Combustible DustPreventing and Mitigating FireExplosions Hazards

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Combustible Dust-Preventing and Mitigating
Fire/Explosions Hazards

• Mike Lastie, CSP
• Wednesday 115 215
• Texas One

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Combustible 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

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Combustible 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.

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Combustible 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

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Combustible 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

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Key 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.

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Key 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.

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Key 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.

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Key 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.

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Causal Factors in Many Case Studies

• Housekeeping-Unsafe accumulation of combustible
  dust
• Lack of Hazard Recognition-Employees and
  managementunaware of dust explosionhazards

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Causal 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

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Combustible Dust Hazards

• Fires
• Explosions

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Necessary 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

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Necessary 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

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Necessary Elements for a Dust Explosion
Ignition
Fuel

Confinement
Dispersion
Oxygen
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Combustible 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

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Combustible 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

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Combustible 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

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Combustible DustStandards
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Combustible DustStandards
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Combustible DustStandards
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Combustible DustStandards
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Combustible DustStandards
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Combustible DustStandards
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Combustible 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.

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Combustible 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.

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Combustible 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)

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Combustible 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

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Combustible 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

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Combustible 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

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Suggested 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

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Key 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

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Key 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.

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Key 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.

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Key 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

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Key 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

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Questions Answers

• End of Presentation