report on occupational fatalities.

Tuesday, September 20, 2011

It's Only DUST! What's the big deal?

"It's only DUST! What's the big deal? Under the right conditions, many types of industrial dust, including coal, paper, and wood dust, can ignite and produce a devastating explosion. With our Combustible Dusts course, you'll learn to identify the hazards of combustible dust by using the Dust Fire and Explosion Pentagon. You'll get a clear understanding of dust control and preventions measures as well as dust analysis and explosion risk reduction. Our course will also help identify additional risks and prevention techniques associated with primary and secondary dust explosions.
Based on OSHA's ""Status Report on Combustible Dust National Emphasis Program"" and ""Hazard Communication Guidance for Combustible Dusts."""

From the Combustible Dusts Safety Video - BuisnessTrainingMedia.com
It's Only DUST! What's the big deal?

Monday, August 22, 2011

Category » Dr. Gerd Mayer « @ Ask The Experts

From Poweder and Buld Solids "Ask The Experts" Blog, here is a great seires of questions about dust collectors and combustible, answered by Dr. Gerd Mayer with Rembe, Inc.

Category » Dr. Gerd Mayer « @ Ask The Experts

Explosion Venting/Suppression Q&A

  • If you have an existing dust collector with no provisions for handling explosive/combustible dust and you test your dust and find out it is combustible, what are the issues to consider in determining if the system can be modified to handle explosive dust or if it needs to be replaced with a new system?

    Under typical circumstances where you have complete information about your dust collector, such as the strength of the collector, retrofitting should be no problem. In that situation, in accordance with NFPA standards 654, 68, 69, and perhaps other standards that specifically address your industry, a dust collector must be vented/suppressed and isolated ( the inlet always needs to be isolated; the clean air side must be isolated if it is a return-air installation). If the dust collector is inside, the dust collector might be vented through a duct to the outside, an indoor flameless vent can be installed or chemical suppression might be used. If the dust collector is located outside, explosion panels or flameless vents can be used depending on the proximity to other structures and people. NFPA standard 68 provides the method by which to calculate the required vent areas.
    If you are in a situation where you don’t know the strength of the dust collector and you have no way of finding out the strength, you will either need to have an engineering analysis done on the dust collector or replace the collector to be absolutely sure you are properly calculating the vent area. There is no way to calculate the vent area if you don’t know the strength of the dust collector, and effective vent area is the critical component to minimizing damage to people and structures should there be a combustible dust explosion in the dust collector. In that case, you may decide you are better served by replacing the dust collector but you will still need to equip the collector with the appropriate venting/suppression and isolation equipment as indicated above.
    Note: Even if you have all the information about your dust collector, you may find that the strength of the dust collector is such that it is more cost effective to increase the strength of the collector to reduce the costs of equipping with explosion protection equipment or to buy a new collector and properly equip it to protect it.
  • If an existing older dust collector is collecting dust that can explode, is it better to upgrade the existing dust collector with explosion protection or buy a new one that already has the explosion protection built in?

    Per NFPA regulations, each enclosure containing a combustible particulate has to be vented or suppressed, no matter how old the enclosure is. In the case of a dust collector, if the reduced pressure (Pred) for the existing dust collector can be determined either by the manufacturer’s specifications or through a structural analysis, the old dust collector can be upgraded and still be used. In some cases, the cost to determine the Pred could be quite high, and the dust collector may need too much “strengthening” or other redesign—retooling doors that will not withstand explosions, for example, so that purchasing a new dust collector could be the more economic solution. Whether you retrofit an old dust collector or install a brand new one: either one of them has to include explosion protection and explosion isolation.
  • This question pertains to dust collectors that are 8 ft in diam. and 11 ft high. Currently our dust collector bags are at the same elevation as the explosion vents. We are considering a modification - increasing the air to cloth ratio by increasing the length of the bags, hence increasing the height of the dust collector housing. Are there any regulations that require the explosion vents to be mounted lower than the bottom of the dust collector bags?

    NFPA Standard 68 gives you precise guidelines for how explosion vent panels should be installed. The goal of NFPA Standard 68, 8.7.1 is to prevent the bags from blocking the vent such that the bags might be “sucked through” the vent if there is an incident.
    Explosion vent panels should be installed underneath the bottom of the filter bags as described in NFPA Standard 68, 8.7.1. If, for any reason, there is not enough space to install the panels underneath the filter bags, you may, per NFPA Standard 8.7.1 (2), install the panels along the dirty air wall if “… bags are either completely removed or shortened so that they do not extend below the top of the vent for a distance of one vent diameter from the vent. In addition, bags immediately adjacent to the vent shall be removed and the remaining bags shall be restrained from passing through the vent.” NFPA Standard 68, 8.7.1(2), 2007 edition.
    Another acceptable explosion vent panel placement option, per NFPA Standard 8.7.1 (3): “…the bottom of the vent(s) is at or above the bottom of the bags,…and the row of bags closest to the vent are restrained from passing through the vent… For this case, the volume used to calculate the vent area shall be the entire volume (clean and dirty) below the tube sheet.”

Thursday, August 18, 2011

Sawdust Cannon

From Navy Island, Inc., a MN manufacturer of veneers and doors. Excellent example of a controlled wood dust explosion. Notice how the flame front moves through the suspended dust. This is a perfect example how a flame front will travel in a primary or secondary explosion. Click on the link to see the original:

Sawdust Cannon


Or watch this YouTube video:

Thursday, July 21, 2011

Non-compliance can be expensive

From InsuranceJournal.com comes a story about a judge who ruled in favor of the insurance company after a fire, when a company had not updated it's protection systems. This could also apply to the process industries. Think about what this could mean for your company. If you think compliance is expensive, look at the cost of non-compliance.

