Combustible dust wic may 2011

Combustible Dust…an Explosive Issue

WICMay 2011Presented byJamison [email protected] info on combustible dust: http://www.airhand.com/combustibledust.asp

mailto:[email protected]

http://www.airhand.com/

http://www.airhand.com/combustibledust.asp

Combustible DustTopics Covered:

• What is It?• Sawdust Cannon - http://www.vimeo.com/260680• Myth busters - Creamer Cannon - http://www.youtube.com/watch?v=yRw4ZRqmxOc&NR=1• Powdered Milk Container - http://www.youtube.com/watch?v=-yMOujZMXP8&feature=fvwrel• Flour Dust - http://www.youtube.com/watch?v=zKMPC2l80NU&feature=related

• Who’s in Charge?

• Can it Happen in My Facility?

• Prevention

Air Handling Systems - Copyright 2011 For informational use only

http://www.vimeo.com/260680

http://www.youtube.com/watch?v=yRw4ZRqmxOc&NR=1

http://www.youtube.com/watch?v=-yMOujZMXP8&feature=fvwrel

http://www.youtube.com/watch?v=zKMPC2l80NU&feature=related

What is It – OSHA Fact Sheet


What is It – OSHA List


What is It – Classic Fire Triangle

Remove any one element

eliminates the possibility of fire.


What is It - Dust Explosion Pentagon

Remove any one element prevents explosion, but not necessarily fire!*

*the concentration of suspended dust must be within an explosible range, lowest amount of dust in air that will explode, referred to as Minimum Explosible Concentration (MEC) – (1)


What is It – Particles & LayerCombustible Fine Particles

– Deflagrable Wood Dust 420 micons (.425 mm, 425 um micrometers, .0165”) or smaller (having moisture content of less than 25%). Material that will pass through U.S. No. 40 Standard Sieve. Size of fairly coarse sand. However will most likely change in 2013.

“Dust Layer depth 1/64 in. (0.4mm) or less or the underlying surface colors are readily discernible.” Revised per NFPA 654 6.1.1.1 TIA March 21, 2011


What is It – Primary & Secondary

Primary Issues• Explosion

Secondary Issues• Disturbing of dust on structural supports

can create a secondary source of fuel• Video Clip: (3:20-5:28)

http://www.chemsafety.gov/videoroom/detail.aspx?VID=33


http://www.chemsafety.gov/videoroom/detail.aspx?VID=33

Who’s in chargeRegulatory Organizations & Agencies• OSHA - Occupational Safety and Health Administration

• July 2005 - Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions

• February 2008 – Imperial Sugar, dust explosion and subsequent fire at a sugar refinery in Port Wentworth, Georgia, caused 14 deaths and left many others seriously injured.

• 2007 – National Emphasis Program which targeted inspection efforts on facilities that create or handle combustible dusts. Results from these inspections indicated that facilities had unusually high numbers of general duty clause violations, indicating a strong need for a combustible dust standard.

• March 2008 - Hazard Alert: Combustible Dust Explosions. OSHA Fact Sheet

• April 2008 – See Congress below

• Spring 2009 - The Occupational Safety and Health Administration (OSHA) is considering rulemaking to develop a combustible dust standard for general industry.

• 2009 - Hazard Communication Guidance for Combustible Dust OSHA 3371-08 2009

• October 21, 2009 - Combustible Dust ANPR Feb 2011 – WMMA Submits comment

• October 2009 – Status Report on Combustible Dust National Emphasis Program


http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=200904&RIN=1218-AC41

http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=200904&RIN=1218-AC41

Who’s in charge (cont.)Regulatory Organizations & Agencies• Congress

• 110th Congress - April 2008 - The House passes the Worker Protection Against Combustible Dust Explosion and Fire Act, H.R. 5522 by a vote of 247-165 and referred to the Senate.

• 111th Congress - H.R. 849 - Worker Protection Against Combustible Dust Explosions and Fires Act of 2009. Same as H.R. 5522 from 110th Congress. Status: Referred to Committee.

• 112th Congress – U.S. Rep. John Barrow from Georgia reintroduced “Worker Protection Against Combustible Dust Explosions and Fires Act” in the House in February, 2011

• SBA - U.S. Small Business Administration's (SBA) Office of Advocacy

• Early 2011 OSHA was exploring creation of SBREFA for April 2011 (Small Business Regulatory Enforcement Fairness Act) requiring OSHA to convene a task force of small business to review effects of OSHA regulations. Per contact with SBA in late April 2011 – SBREFRA has been put off for a month or so.

