Protecting Workers from Combustible Dust with FR … s/EEI Fall 2010... · Protecting Workers from Combustible Dust with FR ... • Dust testing adequate housekeeping Dust testing,

Protecting Workers from Protecting Workers from Combustible Dust with FR Clothing

June 2010

Service • Experience • Trust • Quality • Flexibility

Agenda

• Introduction: Combustible Dust & OSHAIntroduction: Combustible Dust & OSHA• What is Combustible Dust?• Combustible Dust Statistics• Case Studies• Hazard Analysis• Mitigation Strategies• FR Clothing: Background

FR Cl thi C P t t W k• FR Clothing Can Protect Workers• Conclusion: Preventing and Protecting

Against Combustible Dust


Against Combustible Dust

Combustible Dust: Background

• Nearly 300 explosions have injured or killed over y p j800 workers since 1980.

• Imperial Sugar Plant explosion in 2008 caused OSHA to re-intensify a National Emphasis OSHA to re intensify a National Emphasis Program targeting the hazard.

• OSHA has cited over 1,000 firms for combustible dust Of firms visited 87% have received dust. Of firms visited, 87% have received citations.

• As yet, there is no enforceable standard to regulate combustible dust.

• The complexity of the combustible dust hazard poses a challenge to standard-makers.


poses a challenge to standard makers.

What is Combustible Dust?

• There is no widely accepted definition of There is no widely accepted definition of combustible dust.

• OSHA defines combustible dust as: “organic or inorganic dust particles that are finely ground and pose a deflagration or other fire hazard when suspended in air or another hazard when suspended in air or another oxidizing medium over a range of concentrations.”C b tibl D t i t f t i l • Combustible Dust can consist of any material and varies in the dangers of its explosivity.


How does dust “combust”?

• Finely divided dust is disturbed from its resting position and suspended in the air or introduced to another oxidant introduced to another oxidant.

• Ignition sources such as static, a spark, an ember, a hot surface, friction heat or flame , ,come in contact with dispersed dust, causing an explosion.


5 Elements of an Explosion


Vulnerable Industries


C C b tibl D tCommon Combustible Dusts


Known Injuries & Deaths Over Time


i iOSHA is Acting

• OSHA is working to create a Combustible Dust gStandard applicable to a variety of industries.

• HR 849, requiring a combustible dust regulation from OSHA following the 2008 Imperial explosion from OSHA following the 2008 Imperial explosion, was passed but never signed into law.

• OSHA is targeting dozens of industries, including refineries, chemical companies, and petrochemical companies, and delivering citations at a rate of 87%.

• An estimated 100,000 companies are at risk!• Go to OSHA.gov to keep up with the latest

li


rulings.

Combustible Dust Fines

• As part of its National Emphasis Program • As part of its National Emphasis Program, OSHA is targeting industries with a known combustible dust hazard.

• The following are fines issued recently by OSHA for combustible dust:• Plastics Manufacturer $133 500• Plastics Manufacturer—$133,500• Log Manufacturer—$215,000• Ohio LLC—$472,900• Food Processor—$1.1M

• Imperial Sugar—$8.8M (Largest fine in OSHA history!)


y )

d dCurrent OSHA Dust StandardsSome industry-specific standards already exist

b t t h ibut are not comprehensive.• 1910.22(a)(1)—Housekeeping, allowable

dust accumulationsdust accumulations• 1910.22(a)(2)—Housekeeping, allowable

dust accumulation on floors• 1910.178(c)—Classification in hazardous

environments• 1910 307 Hazardous Locations• 1910.307—Hazardous Locations• 5(a)(1)—General Duty• 1910.272—Grain Handling Standard


1910.272 Grain Handling Standard

d dCurrent NFPA Dust Standards• NFPA 68—Guide for Venting of Deflagrations• NFPA 85—Boiler and Combustion Systems

Hazards Code• NFPA 69—Standard on Explosion Prevention p

Systems• NFPA 499—Classification of Combustible Dusts• NFPA 654 Prevention of Dust Explosions from • NFPA 654—Prevention of Dust Explosions from

Manufacturing Processing, and Handling of Dust• NFPA 61—Prevention of explosions in agricultural

and food processing facilities• NFPA 484—Metal Dust Standard• NFPA 664—Wood Dust Standard


NFPA 664 Wood Dust Standard

Challenges of Combustible Dust

• Combustible dust, as a flash fire hazard, is highly unpredictable. Dust can collect in a wide variety of materials and consistencies.