Massachusetts Judge: Obsolete Fire-Suppression Means No Claims Paid
A Massachusetts restaurant owner who failed to upgrade his obsolete fire suppression system was not entitled to collect insurance money after a massive fire six years ago — and must return $15,000 advanced to him by his insurer, an appeals court judge ruled.
At issue is an exclusion in a commercial lines policy issued to the French King restaurant in Erving, which required the restaurant owner to maintain a fire suppression system. The insurer — Interstate Fire & Casualty Co., a subsidiary of Fireman’s Fund — claimed that the fire-suppression system installed at the restaurant was obsolete, and therefore triggered the exclusion and did not require them to indemnify the restaurant.
Lawyers for Interstate argued that the restaurant owners and managers knew the system was obsolete and failed to correct problems that might have averted a fire that caused substantial damage to the restaurant in October 2005, when the system failed to function properly.
A so-called “dry” fire-suppression system, manufactured by Kidde, had been installed in the restaurant since before 1974. In 2000, the manufacturer recommended that all dry systems be upgraded to “wet” ones. Two years later, it ceased supporting, inspecting and repairing dry systems.
In 2004, the state’s Executive office of Public Safety issued a bulletin saying that dry systems were no longer supported by manufacturers, and were no longer in compliance with National Fire Protection Association codes — a requirement in the Bay State.
In 2003, the company hired by French King to service its dry system told the restaurant owners that the system was no longer in compliance and needed upgrading to a wet system — an estimated cost of $3,250. A year later, a building inspector told the restaurant it could no longer issue an inspection certificate because of the obsolete “dry” system.
A previous insurer — MassWest — had non-renewed the restaurant’s policy in 2002 because its system was out of date.
Following the fire, Interstate initially advanced the restaurant a $15,000 payment. But following an investigation of the fire suppression system, it declined to pay the claim and sought to recover the money it had paid.
French King sued the insurer and two superior court judges ruled in favor of the insurance company — finding that the system was no properly maintained and that the money should be repaid. Appeals Court Justice Francis Fecteau affirmed those rulings.
“There is nothing in the record that indicates that this was an unconditional advancement, especially because the (insurer) had not commenced investigating why the fire suppression system did not work,” he wrote in his opinion on the case. “There was evidence that the plaintiff did, in fact, know that there could be potential issues with the Kidde system” thus Interstate “was entitled to reimbursement of $15,000.”

Wednesday, July 20, 2011

Georgia Biomass Explosion

From the Florida Times Union and Jacksonville.com, a brief story about the explosion at Georgia Biofuels.  Pelletizers, dryers, grinders, pellet coolers, dust collection systems, and storage silo's are main concerns for safety systems to prevent fires and explosions at biomass pellet plants. This fire appears to have started in one of the pellet mills or "pelletizers" which extrude wood dust into pellets at high speed creating friction and heat. The fire was then likely transferred to the pellet coolers and dust collection systems which contain combustible dust in suspension causing the deflagration.

-Jeff Nichols


Overheated assembly caused Georgia Biomass explosion | jacksonville.com

Wood pellet production should resume today at Georgia Biomass, which was crippled by a dust explosion last month. The plant is near Waycross.
"We're ramping up now ... starting the equipment and getting it all ready to go," plant manager Ken Ciarletta said about noon Tuesday.
No one was injured in the early morning explosion June 20, which damaged some of the processing equipment at the plant that employs about 80 people.
An investigation revealed that an overheated roller/bearing assembly in a pelletizer sparked the blast at the factory, Ciarletta said.
No employees were laid off while production was shut down at the plant, he said.
As equipment was repaired and modifications made to prevent a recurrence, employees went through training and worked in other areas of the plant, he said.
He wouldn't reveal the cost of the damage, saying it was proprietary information. Ciarletta did say "the capital damage was comparatively low and has been repaired."
Georgia Biomass is a subsidiary of RWE Innogy of Germany, one of the top five electricity and gas companies in Europe. An estimated $175 million investment, the plant is in the Waycross-Ware County Industrial Park about five miles west of Waycross off U.S. 82 and U.S. 1.
The plant began operating May 12. Using yellow pine timber from throughout Southeast Georgia, its goal is to produce about 750,000 tons of wood pellets annually. Wood pellets are used as fuel - a cleaner-burning substitute for coal - primarily in Europe.

Read more at Jacksonville.com: http://jacksonville.com/news/georgia/2011-07-13/story/overheated-assembly-caused-georgia-biomass-explosion#ixzz1SeuqV33r

Monday, July 11, 2011

Workplace Safety * Consider Inherent Safety at Your Plant

Workplace Safety | Consider Inherent Safety at Your Plant | Chemical Processing

From CheicalProcessing.com, an excellent article on Inherent Safety Design (ISD).  Here are a few important highlights for ISD.  This article has been condensed for space, for the full article, click on the link above.


Consider Inherent Safety at Your Plant

Many sites can benefit -- but confusion about how to identify options stymies efforts.

By Dennis C. Hendershot, process safety consultant.

Inherently safer design (ISD) is a philosophy for designing and operating a safe process plant [1,2]. ISD aims to eliminate or significantly reduce hazards, rather than managing them with hardware and procedures. When feasible, ISD provides more robust and reliable risk management and, by eliminating costs associated with safety equipment and procedures, may make processes simpler and more economical.

Levels of Inherent Safety
Used during detailed equipment configuration and design, it can eliminate or significantly reduce many risks within a process that still contains major hazards.


You can classify levels of ISD as follows:
• First-order inherent safety — eliminating hazards from the process altogether;
• Second-order inherent safety — reducing the magnitude of a hazard, or making it extremely unlikely, perhaps nearly impossible, for an accident to occur; and
• Layers of protection — making passive, active and procedural risk-management safeguards inherently more reliable and robust.

Many opportunities exist to design a more robustly safe plant by applying second-order strategies and even by using ISD thought processes during design of safety hardware and procedures that manage risk of major inherent hazards.


