Translate

Wednesday, May 23, 2012

New Dates for Seminars in the GreCon Academy

New Dates for Seminars in the GreCon Academy

From our friends at GreCon:

GreCon Press Release

New Dates for Seminars in the GreCon Academy

Alfeld/Hanover, Germany. GreCon in Alfeld, leading manufacturer of spark detection and extinguishment systems and measuring technology, offers an extensive range of seminars again this year. The focus of the GreCon Academy is again the transfer of know-how to increase system reliability and production efficiency and to reduce costs. Much importance is attached to the conveying of theoretical basics as well as to practical training directed at the system technology. Target groups are production staff, safety officers, system operators, maintenance and engineering staff.

The fire protection systems seminar gives an introduction to the rules and regulations as well as the engineering and peripheral equipment of spark extinguishing systems. The construction, the operation of the software and the components of the CC 700/CC5000/CC7000 series are treated as intensively as the detection and elimination of the causes of defects. Due to the high demand for spark extinguishing systems trainings, an additional trainer has been employed so that participants' needs can be dealt with even more individually and extensively.

The measuring systems training gives insights into the measuring principle, the construction and the process optimisation potentials of each measuring system. The control unit, the operation of the software as well as troubleshooting are dealt with in practical exercises. The work necessary to maintain the operational availability is explained and trained in detail.

The following dates for 2-day trainings in the first half-year 2012 are already fixed:
Fire protection:                       28. - 30.03.2012         09. - 11.05.2012
Measuring systems:                14. - 16.03.2012         06. - 08.06.2012

The training takes place on the GreCon premises in Alfeld or, if desired, also on the customer's premises. Individual training dates, differing from these dates, are also possible.

Since the middle of February, training by the GreCon Academy can be easily and comfortably booked on the GreCon website at www.grecon.de/_link/academy.

 

Friday, May 11, 2012

HazCom Gets a Facelift - ads combustible dust

OSHA HazCom also ads combustible dust

From EHSToday.com, By Eric J. Conn and Casey M. Cosentino of Epstein Becker Green

Note:
10) Combustible dust: Against much industry protest, the final rule added combustible dust to the definition of hazardous chemicals. This means that combustible dust hazards now must be addressed on labels and SDS. The new standard outlines the label elements required for combustible dust, including the signal word “warning” and the hazard statement, “May form combustible dust concentrations in the air.” Notably, OSHA failed to provide a definition for combustible dust in the new standard, creating uncertainty for employers. OSHA claims that it did not give a definition due to the ongoing combustible dust rulemaking and work of the United Nations’ Sub-Committee of Experts on the GHS. Instead, OSHA pointed to existing documents, including OSHA’s Hazard Communication Guidance for Combustible Dusts, OSHA (3371-08 2009) and its Combustible Dust National Emphasis Program Directive (CPL 03-00-008), as guidance on the nature and definition of combustible dust. Although the new HazCom standard expressly states that combustible dust is covered, OSHA’s failure to define combustible dust likely will create substantial confusion.
- This means that your combustible dust is now considered a dangerous chemical, and subject to PSM.


OSHA, on March 26 in the Federal Register, published the final rule to integrate the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into OSHA’s hazard communication (HazCom) standard. The amended HazCom standard requires employers to classify chemicals according to their health and physical hazards, and to adopt new, consistent formats for labels and safety data sheets (SDS)1 for all chemicals manufactured or imported in the United States.

When introducing the final rule, Assistant Secretary of Labor for OSHA Administrator Dr. David Michaels said, “This is a very exciting day for OSHA. We’ve been working on this standard for quite some time. Over the years, it became clear that the old HazCom standard was inadequate because of inconsistency and inaccuracy, which affected workers who had trouble finding the information they needed.”

The old HazCom standard was lauded for years as employees’ “right to know” about the hazards they faced in the workplace. Since it was first issued in 1983, the HazCom standard required employers to provide information about the various hazards, treatment and mitigation measures, and proper handling and storage of chemicals in the workplace. Chemical manufacturers and importers were required to:
➤ Evaluate the hazards of chemicals;
➤ Provide information about the hazards through labels and material safety data sheets (MSDS);
➤ Implement a written hazard communication program;
➤ Maintain a list of all hazardous chemicals in the workplace; and
➤ Train all employees in the program.

As a performance-based standard, the previous HazCom standard provided only guidance for defining hazards and for performing hazard determinations.

The United Nations’ GHS provides a single set of harmonized criteria for classifying chemicals according to various health hazards (e.g., irritation, sensitization and carcinogenicity) and physical hazards (e.g., fire, explosion and corrosion), and specifies model formats and substantive requirements for labels and SDS. GHS is not a mandatory regulation, but it is implemented globally throughout the EU, China, Australia and elsewhere. Labor Secretary Hilda Solis characterized GHS as an “unprecedented international effort to establish a common framework” for classifying and labeling chemicals, and said “this information will reduce confusion in the workplace, especially for low-wage and low-literacy workers.”

