Focus 2007 - No. 9

OSHA’s Combustible Dust National Emphasis Program

David E. Kaelin Sr., Senior Process Safety Specialist

The Occupational Safety and Health Administration, OSHA, has issued a directive (CPL 03-00-006) effective 10/18/07 initiating a Combustible Dust National Emphasis Program (NEP). This program will require OSHA offices to begin inspections of sites that handle combustible dusts specifically targeting dust explosion hazards.

Previously the US Chemical Safety and Hazard Investigation Board (CSB) had found that “...combustible dust explosions are a serious hazard in American industry, and ... existing efforts inadequately address this hazard” (ref: “Investigation Report Combustible Dust Hazard study” U.S. Chemical Safety and Hazard Investigation Board, Report N0. 2006-H-1, November 2006) The CSB study examined the record and literature to assess the magnitude of the dust explosion hazard and found that 281 combustible dust incidents were reported in the 25 year period ending in 2005. These incidents were responsible for 119 fatalities, 718 injuries and millions of dollars in lost facilities and productivity.

You are a target of the OSHA National Emphasis Program (NEP) if:

You are covered by OSHA,

You handle/process combustible dusts and powders including (but not limited to):

• Metal dust such as aluminum and magnesium,

• Wood dust,

• Coal and other carbon dust,

• Plastic dust and additives,

• Biosolids,

• Other organic dusts such as sugar, paper, soap and dried blood,

• Certain textile materials

OSHA is creating an all inclusive listing of facilities that handle combustible dusts from its facility classification lists including specific Standard Industrial Classification (SIC), and North American Industry Classification System (NAICS) codes. These applicable classification codes are provided in a Table included in the OSHA NEP document; a download is available on the Chilworth Technology Inc. website.

Many types of industrial activities will be listed including: chemicals, pharmaceuticals, textiles, agriculture, forest and furniture products, metal processing, tire and rubber manufacturing, coal dust and recycling operations.

When inspecting a site as part of the NEP, OSHA inspectors will focus on using specific guideline documents from the National Fire Protection Association, NFPA (NFPA 68, 69, 85, 484, 499, 654, and 664) and FM Global safety data pamphlet FM 7-76. These NFPA codes and standards were discussed in a previous Chilworth Technology Inc. Focus article available on our website. Your knowledge and good faith application of these standards will be critically important to the NEP inspection.

OSHA Combustible Dusts NEP Inspection and Citation Procedures

The procedures include:

Assessment of the combustible dust threat to employees

• Are the dust and management practices hazardous?

• What is the site history of fires involving dust?

• Does the MSDS indicate a dust explosion hazard?

• Are accumulations hazardous?

Collection of samples of combustible dusts for laboratory analysis

• From high places

• From floors and equipment surfaces

• From within ductwork

Audit of dust management practices and equipment including dust collectors, ductwork, and other dust containers.

Audit of room safeguards

Audit of ignition source management

Citation of facilities based on the above and test results using one or more of the following OSHA standards:

• General Duty Clause Section 5(a)(1) Provide a site free of recognized explosion hazards.

• If grain facility: 29 CFR 1910.272 grain handling standard

• Ventilation standard 1910.94 covering abrasive blasting, grinding, polishing and buffing operations

• Housekeeping if not a grain facility, 29 CFR 1910.22 or 1910.176 for storage areas

• If coal handling: 29 CFR 1910.269(v)(11)(vii)

• Personal protective equipment standard 29 CFR 1910.132(a) if personnel could be exposed to a fireball hazard.

• PSM violations under 29 CFR 1910.119

• Electrical area classification violations for Class II (dust) or Class III (flock) areas 29 CFR 1910.307 or 1910.399.

• Other standards as listed in the NEP document

For more information, please visit:

[https://edir.bulk-online.com/profile...technology.htm

http://www.google.com/search?client=...UTF-8&oe=UTF-8

Attachments

chilworth (JPG)

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