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COMBUSTIBLE DUST
certified by one of the Nationally Recog- nized Testing Laboratories. Equipment that meets this requirement will be clearly labeled as being NRTL certified. You can access the current NRTL list and see what the labels look like on the OSHA website.11 ATEX is a European Union directive that covers equipment and protective systems intended for use in potentially explosive atmospheres.12 Since many equipment manufacturers operate in both the United States and Europe, many vacuum cleaners available here have an ATEX certification.
While this certification may denote a certain level of safety, there are a couple of things you need to keep in mind:
■ Some classes of ATEX certification are self-certified, meaning that no third- party testing or verification is required.
■ OSHA states13 that products used in the United States must have “the specific mark of one of the NRTLs recognized to test and certify this type of product.”
Stephen Watkins is an Application Engineer with Nilfisk Inc.’s Industrial Vacuum Division.
REFERENCES
1. Combustible Dust Policy Institute. http://dustexplosions.blogspot.com/
2. National Fire Incident Reporting system. https://www.nfirs.fema.gov/
3. “About the National Fire Incident Reporting System.” U.S. Fire Administration. https://www.usfa.fema. gov/data/nfirs/about/
4. Combustible Dust National Emphasis Program. https://www.osha.gov/OshDoc/Directive_pdf/CPL_03- 00-008.pdf
5. “CSB Releases Final Investigation Report on Three Accidents at the Hoeganaes Iron Powder Facility in Gallatin, Tennessee.” U.S. Chemical Safety Board. http://www.csb.gov/csb-releases-final-investigation- report-on-three-accidents-at-the-hoeganaes-iron-powder-facility-in-gallatin-tennessee/
6. “OSH Act of 1970: SEC 5: Duties.” OSHA. https://www.osha.gov/pls/oshaweb/owadisp.show_ document?p_id=3359&p_table=oshact
7. OSHA letter. https://www.dol.gov/sites/default/files/newsroom/newsreleases/OSHA20162382a.pdf 8. “PA Mill Faces $195k OSHA Fines for Combustible Dust Hazards.” Powder Bulk & Solids. http://www.
powderbulksolids.com/news/PA-Mill-Faces-195k-OSHA-Fines-for-Combustible-Dust-Hazards-08-09-2016
9. NFPA 652: Standard on the Fundamentals of Combustible Dust. http://www.nfpa.org/codes-and- standards/all-codes-and-standards/list-of-codes-and-standards
10. “Making Sense of Combustible-Dust Hazard Analysis.” AICHE.org. https://www.aiche.org/resources/ publications/cep/2016/april/making-sense-combustible-dust-hazard-analysis
11. “Current List of NRTLs.” OSHA. https://www.osha.gov/dts/otpca/nrtl/nrtllist.html
12. “Equipment for potentially explosive atmospheres (ATEX.)” European Commission. http://ec.europa.
eu/growth/sectors/mechanical-engineering/atex_en
13. “Frequently Asked Questions.” Nationally Recognized Testing Laboratory Program FAQ. https://www.osha. gov/dts/otpca/nrtl/nrtl_faq.html
CSB CLOSES RECOMMENDATION FROM US INK INVESTIGATION
EBY JERRY LAWS
ffective March 24, 2017, the U.S. Chemical Safety Board changed the status of its Recommendation 2013-1-I-NJ-R7 to “Closed—Acceptable Action.” Is-
sued in January 2015 with the board’s final report on the US Ink/Sun Chemical Corporation explosion and flash fire in East Rutherford, N.J., on Oct. 9, 2012, injuring seven workers, the recommendation asked the companies to revise the Capital Appropriations/Asset Request (CAR) form procedure for new installations and modifications to existing equipment to require at minimum these things:
■ Process hazard analysis (PHA)
■ Management of change (MOC)
■ Review of engineering drawings for permits
■ Safety management of contractors
■ Training of plant operators based on applicable dust
collection system guidelines and standards, including NFPA 91 and NFPA 654
Three of the workers suffered third-degree burns in the incident, which occurred during start-up of a new dust col- lection system at the ink manufacturing facility as a mixture of hydrocarbons and combustible dusts accumulated in the ductwork and ignited, according to the board’s investiga- tion. The CAR form was filed by Sun Chemical’s engineering team before the new dust collection system was de- signed—company policy required a CAR if a project’s total
cost exceeded $350,000—but the board determined that company management provided inadequate oversight of the replacement project and recommended these changes.
According to CSB’s final report, the checkbox for a PHA or management of change was not checked in the environ- mental health and safety section of the CAR filed for this dust collection system, indicating that neither was neces- sary for the system.
In its summary of the changed status, the board report- ed that Sun Chemical now requires that all CARs complete management of change, a hazard review checklist, and, where applicable (such as when flammable or combustible materials are introduced), a process hazard analysis.
“Finally, Sun Chemical developed a contractor safety management program that requires the contractor to provide Sun Chemical with information relating to its safety programs and allows Sun Chemical to audit and oversee the contractor safety management program. In completing these actions, Sun Chemical improved its CAR program to ameliorate the safety and oversight gaps identified in the CSB investigation,” the summary stated.
The board determined that lack of adequate manage- ment oversight in the planning, design, installation, and commissioning of the dust collection system probably con- tributed to the explosion and fire. And its report found that the fire hazard and emergency training received by plant employees was inadequate.
Jerry Laws is the editor of Occupational Health & Safety.
44 Occupational Health & Safety | MAY 2017
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