The new harmonized HazCom standard from OSHA amends the existing HazCom standard by integrating GHS. The “harmonized” standard ensures that employees will continue to have access to labels and SDS, but now that information should be easier to find and more understandable because of standardized formats and information, including the use of common signal words, pictograms, hazard statements and precautionary statements. According to Michaels, “OSHA’s 1983 hazard communication standard gave workers the right to know … this update will give them the right to understand.” 2

OSHA estimates the new HazCom standard will impact more than 5 million workplaces and 43 million employees. OSHA estimates the total cost for complying with the new standard for all employers and industries to be $201 million per year on an annualized basis. This total cost includes, among other activities, classifying chemical hazards, revising SDS, creating or modifying labels to meet new requirements, training employees in the new warning symbols and revised SDS, familiarizing management with the new GHS system and printing new packaging and labeling materials for hazardous chemicals.

10 Things Employers Need to Know
 
1) Hazard classification: The new standard has specific criteria for classifying health and physical hazards into a (i) hazard class and (ii) hazard category. The hazard class indicates the nature of hazard (e.g. flammable liquids, carcinogen and explosives) and the hazard category is the degree of severity within each hazard class (e.g. flammable liquid includes four hazard categories).3 The hazard classification is based on the weight of evidence using expert judgment. However, with respect to some hazard categories, all studies performed according to good scientific principles that result in a finding that the chemical falls into a hazardous class must be disclosed on SDS, even if the weight of the evidence suggests that it does not. For example, if one study reports that a chemical is carcinogenic, but 10 other studies report the opposite, that one study still must be disclosed on the SDS. Employers may explain away that study, but the finding must at least be included on the SDS. According to OSHA, the specific criteria will help to ensure consistent evaluations of hazardous effects, and in turn provide more accurate labels and SDS.

2) Mixtures: Unlike the old HazCom standard, which defined across-the-board percentage cut-offs for mixtures, the new standard employs a tiered approach to classifying mixtures. Evaluating health hazards of mixtures is based on data for the mixture as a whole when such data is available. If data is not available, however, manufacturers and importers may extrapolate from data on ingredients and similar mixtures to classify the mixture. Additionally, “[w]hen chemical manufacturers and importers are classifying mixtures, they [generally may] rely on the information provided on current safety data sheets of the individual ingredients.”

3) New label requirements: Where the old HazCom standard gave manufacturers and importers discretion to convey any language on labels they deemed appropriate, the new standard provides specific information required on all labels. The new label requirements directly are linked to the hazard classification. For each hazard class and category, chemical manufacturers and importers are required to provide harmonized signal words, pictograms with red borders,5 and hazard statements. Additionally, precautionary statements are required on the labels to describe recommended measures to protect against hazardous exposures. Product identifiers and supplier information are also required.

5) Safety data sheets: The new HazCom Standard uses a standardized, 16-section format for all SDS to provide a consistent sequence for organizing the information.

6) Non-mandatory threshold limit values in SDS: After several exchanges with industry organizations, internal deliberations and floating different draft proposals, OSHA ultimately decided to require employers to include OSHA’s mandatory permissible exposure limits (PELs) and the non-mandatory threshold limit values (TLVs) developed by the American Conference of Governmental Industrial Hygienists on the SDS. OSHA believes that TLVs on SDS furthers employees’ “right to understand.” In addition to the TLVs and OSHA’s PELs, any other exposure limit used or recommended by the chemical manufacturer, importer or employer preparing the SDSs now are required on the SDS.

7) Information and Training: To facilitate recognition and understanding, employers are required to train employees on the new label elements (e.g. signal words, pictograms and hazard statements) and SDS format by Dec. 1, 2013.

8) Effective dates: In addition to training employees by Dec. 1, 2013, compliance with modified provisions of the final rule is required by June 1, 2015. Distributors, however, may ship products labeled under the old HazCom standard until Dec. 1, 2015. Finally, by June 1, 2016, employers must update workplace labeling and written hazard communication programs as necessary, and provide additional worker training for newly identified physical and health hazards. During the transition period, all chemical manufacturers, importers, distributors and employers may comply with the old HazCom standard, the amended HazCom standard or both. The chart above summarizes the rolling effective dates of the new standard. 8

8) Hazards not otherwise classified: Hazards covered under the old HazCom standard but not addressed by GHS are covered under a separate category titled “Hazards Not Otherwise Classified” (HNOC). In the notice of proposed rulemaking, OSHA originally titled this category “Unclassified Hazards.” Due to industry comments, however, OSHA renamed the category to HNOC. “Chemical manufacturers and importers are expected to assess [HNOC] hazards when they are conducting their hazard evaluation of physical and health hazards,” but are not required to conduct new or separate evaluations.9 Hazards classified as HNOC need only be disclosed on the SDS under Section 2: Hazard(s) Identification, and do not need to be disclosed on labels. Notably, pyrophoric gases, simple asphyxiants and combustible dust are not classified under the HNOC category in the new standard, as OSHA originally proposed in the NPRM. Rather, these chemicals are addressed individually in the new standard.