• NFPA – National Fire Protection Association (Current Edition noted)• NFPA 68 Standard on Explosion Protection by Deflagration Venting. (2007 Edition) • NFPA 484 Standard for Combustible Metals (2009 Edition) • NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing,

and Handling of Combustible Particulate Solids. (2006 Edition)• NFPA 664 Standard for the Prevention of Fires and Explosions on Wood Processing and Woodworking

Facilities (2007 Edition)

• Insurance Companies• FM Global - Prevention and mitigation of combustible dust


Who’s REALLY in charge

Sugar Refinery Ignored Explosive Dust Before BlastSeptember 25, 2009 by Rruss Bynum, Associated Press Writerhttp://www.impomag.com/scripts/ShowPR.asp?RID=11927&CommonCount=0


http://www.impomag.com/scripts/ShowPR.asp?RID=11927&CommonCount=0

Can it Happen?

(2) www.woodchuckles.com

http://www.woodchuckles.com/

Can it Happen - ExplosionExplosion• 2008 Georgia sugar refinery explosion

The 2008 Georgia sugar refinery explosion was an industrial disaster that occurred on February 7, 2008 in Port Wentworth, Georgia, United States. Thirteen people were killed and 42 injured when a dust explosion occurred at a sugar refinery owned by Imperial Sugar. http://en.wikipedia.org/wiki/2008_Georgia_sugar_refinery_explosion

• Combustible Dust Explosion at Motorcycle Rim Manufactured Factory November 2010 - 8 workers were injured as a result of the dust explosion and 2 of them received serious injuries. The explosion also caused damage to buildings and manufacturing plant, the destruction of the dust collector system and also broke windows of factories nearby. http://www.dosh.gov.my/doshV2/index.php?option=com_content&view=article&id=295%3Acombustible-dust-explosion-at-motorcycle-rim-manufactured-factory&Itemid=118&lang=en


http://en.wikipedia.org/wiki/2008_Georgia_sugar_refinery_explosion

http://www.dosh.gov.my/doshV2/index.php?option=com_content&view=article&id=295%3Acombustible-dust-explosion-at-motorcycle-rim-manufactured-factory&Itemid=118&lang=en



Can it Happen – Inspection OSHA Inspection - $617,000 in proposed fines!• RY Timber (MT) cited by OSHA for worker ComDust exposure - $79,200

April 19, 2011 - BILLINGS, MT -- RY Timber Inc., a manufacturer of 2x4 studs, has been cited for five repeat and four serious violations for exposing workers to combustible dust hazards by the U.S. Occupational Safety and Health Administration (OSHA). The repeat violations address deficiencies involving inadequate housekeeping in areas where combustible dust build-up had exceeded allowable limits.

• Seating Company (NJ) Slapped with $117,600 in Fines for Combustible Dust, Health Hazards - $117,600April 15, 2011 - “Combustible dust, with its fine particulate composition, has the ability to create an explosive atmosphere and rapidly engulf a facility in fire,” said Lisa Levy, director of OSHA’s Hasbrouck Heights Area Office. “The accumulations of combustible dust must be removed, and a program must be put in place to prevent any potential build up from occurring.”

• Gov. Malloy tours Connecticut firm cited by OSHA - $83,400March 29, 2011 - OSHA cited specific safety violations in its announcement on Tuesday. They include improperly designed combustible dust collection system. – SEE NEXT SLIDE for DETAILS

• OSHA: Carolina Skiff (GA) cited for combustible dust and hexavalent chromium exposure - $95,000March 22, 2011 - US Department of Labor's OSHA fines Waycross, Ga., manufacturer more than $95,000 for safety and health violations

• Mississippi mill slapped with ComDust violations - $67,800February 2011 - SILVER CREEK, MS -- The Occupational Safety and Health Administration has cited a Mississippi lumber mill for a variety of violations, including for having an electrical junction box open in an area where combustible wood dust accumulates. OSHA cited Joe N. Miles & Sons Inc. of Silver Creek with 19 willful and serious safety violations and associated proposed penalties totaling $67,800.

• Combustible Dust Exposure Leads to Georgia Company's $55,250 FineFebruary 2011 – OSHA has cited Protech Environmental South Inc., doing business as U.S. Erosion Control Products Inc., following an inspection that uncovered 46 alleged safety and health hazards including worker exposure to heavy accumulations of combustible dust. Proposed penalties total $55,250.

