Combustible dust accumulation in plants continues to be of major concern throughout multiple industries. The risk of a combustible dust explosion is a real threat if fugitive dust is allowed to accumulate. Along with the safety risk to employees, comes the financial importance of being in compliance with OSHA and NFPA regulations. What many fail to realize is the significant role that preventative measures can play in achieving compliance while creating safer work environments. This paper will help to outline several key steps that companies can take to help ensure compliance of combustible dust regulations and discuss ways to prevent fugitive dust buildup.
Regulatory compliance continues to be an issue that employers must deal with on a daily basis and even though OSHA has decided to table the adoption of further regulations on combustible dust for now, it is important to realize that facilities can still be fined for combustible dust issues under the general duty clause and other relevant standards. Just last year, a combustible dust explosion at Didion Milling Inc. in Cambria, Wisconsin left five workers dead and several seriously injured. OSHA leveled 14 willful citations against the company, proposing fines of more than $1.8 million. The company was also placed on the Severe Violators Enforcement Program (SVEP). In this particular case, the egregious willful citations were issued, in part, for violating OSHA’s Grain Handling standard for failing to develop a housekeeping program to control dust accumulations.
Adherence to NFPA 652 is the best way to ensure compliance on combustible dust issues and is considered the umbrella standard for all other combustible dust standards. NFPA 652 was issued to mandate combustible dust hazard analysis, awareness, management and mitigation. The standard has been globally recognized and it is important to note that the 2018 International Fire Code now includes combustible dust standards and requires compliance with NFPA 652.
Below are 5 tips for driving compliance of NFPA combustible dust standards and avoiding a disaster in your facility:
NFPA 652 requires all facilities that create, handle or store dust to be tested. Even if there is no history of the type of dust you deal with causing a combustible event, you must still have it tested by a qualified laboratory. Results from these tests must be kept on file.
NFPA 652 also requires that all facilities dealing with combustible dust complete a dust hazard analysis (DHA). Time is of the essence, as facilities are required to complete a DHA before October 2018. The following steps are required when conducting a DHA:
More information on completing a DHA can be found in chapter 7 of NFPA 652.
Employee education is essential to a safe work environment and ensuring compliance. Fully understanding the dangers that combustible dust can present to employee safety creates a desire among employees to help prevent a combustible dust event. Training employees on standard operating procedures, safety measures and emergency action plans allows your employees to help drive compliance within the facility, and more importantly, helps save lives.
Along with requiring a DHA, NFPA 652 also requires that facilities develop a housekeeping plan with documentation. Housekeeping plans should include information on how a facility plans to address and control fugitive dust buildup. Dealing with combustible dust can involve multiple processes. From dust controlling equipment to manual clean-up, all options need to be considered when developing a housekeeping plan. Once a housekeeping plan has been developed, employees need to be trained prior to implementation and retrained at regular intervals. As noted above, poor housekeeping was cited as an OSHA violation in the Didion Milling event and resulted in fines.
“An ounce of prevention if worth a pound of cure” is an old saying, but one that warrants repeating. Preventing dust accumulation in the first place is critical to helping facilities stay in compliance. Prevention methods are also a more cost-efficient and safer method for dealing with combustible dust. Even with the use of dust collectors, dust particles still enter the air and start to accumulate on overhead and hard to reach areas. In order to deal with this accumulation, most facilities turn to manual housekeeping methods, dealing with the dust AFTER it accumulates. Not only can these labor costs be high, but sending employees into overhead areas can be a safety risk. It is ideal to prevent the dust from accumulating on these structures to begin with. Addressing combustible dust issues on a continuous basis, rather than intermittently, is the best approach. Investing in equipment that can aid in the prevention of fugitive dust buildup should remain a top priority for facilities dealing with combustible dust.
SonicAire fans offer an engineered solution for not only preventing fugitive dust accumulation, but also attaining a continuously clean environment. Using proprietary BarrierAire technology, SonicAire fans prevent dust from accumulating in overhead and hard to reach areas in the first place.
Here’s how it works: High Velocity and High Mass airflow from a robotic clean-fan creates an overhead barrier in the facility. BarrierAire technology controls the direction of the dust and forces it to the floor by preventing upward convection currents and stagnant air that keeps dust in suspension, preventing accumulation of fugitive dust in overhead and hard to reach places.
The use of SonicAire fans help facilities to reduce their manual housekeeping costs, maintain regulatory compliance, and most importantly, create a safer working environment for employees.
Compliance to combustible dust standards must remain a key goal of companies that deal with combustible dust. Exploring and implanting preventative measures from the beginning not only has a positive financial impact, but helps to avoid fugitive dust events in the future.
Brad Carr is president of SonicAire, Inc., located in Winston-Salem, NC.