Dust Mitigation: Housekeeping to Avoid

Dust Hazards, Contamination and Fines

PART 1:

A FOCUS ON HOUSEKEEPING TO AVOID

COMBUSTIBLE DUST HAZARDS AND FINES

SCOTT C. BOERSMA, NILFISK, INC., BOOTH 9400

INTRODUCTIONS

• Scott C. Boersma, Business Development Manager,

Food Market Specialist, has more than 17 years of

experience in designing systems and solving

housekeeping challenges for Fortune 500 companies.

Currently, he works directly with food processing and

manufacturing customers and guides Nilfisk’s sales team

and engineers to better understand their housekeeping

and maintenance requirements.

Overview

Introduction to Combustible Dust Issue

OSHA & NFPA Regulatory Overview

Maintenance and Housekeeping Best Practices

Choosing the Right Housekeeping Equipment

Resources

Questions

1

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3

4

5

6

Introduction to

Combustible Dust Issue

• OSHA: particulate solid that presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations, regardless of particle size or shape

• NFPA: any finely divided solid material that is 500 microns or smaller in diameter that presents a fire or explosion hazard when dispersed and ignited in air

COMBUSTIBLE DUST: DEFINITION

1) Fuel to burn (combustible dust)

2) Oxygen to sustain the fire (air)

3) Heat from an ignition source (spark)

4) Dispersion of a high concentration of dust into the air (deflagration)

5) Confinement of the dust within an enclosure or structure (explosion)

DUST EXPLOSION PENTAGON &

SECONDARY EXPLOSIONS

• The FOOD industry has the highest incidents of combustible dust issues.

• 771 Food Facility Inspections completed from 2007-2013

• $28 Million+ in Fines issued under the NEP

• Any dust with a Kst value greater than 0 is considered potentially

combustible

WHO’S AT RISK?

Furniture & Fixtures, 4%

Equipment Manufacturing,

7% Fabricated Metal

Products, 7%

Other, 7%

Electric Services, 8%

Rubber & Plastic

Services, 8%

Food24%

Wood, 15%

Chemical, 12%

Metal, 8% Material

-

Kst Value

(bar-m/sec)

Limestone 0

Act. Carbon 44

Wood dust 102

Flour 108

Sugar 138

Barley Grain Dust 240

Aluminum 415

Magnesium 508

OSHA & NFPA

Regulatory Overview

OSHA PROPOSED COMBUSTIBLE DUST

STANDARD

• OSHA National Emphasis Program (NEP),

created in 2008

• Continue to inspect facilities that

generate/handle combustible dusts which

pose a deflagration hazard that can lead to

an explosion

• OSHA penalty levels increasing by 78%

effective August 1, 2016

Source: OSHA, “Unified Agenda 2015”

Most Frequently Cited Violations During Inspections

1. Hazard communication (1910.1200)

2. Respiratory protection (1910.134)

3. Housekeeping (1910.22(a))

4. Electrical safety (1910.305)

5. Lockout/Tagout (1910.147)

6. Electrical safety (1910.303)

NFPA 652: FUNDAMENTALS OF

COMBUSTIBLE DUST

NFPA 652

Fundamentals of Combustible Dust

Effective September 2015

NFPA 61Agricultural & Food Processing Facilities

NFPA 484Combustible Metals

NFPA 664Wood Processing &

Woodworking Facilities

NFPA 654Other Industries

(i.e. Plastics, Pharmaceutical)

NFPA 655Sulfur

Source: NFPA 652, Origin and Development

Not Law, but violation of NFPA Standards is used as a

determining factor to identify risk and cite or fine

facilities under the General Duty Clause.

NFPA 652: APPLICATION (1.3)

• Applies to all facilities and

operations that manufacture,

process, blend, convey,

repackage, generate, or handle

combustible dusts or combustible

particulate solid (1.3.2)

***NOT JUST CLASSIFIED

(HAZARDOUS) LOCATIONS***

NFPA 652: SCREENING FOR COMBUSTIBILITY OR

EXPLOSIVITY (SECTION 5.2)

• Dust Test Required

• The absence of previous incidents

cannot be used as the basis for

deeming a particulate not combustible

(NFPA 652, Section 5.2)

– Owner/operator of a facility is

responsible for determining the

combustibility of material

– Test results, historical and published

data must be kept on file at all times

– Can use historical data if you can prove

the properties of your dust are the same

as previously tested dust

NFPA 652: DUST HAZARD ANALYSIS (7.1)

• Required at all operations that generate, process, handle or store combustible dusts/particulates

• For existing facilities, must be completed by September 2018 (3 years from effective date of standard)

• NFPA 652 offers a recommended method for and examples of DHAs

Dust Hazard Analysis (DHA)

(Verb)

A systematic review to identify and evaluate the potential fire, flash fire, or explosion hazards associated with the presence of one or more combustible particulate solids in a process or facility.

