Page 46 - Occupational Health & Safety, May 2017

COMBUSTIBLE DUST
What You Don’t Know About Combustible Dust, But Should
By understanding the risks of this hazard and the regulations surrounding it, you can better equip your facility to prevent “near misses” so they never turn into catastrophic explosions. BY STEPHEN WATKINSC
ombustible dusts are like computer viruses: Most people know they’re out there but don’t completely understand them. This makes it easy to underestimate the risks
and fail to take the necessary precautions. As a result, when a severe incident occurs, it can be devastating.
In talking with people across the manufacturing spectrum, we’ve found that there are a lot of miscon- ceptions about combustible dust, especially concern- ing its risks, the laws surrounding it, and what com- panies need to do to protect themselves. Here are five things you probably don’t know about combustible dust . . . but should.
1. Combustible dust causes fires in facilities every day.
We tend to hear only about big combustible dust explosions, the ones that result in injuries or fatali- ties, or at least significant penalties for companies. These major catastrophes, however, don’t provide a complete picture. In 2012, the Combustible Dust Pol- icy Institute1 analyzed data from the Department of Homeland Security’s National Fire Incident Report- ing System (NFIRS).2 They found that, in 2011 alone, there were more than 500 combustible dust related fires and explosions, covering many industrial sectors. The majority of these incidents were classified as “near misses,” meaning the companies just got lucky.
Of course, these 500+ incidents are just the ones in the NFIRS database. This comprises only about 75 percent of all reported fires.3 There are also undoubt- edly many fires that go unreported.
Combustible dust causes fires in facilities all of the time. Every one of these incidents has the potential to become a catastrophe. Companies that don’t rec- ognize these risks are, quite literally, playing with fire.
2. These incidents are entirely preventable.
If that first point was alarming, this one will help you breathe a little easier. While dust is a fact of life in nearly all manufacturing facilities, it never needs to reach the point of combustion.
Dust becomes a fire risk only when it accumulates. In its Combustible Dust National Emphasis Program,4 OSHA recommends not letting dust accumulate more than 1/32 of an inch (about the thickness of a paper- clip) over more than 5 percent of the facility floor.
Based on its investigations of combustible dust incidents, the U.S. Chemical Safety Board has con-
cluded they are entirely preventable. Following three accidents that claimed five lives at a powdered met- als plant, then-CSB Chairperson Rafael Moure Eraso5 urged that “no more lives should be lost from these preventable accidents.” Manufacturers can reach that goal by implementing proper dust control and house- keeping measures.
3. You can be cited for combustible dust viola- tions, even though there’s no OSHA standard (yet). OSHA doesn’t currently have a combustible dust
standard, though one is widely expected next year. But that doesn’t mean manufacturers should wait until next year to start thinking about the issue. Under the Combustible Dust National Emphasis Program, OSHA can issue fines for violations under 18 different standards. That includes 29 CFR 1910.22, the main housekeeping standard. You can also be cited under the General Duty Clause,6 which is a catch-all for rec- ognized hazards not specifically addressed in OSHA standards. Just last month, OSHA issued $5,000 in combustible dust penalties7 to an Atlanta plastics recycler. And that’s nothing compared to the nearly $200,000 in fines8 the agency handed to a Pennsylva- nia mill for willfully failing to protect workers from
combustible dust hazards, among other violations. OSHA relies on the National Fire Protection Asso- ciation to determine best practices for fire prevention. Just last year, the NFPA released NFPA 652: Standard on the Fundamentals of Combustible Dust.9 If you want to avoid combustible dust incidents and OSHA penalties, complying with this standard is a great
place to start.
4. You’re required to have your dust tested, even if you’ve never had a problem.
We commonly encounter the misconception that facilities that have never had a problem have nothing to worry about; this couldn’t be further from the truth.
NFPA 652 requires all facilities that process, han- dle, convey, or manufacture potentially combustible dust to have their dust tested and keep the results on file. This is required even if your type of dust has no his- tory of causing an incident. You can get your dust test- ed through either OSHA or a private lab. Depending on the results, you may then be required to perform a Dust Hazard Analysis to assess the hazards and risks of each operation that produces combustible dust.10
The takeaway here is that ignorance is no excuse. And it could cost you big time. By getting your dust tested now, you can avoid potential incidents and cita- tions in the future.
5. The housekeeping equipment you use in com- bustible dust environments must meet certain re- quirements.
OSHA requires all equipment to be tested and
42 Occupational Health & Safety | MAY 2017
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