OSHA has been stalled on the combustible dust rule-making process for many months, likely waiting on the recent elections, before moving forward. However, NFPA has not been idle.
NFPA has been working on combustible dust standards from several different fronts. It has made revisions to the existing NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids – 2013 Edition. It has published a new guide, and is in the development process of a new standard, 652 Standard on Combustible Dust, which is scheduled for publication in 2015.
The 2013 edition of NFPA 654 has recently been released, and the revision that directly relates to FR clothing is located in Chapter 11, section 11.2.2. This section states, “Operating and maintenance procedures shall address personal protective equipment (PPE), including flame-resistant garments, in accordance with the workplace hazard assessment required by NFPA 2113 …” Also in Chapter 6 section 184.108.40.206, under Hazard Assessment, it states, “Personnel exposed to a dust flash fire hazard shall be protected in accordance with 11.2.2.” These two new sections formally add the verbiage that was in the Temporary Interim Amendment issued back in March 2011. So companies are required to perform a hazard assessment and protect employees with FR garments if they have potential exposure.
Guide to Combustible Dust
NFPA also developed a new comprehensive guide that covers, in depth, the best practices and techniques for analyzing and mitigating combustible dust hazards.
Written by experts, this NFPA Guide explains the best practices and techniques for analyzing and mitigating risk on the job site through:
- – Clear, easy-to-understand discussion of topics and terms directly related to combustible dust standards referenced by OSHA in the 2008 National Emphasis Program (NEP) on combustible dusts, including NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids. For specific types of dust and industry processes, NFPA 61, NFPA 484, NFPA 655 and NFPA 664 are also included in the discussion, along with NFPA 68 and NFPA 69 on explosion protection and prevention measures referenced in the Guide.
- – Photographs from a wide array of environments — plus a 16-page, full-color insert.
- – Case studies explaining the lead-up and consequences of various types of dust events.
- – Flow charts, conversions and equations.
- – Details on developing audit and analysis programs.
In addition to the existing NFPA 654 and the new Guide, there is also a task group working on the development of a general standard on Combustible Dust NFPA 652. Within this new standard, there is a section on personal protective equipment Section 7.6. This section requires a hazard assessment based on NFPA 2113; where personnel is working in areas where there is a threat of exposure to a dust deflagration hazard, they must be provided with and wear FR garments. These FR garments are required to comply with NFPA 2112 and also NFPA 70E if there is an electric arc exposure potential.
Although OSHA has not yet published any rules/regulations regarding combustible dust, NFPA continues to move forward with standards designed to identify and mitigate combustible dust hazards and protect workers. Although the first line of defense is to mitigate the potential hazard, there are workers who risk exposure and, therefore, are required to wear FR garments.
As a reminder, the types of dust identified by OSHA as being likely to cause dust deflagrations, other fires or explosions include, but are not limited to:
- Metal dust, such as aluminum and magnesium
- Wood dust
- Coal and other carbon dusts
- Plastic dust and additives
- Other organic dust, such as sugar, flour, paper, soap and dried blood
- Certain textile materials
The industries that handle these combustible dusts include, but are not limited to:
- Food products
- Forest and furniture products
- Metal processing
- Tire and rubber manufacturing plants
- Paper products
- Wastewater treatment
- Recycling operations (metal, paper and plastic)
- Coal dust in coal handling and processing facilities
If your industry falls into one of these categories, you should probably start a process to determine if you have a potential problem waiting to happen and figure out a course of action. Eventually, OSHA will publish combustible dust regulations and being ahead of the curve will put you in a good position.