• Even two scenarios with the exact same type, volume and density of dust, ventilation source, and ignition source may produce entirely different and ignition source may produce entirely different explosions at different times.

• Practical and cost-effective mitigation strategies can significantly diminish the possibility of an can significantly diminish the possibility of an explosion at your firm, including the use of flame resistant clothing.


hWhat Can Be Done?

• Multi-step safety processes will help to ensure that combustible dust is mitigated.

• Dust testing adequate housekeeping • Dust testing, adequate housekeeping, communication, training, and use of personal protective equipment (PPE) can all be used to ensure that combustible dust is kept at bay.

• No mitigation strategy will ensure that dust will be 100% prevented It is safest to follow will be 100% prevented. It is safest to follow as many precautions as possible.


Hazard Analysis by Lab Testing• Though hazard assessment under these

i t i diffi lt t b t t ti f circumstances is difficult at best, testing for dust explosiveness is both possible and practical.p

• No enforceable, set method for conducting hazard analysis.D b d f l NFPA• Dust can be tested for a general NFPA-classified “KST” number to estimate the anticipated behavior of dust deflagration, or p g ,explosion.

• KST testing may be a good way to assess combustible dust hazard


combustible dust hazard.

h dWhat does KST mean?

• When a facility opts to have testing When a facility opts to have testing performed, the following are analyzed:

1. Minimum Dust Concentration2. Minimum Ignition Temperature3. Minimum Ignition Energy

• KST is a generalized number used to • KST is a generalized number used to estimate the anticipated behavior of dust deflagration, or explosion.


How is KST Testing Conducted?

• Bulk samples of dust material in plastic bottles Bulk samples of dust material in plastic bottles between 2-2.5 lbs are tested for a general NFPA-classified “KST” number.

• Samples of dust are taken from several locations, such as ceilings, ductwork, and corners.

• Labs assess the above factors to analyze the y“KST” number, or a dust’s approximate explosive power and explosive probability.


KST Categories & Explosiveness

EXPLOSION KST CharacteristicCLASS

ST 0 0 No explosion

ST 1 >0 and ≤ 200Weak Explosion

ST 2 >200 and ≤ 300Strong Explosiong p

ST 3 >300+Very Strong Explosion


y g p

Common Dusts & KST Values

Common Dusts KST Value

Aluminum Powder 400

Barley Grain Dust 240y

Charcoal 117

Cotton 24

Magnesium 508

Soap 111

S lph 151Sulphur 151

Tobacco 12

Wood Dust 102


Wood Dust 102

Case Studies


Combustible Dust Case Studies

Y F ilit St t D t Kill d I j d Reasons for Year Facility State Dust Killed Injured easo s oExplosion

Inadequate housekeeping,

1999Iron

Casting Foundry

MA Phenolic Resin 3 9

Poor ventilation, Poor oven

maintenance, Inadequate safety

equipmentequipment

1999 Electrical Generation MI Coal Dust 1 14

Lack of worker awareness, Inadequate

housekeepinghousekeeping

2002 Rubber Recycling MS Scrap Tire

Grindings 5 6

Lack of worker awareness,

Improper building t ti


construction

Combustible Dust Case Studies

Year Facility State Dust Killed Injured Reasons for Explosionp

2003Rubber Drug

dNC Polyethylene 6 38

No hazard assessment, No

hazard i iProducts communication,

Poor engineering

No hazard assessment. No

2003 Fiberglass Insulation KY Phenolic

Resin 7 37 hazard communication,

Poor building design

P i t

2008 Sugar Refinery GA Sugar 14 36

Poor equipment design,

Inadequate housekeeping,

Dust


accumulated over MEC

M ld Mill (MA)Malden Mills (MA)


F d Ri R (MI)Ford River Rouge (MI)


l i ( )Rouse Polymerics (MS)


W t Ph ti l (NC)West Pharmaceutical (NC)


Rubber Dust Explosion at West


CTA A ti (KY)CTA Acoustics (KY)


I i l S (GA)Imperial Sugar (GA)


I i l S I id tImperial Sugar Incident


Weak Explosions?

How explosive was the dust at the above facilities?