9) The new HazCom standard does not preempt state tort law: Following the Obama administration’s broad policy against federal preemption, the new HazCom standard does not preempt state tort laws. Accordingly, the new standard will not limit personal injury lawsuits at the state level regarding chemical exposures, inadequate warnings on labels and/or failure to warn. Organized labor hailed OSHA’s decision not to preempt state tort law as a victory.

10) Combustible dust: Against much industry protest, the final rule added combustible dust to the definition of hazardous chemicals. This means that combustible dust hazards now must be addressed on labels and SDS. The new standard outlines the label elements required for combustible dust, including the signal word “warning” and the hazard statement, “May form combustible dust concentrations in the air.” Notably, OSHA failed to provide a definition for combustible dust in the new standard, creating uncertainty for employers. OSHA claims that it did not give a definition due to the ongoing combustible dust rulemaking and work of the United Nations’ Sub-Committee of Experts on the GHS. Instead, OSHA pointed to existing documents, including OSHA’s Hazard Communication Guidance for Combustible Dusts, OSHA (3371-08 2009) and its Combustible Dust National Emphasis Program Directive (CPL 03-00-008), as guidance on the nature and definition of combustible dust. Although the new HazCom standard expressly states that combustible dust is covered, OSHA’s failure to define combustible dust likely will create substantial confusion.

To view this article’s citations, read the online version on EHSToday.com.
Eric J. Conn is head of Epstein Becker Green’s OSHA Practice Group, which is part of the firm’s National Labor and Employment Practice in the Washington, D.C., office. To learn more, visit http://www.ebglaw.com.

Best Practices Dust Control - WorkSafeBC.com

From  WorkSafeBC.com  Here is an article about the BC Mountain Pine Beetle tree mill explosions and a resource for mills creating combustible wood dust. The link below is a list of resources and the last one is referenced in the story.

Industry resources

From WorkSafeBC

From industry

 

Thursday, May 10, 2012

Russian sawmill fire offers revealing insights | Vancouver Sun

Russian sawmill fire offers revealing insights | Vancouver Sun

"...it doesn’t matter whether a mill is is Asia or North America, sawdust is just as flammable and requires systems to ensure it is safely managed"

British Columbia isn’t the only place where sawmills have been catching fire. There’s an interesting report out of Russia passed on by Ian Ogilvie, of  Pacific Russia News. It’s about a fire at a mill April 20 in the Russian Far East.

The mill didn’t explode, as has been the case at two mill fires recently in British Columbia. In this case it was a massive pile of sawdust that appears to have caught fire through spontaneous combustion. It destroyed a good part of the adjacent village, leaving 125 households homeless. Three people lost their lives.

 The report, from the minutes of an April 26 government presidium meeting chaired by President Vladimir Putin, is revealing for a number of reasons.

First, I think it shows how far the Russian industry is from being any kind of real threat to British Columbia’s growing lumber export business with China. The sawmill, in the Amur region immediately north of China, had a storehouse of 1.9 million cubic metres of sawdust. It  is strategically located close to the China market but clearly there is no pulp industry or pellet industry or any other industry for that matter, to utilize residual  products from the sawmill.

Wood waste accounts for 40 per cent of the average log. In B.C., sawmills can keep their costs down by selling that waste to pulp mills or pellet plants or using it themselves to generate heat and power.

When lumber prices are low, that additional revenue stream can mean the difference between profit and loss. Russian mills, it appears, don’t have that revenue stream. How competitive can that be?

Secondly, the Russian fire shows that it doesn’t matter whether a mill is is Asia or North America, sawdust is just as flammable and requires systems to ensure it is safely managed. There was a clear breakdown in any attempt to manage the fire threat at the Amur sawmill. After the fire was extinguished, workers drilled down through four metres of sawdust to locate a hotspot that had been flaring up regularly because of the massive accumlation of sawdust above it.

Here’s was Putin had to say about the company that ran the sawmill, referred to earlier in the minutes as an operating entity.

“An operating entity or a derelict one – that’s guesswork as to how they were working when their facility repeatedly caught fire and threatened the village. In the end, it resulted in deaths. How could that happen? They had known about the danger, which means they did not prevent it in time, that’s the long and the short of it. A legal assessment is required.”

It shows how far a leader with dictatorial powers is willing to go in assigning blame, long before all the facts are in, when he senses that public opinion is on his side.

Here’s the link to the Russian sawmill fire: http://premier.gov.ru/eng/events/news/18791/

Wednesday, May 9, 2012

Five explosions preceded deadly incidents in Burns Lake, Prince George

One B.C. pellet mill blast went unreported

From The Vancouver Sun:

Five explosions preceded deadly incidents in Burns Lake, Prince George



A wood dust explosion 16 months ago that blew apart a small control room and started a fire at a Williams Lake sawmill went unreported to WorkSafeBC, the chief workplace safety agency in the province.

