Title: Combustible DustPreventing and Mitigating FireExplosions Hazards
1Combustible Dust-Preventing and Mitigating
Fire/Explosions Hazards
- Mike Lastie, CSP
- Wednesday 115 215
- Texas One
2Combustible DustIncidents
- Following three major dust explosions in 2003,
the Chemical Safety and Hazard Investigation
Board (CSB) initiated a study of dust explosions
in general Industry-West Pharmaceutical Services
(01/03)-CTA Acoustics, Inc. (02/03)-Hayes
Lemmerz International (10/03) - According to the CSB Investigation Report
Combustible Dust Hazard Study (11/06), there
were- 281 dust fires and explosions between 1980
and 2005- They claimed 119 lives and injured 718
people-They occurred in 44 states, in many
different industries and involved a variety of
different materials
3Combustible DustIncidents
- 82 new dust explosions has occurred between
January 2006 and July 2008 - Two of those 82 new dust explosions involved
Domino Sugar and Imperial Sugar - Based upon oral testimony of John S. Bresland,
Chairman and Chief Executive Officer of the CSB
before the U.S. Senate Committee - on Health, Education, Labor, and Pensions
Subcommittee on Employment and Workplace Safety
on July 29, 2008.
4Combustible DustIncidents
- There was an explosion at the Domino Sugar
refinery in Baltimore Maryland on November 2,
2007. - There were no fatalities- 3 employees
suffered minor injuries- Employees were
performing maintenance on a dust collector at the
time of the explosion - Maryland Occupational
Safety and Health Administration fined Domino
4,000 for allowing dust to accumulate in its
refinery which wasbelieved to be the cause of
the explosionbased upon a Baltimore Sun
newspaper report on July 26, 2008
5Combustible DustIncidents
- There was an explosion at the Imperial Sugar
refinery in Port Wentworth, GA on February 8,
2008. - There were 13 fatalities- 40 employees
suffered injuries including severe burns - OSHA
issued penalties of 5.06 MM for the companys
Port Wentworth refinery and 3.7 MM based upon an
inspection of the companys refinery in Gramercy,
LAfollowing the Port Wentworth explosion.-The
company was issued 69 Willfulviolations and 51
serious violations at thePort Wentworth refinery
and 49 Willfulviolations and 48 serious
violations at itsGramercy, LA refinery
6Key Findings From CSB Investigation Report
- The following are some of the key findings taken
directly from the CSB Investigation Report
Combustible Dust Hazard Study - No
Occupational Safety and Health Administration
(OSHA) standard comprehensively addresses
combustible dust explosion hazards in general
industry. -OSHAs Grain Facilities Standard has
successfully reduced the risk of dust explosions
in the grain industry. -Secondary dust
explosions, due to inadequate housekeeping and
excessive dust accumulations, caused much of the
damage and casualties in recent catastrophic
incidents.
7Key Findings From CSB Investigation Report
- The following are key findings taken directly
from the CSB Investigation Report Combustible
Dust Hazard Study - Consensus standards
developed by the National Fire Protection
Association (NFPA) that provide detailed guidance
for preventing and mitigating dust fires and
explosions are widely considered to be effective
however, these standards are voluntary unless
adopted as part of a fire code by a state or
local jurisdiction, and have not been adopted in
many states and local jurisdictions, or have been
modified. among jurisdictions that have
adopted the fire codes, enforcement in industrial
facilities is inconsistent, and, in the states
the CSB surveyed, fire code officials rarely
inspect industrial facilities.
8Key Findings From CSB Investigation Report
- The following are key findings taken directly
from the CSB Investigation Report Combustible
Dust Hazard Study -The OSHA Hazard
Communication Standard (HCS) inadequately
addresses dust explosion hazards, or safe work
practices and guidance documents, in Material
Safety Data Sheets (MSDSs). -41 of the 140
combustible powder MSDSs the CSB surveyed did not
warn users about explosion hazards, and only 7
referenced appropriate NFPA dust standards to
prevent dust explosions.
9Key Findings From CSB Investigation Report
- The following are key findings taken directly
from the CSB Investigation Report Combustible
Dust Hazard Study -The voluntary American
National Standards Institute (ANSI) consensus
standard for MSDS format and preparation, ANSI
Z400.1, inadequately addresses combustible dust
explosion hazards, and does not define
combustible dust or discuss the need to include
physical properties for combustible dusts.