Implementing ISD
In an ideal world, plant designers and operators would think about ISD throughout the process design and operational lifecycle; specific ISD review tools wouldn't be needed. But, in the real world, most facilities already exist and ISD wasn't considered during their design, or companies and engineers aren't familiar with ISD and don't look for opportunities in process design. Specific ISD review tools can help overcome these problems. Chemical engineers have used three approaches for implementing ISD in new and existing plants:
1. An inherent safety analysis of a process using an ISD checklist;
2. An independent process hazard analysis (PHA) for a plant focusing on ISD; and
3. A complete PHA of the plant with ISD considerations fully incorporated into the PHA discussions.

ISD checklist analysis. A checklist is a common PHA technique and can serve to identify ISD options. The checklist is best used in a team setting, with a variety of people familiar with all aspects of the plant and process considering the questions on the checklist. Treat it as as a "creative checklist" — in other words, use it to prompt creative thinking by the team, not just "yes" or "no" responses.

An extensive checklist of practical inherent safety considerations. It's organized around four major ISD strategies as well as plant geography:

• Substitute;
• Minimize;
• Moderate;
• Simplify; and
• Location, siting and transportation.

 It's important to make sure use of checklists doesn't limit team creativity. No general checklist can identify every potential ISD option for a specific process — the review team itself will have more knowledge about the plant and should use the checklist as a tool to facilitate creative thinking about how to eliminate or reduce hazards.

Independent ISD PHA.  This type of a review - also a team activity - focuses on specific hazards associated with the process and applies ISD strategies (substitute, minimize, moderate, simplify) to identify ways of eliminating or minimizing them. It uses one of the standard PHA tools (e.g., What If, Hazop) to pinpoint hazards but team discussion centers on ISD considerations.

CCPS has published another useful tool for consideration of ISD [4]. This book provides a series of tables of potential failure mechanisms for a wide range of process equipment and identifies potential design solutions, including inherent, passive, active and procedural approaches to managing risk.

Plant PHA incorporating ISD.  My personal preference is to minimize (an ISD strategy!) the proliferation of process reviews that seem to be required by the many demands being made on plant designers and operators. Plants are asked to do PHA, reliability and maintenance evaluations, ISO certification reviews, and now it's suggested (or required in some jurisdictions) ISD studies. Many of these use similar techniques. Combining them as much as possible increases efficiency and yields a better review. All reviews aim to accomplish the same thing — excellence in manufacturing, which includes best possible safety, environmental performance, product quality, productivity, plant reliability and profitability. These multiple demands often result in design or operational changes that improve performance in several areas simultaneously - e.g., a change boosting reliability and profitability also may enhance safety. But this isn't necessarily always true. So, it makes sense to consider as many of the competing performance demands as possible with a team having a broad understanding of the benefits and costs in all important performance areas.

Friday, July 8, 2011

Failure Modes of Equipment Reliability Processes

Failure Modes of Equipment Reliability Processes

From ReliablePlant.com a great and timely article outlining various Failure Modes including not understanding the Equipment Reliability Process, and related to combustible dust fires and explosions not understanding Mechanical Ignition sources. For the full article click on the link above.

Failure Modes of Equipment Reliability Processes


Most equipment failures are a result of failed reliability processes. This article covers many of the reasons why equipment reliability processes fail. The authors have personally observed all of the reasons for reliability process failure discussed in this paper.

Failure Mode: Implementation Failure
It can be rightfully argued that all equipment reliability process (EqRP) failure modes are somehow tied to poor implementation. Not establishing an initial direction is a critical mistake in the implementation process. Establishing clear goals and expectations and a clear direction can increase the success rate of an EqRP. If upper management fails to communicate the expectations of the program, accountability can never be achieved. The authors have witnessed millions of dollars being dumped into reliability processes that had no established direction and goals. The Penn State manual Operating Equipment Asset Management identifies some critical elements that should not be overlooked when instituting the EqRP.
Top-down vision, drive, participation, support and clear, ambitious objectives are elements that should not be overlooked on implementation. It’s a good idea to examine this entire publication before implementing an EqRP.

Failure Mode: Not Understanding the EqRP (Equipment Reliability Process)
Sometimes a company will have the best of intentions for implementing an EqRP, but no one in the company may have an understanding of how machine reliability is achieved. Sometimes a person in the company may have the necessary knowledge, but they are overruled on important issues that could insure success of the EqRP. Knowing how to maintain equipment for the desired reliability requires knowledge that is acquired through training. If that knowledge isn’t present, no EqRP will bring plant reliability. There are a few good ways to maintain machines and thousands of poor ways, but there is only one best way for any given machine. It is critical to choose one of the good processes and work toward making it the best EqRP for your plant. In short, it isn’t possible to maintain a machine to required reliability if machine reliability isn’t fully understood. If managers and plant personnel don’t truly understand the EqRP, they will lack confidence in the process and will be destined to failure. Many EqRPs fail simply because the managers and practitioners don’t have confidence that it can deliver the required results.

Failure Mode: Lack of Accountability
These days, we hear much about empowerment self-direction. This sometimes leads to the idea that everyone can do their own thing as long as they do those things with good intentions. The authors are strongly in support of empowerment and a self-directed workforce as long as the empowered conform to the directives of the EqRP. The EqRP is not perfect and will need to be continuously revised and improved, but the basic framework, if correct when chosen, should remain intact. Any modification should be subject to a formal management of change. Everyone in the plant needs to be held accountable for their work.
Corporate managers often fail to keep the EqRP on track by letting small factions steer off course with practices that vary from the EqRP. This is the result of the corporate manager either not understanding the EqRP or not having confidence in the EqRP. Too often, corporations turn over the management of an EqRP to managers who have had success in non-maintenance areas, but have little or no reliability experience. Combine the lack of reliability experience with no established goals or direction and you have induced a failure mode right out of the gate. How can people be held accountable when they don’t know what is expected from them?

Failure Mode: Market Conditions Cause a Change in Plans
Too often, companies are willing to invest in various programs when times are good. Sometimes this is even to the point of waste. But when markets go sour, policies are changed in order to conserve dollar assets. In such times, EqRPs may have funds cut to the point that past gains are lost. The EqRP may not survive a bad market. Companies should develop spending strategies that are stable regardless of market conditions. A wasted dollar can never be recovered. Some producer will sell products even in down markets. The lowest-cost, highest-quality producers will survive difficult times. A good EqRP is an important factor in enabling a company to be the low-cost, high-quality producer.