The incident was among five explosions news reports linked to wood dust in north and central B.C. between 2009 and 2011 that took place before two fatal sawmill explosions this year at Babine Forest Products in Burns Lake and Lakeland Mills in Prince George.
WorkSafeBC also said it has no record of an explosion in 2011 at a Pinnacle Pellet plant in Armstrong.

WorkSafe inspectors and industry representatives have not directly linked the two fatal sawmill explosions, which killed four workers and injured dozens more, to wood dust. But increasing attention has been directed to the fine powder produced from dry, pine beetle-killed timber milled at these facilities in north and central B.C.

The safety agency has ordered sawmills to investigate dust levels and other hazards, saying the review is urgently needed given the recent deaths.

It is possible the small explosion at Tolko’s Soda Creek sawmill in Williams Lake in January 2011 and the Pinnacle Pellet explosion in April 2011 were not reported to WorkSafe because they did not result in injury, but it is not clear if that is the case.

The agency refused to provide an official for an interview Tuesday, instead pointing to requirements for reporting incidents as outlined in the Workers’ Compensation Act.
The act says that any incident that injures or kills a worker must be reported to WorkSafeBC. But incidents that have the potential to cause severe injury must also be investigated by the company and reported to WorkSafeBC.

Officials from the safety agency noted via email the B.C. Fire Commissioner’s Office has primary jurisdiction over fire safety in the province, although the two organizations are meant to communicate with each other.
News reports of the Soda Creek sawmill incident described a dust explosion that caused a fire in the walls, which was “tough” to put out.

The Williams Lake fire department had called the nearby 150 Mile House fire department for help. Fire department chief Randy Isfeld said Tuesday the local fire department does not inspect sawmills in the area, although they do inspect public buildings, hotels, motels, and retail stores.
Instead, the sawmills’ insurers inspect the mills for fire risks, said Isfeld.

Dean Colville, who worked at the Soda Creek mill, said the 2011 explosion happened just as he arrived for the afternoon shift. Workers ended up waiting in the parking lot as the fire was put out, he said.

Colville said the explosion blew out the wood walls of the small control centre (a wood-framed room about 25 feet by 10 feet), which allowed the mill’s machinery to be shut down during maintenance.

Following the explosion, the company made efforts to clean up dust in the mill, said Colville, who is vice-president of United Steelworkers 1-425.

Colville said the Soda Creek mill was sawing about 90 per cent pine killed by the mountain pine beetle, which created more dust.
“I think everyone was aware of the fire hazard — of the dust and how dry it was. To get [an] explosion out of it, I don’t think they thought it was possible,” he said.
“Hindsight is 20-20. You see what’s going on now, and you say, ‘Holy crap,’ ” said Colville, referring to the two recent fatal explosions.

Tolko, which operates the Soda Creek mill, could not be reached for comment on Tuesday.
Additionally, WorkSafeBC relied on Pacific Bioenergy to investigate itself in a pair of explosions at its pellet plant in Prince George which occurred in December 2010 and March 2008. Pellet plants press wood shavings and sawdust into pellets used in industrial and home heating.

WorkSafeBC regional manager Bruce Clarke would only speak about Pacific BioEnergy’s investigations, saying they were reviewed and found adequate.
He said the explosions at the pellet plant in Prince George can’t be compared to the recent deadly sawmill blasts.

That’s because the explosions at the pellet plant happened in the piping system that handles the dust, which is designed with explosion safety measures, said Clarke, while the explosions in the two sawmills took place in open areas where employees were working.

ghoekstra@vancouversun.com

Pellet plant facing OSHA fine on fire

Pellet plant facing OSHA fine on fire 
From- SentinelSource.com


"According to the inspection report stemming from October’s fire, the flames in that blaze led to a series of explosions in the plant.

“The fire, which started in the pellet mill, was transported through several conveying systems to a pellet cooler and then to a dust collector, and caused several other flash fires,” an OSHA news release said. “Shortly thereafter, explosions occurred in the dust collector and an exhaust muffler.

“The explosions sent fireballs outside of the building and likely ignited materials in two silos.”
Without the required protective devices in the pellet transport system, dust collection duct and conveyor systems, sparks and embers are able spread throughout the system, officials said."

Lessons Learned:  Pellet mills create fuel. Fires and Explosions migrate through processes.   Damage limiting construction, inherently safer design, and proper engineering and administrative controls are required for mitigation. Combustible dust safety education is required for all stakeholders involved in these plants.
- Jeff Nichols

Pellet plant facing OSHA fine on fire

Ruling issued as blaze hits in Jaffrey again

Posted: Saturday, April 28, 2012 8:30 am | Updated: 11:53 am, Tue May 1, 2012.
JAFFREY — A federal agency found serious workplace safety violations at the time of a Jaffrey wood pellet manufacturing plant fire last year, a report released Friday said. Now Jaffrey-based New England Wood Pellet is facing up to $147,000 in fines from citations stemming from the Oct. 20, 2011, fire, the Occupational Safety and Health Administration announced Friday.