-Training programs for OSHA compliance officers
and fire code inspectors generally do not address
recognizing combustible dust hazards.
10Causal Factors in Many Case Studies
- Housekeeping-Unsafe accumulation of combustible
dust - Lack of Hazard Recognition-Employees and
managementunaware of dust explosionhazards
11Causal Factors in Many Case Studies
- Lack of Ventilation or Engineering
Controls-Missing or improperly maintained dust
collectors - Improper Maintenance -Leaks which allows dust
to escape - Lack of Safety Devices
12Combustible Dust Hazards
13Necessary Elements for a Dust Fire
- Basic Fire Triangle-Fuel Combustible Dust
/Organic Material or Powder Metal of correct
particle size (lt400 micron)-Ignition Source
Heat, static charge, open flame-Oxygen Air
14Necessary Elements for a Dust Explosion
- All of the three fire elements plus the
simultaneous presence of the following two
elements-Dispersion and concentration (LEL 20
60 g/m3 or UEL 2 6 kg/m3 )-Confinement
Inside of a structure
15Necessary Elements for a Dust Explosion
Ignition
Fuel
Confinement
Dispersion
Oxygen
16Combustible DustStandards
- OSHA issued its National Emphasis Program (NEP)
for Combustible Dust on October 18, 2007.-
Primary purpose was to increase enforcement
activities and focus on specific industries that
have experienced frequent combustible dust
incidents- Each OSHA Area Office was to conduct
at least one inspection per fiscal year - The NEP for Combustible Dust (CPL-03-00-008) was
reissued on March 12, 2008 following the Imperial
Sugar explosion-Each OSHA Area Office is to
conduct at least four inspection per fiscal year
17Combustible DustStandards
- The dust addressed in the NEP for Combustible
Dust include but are not limited to the
following- Metal dust such as aluminum and
magnesium- Wood dust- Coal and other carbon
dusts- Plastic dust and additives-
Biosolids- Other organic dust such as sugar,
flour, paper, soap and dried blood-Certain
textile materials
18Combustible DustStandards
- There are two main list in the NEP for
Combustible Dust that OSHA Area Offices will
utilize in scheduling inspections- Appendix D-1
(Industries with More Frequent and/or High
Consequence Combustible Dust Explosions/Fires)-A
ppendix D-2 (Industries that may have a Potential
for Combustible Dust Explosions/Fires) - They must schedule 3 inspections from Appendix
D-1 and 1 inspection from Appendix D-2
19Combustible DustStandards
20Combustible DustStandards
21Combustible DustStandards
22Combustible DustStandards
23Combustible DustStandards
24Combustible DustStandards
25Combustible DustStandards
- Recent NEP Inspection (Date of article - 3/11/09)
- U.S. Department of Labor's OSHA cites Thomson,
Ga., automotive parts supplier, H P Pelzer, with
135,000 in proposed penalties - ATLANTA -- The U.S. Department of Labor's
Occupational Safety and Health Administration
(OSHA) is issuing citations for 24 occupational
health and safety violations against H P Pelzer
Automotive Systems Inc. in Thomson, Ga. The
agency is proposing 135,000 in penalties against
the company. - A health inspection of the plant revealed seven
serious violations resulting in penalties of
32,500. The health violations include the
company allowing combustible dust to accumulate,
not protecting employees from noise hazards and
exposing employees to an airborne concentration
of formaldehyde.
26Combustible DustStandards
- The company is also being cited with a repeat
health violation and a 25,000 penalty for using
high pressure compressed air to clean equipment
resulting in clouds of resin dust, and a second
repeat violation with a 25,000 penalty for
exposing employees to high concentrations of
airborne particulates. This location had been
cited for similar violations after inspections
conducted in 2006. - OSHA is issuing an additional 15 citations with
proposed penalties of 52,500 after a subsequent
safety inspection found serious violations
including lack of guardrails, improper
lockout/tagout procedures to prevent accidental
start-up of machinery, electrical hazards and
employees using defective equipment. - "OSHA conducted this inspection as part of its
national emphasis program on combustible dust,"
said Gei-Thae Breezley, director of OSHA's
Atlanta-East Area Office. "No employee needs to
risk their health and their life by working under
these conditions." - Note This article was obtained from OSHAs
website.
