OSHA and Combustible Dust

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OSHA and Combustible Dust

• Richard E. Fairfax, CIH
• Occupational Safety Health Administration
• Director Enforcement Programs

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OSHA History

• 1970s, 1980s, 1990s, and 2000s OSHA had
  investigated and cited for combustible dust
• Grain Handling OSHA standard 1910.172
• Part of Agencys Strategic management Plan
• NEP proposed in early 2000s

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OSHA History

• Region III Local Emphasis Program (LEP) on
  Combustible Dust October 2004 through September
  2007
• 97 inspections conducted under this LEP
• Spring of 2006 OSHA began developing a national
  Emphasis Program (NEP) on combustible Dust

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OSHA History

• November 2006 CSB issued a report on their
  Combustible Dust hazard Study
• OSHA Recommendations
• Issue a standard
• Revise Hazard Communication Standard
• Communicate to European Union on GHS for
  Combustible Dust
• Provide Training
• Implement a NEP

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OSHA History

• October 2007 OSHA launches its Combustible Dust
  NEP
• Focus facilities that generate or handle
  combustible dust which pose a deflagration/explosi
  on hazard
• Winter 2008 Imperial Sugar Dust explosion
• March 2008 OSHA revises combustible dust NEP to
  better focus on most hazardous industries

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Combustible Dust

• Industries which generate or handle combustible
  dust
• Agriculture
• Chemical
• Textile
• Forest products
• Furniture products
• Wastewater treatment

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Combustible Dust

• Industries which generate or handle combustible
  dust (cont.)
• Metal processing
• Paper products
• Pharmaceuticals
• Metal, paper, plastic recycling

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Top Ten Industries Inspected under NEP
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OSHA Training

• Over 350 compliance officers trained on PSM with
  combustible dust being a component
• 150 compliance officers have reseived specific
  combustible dust training
• Approximately 1400 state and federal compliance
  officers received webinar refresher training

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Guidance Products

• OSHA field offices conducted outreach and
  training
• 2005 OSHA issued a Safety and Health Information
  Bulletin on combustible dust (SHIB)
• Following Imperial Sugar OSHA mailed the SHIB to
  employers identified as potentially at high risk

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Guidance Products

• Combustible Dust Web page
• OSHA published a safety alert on combustible dust
  as well as a poster

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Applicable Standards

• Existing OSHA Standards
• 1910.22 housekeeping
• 1910.38 emergency action plans
• 1910.94 ventilation
• 1910.119 process safety management
• 1910.269 electric power generation
• 1910.272 grain handling facilities

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Applicable Standards

• Existing OSHA Standards (cont)
• 1910.307 hazardous locations
• 1910.1200 hazard communication
• Section 5(a)(1) General Dusty Clause
• Applicable ANSI and NFPA standards

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Combustible Dust Inspection Data

• November 1, 2007 March 6, 2009

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Inspections Conducted
813 Total Inspections
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Total Violations Issued
3,662 Total Violations
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Total Violations Cited As Serious
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Total Violations Cited As S,W,R,FTA, Unclass
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Avg. Number Violations Issued Per Initial
Inspection
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Avg. Penalty Per Serious Violation
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Inspections In-Compliance(Insps W/O Violations
Closed)
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Contest Rate (through March 6th)

• 665 Inspections
• 45 inspections contested
• Contest rate is 6.8

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Combustible Dust Violations

• 5(a)(1) Violations
• Housekeeping violations
• Electrical Violations

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Other Violations found under the Combustible Dust
NEP

• Powered Industrial Truck
• Hazard Communication
• Personal Protective Equipment
• Lockout/tagout
• Machine Guarding
• Means of Egress

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Combustible Dust Related Violations
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General Duty Clause Violations

• Baghouse dust collectors (at several facilities)
  were located inside a building without proper
  explosion protection systems, such as explosion
  venting or explosion suppression systems.
• Deflagration isolation systems were not provided
  to prevent deflagration propagation from dust
  collectors to other parts of the plant.
• The rooms with excessive dust accumulations were
  not equipped with explosion relief venting
  distributed over the exterior walls and roofs of
  the buildings.

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General Duty Clause Violations

• The horizontal surfaces such as beams, ledges and
  screw conveyors at elevated surfaces were not
  minimized to prevent accumulation of dust on
  surfaces.
• Air from the dust collector was recycled through
  ductwork back into the work area. This was found
  at several facilities.
• 6. Legs of bucket elevators were not equipped
  with explosion relief venting.
• 7. Explosion vent on bucket elevators were
  directed into work areas and not vented to a
  safe, outside location away from platforms, means
  of egress, or other potentially occupied areas

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General Duty Clause Violations

• 8. Equipment (such as grinders and shakers) were
  not maintained to ensure that they were dust
  tight, thus combustible dust would leak into the
  surrounding area.
• 9. Pulverizer were not provided with explosion
  venting or deflagration suppression systems.
• Ductwork from the dust collection system to other
  areas of the plant were not constructed of
  metal.
• Employees were using electric grinder(s) on a
  duct entering a baghouse style dust collector
  without a hot work permit system.
• Open flames from a propane heater for comfort
  heating were in an area where agricultural
  products were ground

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OSHA Findings Under the NEP

• Hazardous levels of dust accumulations in
  workplaces due to poor housekeeping
• Process equipment such as grinders, ventilation
  ducts, shakers, baghouses, and bagging equipment
  not designed or maintained to keep dust out of
  surrounding areas

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OSHA Findings Under the NEP

• Electrical equipment and vacuums not approved for
  locations handling combustible dust
• Powered industrial trucks not approved for
  locations handling combustible dust
• Hot work performed in dust handling locations
  without hot work procedures

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OSHA Findings Under the NEP

• Heating appliances with open flames used in dust
  handling or generating areas
• Lack of preventative maintenance on mechanical
  equipment creating heat and friction
• Baghouses located inside buildings without proper
  explosion protection systems

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OSHA Findings Under the NEP

• Dust work lacking in venting or explosion
  suppression systems
• Deflagration isolation systems not provided
• Rooms with no explosion releif systems
• Horizontal surfaces not minimized

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OSHA Findings Under the NEP

• Explosions vents or suppression systems not
  provided on hoppers, silos, bucket elevators, and
  dust collectors
• Baghouses located indoors
• Explosion venting directed into work areas rather
  than to the outside

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Future Regulation

• Stay tuned
• OSHA without an Assistant Secretary so no
  decisions have been made

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QUESTIONS..

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