“While it is fortunate that no one was killed in this conflagration, there is no excuse for the employer’s failure to effectively minimize and address clearly recognized hazards that could kill or disable workers in a catastrophic incident,” said Rosemarie Ohar, OSHA’s area director for New Hampshire, in a statement.

The agency’s report was released just hours after a dozen area fire companies responded to a three-alarm blaze at the Old Sharon Road manufacturing plant Friday at about 2 a.m.
It’s the third fire at the plant since August 2008.

Company officials said Friday’s fire was caused by sparks after one of the pellet mills had a mechanical malfunction.

Jaffrey fire officials said Friday the cause of the fire was not determined, but the blaze was contained to a portion of the manufacturing floor called the cooler, where newly pressed pellets are cooled before being bagged.

Federal workplace safety officials have opened a new investigation as a result of Friday’s fire, said Ted Fitzgerald, a spokesman for OSHA.
According to the inspection report stemming from October’s fire, the flames in that blaze led to a series of explosions in the plant.

“The fire, which started in the pellet mill, was transported through several conveying systems to a pellet cooler and then to a dust collector, and caused several other flash fires,” an OSHA news release said. “Shortly thereafter, explosions occurred in the dust collector and an exhaust muffler.

“The explosions sent fireballs outside of the building and likely ignited materials in two silos.”
Without the required protective devices in the pellet transport system, dust collection duct and conveyor systems, sparks and embers are able spread throughout the system, officials said.
The system’s design also doesn’t meet standards for explosion prevention, officials said. That problem was made worse during the last fire by a buildup of wood dust throughout surfaces in the plant and the use of unsafe electrical equipment to vacuum combustible dust, officials said.
The company was issued fines totaling $140,000 for two “repeat” citations — issued when an employer has previously been cited for the same or similar violation — for failing to provide a workplace free of fire and explosion hazards and for using unapproved vacuum equipment, officials said.
A “serious” citation was also issued for the buildup of dust on surfaces, which carries a proposed $7,000 fine, officials said.

The company has 15 days to comply, meet with OSHA officials or contest the findings before the agency’s review commission.

Company officials are scheduled to meet with OSHA officials next week, Fitzgerald said.
In 2008, the company reached a settlement with the agency on more than $135,000 in fines stemming from 12 safety violations issued before the 2008 fire.

Company officials did not return a call for comment Friday afternoon about the agency’s findings.

Casey Farrar can be reached at 352-1234, extension 1435, or cfarrar@keenesentinel.com.

More Coverage



And a related story from The UnionLeader.com:

Pellet maker faults OSHA

New England Wood Pellet LLC of Jaffrey will meet Wednesday with U.S. Occupational Safety and Health Administration to discuss proposed fines totaling $147,000 related to an Oct. 20, 2011, fire and explosion at the plant.

The fire started in the pellet mill, was transported through several conveying systems to a pellet cooler and then to a dust collector, and caused several other flash fires, OSHA said in a news release Friday.

OSHA issued two repeat citations with $140,000 in fines for failing to provide a workplace free of recognized fire and explosion hazards, and for using unapproved electrical equipment to vacuum combustible dust. OSHA said it cited New England Wood Pellet for similar violations in July 2008.

On Monday, New England Wood Pellet faulted OSHA's comments.

“The company finds the recent public comments of OSHA's Area Director for New Hampshire about New England Wood Pellet to be one-sided and unfairly dismissive of the company's past and ongoing efforts to improve worker safety at its Jaffrey facility,” the company said in a statement. “Since 2008, New England Wood Pellet has worked cooperatively with her office, retained engineers and consultants, and spent over $2 million on various improvements to enhance worker safety at its Jaffrey facility.”

In a press release last week, OSHA N.H. Area Director Rosemarie Ohar said, “While it is fortunate that no one was killed in this conflagration, there is no excuse for the employer's failure to effectively minimize and address clearly recognized hazards that could kill or disable workers in a catastrophic incident.”

Separately, OSHA's Concord office opened a new inspection on Friday as a result of the latest fire last week, U.S. Department of Labor regional spokesman Ted Fitzgerald said.

Ohar said Monday, “OSHA looks forward to working with New England Wood Pellet in the future to improve safety and health at the facility.”

In its 28-page citation, OSHA also cited the wood pellet plant for buildup of combustible dust on equipment and surfaces and proposed a $7,000 fine.

“We're looking forward to presenting our side, and again, we've had a cooperative relationship,” New England Wood Pellet Chief Operating Officer Mark R. Wilson said.

He said a fire Friday morning at 2 a.m. was followed by the OSHA citation regarding the October 2011 fire. He said there were no injuries and minimal property damage in that fire.

But he said the firm spent $2.5 million over nine months for improvements in electrical systems, safety platforms and guards and hazardous dust fire and explosion protection.

“We have a cooperative relationship with the New Hampshire OSHA office,” Wilson said. Looking ahead to the Wednesday meeting, he said, “This is the first time we'll get to share with them what we think since this citation was issued. We'll discuss the content of the citation and the amount of the penalties, and hopefully we can come to agreement there and continue to work together to make improvements in our plants, which we plan on doing anyway.”