(Noun)

The review documents a facility keeps on file to document safe handling of combustible dust.

Proper Maintenance &

Housekeeping Practices

IMPORTANCE OF HOUSEKEEPING

Did you know?

During a 2011 expert forum on combustible dust held by OSHA, one

expert estimated that 95-99% of injuries and fatalities could be

prevented through proper housekeeping.

NFPA 652: HOUSEKEEPING (8.4)

• Requirement General Takeaways:

– Vacuuming is the preferred

method of cleaning (equipment

requirements laid out in 8.4.2.2)

– When vacuuming is impractical,

sweeping/water washdown is

permitted

– Compressed air blowdown used

for cleaning presents significant

hazards • Only use when other cleaning

methods present higher risk

• NOTE: this method does not remove

accumulated dust, it simply moves the

dust to another area

Choosing the Right

Housekeeping Equipment

OSHA VIOLATION FOR EQUIPMENT

• Selecting inappropriate equipment to clean combustible

dust can result in a fine

• Fragrance company fined $35,000 for:

“…failure to use approved electrical equipment to

clean up combustible dust.”

Source: https://ohsonline.com/articles/2016/06/06/combustible-dust-standard.aspx

NFPA 652: VACUUM CLEANING METHOD

(8.4.2.2)

• NFPA does not approve/certify vacuum equipment

• In classified (hazardous) locations vacuums must be 3rd party CERTIFIED for that specific location (Class II, Division 1 or 2, Group G)

• Vacuums MUST meet minimum NFPA design requirements to collect any type of combustible dust in non-classified locations!

NFPA-COMPLIANT VACUUMS

Design Requirements for portable vacuums collecting combustible dust in nonclassified(nonhazardous) areas

1. Non-combustible construction and meets requirements for construction and static electrical hazard controls (8.5.7.1)

2. Conductive or static-dissipative hoses including both suction and air delivery hoses

3. All conductive accessories, including wands and attachments, must be bonded and grounded

4. Dusty air should not pass through the fan/blower

5. Electrical motors must not be in the dust laden air stream unless listed for Class II, Division 1 locations

6. No paper filter elements for liquid/wet collection

7. Vacuum cleaners used for metal dusts must meet NFPA 484 requirements

• NFPA-compliant vacuums are designed to meet the requirements laid out in the standard, without requiring the 3rd party certification

• Only to be used when handling combustible dust in NON-classified locations

Additional Key Drivers

WHY INVEST IN HOUSEKEEPING?

• Eliminate risk of costly recalls, lawsuits and fines

• Improve air quality with certified HEPA and ULPA

filtration

• Good Manufacturing Practices (GMPs)

• HACCP

• Quality Assurance & Quality Control

• Cross-Contamination prevention (Allergens, Mold,

Microbacteria, Spores, Salmonella, etc.)

Combustible Dust Mitigation

• Compliance with OSHA & NFPA Guidelines

• Authorities Having Jurisdiction may require

compliance: Building Inspector, OSHA Rep., Fire

Marshall, Insurance Agent, Safety Manager at the

company, etc.

• Housekeeping – keep dust cover to less than 1/32”

• No more air blow down, per NFPA

• Insurance agencies mandating dust control plan

• Meet requirements for NRTL-certified equipment

OSHA resources:

Combustible Dust NEP:

www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=3830

Fact Sheet:

http://www.osha.gov/OshDoc/data_General_Facts/OSHAcombustibledust.pdf

Poster:

www.osha.gov/Publications/combustibledustposter.pdf

NFPA resources:

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

http://www.nfpa.org/aboutthecodes/

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RESOURCES

Questions?

For more information:

Scott C. BoersmaNilfisk, Inc.

scott.boersma@nilfisk.com

BOOTH 9400

PART 2:

UNDERSTANDING SILO CLEANINGROBERT VERDUGO, M.S.