Failure Mode: Commitment Falters over Time
When mangers fail in the implementation of the reliability process, it allows other failure modes to begin eroding the program. If the direction and expectations are not initially established, accountability has no teeth. Without accountability, the commitment from upper management becomes viewed by the people as being more relaxed with each and every sunrise. Before long, even upper management forgets the initial purpose of the program. As the perceived importance of the EqRP lessens, the commitment is shifted to other programs or issues.

Failure Mode: Failure to Measure Results
You can’t measure what you can’t quantify, and what gets measured gets done. The difference between a well-designed metrics system and a poor one can be detrimental to improvement efforts. A metric is essentially a clear, quantitative, objective measure to assess performance in a particular area or progress toward a goal. A good computerized maintenance management systems (CMMS) coordinator can pay big dividends when helping establish metrics and deciding how data needs to be measured within the CMMS. Most systems can generate good, consistent reports if it is set up to do so. However, most of these systems are grossly underutilized, and companies are too dependent on CMMS coordinators to decide what can be measured and what can’t be measured. The metrics should be established by a committee with the EqRP goals in mind.
Six Sigma has been used on the process side in a lot of companies for sometime now. It could be argued that the utilization of black belts and green belts on the maintenance side could be beneficial, and in some companies, they are utilized in that capacity. But in the author’s experience, that generally was not the case. Managers sometimes concentrate on standard deviation of product moisture content and overlook mean time between failures. Assessment results can’t be consistent without good, solid metrics. Too many times, the authors have witnessed variations in assessment scores from one facility to the next because of inadequate metrics, peer pressure and managerial perception. Nothing can compromise the integrity of an assessment process more than the perceived inconsistencies of the assessment team’s scoring procedures.

Failure Mode: Cultural Integration
A company may establish a reliability steering committee, select champions and mentors, even train their entire workforce on cultural change. They may then hire outside people to oversee the EqRP. Is it really a good idea to hire outside people to fill roles such as plant reliability engineers, planners, schedulers, plant managers and maintenance managers, especially, if these people have little or no reliability experience? Sometimes the outside people may come from a completely different industry that doesn’t understand the manufacturing process or from the same industry but from a run-to-fail culture. Fosters of EqRPs should guard against infiltration of cultural integration. If people are brought in from different cultures, they should be in complimentary roles and trained in the company’s culture before taking on major roles in the EqRP. Too often, a little outside influence causes regression back into the run-to-fail maintenance of yesterday

Failure Mode: Lack of a Strategy for Managing Equipment
Even though condition-based monitoring methods may be established, strategies for managing equipment are still needed. Condition monitoring is a requirement for good machine management, but other strategies also should be incorporated into the EqRP. Reliability-Centered Maintenance (RCM) and Total Productive Maintenance (TPM) are two good tools that should be considered to help with the management of equipment reliability. Consider setting up pilot machine centers and conduct RCM or TPM projects. The information learned from these pilot projects can then be transferred to similar machine centers in other facilities.

Failure Mode: Low-Hanging Fruit Syndrome
When these types of programs are initiated, the benefits are quite obvious. Just about everything attempted – from instituting an oil cleanliness program to condition monitoring or failure analysis – reaps big initial benefits and everyone is happy. But, just as soon as the low-hanging fruit is picked, a program with no direction or structure starts to look more like a dog chasing its tail. Unfortunately, this happens too often in industry. Someone suggests an EqRP and it seems like a good idea when you look around and see all of the potential for improvement. But, the EqRP is an ever-changing process and every bit of beneficial juice has to be squeezed out of the reliability process.
Both authors agree that all of the potential failure modes of an EqRP seem to point to several key elements, such as commitment to reliability, accountability and sustainability. We have witnessed some success and eventual regression of EqRPs based on some or all of these failure modes. There are other failure modes, but the ones mentioned here have been witnessed by the authors.

About the authors:
Gary Fore, CMRP, has 22 years in the energy and building products industries, specializing in reliability engineering with a heavy emphasis on condition monitoring. He holds a bachelors of science degree in mechanical engineering and an associates of applied science in electro-mechanical technology. His certifications include: Certified Maintenance and Reliability Professional (Society for Maintenance & Reliability Professionals), Category III vibration analyst (Vibration Institute), CLS (Certified Lubrication Specialist), Level II infrared thermographer, and Machine Lubricant Analyst Level I (International Council for Machinery Lubrication).
Bill Hillman has 30 years experience in the steel industry and six years in the wood products industry. His entire career has been in equipment asset management, of which more than 20 years have been in predictive maintenance. Bill is a Certified Maintenance and Reliability Professional, past chairman on the board of the International Council for Machinery Lubrication, certified by the Society of Tribologists and Lubrication Engineers, and a certified infrared thermographer. He holds or previously held certifications by the Vibration Institute, NDT in ultrasonics, magnetic particle testing, and liquid penetrant testing. He is trained in Reliability-Centered Maintenance and is an experienced RCM facilitator. Bill is also trained in Total Productive Maintenance and 5-S. He is now a managing partner of Asset Management Specialists Company. Bill can be contacted at billcmrp@yahoo.com or 903-407-9488.
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This is an excellent article outlining various Failure Modes, I would suggest another:

Failure Mode: Lack of a Strategy for Managing Change
Even though inherently safer design and safety methods may be established, strategies for managing change are still needed. Many times we see safety systems installed in processes, but personell changes have occured, and the safety sytems and equipment are in fault condition, as the new personell do not understand the opperation of the safety equipment.

Wednesday, June 29, 2011

Top Sites for Fire Safety for Your Home or Business

Adapted from FireScienceDegree.com blog post Top 30 Sites to Teach Kids About Fire Safety

Top Sites for Fire Safety for your Home or Business

National Fire Prevention Association They are the authority on fire, electrical, and building safety. Visit to get codes and standards, safety information, training, and much more. There is also a special section for kids, blogs, and much more on fire education.