On the Net: www.pelletheat.com. Write to dpaiste@unionleader.com.



Tuesday, May 8, 2012

False Security: Relying on housekeeping as a first line of defense against explosion and fire is a false economy

Relying on housekeeping as a first line of defense against explosion and fire is a false economy


False security - relying on housekeeping as your first line of defense in dealing with combustible dust.  Great article by our friend Eric Anderson, as posted in the Combustible Dust Explosions and Fires blog.  Housekeeping is a secondary strategy to managing combustible dust, not a primary method of preventing dust fires and explosions.

Why going cheap on the dust collection and control system is short sighted...
We all know that our cars and trucks have air and oil filters to catch dust to avoid abrasive wear of the engine. We have seen news articles about how airborne dust is not good for jet engines - like when that Icelandic volcano erupted in 2010, or the Argentinean eruption in 2011.
So, why do so many industrial operations let their dust collection systems get plugged up and fail to perform? Assuming that they bother to install adequate dust controls in the first place?
One common complaint from the people who run foundries and factories is cost - buying a dust control system costs some serious coin, and too many operations try to go bottom dollar when they buy equipment. 
Another issue is maintaining and cleaning the equipment - this requires technicians with some training, whereas handing a laborer a shovel or a broom is a good way to keep him busy when things are a bit slow for making product.

This is especially problematic when the dust in question is combustible.
I've lost track of the mills and factories I've consulted for who have had "snowdrifts" of dust piled up because they didn't have the right dust collection and control system, and instead relying on housekeeping to deal with the mess.
 Fortunately, most of these operations were making steel or cement, and slag and rock dust don't burn or explode. They are abrasive however, and the dusts stick to exposed lubricated parts, like the cables of the hoist of an overhead crane, or the packing of a pillow-block bearing.

 It's difficult to quantify how much service life get eaten up by the grit grinding away on the machinery, but a knowledgeable maintenance superintendent can do predictive maintenance for his/her own shop, and develop the trend data.
Things get more complicated when the dust has hazardous qualities, such as toxicity or flammability.
OSHA has a distinct preference for engineering controls of such dusts - it makes sense to control and confine the potential hazard, making the work environment safer.
When we look at some key fatal accidents, we find that the dust control systems were no longer working as designed or installed.
The Hayes Lemmerz explosion in Huntington, IN in 2003 was largely due to the inadequacy of their dust collection system  which was leaking aluminum powder from its ductwork.
 The rash of explosions and fires at Hoeganaes in Gallatin, TN in 2011 were exacerbated by the prevalence of combustible iron powder due to the lack of adequate function of the ageing dust control equipment.
   The Imperial Sugar explosion in Port Wentworth, GA in 2008 was also largely due to inadequate dust controls. 
When we look at the accident investigation photographs from these incidents, the prevalence of fugitive dust (dust which has escaped containment) is obvious - and frightening to a knowledgeable observer.
Housekeeping presents several problems as a means to control combustible dust. A major problem is that dust will deposit on any horizontal surface - like roof beams, conduits, and the top surfaces of machinery and internal enclosures (electrical & machinery rooms for example).
Then there is the issue of just how one goes about cleaning up the accumulated fugitive dusts. The CSB report on the explosion and fire at CTA Acoustics in Corbin, KY in February of 2003 shows that sweeping and blowing combustible dust can easily generate a combustible cloud, which can react with any ignition source.
Conventional industrial vacuum cleaners ("Shop Vacs") are not much better, since they lack specific grounding and venting to prevent internal explosion of the dust which they are sweeping up.
The recent sawmill explosions in British Columbia in January and February would appear to also be due to fugitive dust (final reports from the BC government are not yet available). The news reports indicate that the mills were operating with reduced staff, which would indicate that there were fewer employees available for maintenance and housekeeping.

Factor in a drier source of timber - beetle killed trees - and the possibilities for dust problems become all too real.

The destructive fire at the Swany White flour mill in Minnesota in December of 2011 appears to be another example of fugitive dust catching fire - possibly due to a hot bearing on the ~100 year old milling and sifting equipment.
So, relying on housekeeping as a first line of defense against explosion and fire is a false economy - not only is there a greater risk to the workers workers, but the maintenance costs for machinery are higher, due to increased abrasion from dust getting into the moving parts of machinery.

Eric Anderson Contributed by Eric Anderson
Vice President
Renewable Energy Technologies, Inc.
eanderson@eandersonventilation.com

Tuesday, May 1, 2012

How to Stay Safe from OSHA!

From Pallet Enterprise online -

How to Stay Safe from OSHA! Recent Industry Fines Offer Lessons on OSHA Enforcement Trends
Heightened enforcement environment puts the industry on notice that OSHA fines and citations are a serious matter. Experts discuss recent citations and lessons for the industry to avoid similar hazards.