• US Department of Labor's OSHA cites 2 Tuscumbia, Ala., companies for 40 safety and health violations with $121,800 in penalties

• February 2011 – TUSCUMBIA, Ala. – The U.S. Department of Labor's Occupational Safety and Health Administration is proposing $121,800 in penalties for 40 safety and health violations at two Tuscumbia companies with shared family ownership, Tri-Cities Manufacturing Inc. and Tool Masters Inc.


http://woodworkingnetwork.com/RY-Timber-cited-for-exposing-workers-to-ComDust-hazards/2011-04-17/Article.aspx?oid=1318084&hq_e=el&hq_m=987534&hq_l=4&hq_v=844684e68d

http://www.runtherisk.info/seating-company-slapped-with-117600-in-fines-for-combustible-dust-health-hazards/

http://www.runtherisk.info/seating-company-slapped-with-117600-in-fines-for-combustible-dust-health-hazards/

http://www.businessweek.com/ap/financialnews/D9M957GO0.htm

http://www.mmdnewswire.com/carolina-skiff-32950.html

http://www.mmdnewswire.com/carolina-skiff-32950.html

http://woodworkingnetwork.com/Mississippi-mill-slapped-with-ComDust-violations/2011-02-19/Article.aspx?oid=1308526&fid=WWN-ARTICLES&aid=79

http://ohsonline.com/articles/2011/02/10/combustible-dust-exposure-leads-to-georgia-companys-55250-fine.aspx

Can it Happen – Inspection CT FirmGov. Malloy tours Connecticut firm cited by OSHA - $83,400• The employer did not furnish employment and a place of employment which were free from recognized hazards

that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to fire and explosion hazards caused by the presence of combustible dust :

• Current Penalty:$5000.00• Aluminum and titanium aircraft engine parts were de-burred using pneumatic hand tools which generated

combustible dust. The Donaldson Torit Model VS1200 dust collection system provided was not designed and installed to be used with combustible metal dust.

• Specifically:1. The collection hood provided at the de-burring workstation was not designed and maintained so that fine

particles would either fall or be projected in the direction of airflow. (NFPA 484, Section 6.3.2.2) 2. The dry-type dust collector was located inside of the building. (NFPA 484, Section 6.3.2.5) 3. The dust collection system was not dedicated to the collection of aluminum or aluminum alloy dust . It

was also used to collect nickel-based and steel based aircraft alloys and served a surface grinder used to modify milling machine tooling. (NFPA 484, Section 6.3.2.6)

4. The plastic hose that connected the exhaust hood to the dust collector was not short, straight, conductive and provided with a smooth interior surface, factors required to maximize free air flow and minimize accumulations of combustible dust inside the ductwork. (NFPA 484, Sections 6.3.3.4, & 6.3.3.5.1 & 10.4.4.2)

5. The pneumatic hand tools provided for use were not interlocked with the dust collector to ensure that the dust collector was on and properly functioning before deburring operations commenced. Also, a time delay switch or equivalent device was not provided on the dust collector to prevent hand tools from starting until the dust collector was in full operation. (NFPA 484, Section 6.3.4.7.1, 6.3.4.7.2, 10.4.4.6.1 & 10.4.4.6.2)

6. Exhaust air from the dust collector was recycled into the work area. (NFPA 484, Section 6.3.6 & 10.4.9)7. A media type dust collector was used to collect titanium dust. The Donaldson Torit Vibra Shake dust

collector contained dry fabric-type collection media. (NFPA, Section 10.4.8.1)• Among other methods, one feasible and acceptable abatement method to correct this hazard is to design

and install a dust collection system that complies with generally accepted guidelines such as National Fire Protection Association (NFPA) Standard 484 Standard for Combustible Metals.


http://www.businessweek.com/ap/financialnews/D9M957GO0.htm

PreventionOSHA• Use NEP and ANPR as guidelines.• National Emphasis Program (NEP) - Using General Duty Clause• Advanced Notice of Proposed Rulemaking (ANPR). ANPR is

basically data collect from a series of questions. You will note there is overlap in the various sections. However, “Preparation is the best medicine.” Highlights include:• Hazard Recognition/Assessment• Engineering Controls• Administrative Controls – Document, Document, Document• Housekeeping• Building Design• Explosion Protection• Operating Procedures• Worker Training

Source OSHA ANPRAir Handling Systems - Copyright 2011

For informational use only

Prevention - Hazard AssessmentHazard Recognition/Assessment• Recognition/Assessment

• Determining if dust is combustible via Dust Testing - Explosion Severity Test, Minimum Explosible Concentration (MEC)

• Communication• HazCom Standard, MSDS

• Industry Standards• NFPA

• State and Local Codes• AHJ (Authority Having Jurisdiction) – Fire Marshall, Building

Inspector• Insurance Company



Prevention – Engineering Controls

Engineering Controls

• Fixed measures that are built into a facility or processing equipment to remove or minimize hazard.• Primary (building, facility)

• Prevent accumulation of dust on surfaces, beams, etc. Flat surfaces are not good.

• Secondary (equipment)• Dust Collection Systems• Sprinkler system



Prevention – Admin ControlsAdministrative Controls

• Document, Document, Document

• Do you have a method to prevent escape of dust?

• Do you have a policy to remove fugitive dust from surfaces?