Fire Safety Medline Plus often shares trusted health information. In this section, they share fire safety and prevention tips. Scroll down to get information on fireworks, gasoline, smoking, and many other fire related topics.

Fire Extinguisher 101 This site’s goal is to teach all visitors about the different kinds of fire extinguishers and why it is important to have one in the home. There are sections on types, how they work, how to use one, maintenance, and more. You can even visit to learn about the biggest fires in history.

How Smoke Detectors Work HowStuffWorks is a leading science. In this entry, they show how smoke detectors work including the science behind them. You can also choose from tips, fire extinguishers, and more.

Fire Prevention Tips The Home Safety Council shares fire prevention tips. You can choose from sections on everything from bathroom to grilling safety. There is also an Expert Network with entries by fire safety professionals.

Fire Prevention in the Home Michael J. Sheehan edited this piece for The Senior Corner. However, everyone can take advantage of the quick and timely tips on fire safety. Help is given with fire extinguishers, fireplaces, and exit plans.

U.S. Fire Administration Get an education in fire safety on this site from FEMA. Safety topics include smoke alarms, sprinklers, escape planning, extinguishers, and even carbon monoxide.

Fire Education The US Forest Service is the home of Smokey the Bear and some online fire safety education. Visit here to learn the importance of fire safety outdoors. There are also sections on equipment, management, and even fire science.

CAL Fire You don’t have to live in the state to take advantage of this site from the California Department of Forestry and Fire Protection. They have fact sheets, teacher’s tools, kids section, and even a video where a fireman shows a child how to use the water hose. There is even safety by holiday such as Fourth of July or Halloween.

Fire Safety Read this guide on fire safety from the U.S. Department of Labor. They include many standards set by the Occupational Safety & Health Administration.


Remember that each home or business is different and that the above sites provide information about fire safety and are for educational purposes only. Visit your local fire department to learn more on fire safety in your area and always dial 911 when in an actual emergency.

Tuesday, June 28, 2011

HazardEx - Dust to Dust

From the HazardEx website, a good overview of hazardous materials, fines, explosion vents.


HazardEx - Dust to Dust

Dust to Dust

28 February 2011

Author : J GALE

Dr Julian Hought of risk management specialists, HFL Risk Services, explains the hidden dangers of flour and other dry ingredients and how we can guard against potentially fatal explosions.

Dr Julian HoughtEvery year an estimated 2000 dust explosions occur in factories and refineries in Europe. There are approximately 50 reported dust explosions in the UK alone – that’s roughly one every single week. But these explosions are not solely the preserve of chemical or wood processing companies.

A staggering 24 per cent of them occur within the food industry.
In fact dry ingredients such as flour, custard powder, instant coffee, sugar, dried milk, potato powder, soup powder and cocoa powder have been responsible for 120 deaths in the past 30 years.

All dust explosions are preventable. However in order to prevent them you first need to know how they can occur. Essentially for a dust explosion to occur, five conditions must co-exist:

 Combustible dust
 Dispersion
 An oxidiser (such as air)
 Confinement
 Ignition source

These five factors are known as the dust explosion pentagon. Practically all organic-based dusts can explode, given the right conditions. It’s important to be aware that it is not just a question of a build-up of dust on a surface that can have devastating results. Explosions can also occur inside vessels; during storage, handling and transportation; and during any processes such as blending, milling or spray drying.

By way of an example, the overfilling of a hopper with cornstarch during custard making triggered a dust explosion in 1981 at General Foods, Banbury. This created a dust cloud which was ignited by nearby electrical equipment, leaving nine men badly burnt. Thankfully there were no fatalities, but unfortunately the same cannot be said for the explosion which occurred in a grain storage complex at Société d’Exploitation Maritime Blayaise in August 1997. This killed 11 people in nearby offices and the ferocity of the explosion is comprehensible when we consider that significantly-sized debris from the explosion was found up to 100 metres from the silo.

You might argue that these are examples from several years ago and that things have now changed – sadly not. Less than 3 years ago 13 workers died and 40 were hospitalised following a sugar dust explosion at the Imperial Sugar Refinery in Georgia, USA – and many more explosions occur on a smaller scale every week. In the case of Imperial Sugar, it was the secondary dust explosion caused by dust layers in the workplace (often referred to as ‘fugitive dust’) that caused the major loss.

Of course there is legislation in place to prevent the occurrence of such tragedies. Under UK law, where there is the potential for dust explosions, companies must comply with the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR). This requires companies to:

 Find out what dangerous substances are in their workplace and what the fire and explosion risks are
 Put control measures in place to either remove those risks or, where this is not possible, control them
 Put controls in place to reduce the effects of an incident involving dangerous substances
 Prepare plans and procedures to deal with accidents, incidents and emergencies involving dangerous substances
 Identify and classify areas of the workplace where explosive atmospheres may occur and avoid ignition sources (from unprotected equipment, for example) in those areas

Where a workplace containing potentially flammable atmospheres exists, the employer must ensure that the overall explosion safety measures are confirmed (verified) as being safe. This must be done by a person or organisation competent to consider the particular risks in the workplace and the adequacy of the explosion control and other measures put in place.

To safeguard against a potential dust explosion a ‘Basis of Safety’ must be defined. This should ideally be based on preventative measures, but where this is not possible, adequate protection measures must be employed.

Effective prevention measures will prevent the fire triangle (fuel, oxygen, heat) from being formed through either the avoidance of a flammable atmosphere or the elimination of ignition sources.

Protection measures on the other hand include explosion venting, explosion suppression or containment. Where explosion protection measures are employed it is critical that suitable ‘chokes’ are in place to prevent the explosion propagating up or downstream.

In a bakery or food manufacturing environment, where dry powders such as flour and sugar are handled, potential flammable atmospheres can arise in equipment such as silos, bins, hoppers, cyclones, mills and filters. There are also numerous possible ignition sources. The most common of these include mechanical friction, electrostatic discharges, hot surfaces, smouldering nests, and mechanical sparks (e.g. during maintenance).