By Chaille Brindley
Date Posted: 5/1/2012

                The kinder, gentler Occupational Safety & Health Administration (OSHA) that existed under President George W. Bush has been replaced since 2009 with a much more aggressive enforcement approach under President Barack Obama. And if you haven’t taken safety seriously, you should. It is not only the right thing to do. It is expensive if you ignore it in terms of lost production and potential government fines.
                The problem is that it seems OSHA is becoming increasingly aggressive when it comes to enforcement and leveling fines cautioned Adele Abrams, noted safety lawyer who also runs the National Wooden Pallet & Container Association (NWPCA) safety program.
                Abrams told attendees at the NWPCA’s Annual Leadership Conference that even efforts to help make your workplace safer could backfire if not done properly. For example, some safety incentive programs tied to incident reporting, such as days without an accident, could produce fines if OSHA deems it discourages employees from reporting problems. Abrams suggested using safety incentives that reward employees for taking proactive safety measures, conducting job safety analysis, etc.
                And it looks like the current enforcement focus is only going to get more severe with new rules changes in the works. Abrams cautioned that OSHA is working on developing an Injury and Illness Prevention Program (I2P2) similar to what the state of California has in place. This is the centerpiece of Obama’s OSHA enforcement initiatives and is expected to be finalized later this year or sometime next year.
                Abrams said that “I2P2 in essence requires you to go through your entire workplace, analyze and evaluate it for every possible risk and hazard, and then develop procedures on how you are eliminating or mitigating those hazards. It could be personal protective equipment. It could be improved ventilation systems or getting rid of one type of equipment or chemical substance for another. I2P2 is like a supercharged general duty clause that will cover things that OSHA hasn’t even written rules for yet. It will cover things like ergonomics.”
                In states that have I2P2 standards in place, Abrams said that OSHA has cited companies for both the I2P2 rule as well as whatever general standard was violated, which allows OSHA to double up on fines for one infraction. Abrams explained, “This is pretty much going to double up the cost of any inspection that you have down the road. And it encompasses both safety hazards and health hazards.”
                Overall, companies should be aware that a couple of years ago OSHA changed the statute of limitations for repeat violations from three to five years. Also, the reductions given to small employers were reduced. Penalties were not increased. But the reductions given to employers were decreased under these new penalty policies. So, if you have faced fines lately, you may have already noticed the higher price tag at the end of the day.

IFCO Fines Offer Industry Lessons
                One of the biggest names in the pallet industry recently faced fairly significant fines after an inspection. OSHA cited the largest recycler in the country, IFCO Systems North America Inc., with 10 serious, three repeat and six other-than-serious violations for exposing workers to safety and health violations at its facility on Tacco Drive in San Antonio, Texas. This facility was inspected as part of OSHA’s Site-Specific Targeting program, which directs enforcement activity to work sites with higher-than-average injury and illness rates. The proposed penalties total nearly $164,000.
                OSHA issued a press release because the fine amount totaled over a specific threshold. This citation report provides a number of lessons for the pallet industry. Specifically, the areas of concern are machine guarding for any equipment with rotating shafts, hearing protection issues, and injury/illness reporting.
                Leroi Cochran of IFCO Systems said, “IFCO takes the findings made by OSHA very seriously and we are immediately addressing all of the OSHA recommendations and we are conducting a follow-up safety review at all of our facilities.”
                According to Cochran, IFCO provides regionally dedicated safety and HR managers who audit each IFCO facility quarterly and work with local management to ensure compliance. IFCO also offers incentives for employees to meet both individual and team based safety goals as well as regular safety training for all employees.
                “IFCO has been very proactive. They have corrected the alleged hazards in 90% of the cases. I have met with them, and we have not settled the case as of yet. But I am optimistic that we can,” said Jeff Funke, the agency’s area director in San Antonio.
                When a company is cited by OSHA it has three options to react and is required to do one of these in 15 working days. A cited company can correct the hazards and pay the penalty, meet with the area director for a consultation to negotiate a settlement, or contest the violation with a written contest notice. An administrative law judge will decide the outcome of contested citations. Funke suggested, “An informal consultation with the area director is well worth the time.” And in this case, that is what IFCO chose to do although it could still contest violations if the negotiation doesn’t produce a suitable outcome.
                In this inspection, IFCO was cited for improper guarding of a rotating shaft for a wood grinder. The company was cited for a similar problem on a different kind of equipment at another plant within the five year statute of limitations. Funke explained, “If we cite a general standard, it better be the same piece of equipment or we are on shaky legal ground. In this case, it was a rotating shaft, and a rotating shaft is a rotating shaft regardless of the piece of equipment.”
                Funke suggested that many of the large grinders on the market today are not properly guarded coming from the factory. The argument that’s how it came from the factory doesn’t matter when OSHA comes to visit. Funke said, “There is machinery built in this country every day that is not OSHA compliant. It is the burden of the employer to inspect machinery and add guards as needed.”
                If you have open rotating shafts on any equipment, you are at risk of an OSHA violation. This hazard needs to be mitigated by proper guarding. Funke said, “Rotating shaft can be guarded with anything. With a rotating shaft, you can cut the shaft off so that it is flush. You can put a stationary cap over the top so that you can’t get snagged on it or wrapped up in it. Or you can make your own guard that goes over the top.”
                Another issue of note at the IFCO facility was improper incident reporting in its OSHA 300 logs. Whenever you have a workplace incident resulting in an injury or illness, you are required to record the issue by describing what part of the body was affected and what caused the incident. Be as specific as possible. In this case, there wasn’t enough detail in the log, which cost IFCO $4,000.
                Funke said that you need to be able to identify the body part from the description. Thus, writing a “finger laceration” is insufficient, but “right index finger lacerated with a utility knife” is fine.
                Finally, OSHA cited IFCO for not effectively recording hearing loss, retraining and refitting employees with hearing protection. Because hearing loss is a permanent disability, OSHA takes it very seriously. Funke suggested that almost any company dealing with wood likely meets the minimum threshold requiring a hearing conversation program. This involves noise monitoring, annual biometric testing to detect employee hearing loss, providing hearing protection, training and
monitoring employee compliance, etc. Excessive noise (over 100 decibels) requires engineering controls to mitigate noise levels.
                               
