Those of you who know me well are aware that I have worked with hundreds of plants in their combustible dust compliance efforts and have been involved with a number of explosion/deflagration fatalities, including the catastrophic explosion at the Imperial Sugar plant in Port Wentworth, Georgia.
- It doesn’t matter that there is not yet a specific general duty standard
Although there is still no general industry combustible dust standard, OSHA has issued hundreds of citations against employers in numerous industries. More importantly. potentially dangerous conditions do not lat dormant simply because of a lack of an applicable OSHA vertical standard.
- Do you know if you are affected? Most don’t….
Regardless of your industry, if you have dust collection systems, accumulation of product-related dust, fit into certain NAICS or SIC codes, or have MSDS’s indicating a possibility of explosion or deflagration, you should at least consider whether you may need to address housekeeping, fugitive dust release, or technical compliance issues with a dust collection system.
Every setting seems a bit different, so do not assume that because a similar plant has no issues, neither do you. Likewise, a history of no problems means little. five elements are necessary for an event and your modification of a collection system or enclosure of a conveyor to protect food safety may provide a missing element , such as ignition source, oxygen, containment or the correct particle size and mix.
- One size solution does not fit all and may cost you unnecessary millions.
NFPA standards are the recognized guidance but are not “the law.” OSHA applies these standards in a fairly prescriptive way during inspections because no compliance officer or expert could conduct an adequate evaluation in the scant six months provided OSHA. You need one of the experts who are experienced in conducting a Process Hazard analysis (PHA) and determining the most effective, practical and cost-effective way to protect your employees, product and facilities. Likewise, the legal issues and the often long abatement periods really suggest the need for one of us nerds who handle many combustible dust cases.
Compliance can involve simple improvements in housekeeping or time-consuming million dollar changes to each plant. And of course, once you are aware of a potential hazard at one site, how do you address the other sites without appearing negligent or acting willfully? The abatement and improvement may take more than a year. It is not a fast process to find the right experts, test, conduct a PHA, select the best contractors, and then make changes which may necessitate plant shutdowns.
I have attached a link to an article by a very fine expert with whom I have worked. The Article was selected by ASSE as the “best of the best:” http://www.conversiontechnology.com/brochures/SafelyMade_V03N01_CTI.pdf
Remember… there is no such thing as a minor combustible dust explosion and deflagration.