• Senior Account Exec. – Action Duct Cleaning – Western region. Founded in 1978.

• AIB certified in Food Safety and Sanitation.

• Regularly visits food processing plants to review cleaning needs for silos, ovens, tanks and similar equipment.

• Consultant for food sanitation issues.

WHO’S ROBERT VERDUGO?

WHAT IS A SILO?

• Goes back to Latin sirus (sĭrūs).

• Latin word comes from Greek

siros.

• Meant a pit or underground

storage for keeping grain.

WHAT IS A SILO?

• No pallets of bagged material to store and keep from pests.

• No need to tear open 50-100 lb. bags and dump the contents into a hopper – and then clean up the overspray and deal with the empty bags.

• By simply opening a valve, the rate and amount of material can be regulated as it flows continuously from the silo into the manufacturing process.

ADVANTAGES OF A SILO

• The Code of Federal Regulations (CFR) is the code of rules and regulations (sometimes called administrative law) from the executive departments and agencies of the federal government.

• Title 21 covers food and drugs.

• Sec. 110.35(a) Sanitary operations: “Buildings, fixtures, and other physical facilities of the plant shall be maintained in a sanitary condition and shall be kept in repair sufficient to prevent food from becoming adulterated within the meaning of the act. Cleaning and sanitizing of utensils and equipment shall be conducted in a manner that protects against contamination of food, food-contact surfaces, or food-packaging materials.”

REGULATIONS RE: SILO MAINTENANCE

“Cleaning is done in a way that prevents contaminationof raw materials, products,

and equipment.”

AIB (American Institute of Baking) International Consolidated Standards for Inspection,

Section 3.1.1.1

REGULATIONS RE: SILO MAINTENANCE

• Mold

• Insects

• Contaminants (e.g., rust, paint

flakes)

• Environmental: Rain, dirt, etc.

• Rodents and other pests

SILO SANITATION ISSUES

• Mold

• Insects

• Contaminants (e.g., rust, paint

flakes)

• Environmental: Rain, dirt, etc.

• Rodents and other pests

SANITATION ISSUES

• Commonly seen at top of silo.

• Visible as shades of green or black, particularly on inside walls.

• Can be an inch deep on the walls.

• Moisture is key.

• Can occur when warm flour is pumped in and cools down.

• Dehumidifiers can reduce moisture.

MOLD IN SILOS

• Typical pests: Red Flour Beetle, Confused Flour Beetle.

• Lesser: Warehouse Beetle, Cigarette Beetle

INSECTS IN SILOS

• Typically have 28-day life cycle.

• Invasive insects tend to be seen a

month or so after cleaning.

• Cleaning breaks the 28-day cycle

and brings insect load back to

near zero.

INSECTS FOUND IN SILOS

• Holes in exterior – rusted out,

gunshot, impact damage.

• Interior rusting or flaking.

• Holes in filters and breather bags.

• Leaking gaskets.

• Poor-fitting doors or covers.

DAMAGED SILOS

• Access doors at

top

• Interior cage

• Interior stairs

• Tripod at top, lower

personnel into silo

ACCESS FOR CLEANING SILOS

• Falls

• Lack of oxygen

• “Drowning” in flour

or other material

• Explosive dust

hazard

CLEANING SAFETY ISSUES

• Confined Spaces (29 CFR

1910.146)

• Fall Protection (29 CFR 1926.501)

• Ladder Safety (29 CFR 1926.1053)

• Personnel Protective Equipment (29

CFR 1910.132)

• Combustible Dust (OSHA 3371-08)

SILO CLEANING SAFETY - OSHA

Explosion beneath sugar silos

IMPERIAL SUGAR FIRE, GEORGIA

• The Department of Justice requested that U.S. Attorney for the Southern District of Georgia pursue criminal prosecution against Imperial Sugar and its executives.

• OSHA cited Imperial with 124 safety violations, finding that the company acted with "plain indifference to, or intentional disregard for, employee safety and health."

IMPERIAL SUGAR FIRE, GEORGIA

• Clean silos two to four times a year or as needed.

• (Optional) Fumigate after each cleaning.

• Change filters monthly.

• Conduct a self-audit through your HACCP system (Hazard Analysis and Critical Control Points).

• Hire a third party auditor to perform a routine review.

SILO PREVENTATIVE MAINTENANCE

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