• OSHA wants written rules and procedures

• Document, Document, Document



Prevention - HousekeepingHousekeeping• Fugitive Dust Control (NFPA 654, Chapter 8)

• Dust layers as thin as 1/64 of an inch or less or the underlying surface colors are NOT readily discernible. If you can see dust, don’t ignore it!

• Clean it up and examine where it’s coming from. Seal all openings in processing and conveying equipment to prevent the release of dust.

• When you inspect your workplace also consider overhead beams, electrical cabletrays, lighting fixtures, and “invisible” areas such as areas above false or suspended ceilings. – Source NFPA http://www.nfpa.org/publicJournalDetail.asp?categoryID=1691&itemID=40964&src=NFPAJournal


http://www.nfpa.org/publicJournalDetail.asp?categoryID=1691&itemID=40964&src=NFPAJournal

Prevention – Housekeeping

Housekeeping (cont.)• Dust Collectors – Clean it Up!

• NFPA 664 (combustible dust standard just for woodworking) applies to shops larger than 5,000 sq ft or collector greater than 1500 cfm) Essential in any size shop

• So when it comes to Combustible Dust - Size of shop doesn’t matter, size of dust does.

• Changing filters, bags, tightening clamps.• Explosion Relief – Deflagration Venting

• NFPA 68 Example: http://www.youtube.com/watch?v=af4IANnITeM&NR=1


http://www.youtube.com/watch?v=af4IANnITeM&NR=1

Prevention – HousekeepingHousekeeping (cont.)• Dust Collectors – Clean it Up! (cont.)

• Hanging Air Filter for ambient dust.• DO NOT blowing off machinery to clean

• Shop Vacuum or Vacuum Kit which attaches to your dust system for everything else.

• Using explosion proof vacuum?

• Sprinklers – Test, Test, Test• Building• Spark Detection system in Dust Collectors and

Ductwork


Prevention – Finally• Building Design

• Explosion Protection

• Operating Procedures

• Worker Training• Do the worker know what to do?• Have they read the operating procedures?• Do they understand?• Have they been tested?



Hot off the PressNFPA

• March 21, 2011 – TIA (Tentative Interim Amendment) to NFPA 654

• March 25, 2011 – Report on Consolidation of the Combustible Dust Committees and Documents

• 61 Agricultural Dusts

• 484 Combustible Metals

• 654 Manufacturing of Combustible Particles

• 664 Wood Processing

OSHA• May 13, 2011 - Occupational Safety and Health Administration

invited outside experts to participate in a Combustible Dust Expert Forum May 13, 2011. OSHA will gather experts' views on possible regulatory options for addressing combustible dust hazards.

ResourcesOSHA – Occupational Safety & Health Administration - http://www.osha.gov/

• Combustible Dust: http://www.osha.gov/dsg/combustibledust/index.html• OSHA Advanced Notice of Proposed Rulemaking: http://edocket.access.gpo.gov/2009/pdf/E9-25075.pdf

Congress - http://thomas.loc.gov/

NFPA - http://www.nfpa.org• NFPA 68: Standard on Explosion Protection by Deflagration Venting

• http://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=68

• NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids


• NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities


US Chemical Safety Board - http://www.chemsafety.gov/• Imperial Sugar Company Dust Explosion and Fire

• http://www.chemsafety.gov/investigations/detail.aspx?SID=6

WMMA - http://www.wmma.org• NFPA 664 Combustible Dusts Overview is now available!


http://www.osha.gov/

http://www.osha.gov/dsg/combustibledust/index.html

http://edocket.access.gpo.gov/2009/pdf/E9-25075.pdf

http://thomas.loc.gov/

http://www.nfpa.org/

http://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=68

ResourcesInsurance Company - http://www.fmglobal.com (registration required)

• Loss Prevention Data Sheet 7-73, Dust Collectors and Collection Systems• Loss Prevention Data Sheet 7-76, Prevention and Mitigation of Combustible Dust Explosions and Fires

Combustible Dust Policy Institute• http://dustexplosions.blogspot.com/

Linkedin - The Combustible Dust Forum• http://www.linkedin.com/groups?gid=946657&trk=myg_ugrp_ovr

Building Code Reference Library• http://www.reedconstructiondata.com/building-codes



Questions & SummaryJamison [email protected]

www.airhand.com

More info on combustible dust: http://www.airhand.com/combustibledust.asp

Appendix A Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions


Appendix B Hazard Alert: Combustible Dust Explosions. OSHA Fact Sheet, (2008, March)


Appendix C Hazard Communication Guidance for Combustible Dusts OSHA 3371-08 2009


Appendix DOSHA ANPR


Appendix EStatus Report on Combustible Dust National Emphasis Program


Appendix FFM Global – an Insurer’s View


Appendix Ghttp://www.wmma.org


Appendix H TIA


Appendix IWMMA ANPR Comment Feb 2011