• Phenolic Resin: 129• Coal Dust: 129• Coal Dust: 129• Polyethelyne: 134• Sugar Dust: 138

Ti G i di 139• Tire Grindings: 139

• All of these industries were ST Category 1: g yWeak Explosion, yet all six explosions resulted in significant damage, injury, and worker death.


Mitigation Strategies


Mitigation: Communication is KeyWorkers are always the first line of defense in

preventing and mitigating fires and explosions preventing and mitigating fires and explosions.

“If the people closest to the source of the hazard are trained to recognize and prevent hazards associated with combustible dust in the plant, they can be instrumental in recognizing unsafe conditions, taking preventative action, and/or alerting management.” (OSHA, 2005).

Perhaps the most important component of hazard mitigation is raising employee awareness


awareness.

Mitigation: OSHA Recommendations

OSHA recommends guarding against the following:• Materials that can be combustible when finely

divided• Processes which use consume or produce Processes which use, consume, or produce

combustible dusts• Open areas where combustible dusts may

build upbuild up• Hidden areas where combustible dusts may

accumulate• Means by which dust may be dispersed in the

air• Potential ignition sources


• Potential ignition sources

Mitigation: NFPA Recommendations• Minimize escape of dust from process

equipment or ventilation systemsequipment or ventilation systems.• Use dust collection systems and filters.• Utilize surfaces that minimize dust Utilize surfaces that minimize dust

accumulation and facilitate cleaning.• Provide access to all hidden areas to permit

i iinspection.• Inspect for dust residues in open and hidden

areas at regular intervalsareas, at regular intervals,• Clean dust residues at regular intervals.• Use cleaning methods that do not generate


g gdust clouds, if ignition sources are present.

FR Clothing: Additional Protection

• No mitigation strategy will provide 100% No mitigation strategy will provide 100% protection against a combustible dust explosion for an at-risk firm.

• Choosing flame resistant clothing is an effective method to protect at-risk employees if primary mitigation strategies employees if primary mitigation strategies are economically or practically ineffective—and even if primary mitigation strategies areeffective and employers want to prevent or effective and employers want to prevent or minimize worker injury.


FR Clothing Reduces Injury

Wh fl h fi h d i i • Where any flash fire hazard exists, using flame resistant clothing is a common-sense method to significantly reduce the chance of g yworker injury in the event of an explosion.

• On top of preventing the added burn injury inherent in the melting and dripping of noninherent in the melting and dripping of non-flame resistant fabrics, the cost of flame resistant clothing is minimal compared to the devastation of a burn injury on a worker personally and economically.


FR Clothing: Voluntary Protection

• Though flame resistant clothing is not yet Though flame resistant clothing is not yet required for workers exposed to flash fire hazards, its procurement may be the last

d t i t t t t k and most important step a company can take to insure the lives of workers.

• Many companies exposed to flash fire have Many companies exposed to flash fire have already taken this preventative measure to avert worker injury, especially in the refinery industryindustry.

• OSHA may require FR clothing in its combustible dust ruling.


g

FR Industry ComparisonElectric Utility

Refinery Combustible DustUtility Dust

Hazard Arc Flash Flash Fire Flash Fire

Relative Accuracy of Hazard Analysis

High Low Low

Analysis

OSHA Regulated

Yes Maybe* (New interp of OSHA 1910.132 may require FR as of March 2010)

No

)

Use of PPE High High Low

Mitigation Simple Complex Complex


Mitigation Strategies

Simple Complex Complex

The Statistics: FR Works!

• The most serious injuries typically occur j yp yAFTER the flash fire, from non-FR fabric burning against the skin. N FR l thi b d lt i t th • Non-FR clothing burns and melts against the skin, increasing the risk of injury.

• Flame resistant clothing self-extinguishes Flame resistant clothing self extinguishes once the source of heat is removed.

• Until there is a unified, enforceable standard di thi h d l t li regarding this hazard, voluntary compliance

with the current recommendations is necessary to ensure worker safety.


y y

Flash Fire Incident Video


FR Clothing Requirements

• All flame resistant clothing must be tested for safety and durability.

• NFPA 2112 is the best FR Clothing standard to address flash fire hazards such as to address flash fire hazards such as combustible dust.

• NFPA 2112 says that flame resistant clothing must protect the wearer by, “not contributing to the burn injury of the wearer, providing a degree of protection to the providing a degree of protection to the wearer, and reducing the severity of burn injuries resulting from accidental exposure to h d oca bon flash fi es ”


hydrocarbon flash fires.”