Since it is difficult to guarantee that ignition sources will not arise during the life of the plant, explosion prevention is not usually employed alone. Safety for the types of equipment listed above is usually based on protective measures.

We have already established that the presence of dust from dry powders combined with an ignition source has the potential to cause an explosion. But just how likely is an explosion to occur? And with what magnitude? In order to demonstrate the safety of a plant it is sometimes necessary to measure the flammable properties of the powders involved. The violence of a dust explosion can be measured by measuring the rate of pressure rise (Kst) and determining the maximum pressure that could be achieved in an unvented explosion (Pmax).
Depending on the Kst value, the dust risks can be classified as follows:

Dust explosion class KST ( Bar m s-1) Characteristics

St 0 0 No explosion
St 1 >0 <200 Weak explosion
St 2 >200 <300 Strong explosion
St 3 >300 Very strong explosion

Other characteristics that may need to be tested are:
Vertical tube apparatus – this explosibility test is used to identify which powders require an explosion risk assessment and which don’t. Under this test, dust can be classified as either combustible or non-combustible (Group A or B respectively).Obviously if dust is classed as non-combustible it cannot explode.

Minimum ignition energy – a test to assess how sensitive a dust is to ignition by determining the minimum ignition energy required to ignite the dust/air mixture.
Layer ignition temperature – This is often used to assess the ignition risk of equipment and is a test to find the minimum ignition temperature of a hot surface which will ignite a layer of dust deposited on it.

Minimum ignition temperature – again used to assess the ignition risk of equipment, this test determines the minimum ignition temperature of a dust cloud on a hot surface.
The DSEAR regulations require areas where there is the potential for dust explosions to be ‘zoned’ and equipment within these zones to be suitably protected.

Zone 20: A place in which an explosive atmosphere in the form of a cloud of combustible dust in air is present continuously, for long periods, or frequently. In general these conditions arise only inside containers, pipes, vessels etc. i.e. usually only inside plant (mills, dryers, mixers, silos, etc.)

Zone 21: A place in which an explosive atmosphere in the form of a cloud of combustible dust in air is likely to occur in normal operation occasionally. This zone can, for example, include places in the immediate vicinity of for example powder filling and emptying points.

Zone 22: A place in which an explosive atmosphere in the form of a cloud of combustible dust in air is not likely to occur in normal operation but, if it does occur, will persist for a short period only. This zone can include places in the vicinity of the plant containing dust, if dust can escape at leaks and form deposits in hazardous quantities.

Once these areas have been identified then a suitable plan and (if beneficial) elevation drawing is required. The phrase ‘ATEX compliant is often used to refer to electrical and mechanical equipment to be used in hazardous (zoned) areas. Zone 20 requires Category 1 equipment (also covers protective devices), Zone 21 Category 2, Zone 22 Category 3. The intent is to have more ignition protected equipment in the more hazardous area. Thus an overall acceptable level of risk is achieved. Old equipment predating the DSEAR Regulations can be continued to be used provided that a suitable and sufficient ignition risk assessment is carried out.

It is critical that housekeeping within the workplace is kept at a very high standard. It is often the secondary dust explosion that causes the most destruction (as we know was the case at the Imperial Sugar Refinery). This can occur when the pressure wave from a small primary explosion rouses dust layers that are then ignited by the following flame front. A dust layer of just 1/32 inch thickness over 5 percent of the floor area is sufficient to cause a very destructive dust explosion. That’s about the thickness of a paper clip. Regular visual checks should be made of the floor, but also of overhead pipes and vents etc.

Despite the fact that there are regulations in place to guard against and prevent them, dust explosions in the food industry will continue to kill people. Why? Because employers have not carried out their risk assessment and ensured appropriate measures are in place.

The law requires that explosion risk assessments must be carried out by someone ‘competent in the field of explosion protection’ through experience or professional training. There are several risk management companies with the expertise to undertake a full assessment of all credible release scenarios, determine what is required and then provide the necessary support to ensure that your workforce and your business are fully protected. If you cannot demonstrate that you have met your statutory duties under DSEAR, don’t delay – act now before it’s too late. You will not only be saving lives, but also saving your business from loss of revenue due to forced plant closures and potential compensation claims.


Contact Details and Archive...

Saturday, June 25, 2011

Events leading up to Federal Mogul Explosion

From http://www2.wsls.com WSLS10 Roanoak, VA, here is "the rest of the story".

Events leading up to Federal Mogul Explosion: "WSLS has obtained more information through the Virginia Freedom of Information Act."
In information obtained through the Virginia Freedom of Information Act, WSLS has learned more about the December explosion at the Federal Mogul plant in Blacksburg.
According to inspectors the explosion happened inside a 14 inch diameter exhaust ventilation duct.
The ducts were inspected in early November. Federal Mogul employee said could not remember if mention of the explosivity of aluminum dust to inspectors or not.
Then inspectors submitted a request to Federal Mogul to do an inspection of the exhaust ducts, also in November, but according to the report, due to work schedules at Federal Mogul the inspection kept getting pushed back until it was accomplished on December 30.
The inspection revealed only one exhaust duct needed cleaning of the 8 that were inspected/ This duct was on bonding line number two and it exhausted aluminum dust from the operation, so it was scheduled for cleaning the next day, December 31.
Technicians doing the cleaning estimated the duct was half full of debris build up, and there was no immediate knowledge at Federal Mogul of the duct have been cleaned in the past.
Duct was cleaned by vacuuming. The section of the duct which ran back into the machine had been successfully cleaned, and the crew was now cleaning the section fo the duct which ran into the bag house, when one crew member asked to turn the suction down on the vacuum.
Then fire and explosion happened, after a pipe was put in. Two people on the lift were burned, then fire traveled through the vacuum line to the truck andset part of the truck on fire.

Friday, June 3, 2011

CSB investigates Hoeganaese - Finds Tons of Combustible Dust

U.S. Chemical Safety Board

The CSB investigates Hoeganaese finds literally "tons" of combustile dust on-site.

