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Monday, February 21, 2011

Risk Factors: Combustible Dust Standards Update

From Risk Factors blog and WestField Insurance, here is a good overview of the current state of the OSHA Combustible Dust Standard, with related links.

February 16, 2011

Risk Factors: Combustible Dust Standards Update

Background/History
Combustible dust has become a much more visible hazard in the past few years as the Occupational Safety & Health Administration (OSHA) in 2008 communicated that they were proposing a new standard on combustible dust. They also set in play a new directive for their staff to step up their inspections of plants that produce combustible dust, and began forcing companies to control the risk of explosion/fire (and related health concerns) through the execution of the general duty clauseusing best practice industry consensus standards (mostly National Fire Protection Association (NFPA) standards).

The concern was that in the past couple decades, multiple industries experienced dust explosions that resulted in the loss of life/injuries and major property damage. As a result of several high-profile incidents, in 2006 the Chemical Safety Board (CSB) published their Combustible Dust Hazard Study which reported that from 1980 through 2005, combustible dusts caused 281 incidents that killed 119 workers and injured 718. Between 2006 & 2008, an additional 16 deaths and 84 injuries occurred. Finally, in February 2008, the high-profile explosion(s)/fire at the Imperial Sugar refinery (Port Wentworth, GA) resulted in 14 fatalities and 42 injuries. This was the proverbial “last straw” for OSHA to take action.


Current Status
Almost exactly one year ago today (Feb 17, 2010), OSHA closed their public comments on their “approach” to use in developing their federal standard for combustible dust and hosted a Combustible Dust Stakeholder Meeting in Atlanta, GA to gather additional feedback from stakeholders before they started developing the standard in full force. On April 13, 2010, they published a summary report of the meeting (see http://www.osha.gov/dsg/combustibledust/dust-meeting-notes.html).

Currently, OSHA continues work on this standard. In a “web chat” a couple days ago (2/14/11), Secretary of Labor Hilda Solis noted that the budget proposed by the Obama Administration calls for a $37 million dollar increase in funding for OSHA’s Standards Group. The development of the combustible dust standard is one of just a handful of priorities mentioned- so it is likely a measure of time until a standard is forthcoming.


Nature of Combustible Dust Hazards & Controls
Rather than go into detail here, OSHA has put together a comprehensive overview (in layman’s terms) of the hazards and necessary controls to consider at http://www.osha.gov/dts/shib/shib073105.html.
Other helpful related OSHA web links include:
-          http://www.osha.gov/dsg/combustibledust/standards.html (applicable standards)
-          http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=3830  (Combustible Dust National Emphasis Program)


National Fire Protection Association (NFPA)
The National Fire Protection Association (NFPA) is a national organization that promotes and publishes fire and life safety consensus standards. They are not the only organization that publishes standards, but are the most well known and widely accepted organization in the United States (and much of the world for that matter). The primary standard that applies to combustible dust is NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids. This standard was first published in 1975 and has undergone six revisions, with the newest revision scheduled to be adopted/published in late 2012 (originally in 2011 but was purposely delayed). Under the new edition, look for the following changes from the most recent (2006) edition:
-   Expansion of the definition of combustible particulate since most combustible solids that are broken down into a finely divided solid form can contribute to a deflagration.
-   Implementation of a planned inspection process to determine facility dust accumulation rates and determine housekeeping actions/frequency necessary to maintain accumulations below acceptable levels.
-   Recommended cleaning methods: Such as vacuuming rather than blowing down- which can create more hazardous conditions than simply doing nothing.
-   New/expanded sections on hazard assessment, ignition hazards, and contractors to name a few.

NFPA also publishes the following more specific standards relative to combustible dust (which all reference NFPA 654):
-          NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities
-          NFPA 61: Standard for the Prevention of Fires and Explosions in Agricultural and Food Processing Facilities
-          NFPA 484: Standard for Combustible Metals
-          NFPA 655: Standard for Prevention of Sulfur Fires and Explosions
 These standards refer to a host of other NFPA standards (e.g. NFPA 70 National Electric Code) and can get quite complicated, so competent professional guidance is a must.

FM Global
FM Global (formerly Factory Mutual Insurance Co.) self-publishes Data Sheets that identify hazards and recommended controls based on both industry consensus data as well as their own research data. The company is well-known for its conservative approach to controlling property hazards. FM Global publishes Data Sheet 7-76 Prevention And Mitigation Of Combustible Dust Explosion And Fire as well as several related standards in addition to “approving” equipment that can be used for specific (e.g. dust) environments. FM Global used to charge for this information; however, they no longer do so as long as you register (for marketing/informational purposes). The website where these data sheets can be found is http://www.fmglobaldatasheets.com.

Jeff Hendershot is a Property Specialist with Westfield Group. You can connect with him at http://www.linkedin.com/in/jeffhendershot

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