27Combustible DustStandards
- Remember no consensus OSHA standards for
combustible dust - 1910.22(a)(1) Housekeeping-Accumulations of
dust exist in places of employment , passageways
and service which pose an explosion hazard - 1910.22(a)(2) Housekeeping-Accumulations of
dust exist on floors of workrooms which pose an
explosion hazard - Subpart E (Egress)
28Combustible DustStandards
- 1910.178 (c) Classification in Hazardous
Environments - 1910.307 (Hazardous Locations)-Electrical
equipment not of the right design - 5(a)(1) General Duty-Dust within dust
collection system or other containers such as
mixers pose - Reference NFPA Standards
29Combustible DustStandards
- Listing of Referenced NFPA Standards in NEP for
Combustible Dust-NFPA 654, Standard for the
Prevention of Fires and Dust Explosions from the
Manufacturing, Processing, and Handling of
Combustible Particulate Solids-NFPA 61,
Standard for the Prevention of Fires and Dust
Explosions in Agricultural and Food Processing
Facilities-NFPA 484, Standard for Combustible
Metals, Metal Powders, and Metal Dusts-NFPA
664, Standard for the Prevention of Fires and
Explosions in Wood Processing and Woodworking
Facilities
30Combustible DustStandards
- Listing of Referenced NFPA Standards in NEP for
Combustible Dust-NFPA 68, Guide for Venting of
Deflagrations-NFPA 85 Boiler and Combustion
Systems Hazards Code-NFPA 69, Standard on
Explosion Prevention Systems-NFPA 499,
Recommended Practice for the Classification of
Combustible Dusts and of Hazardous (Classified)
Locations for Electrical Installations in
Chemical Process Areas
31Suggested References
- 1. OSHA Grain Handling Standard
(1910.272)-Emergency Action Plan-Hot Work
Permit-Entry into Bins, Silos and
Tanks-Contractors-Housekeeping (Dust
Accumulations/Emissions)-Filer
Collectors-Preventative Maintenance2. CSB
Combustible Dust Hazard Study3. OSHA Safety and
Health Information Bulletin (October 1998) Dust
Explosion Hazard in Certain Textile Processes4.
OSHA Safety and Health Information Bulletin (July
2005) Combustible Dust in Industry Preventing
and Mitigating the Effects of Fire and
Explosions
32Key Factors In PreventingDust Explosions
- Key factors addressed in OSHAs SHIB July 2005
- Perform a hazard assessment of your facilityto
assess potential for dust explosions. Look for
-Materials that can be combustible when finely
divided-Processes which use, consume, or produce
combustible dusts-Open areas where combustible
dusts may build up-Hidden areas where
combustible dusts may accumulate (i.e. ceilings,
duct work, etc.)-Means by which dust may be
dispersed in the air-Potential ignition sources
33Key Factors In PreventingDust Explosions
- Dust Control - Implement a hazardous dust
inspection, testing, housekeeping, and control
program- Use proper dust collection systems and
filters- Minimize the escape of dust from
process equipment or ventilation systems- Use
surfaces that minimize dust accumulation and
facilitate cleaning- Provide access to all
hidden areas to permit inspection- Inspect for
dust residues in open and hidden areas at regular
intervals- If ignition sources are present, use
cleaning methods that do not generate dust
clouds- Use only vacuum cleaners approved for
dust collection - Locate relief valves away from
dust deposits.
34Key Factors In PreventingDust Explosions
- Ignition Control - Use appropriate electrical
equipment and wiring methods- Control static
electricity, including bonding of equipment to
ground- Control smoking, open flames, and
sparks- Control mechanical sparks and friction-
Use separator devices to remove foreign materials
capable of igniting combustibles from process
materials- Separate heated surfaces from dusts-
Separate heating systems from dusts- Select and
use industrial trucks properly- Use cartridge
activated tools properly- Use an equipment
preventive maintenance program.
35Key Factors In PreventingDust Explosions
- Injury and Damage Control Methods - Separation
of the hazard (isolate with distance)-
Segregation of the hazard (isolate with a
barrier)- Deflagration isolation/venting-
Pressure relief venting for equipment- Direct
vents away from work areas- Specialized fire
suppression systems- Explosion protection
systems- Spark/ember detection for suppression
activation- Develop an emergency action plan-
Maintain emergency exit routes
36Key Factors In PreventingDust Explosions
- Training and Educating Employees on Combustible
Dust Hazards-Safe work practices applicable to
their job tasks-Overview of dust hazard
assessments of the site-Overview of dust and
ignition control procedures at the worksite
-Proper use of fire extinguishers on combustible
dust fires-Emergency evacuation procedures
37Questions Answers