Our goal is simple: To keep employees safe from fires and explosions cause by combustible dust particles.
Take a look at each of these sections and use any of the information to complete the picture. Check in periodically, as we will be adding information when a new development occurs.
Questions? Contact Jordan at 336.712.2437
Brief History of Regulations
The risks of combustible dust are not new. Back in 2003, there were 3 catastrophic dust explosions that killed 14 workers. Subsequently, the Chemical Safety and Hazard Investigation Board (CSB) issued a report identifying 285 separate combustible dust incidents between 1980 and 2005: total killed- 119; total injured – 718. The CSB’s conclusion was far-reaching for all industries: “Combustible dust explosions are a serious hazard in American industry.” CSB then recommended that OSHA issue a standard of tolerance for combustible dust accumulation based on National Fire Protection Association (NFPA) standards. The document for all industries is NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing and Handling of Combustible Particulate Solids.
Precipitated by a lethal combustible dust explosion at a sugar plant in 2008, Congress then issued HR 5522, sponsored by the U.S. House of Representatives, requiring OSHA to enforce NFPA 654 Standards in a systematic and rigorous way. OSHA took this directive and established a National Emphasis Program (NEP), levying stiff fines to those out of compliance. HR 691 represents new momentum to OSHA’s activities because legislators were not satisfied with the progress made from HR 5522.
New bill introduced in 2013
In February 2013, a new H.R. Bill HR691: Worker Protection against Combustible Dust Explosions and Fires Act of 2013 was introduced to congress. The essence of the bill is captured in this excerpt:
“An emergency exists concerning worker exposure to combustible dust explosions and fires, and there is a significant risk of death or severe injury to workers employed at facilities where combustible dusts are present.” [Bill HR 691 Section 2 (1)]
The bill seeks to require the Secretary of Labor to issue an interim set of standards regulating the control of combustible dust and to finalize a permanent ruling within three years of the interim standard.
The gist of HR691 is to set up timelines by which official standards must be accepted and enforced. Initially there was a proposed interim timeline that states that “not later than 1 year after the date of the enactment of [HR691), the Secretary of Labor shall promulgate an interim final standard regulating occupational exposure to combustible dust hazards.” [Section 3(a)]. This interim standard has not been finalized at this time. The bill then calls for the final standard to be set no later than 18 months after issuance of the interim standard.
The bill was then referred to the Subcommittee on Work Force Protection for review, with no new rulings set. But OSHA activities continue nonetheless.
Standards to Consider
Remember that NFPA Requirements = OSHA Regulations. The umbrella standard is NFPA 654, which is referenced here. So let’s take a closer look at some of the specifics of NFPA 654 that clearly focus on the issues that matter most.
NFPA 654 has a strict standard for dust buildup:
- Chapter 220.127.116.11: “The layer depth … [is] 1/32” (0.8mm)….” This is about the size of a paper clip’s diameter.
- Section D.2. (2-4) identifies another requirement: “The dust layer is capable of creating a hazardous condition if it exceeds 5 percent of the building floor area. Dust accumulation on overhead beams and joists contributes significantly to the secondary dust cloud… “
These requirements mean there is essentially a zero-tolerance approach to dust buildup. What is the remedy?
Consider this NFPA 654 requirement:
- Chapter 18.104.22.168 “…the housekeeping frequency shall be established to ensure that the accumulated dust levels on walls, floors, and horizontal surfaces such as equipment, ducts, pipes, hoods, ledges, beams and above suspended ceilings and other concealed surfaces, such as the interior of electrical enclosures, does not exceed the threshold dust mass/accumulation. “
Again, this is the general standard, not the specifics that deal with certain industries. To read the full standards yourself, click on to any of these sites that best suit your industry.
- NFPA 654:Standard for the Prevention of Fires and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible(This is the umbrella standards used across a variety of industries)
- NFPA 664:Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities
- NFPA 61:Standard for the Prevention of Fires and Explosions in Agricultural and Food Processing Facilities
- NFPA 484:Standard for Combustible Metals
- NFPA 655:Standard for Prevention of Sulfur Fires and Explosions
- NFPA also issues NFPA 70: National Electrical Code®, with useful information.
Also, be sure to take note of Specific OSHA violations cited under their General Industry General Duty Clause found in:
- 29 CFR 1910.22 — General Requirements: Housekeeping
- 29 CFR 1910.38 — Emergency Action Plans
- 29 CFR 1910.94 — Ventilation
- 29 CFR 1910.107 — Spray Finishing Using Flammable and Combustible Materials
There are two different strategies to address OSHA’s concerns: a managed solution or an engineered solution. In fact, the NFPA Standards refer to a managed solution, which has been the status quo. But let’s take a look at each approach and its strengths and weaknesses.
A managed approach means that personnel or third party businesses clean the overhead structures on a continuing basis. This has been the conventional approach to controlling combustible dust. One benefit of a managed approach is that there are low upfront costs: contracts are set up for ongoing payments that become part of annual operating expenses.
There are also other issues to consider with a managed approach, however.
- There is risk to personnel for the overhead cleaning.
- The levels of clean in the facility vary based on the proximity to the scheduled cleaning time. For instance, if overhead cleaning is scheduled monthly on the 15th of the month, the combustible dust has had time to accumulate by the 14th of the month, making it possible for the plant to be out of compliance with OSHA regulations…and risk the safety of the employees. Even if a plant owner/manager were not inclined to procrastinate the cleaning, the cyclical nature of the buildup is inevitable with a managed approach.
- Also inevitable is lost production due to the necessary shutdown of the plant.
The assumption for an engineered approach is that technology can be leveraged to automate cleaning processes and continuously protect against the risks of combustible dust accumulation.
Two different types of engineering solutions exist. The first is localized filtration. With this technology, the equipment captures the combustible dust by either vacuuming or suctioning. This approach is often needed, but the reality is that it can’t be used alone. Localized filtration can’t capture every particle.
The second technology is barrier technology, which prevents combustible dust from accumulating on overhead structures. With barrier technology, a robotic clean fan automatically maintains OSHA compliance throughout the plant. With this approach, there is a one-time deep clean of fugitive dust, and once that dust is removed, new dust doesn’t accumulate again.
Often there is synergy between the filtration and the barrier technologies for enterprise-wide compliance, since they can be effectively used together in one facility.
With either engineered approach, there are higher, one-time costs for implementation. These are one-time costs, though. An engineered approach also allows for automated, controlled cleaning that doesn’t interfere with production. Depending on the sophistication of the specific technology, it also delivers consistently higher levels of clean for ongoing compliance to government regulations and for employee safety.
Criteria for Evaluation
So which approach is the smarter, more affordable way to meet OSHA regulations?
Facility managers and plant owners should evaluate the overall cost for any solutions based on a range of variables including the criteria of:
- Initial cost
- Operating cost
- Ongoing labor cost
- Employee morale
- Disruption to normal production
- Energy usage
Whichever approach is chosen, managers must be mindful of the increased need to pay attention to the dangers of combustible dust. Nothing is more important than protecting the lives of your employees.