Tests for FR in NFPA 2112• The Vertical Flame Test determines whether a

fabric will continue to burn after the source of fabric will continue to burn after the source of ignition is removed.

• The Three-Second Manikin Test is the test method for evaluating a garment’s flame resistance method for evaluating a garment s flame resistance using an instrumented manikin. A garment is exposed to a heat flux of 2.0cal/cm2.sec for three seconds. If the garment displays less than 50% seco ds t e ga e t d sp ays ess t a 50%total body burn, the fabric achieves a passing performance.

• The Thermal Protective Performance test (TPP). ( )The 2007 edition of NFPA 2112 requires the Thermal Protective Performance test to be performed both with the fabric against the sensor


and with a ¼” spacer.

Arc Flash Parallel: Proven Protection

• In the 1970s, before OSHA required utility , q yworkers to wear flame resistant clothing, an average of 9.5 burn accidents and 14.7 burn injures per 100 workers resulted in injures per 100 workers resulted in devastating personal and economic costs to utilities.

• After OSHA implemented 1910.269, the Standard for electric generation, transmission, and distribution in the 1990s worker burn and distribution in the 1990s, worker burn injury rates in the 2000s decreased to 4 accidents and 6.2 injures per 100 workers.


NFPA 654 - 2011 • “Operators shall wear flame-resistant garments as specified

in NFPA 2113 and any other personnel protective equipment in NFPA 2113 and any other personnel protective equipment required for protection against flash fire hazards during charging operations”

• “Operating Plans shall include the use of flame-resistant garments as specified in NFPA 2112 for all exposed personnel when the design dust mass / accumulation exceeds the threshold value determined per section 6.1”

• “Operating and maintenance procedures shall address • “Operating and maintenance procedures shall address personal protective equipment (PPE) for tasks involving or handling of combustible dust according to the following:

• PPE shall include flame resistant garments in accordance with the workplace hazard assessment required by NFPA 2113: and,

• Where a dust explosion hazard or flash fire hazard exists, flame resistant garments shall be required for all exposed personnel.


What Next? OSHA is Acting!

• OSHA will most likely consult current NFPA t d d i it f t b tibl d t standards in its future combustible dust

regulation.• Hefty fines will continue to be delivered for y

various violations of existing standards, especially the “General Duty Clause.”

• OSHA may require FR clothing as part of its OSHA may require FR clothing as part of its regulation.

• Voluntary adaption of known mitigation strategies will result in avoiding fines strategies will result in avoiding fines, maintaining productive working conditions, and keeping workers safe until the ruling is finalized


finalized.

Mitigation Strategies: Summary

• Company-wide hazard communication d t i i i kand training is key.

• Proper housekeeping, such as using a dust vacuum to collect dustvacuum to collect dust

• Proper building engineering (i.e. ensuring that dust cannot accumulate in unmonitored

)areas)• Proper ventilation systems• Removal or careful monitoring of potential • Removal or careful monitoring of potential

ignition sources• Use of personal protective equipment, such


p p q pas FR clothing, as a last line of defense

Last Line of Defense

• Flame resistant clothing is a secondary protective strategy providing protection from momentary burns and flames.

• FR has been proven a cost-effective and • FR has been proven a cost-effective and successful measure for employers to take in protecting their employees from thermal h d h dhazards in other industries.

• Even companies that implement all known mitigation strategies will find that cost-mitigation strategies will find that costeffective flame resistant clothing will offer peace of mind in the event that an explosion does occ


does occur.

Want to learn more?

• Sign up now for more information about:

• Combustible DustMiti ti St t i• Mitigation Strategies

• Current Standards• OSHA Activity• OSHA Activity• FR Clothing

• Tyndale will send you an email very soon with these resources so that you can learn more about this insidious hazard!


about this insidious hazard!

iQuestions?

Thank you for the opportunity to meet with you today!

R b Whi b P idRob Whittenberger, PresidentTyndale Company, Inc.

RWhittenberger@Tyndaleusa [email protected]


Documents

Protecting Workers from Combustible Dust with FR … s/EEI Fall 2010... · Protecting Workers from Combustible Dust with FR ... • Dust testing adequate housekeeping Dust testing,