OSHA Focuses on Combustible Dust Concern for Wood Products Firms
                Earlier this year, OSHA cited a sawmill in Georgia for multiple serious health and safety violations, including some related to combustible dust. The alleged violations related to combustible dust include failing to establish and implement a hazard communication program for workers exposed to combustible dust and preventing the accumulation of combustible dust.
                Since 2008, OSHA has made a pointed effort to crack down on companies that could pose a combustible dust risk through its Combustible Dust National Emphasis Program. As a result, the possibility of related citations and fines is now especially high for companies in the forest products industry. Although OSHA, at present, does not have a specific standard on combustible dust hazards, there are several existing standards that apply to combustible dust handling facilities. The emphasis program focuses on these standards, as well as the General Duty Clause.
                Because wood processing facilities are especially susceptible to combustible dust, companies need to take proactive steps to mitigate associated risks. The most recommended way to do so is to establish and maintain good housekeeping practices. This includes proper ventilation, extraction and removal systems, dust collection systems, and regular manual removal where automated collection systems cannot reach. Areas such as ducts and piping near ceilings, ledges, tops of equipment and electrical panels and any hidden areas where dust may accumulate should be regularly inspected.
                Another important step is training workers to recognize and prevent associated hazards. Employers with hazardous chemicals, which include combustible dusts, in their workplaces are required to comply with OSHA’s Hazard Communication standard. This includes using material safety data sheets, and providing employee training. Training should occur before an employee starts work, periodically to refresh their knowledge, when reassigned, and when hazards or processes change.

Tips and Tricks to Play It Safe
                When it comes to having safety programs in place, it all starts with analysis and then developing a written program. But it isn’t enough to just have a program in writing. You need to train employees regularly on all procedures. You need to offer both English and Spanish training if you have any Hispanic employees. You need to monitor compliance and provide warnings and corrections for employees who do not follow the procedures. And you have to document and keep records on everything. This includes who attended what safety demonstration and when it was held.
                Some of the top areas of concern for pallet and lumber companies include: amputation, combustible dust, hearing loss and noise levels, wearing proper safety gear, lock out/tag out of equipment, falling hazards, forklift safety and more. Abrams explained that you must also account for state regulations that may be stricter than federal OSHA standards.
                If OSHA does come knocking on your door, you need to be smart about what you say. Abrams stated, “Nothing is ever off the record when it comes to OSHA.” She said that it is important to review rights and requirements with employees before OSHA ever visits.
                The right to privacy belongs to the employee not the OSHA inspector. Neither you nor your employees have to conduct safety demonstrations or talk to OSHA. At the same time, employers cannot prohibit employees from talking to OSHA or allowing an employee to speak in private with an OSHA inspector.
                Companies should be aware that independent safety audits conducted by employers can be obtained by OSHA in enforcement proceedings if they want to show willful violation of a standard. This could come back and haunt you if you haven’t remedied the problem. Abrams commented that the only type of audit that can be held strictly confidential is one conducted by your legal counsel. If this information is shared with insurance providers or other parties, it opens you up to exposure.
                Any company that operates multiple facilities must be aware that a violation caught at a separate facility can be considered a repeat violation if found at a different facility owned by the same corporate parent. Thus, companies must work to share problems and violation issues across multiple locations. The lists of rules and ways that OSHA can get you seem to go on and on.
                The best defense against serious OSHA fines is to stay up-to-date on the latest regulations and work to fix any problems.

OSHA Safety Program
The NWPCA Plant Safety & Health Program, which includes an industry specific manual, is an important resource for pallet and lumber companies to utilize. The NWPCA is going to update its manual this year, and Adele Abrams is available for private consultation. Find out more by contacting Abrams at safetylawyer@aol.com or calling 301/595-3520.