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From my friend, Brian Edwards, whom I have found to have great wisdom when dealing with combustible dust challenges.

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Conversion Technology engineers to wear FRC when conducting Combustible Dust Hazard Analysis

Flame resistant clothing (FRC) has been used for years in a number of industries to protect workers from flash fires, arc flash, embers, molten metal, and other potential sources of ignition to clothing.  The reason FRC is so important is that many fatalities have occurred because a worker’s clothing has caught on fire, exposing him/her to burning heat for a much longer time than would have occurred during the initial event (e.g. arc flash, vapor flash fire).

When looking at burn victims, there is a “magic” number – well, more accurately, a statistically relevant number – that predicts if the victim has a better chance of surviving … or dying.  This number is 50%.  Meaning, when the percent of a person’s body with 2nd or 3rd degree burns exceeds 50%, it is more likely that he will not survive.  FRC is extremely valuable in minimizing the percentage of 2nd/3rd degree burns for a person exposed to a flash fire or other short duration thermal exposure (less than 3-4 seconds). It does this not by providing insulation, rather, FRC resists catching on fire and becoming a source of burns itself.

As I mentioned earlier, a number of industries have adopted FRC as standard issue clothing – think petroleum refining and steel mills. One area where the need for FRC has become more apparent is for workers potentially exposed to combustible dust flash fires. When combustible dust is suspended in air in sufficient concentrations, and there is a source of ignition, a flash fire very similar to that of a vapor fire can occur. Workers in the vicinity can be exposed to both the initial event, but they also stand the risk of having their clothing ignite.  Because of this, NFPA 654 – Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids – now details the need for considering FRC as part of the hazard analysis conducted for an industrial plant where combustible dust is present.

At Conversion Technology, Inc. (CTI), our safety and environmental engineers have long wore FRC when it was required by our client’s facility. However, we have noticed that a large percentage of industrial facilities with potential combustible dust hazards have not considered FRC in their Personal Protective Equipment (PPE) hazard assessment. Therefore, we have decided that regardless of the Client’s requirements, we will require all engineers conducting combustible dust hazard assessments to wear FRC while on site.

Not all facilities who process and handle combustible dust will need to require FRC.  Part of CTI’s scope of work while conducting a combustible dust hazard assessment is to determine whether or not FRC is needed. However, until we have made that determination, our engineers will not know if they will be walking into an area where they are potential exposed to a dust fire hazard.  This unknown is why we have made this decision.

We hope that all facilities that handle and process combustible dust will make the effort to determine if workers are potential exposed to combustible dust fire and explosion hazards. Conversion Technology is available to help those that need assistance in making this determination.

About mavity2012

I am a Senior Partner operating out of the Atlanta office of Fisher & Phillips LLP, one of the Nation’s oldest and largest management employment and labor firms. My practice is national and keeps me on the road or in one of our 28 offices about 50 percent of the time. I created and co-chair the Firm's Workplace Safety and Catastrophe Management Practice Group. I have almost 29 years of experience as a labor lawyer, but rely even more heavily on the experience I gained in working in my family's various businesses, and through dealing with practical client issues. Employers tell me that they seldom meet an attorney who delivers on his promise to provide practical guidance and to be a business partner. As a result, some executives probably use different terms than “practical” to describe my fellow travelers in the profession. I don't enjoy the luxury of being impractical because I spend much of my time on shop floors and construction sites dealing with safety, union and related issues which are driven by real world processes and the need to protect and get the most out of one's most important business assets ... its employees. That's one of the reasons that I view safety compliance as a way to also manage problem employees, reduce litigation and develop the type of work environment that makes unions unnecessary. Starting out dealing with union-management challenges and a stint in the NLRB have better equipped me to see the interrelationship of legal and workplace factors. I am proud also of my experience at Fisher & Phillips, where providing “practical advice” is second only to legal excellence among the Firm’s values. Our website lists me as having provided counsel for over 225 occasions of union activity, guided unionized companies, and as having managed approximately 450 OSHA fatality cases in construction and general industry, ranging from dust explosions to building collapses, in virtually every state. I have coordinated complex inspections involving multi-employer sites, corporate-wide compliance, and issues involving criminal referral. As a full labor lawyer, I oversee audits of corporate labor, HR, and safety compliance. I have responded to virtually every type of day-to-day workplace inquiry, and have handled cases before the EEOC, OFCCP, NLRB, and numerous other state and federal agencies. At F & P, all of us seek to spot issues and then rely upon attorneys in the Firm who concentrate on those areas. No tunnel vision. I teach or speak around 50 times per year to business associations, bar and professional groups, and to individual businesses. I serve on safety committees at three states’ AGC Chapters, teach at the AGC ASMTC
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