CSB - U.S. CHEMICAL SAFETY BOARD -- An independent federal agency investigating chemical accidents to protect workers, the public, and the environment
STATEMENT FOR NEWS CONFERENCE
Friday June 3, 2011
Nashville, TN
CSB Chairman Rafael Moure-Eraso and
Investigator-in-Charge Johnnie Banks
 
Chairperson Rafael Moure-Eraso: 
 
Good morning and welcome to our news conference. I am Rafael Moure-Eraso, Chairperson of the U.S. Chemical Safety Board, or CSB. We are here today to update the media and the public on the status of our ongoing investigation into the explosion and ensuing fire that occurred at the Hoeganaes facility on Friday, May 27 in Gallatin, Tennessee.  Tragically, two workers died and a third was gravely injured.
 
First, a quick word about the CSB. We are an independent federal agency charged with investigating chemical accidents and reporting on their root causes. We are not a regulatory agency and do not issue fines or penalties. We make formal safety recommendations to prevent similar accidents from happening again. Accidents can be prevented if we find out what happened, and share the findings with industry and the public.
The Hoeganaes facility in Gallatin was also the site of a flash fire on January 31st that fatally burned two workers. A similar flash fire occurred on March 29th and caused one injury.  
The CSB is continuing its investigation into all three accidents. To date, CSB and its experts have done extensive testing on the metal dust from the facility. Tests show that powder samples collected from the sites of both the January and March accidents were combustible and could be exploded under test conditions. These test results largely agree with results obtained by Hoeganaes itself prior to the January accident.
This morning we will be playing a short video clip showing the testing of the dust gathered from the facility.
Combustible dust is an insidious workplace hazard when it accumulates on surfaces, especially elevated surfaces. Since the CSB was established in 1998, three of the four deadliest accidents we have investigated were determined to be combustible dust explosions.
A wide range of common combustible materials can explode in finely powdered form, including metals, wood, coal, flour, sugar, plastics, and many chemicals and pharmaceuticals.
This is a sample of the metal dust that was obtained by CSB investigators from elevated surfaces above the site of the most recent accident on Friday.  It is a finely powdered iron dust. It is similar to material we previously tested, which was shown to cause flash fires or explode when suspended in air, confined, and brought into contact with an ignition source.
Today, we will be detailing the progress of our investigation into the accidents that occurred at the Hoeganaes facility. I would now like to introduce CSB Team Lead Johnnie Banks, the investigator-in-charge for this case. He will be discussing the CSB’s activities to date, in more detail.
***
Investigator Banks:   
            First, allow me to briefly describe the operations at the Hoeganaes facility and recap the CSB’s previous activities at the site. The Hoeganaes facility employs approximately 180 workers and manufactures “atomized” iron powder that is sold to the automotive and other industries for the production of metal parts using powder metallurgy.
Briefly, the plant collects scrap iron, which is then melted, sprayed into powder form, and then annealed using hydrogen gas using a large continuous furnace. This powder is then further milled, packaged, and eventually sold as a final product.
 During all three of our trips to the Hoeganaes plant my team observed alarming quantities of metal dust within close proximity to the incident locations. This was of particular concern as metal dust flash fires present a greater burn injury threat than flammable gas or vapor flash fires. Metal dust fires have the potential to radiate more heat and some metals burn at extremely high temperatures in comparison to other combustible materials. In addition to visible dust particles in the air, 2 to 3-inch layers of dust were observed on flat surfaces, rafters, and railings throughout the facility. 
Following the May 27 accident, the CSB arrived at the Hoeganaes facility at approximately 11:00 am on Saturday May 28. We documented and examined the accident site and began interviews with company personnel. To date we have determined the following preliminary sequence of events.
According to witness interviews the incident took place on Friday, May 27, 2011, between 6:30 and 6:40 am. At about 6:10 am, two annealing operators heard a hissing sound in a trench that housed a number of process pipes carrying hydrogen, nitrogen, and cooling water. When the operators heard the hissing sound, they summoned plant maintenance personnel to lift a cover over the area where the gas leak was thought to have occurred. (show the cover following the accident)
After several attempts to lift the cover with a pry bar were unsuccessful, a call went out to get a forklift. The cover was attached to the forklift with a metal chain and raised.  As the cover was pried opened, an explosion occurred.  Some witnesses saw a flash of light; some heard a muffled boom and felt the building shaking from the explosion. The building filled with dust and the lights went out. Witnesses saw burning dust raining down from above.
The initial explosion, we now know, involved hydrogen gas that had been leaking into the trench from a large hole in the vent pipe. However, the witness statements as well as the physical evidence leave no doubt that combustible iron dust was also involved in the aftermath of the explosion.
Examining the scene following the incident, CSB investigators observed splatterings of burned iron dust.
A hydrogen fire, described as three to four feet high, continued until an operator in the area closed a valve on the hydrogen piping. 
Hoeganaes personnel called 9-1-1 and immediate medical attention was provided by Hoeganaes emergency responders. Gallatin Fire Department responders and EMTs arrived shortly afterwards and took over first aid. Three of the victims were life-flighted to the Vanderbilt Hospital Burn Unit. Tragically, as you know, two victims have since passed away and a third remains critically injured with extensive burns.
            The team examined the area of the plant where the most recent incident occurred. On this diagram, the workers fatally injured by this accident are reported to have been standing at the openings where covers of the trench were removed—north and south of the band for Band Furnace #1. The material being transported on this band, or conveyor, is the same as the material involved in the January 31st incident. The covers on the trench that were not lifted showed about a tenth of an inch of accumulated dust. We also observed iron dust on other surfaces in the area of the incident.
            Yesterday CSB investigators, along with TOSHA and company personnel examined the pipe responsible for the release of flammable hydrogen gas.  For the first time, we were able to locate the hole which allowed the release of flammable hydrogen. This picture taken yesterday shows the large, three- by seven-inch hole in the hydrogen pipe. The trench that held the pipe showed signs of dust intrusion, pipes inside in the trench showed signs of corrosion. The CSB now plans further efforts to understand why the piping failure occurred.
