Has Combustible Dust Been Swept Under the Rug?
Combustible dust has not been in the headlines as much recently but there is still activity going on behind the scenes and accidents occurring on a regular basis. Before getting into the current status, let’s take a brief look at the activity in the past few years.
Most of those following the combustible dust safety activities recall the 2008 re-issuance of the OSHA Combustible Dust National Emphasis Program (NEP) shortly after the Imperial Sugar explosion that killed 14 people and injured dozens more. That accident and the reissued NEP spurred more activity in OSHA area offices. Part of that activity was to start conducting more frequent inspections, for combustible dust hazards in those industries most susceptible. That included industries that produce wood dust, metal dust, coal dust, plastic and rubber dust, organic dusts (sugar, flour, paper, soap etc.) and certain textile materials. This was followed in early 2009 by House Resolution 849 which called for OSHA to write a combustible dust standard/regulation. The process continued later in 2009 by OSHA initiating an Advanced Notice of Proposed Rulemaking which serves to solicit and receive comments on the subject. Also later in 2009 and through the middle of 2010, OSHA held several stakeholder meetings to get input from interested parties. Those attending include companies potentially affected by rulemaking, industry experts and those actually affected by recent accidents. OSHA has continued to collect information, including holding an expert forum in May of 2011 to add to its base of information for the rulemaking process. Their next step is a review process as required by the Small Business Regulatory Enforcement Fairness Act (SBREFA). Part of this process is to attempt to identify the economic impact of a new rule. This process was scheduled to be completed by April 2011, but has been delayed until a yet-to-be established date in 2012.
While OSHA continues to move slowly in the rulemaking development process, accidents continue to occur. There have been over 30 OSHA reported accidents in 2011, where fines have been proposed for hundreds of thousands of dollars. This includes a Chemical Safety Board press release in January of their investigation into three separate combustible dust accidents within one facility, over a five month period. These accidents resulted in 5 deaths and left several other workers with severe burn injuries.
Recent activity from NFPA includes the issuance of a Temporary Interim Amendment for NFPA 654 (Standard for the Prevention of Fire and Dust Explosions from Manufacturing, Processing, and handling of Combustible Particulate Solids) in the spring of 2011. This TIA included the addition of section 6.1.7 which states “Personnel exposed to a dust deflagration hazard shall be protected in accordance with 11.2.3.” Section 11.2.3 goes on to state “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.” The addition of sections on PPE recognizes that there may be personnel exposed to a combustible dust hazard and having them wear flame-resistant clothing based on a hazard assessment may be appropriate.
Besides the OSHA rulemaking process and the NFPA standards development, another behind the scenes activity taking place is the ASTM F23 (Technical Committee on Personal Protective Clothing and Equipment) task group working on a combustible dust guideline. This guide is being developed to serve as a reference guide for employers and safety personnel who are conducting research on the combustible dust hazard and the use of flame and thermal resistant clothing for protection from this hazard. There are numerous NFPA standards and OSHA regulations that address various combustible dust hazards and workplace hazards in general. However, the group felt there was a need to publish a reference guide where the most common documents regarding this hazard could readily be found, making combustible dust research easier. The content of the guide is scheduled to be reviewed and hopefully finalized during the ASTM F23 meeting in late January. If the guideline content is approved by the task group, it will be submitted for a vote later in the year by the full committee.
This ASTM guideline doesn’t take the place of an OSHA regulation or an NFPA standard but it could make finding the right regulation or standard a bit easier.