Combustible Dust Management Training: Rely on Best Practices, Not Shifting Regulatory Winds :: POWER Magazine :
None of you reading this magazine needs an article—or new governmental regulations—to tell you that flash fires and explosions involving coal dust can cause catastrophic incidents, fatalities, facility damage, and financial consequences. One of the most tragic incidents occurred at a Michigan power plant in 1999. Six people were killed and 38 were injured when natural gas from a boiler exploded, setting off secondary explosions caused by disturbed coal dust. In the past decade, managing combustible dust hazards to prevent such tragedies has received increased attention from companies, industry groups, insurers, and regulators. (See “Coping with Coal Dust,” in the March 2012 issue or the archives at http://www.powermag.com.)
A turning point was the 2006 U.S. Chemical Safety Board (CSB) report identifying 281 combustible dust incidents between 1980 and 2005 that caused 119 fatalities and 718 injuries. That sparked efforts to enhance standards and ramp up enforcement, and those efforts intensified after a 2008 combustible dust explosion killed 14 people and injured 38 at an Imperial Sugar refinery in Georgia (Figure 5).
|5. The dangers of combustible dust. The 2008 dust explosion at the Imperial Sugar Refinery in Georgia, shown here, focused increased national attention on issues surrounding combustible dust. Source: Chemical Safety Board|
Recently, on the fourth anniversary of that tragedy, CSB Chairman Rafael Moure-Eraso stated that “safety recommendations that followed from our investigation of this accident will go far in saving lives. I am pleased to report that on this accident anniversary all but one of our recommendations have been successfully adopted.”
The unfulfilled recommendation? That the U.S. Occupational Safety and Health Administration (OSHA) create a new “comprehensive standard to reduce or eliminate hazards from fire and explosion from combustible powders and dust.”
Seeking a Comprehensive Combustible Dust StandardThe quest for a “comprehensive standard” has taken the industry down a long and winding road, inspiring countless debates and some confusion. After OSHA spent years laying the groundwork for such a standard, while pursuing a vigorous Combustible Dust National Emphasis Program (NEP), it is somewhat baffling that the agency recently shifted its combustible dust rulemaking initiative from “active” to the ambiguous “long-term actions” status (Figure 6).
|6. An explosive situation. Fire and explosion can occur where coal is handled, processed, and used. This is one reason why electric power plants are included in OSHA’s National Emphasis Program. Source: UL PureSafety|
Regardless of the meaning of that shift, even without a new standard, OSHA has found plenty of regulations to cite and has made the energy industry a priority for related inspections. Beyond the obvious need to protect your workers, facilities, and bottom line, there are solid reasons not to take a “wait and see” approach that relies on new standards.
OSHA has cited facilities based on 17 existing standards in the NEP, including those involving electrical installations, housekeeping, hazard labeling, personal protective equipment hazard assessment, and the “General Duty” clause.
According to Sanji Kanth, senior safety engineer with OSHA’s enforcement directorate, from the launching of the program through October 2011 there were 2,600 inspections related to the NEP, resulting in more than 12,000 violations (approximately 8,500 classified as “serious,” “willful,” or “repeat”) and total civil penalties exceeding $24 million.
Companies may be held civilly liable in the absence of a federal standard, because consensus standards exist, including stringent state-run OSHA, local, and organization-specific requirements, as well as those defined by insurance risk managers, fire safety enforcement officers, and others.
Industry and public awareness of these hazards remains high due to media attention; even minor shortcomings could damage brand reputation, worker morale, and productivity—as well as expose your company to whistleblowing complaints and liability claims.
Additionally, OSHA’s March 2012 revisions to its Hazard Communication Standard included combustible dust in the definition of “hazardous chemicals”—one more indicator of OSHA’s intent to increase regulation and enforcement.
But here’s the point to remember: Combustible coal dust is not an area where any company should wait for regulators to issue clarifications. If you stay current with existing best practices, you will stay ahead of regulators and prevent your company from becoming a tragic example cited in future reports arguing for stricter regulations.
Industry Best Practices Are the Best Way Forward
The power generation industry as a whole is exemplary in promoting, defining, and following safety best practices. That includes managing coal dust hazards. The National Fire Protection Association (NFPA) regulations, particularly NFPA 654, are widely adopted, and organizations such as the Powder River Basin Coal Users’ Group (PRBCUG) have brought stakeholders together to develop and share best practices that exceed regulatory guidelines. The industry’s shared knowledge is also evident in the many prior articles written by members of the PRBCUG that have appeared in POWER, such as “Proactive Strategies for Dealing with Combustible Dust” (May 2011) and “A Burning Concern: Combustible Dust” (May 2010).
Still, one area of hazard management sometimes gets underestimated: training. That’s understandable, because mechanical solutions and smartly engineered processes sit atop the hierarchy of dust control measures. Developing these solutions comes naturally to many industry professionals, whereas learning effectiveness, behavior modification, and culture change may feel like learning a foreign language.
However, all controls rely to some extent on people. People design and operate the material-handling and dust collection equipment and are responsible for the maintenance and housekeeping that determine whether equipment and systems work as intended. Inadequate equipment maintenance and housekeeping were among the causative factors of the Imperial Sugar explosion, according to the CSB’s investigative findings. Consequently, training was included in the CSB’s post-incident recommendations for both Imperial and its property insurer, Zurich Services Corp.
Training Is Critical for a Proactive Program
Physical and mechanical aspects of a comprehensive combustible dust management program are thoroughly discussed in articles such as those mentioned earlier, so in this article I will highlight three areas where training and safety culture have an impact: inspections, maintaining equipment, and housekeeping. Consider these contributing factors behind the worst combustible dust incidents over the past 15 years:
- Workers and managers were unaware of dust explosion hazards or failed to recognize the serious nature of dust explosion hazards.
- Procedures and training to eliminate or control combustible dust hazards were inadequate.
- Warning events were accepted as normal, and their causes were not identified and resolved.
- Process changes were made without adequately reviewing them for the introduction and addition of new potential hazards.
Hazard and risk assessments performed by safety professionals are important. However, it’s equally important that management, supervisors, and frontline workers are trained to spot hazards on a daily basis. Training can ensure accurate, ongoing recognition of the following:
- Areas where combustible dusts accumulate.
- Processes and activities that cause dust to become airborne.
- Potential ignition sources.
Don’t Wait for Regulators—Or Incidents
Despite increased attention and regulatory enforcement, the CSB has recorded 70 new incidents since 2006. Such incidents are too costly, in both human and business terms, to accept any goal other than zero for your company. Regardless of what regulators do or don’t do in the future, commit to proactively ensuring that your facilities follow the best practices established by the NFPA and PRBCUG. Evaluate all aspects of your program, including whether your people are being adequately trained to take combustible dust threats seriously and avert them.
—Contributed by Jonathan A. Jacobi (firstname.lastname@example.org), a senior environmental, health, and safety consultant at UL PureSafety. Jacobi is a certified safety professional (CSP), construction health and safety technician (CHST), and OSHA-authorized outreach trainer for construction and general industry.