            We have been in the process of obtaining items of flame retardant work uniforms worn by the victims at the time of the incident. This clothing, like that of the January 31 victims, was heavily damaged by fire, indicating an intense thermal event. We plan to examine the clothing and other evidence to try to assess the relative contributions of hydrogen and of iron dust to the incident that occurred.
            Immediately prior to the May 27 explosion and fire, the CSB was actively involved in ongoing testing of iron powder from the previous incidents, which were solely dust related.
            I will now play a short video showing the testing that was conducted on the metal dust collected after the January 31 incident.  The video was obtained just one day prior to the May 27 tragedy. 
I will be showing two different tests – First you will see them as filmed at normal speed; then you will see each of the two tests filmed at 1,000 frames a second, so you will see the playback in slow motion.   
The beginning of the video shows the laboratory near Boston where we conducted the tests.   You can see the experimental setup provides for dust to fall onto an existing flame, in front of protective clothing that has been set up just behind the flame.
 (PLAY VIDEO)
             As you can see from the video, the small sample of just over one ounce of fine iron powder produces an intense flash fire when dropped onto a gas flame.
If this size fire can result from just an ounce of iron powder, you can imagine the magnitude of the fire and explosion hazard from the estimated tons of dust accumulated in the Hoeganaes plant.
The CSB’s investigation will continue to move forward with a comprehensive examination of existing codes, standards, and inspection procedures applicable to this facility. We will also be testing additional dust collected from the most recent accident site.
Now I would like to turn the podium back over to Chairperson Moure-Eraso.
***
Chairperson Moure-Eraso:
Thank you, Investigator Banks. I would like to briefly discuss current codes and standards that have been developed by the National Fire Protection Association – or NFPA – to address combustible dust hazards, as they relate to the recent accidents at Hoeganaes.
As we stated in Wednesday’s news briefing, Hoeganaes has suspended production at the Gallatin plant in the wake of last Friday’s tragedy. It is my view as the chairman of the Chemical Safety Board that Hoeganaes and its corporate parent, GKN, need to make significant safety improvements to this plant before resuming the manufacturing of iron powder. Without such improvements, there is too great a risk that additional tragic accidents will occur here in the future.
Hoeganaes should immediately begin comprehensive actions to bring the Gallatin plant into compliance with the national fire code requirements for combustible metal dust. These recommended practices are contained in the standards of the National Fire Protection Association or NFPA – specifically in NFPA 484, the Standard for Combustible Metals.
The CSB’s lab testing – as well as the testing by Hoeganaes itself prior the accidents this year – show that the iron dust at Hoeganaes is covered by the requirements of NFPA 484 for both combustibility and explosibility.
Our preliminary examination of the plant shows many violations of these safety practices for combustible metal powder. Key safety requirements from NFPA 484 are not being adequately implemented at the Gallatin plant, such as:
·         Conveyors and other equipment are not adequately sealed to prevent the release of dust
·         Combustible dust has been allowed to accumulate on horizontal surfaces, and housekeeping remains inadequate, particularly for elevated surfaces
·         The dust collection system at the Hoeganaes plant is severely deficient, is improperly designed, and has leaks. In fact, our investigators observed combustible dust backflushing into the building more than once every minute from this system.
·         The electrical equipment throughout most of the plant is only suitable for general industrial use, not for a flammable environment
·         The plant has many uncontrolled potential ignition sources, including large open flames and hot surfaces from furnaces, exposed light fixtures, exposed bearings which could overheat from dust, internal combustion engines, and welding equipment.
As you can see, there are a number of serious safety problems at this plant that need to be immediately addressed before production resumes. No one should underestimate the scope of the task. Far more than a one-time cleaning is required. Without design and engineering improvements, dust will quickly accumulate back to its former levels.
 In addition the most recent accident exposes potential weaknesses in hydrogen safety, which is equally important. Our investigation will therefore look at the need for safeguards such as hydrogen gas alarms, automatic shut-off systems, and ongoing maintenance and inspection of hydrogen piping. We will also examine the company’s procedures and training for response to a potential flammable gas leak, as well as the adequacy of the national codes for pipe maintenance and leak detection.
There is a vital need for comprehensive improvements to the safety of the Hoeganaes facility, regardless of the ultimate outcome of the CSB investigation of the three recent accidents. I do not believe the safety changes can await the final CSB report, which will include the formal recommendations of the Board.
Other companies around the country have experienced catastrophic dust explosions and fires, such as Imperial Sugar, where 14 workers were killed in 2008 and the massive sugar packaging plant was destroyed. Similar accidents occurred in 2003 in Indiana, North Carolina, and Kentucky. All were investigated by the Chemical Safety Board. Companies like Imperial Sugar rebuilt and completely redesigned their plants, in close consultation with leading dust experts. I believe similar action is warranted here.   Hoeganaes will likely need to engage significant engineering and safety expertise in order to reduce the hazards at this plant.
I emphasize the devastating results that dust explosions can have on a facility, workers and the surrounding community.  We have been deeply affected by the deaths of the two latest victims this week.   As I have said on numerous occasions, I believe that worker safety is a basic human right. That fundamental belief is why I am so honored to head the Chemical Safety Board after being appointed by the president one year ago. No workers should die or be severely burned or injured simply trying to earn a living and provide for their families.
I ask Hoeganaes to recommit itself to that objective, which we share. If Hoeganaes truly embraces that goal, I believe the company will realize that significant process changes are in order. Those changes should occur before any other worker is exposed to potential harm at the Gallatin plant.
The continued presence of combustible dust throughout this facility presents a hazardous work environment. The inadequate maintenance of hydrogen piping is yet another serious concern. The net result is that this facility is not adequately addressing the safety needs of its employees.
            Thank you. We now invite any questions the members of the news media may now have, and request that you please identify yourself and your news organization.
 

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