Combustible Dust Imperial Sugar 2008 Dust Malden Mills 2004 Kansas 2011 It’s Only Dust Pictures from actual workplaces It’s Only Sugar! Picture from Louisiana sugar plant three months after a fire destroyed a sister plant in Georgia Total OSHA fines to company $8,800,000 for violations found at the 2 plants After the fire at the Georgia plant – why didn’t the company clean this plant???? A Chronology of Past Events • February 7, 2008 – Imperial Sugar Plant explodes • February 11, 2008 – Fire still burning in parts of plant • February 24,2008 – 11th worker dies from injuries • July 2008 – OSHA fines Imperial Sugar Co. $8.8 million For violations in Georgia and Louisiana • August 2008 – 14th worker dies from injuries What’s so bad. • For the employer the millions of dollars in OSHA fines and insurance payments not to mention the cost of rebuilding the plant . • For the workers and their families – the cost, heartbreak and pain – That 14th worker spent 6 months in a burn unit fighting for his life. A total of 40 other workers were injured with severe burns. Between 1980 and 2005 the Chemical Safety Board has knowledge of over 280 dust explosions resulting in 119 deaths and 718 injuries That averages to more than 10 explosions per year Despite the time since the Port Wentworth explosion brought this issue to the national forefront the explosions continue. 10/30/2011 6 killed, 2 injured Kansas Important Points Regarding the CSB Data • According to the CSB, “The combustible dust incidents the CSB lists…from 1980 to 2005 are likely only a small sampling, as no federal or state agency keeps specific statistics on combustible dust incidents, nor does any single data source provide a comprehensive collection of these incidents. • Information about small combustible dust incidents and near-misses is also generally unavailable. • Incidents that cause no fatalities, significant injuries or major fires may not be recorded in the OSHA and fire incident databases • The true extent of the problem is likely understated. • Due to these limitations, the CSB does not represent the incident data as complete or error free and other compilations of dust explosion data are available.” Types of Dust Involved in incidents Inorganic 4% Coal 8% Plastic 14% Metal 20% Other 7% Food 23% Wood 24% Combustible Dust Explosions History Malden Mills Methuen, MA December 11, 1995 37 Injured Nylon Fiber Combustible Dust Explosions History Jahn Foundry Springfield, MA February 26, 1999 3 dead 9 Injured Phenolic resin dust Combustible Dust Explosions History May 16, 2002 Rouse Polymerics Vicksburg, MS 5 dead, 7 injured Rubber Dust Combustible Dust Explosions History •January 29, 2003 West Pharmaceutical Services, Kinston, NC –Six deaths, dozens of injuries –Facility produced rubber stoppers and other products for medical use –Plastic powder accumulated above suspended ceiling ignited Combustible Dust Explosions History • February 20, 2003 – CTA Acoustics Corbin, KY – Seven Workers died – Facility produced fiberglass insulation for automotive industry – Resin accumulated in production area and was ignited Combustible Dust Explosions History • October 29, 2003 • Hayes Lemmerz Manufacturing Plant – Two severely burned (one of the victims died) – Accumulated aluminum dust – Facility manufactured cast aluminum automotive wheels Combustible Dust Explosions History • October 30, 2011 • Bartlett Grain Elevator Atchison Kansas - 6 Workers killed - 2 Workers injured Workers were loading corn onto a train The Dust Explosion Pentagon Ignition Source Ignition Source Dispersion Deflagration Confinement Explosion FIRE Combustible Dust Oxygen in Air/Oxidizers To prevent an explosion – remove one corner of the pentagon The primary explosion is rarely the end of the story. Secondary Explosions • Occur when the blast wave from the initial explosion causes accumulated dust in other areas (which may be remote and unrelated to original explosion) to become airborne and explode • Anecdotally many investigators discover that “puffs” (small unreported explosions) had been observed for some time prior to the reported incident. So How Do I Prevent a Dust Explosion? If one of the five elements of the Pentagon is missing a catastrophic explosion cannot occur. = No Explosion Ignition Source Ignition Source Dispersion Deflagration Confinement Explosion FIRE Combustible Dust Oxygen FIRE I in Air/Oxidizers FIRE Two elements are difficult to eliminate: 1) Oxygen in Air 2) Confinement within processes or buildings Ignition Source Ignition Source Dispersion Deflagration Confinement Explosion FIRE Combustible Dust Oxygen FIRE I in Air/Oxidizers But my process doesn’t include dust! FIRE Are you sure? If you work with any solid combustible material, ingredients or intermediate products or by-products, handling, conveying, or otherwise manipulating these materials can create combustible dust. Even materials typically handled and stored wet can become dry. Definitions and Terminology What is Combustible Dust? NFPA 654 (2006) Definitions • Combustible dust. A combustible particulate solid that presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations, regardless of particle size or shape. • Combustible Particulate Solid. Any combustible solid material composed of distinct particles or pieces, regardless of size, shape, or chemical composition. • Hybrid Mixture. A mixture of a flammable gas with either a combustible dust or a combustible mist. • Different dusts of the same chemical material may have different ignitability and explosibility characteristics depending on variables of particle size, shape, and moisture content. • Good housekeeping might seem like an easy answer. But housekeeping is only part of the answer! • As much as is practical, containment and dust collection systems are important. • But they must be installed and maintained in a manner that keeps them from becoming an ignition source NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing of Combustible Particulate Solids Recommends: 1. 2. 3. 4. 5. 6. 7. 8. 9. Minimize the escape of dust from process equipment or ventilation systems: Use dust collection systems and filters; Utilize surfaces that minimize dust accumulation and facilitate cleaning; Provide access to all hidden areas to permit inspection; Inspect for dust residues in open and hidden areas (at regular intervals); Clean dust residues (at regular intervals); Only use vacuum cleaners approved for dust collection; Locate relief valves away from dust hazard areas; and Develop and implement a hazardous dust inspection, testing, housekeeping, and control program. Use dust collection systems and filters Dust Control Design of facility & process equipment Contain combustible dust Clean fugitive dust Regular program Access to hidden areas Safe cleaning methods Maintenance Inspect for dust residues in open and hidden areas (at regular intervals); Like most pharmaceutical manufacturers this was a “clean” facility. West Pharmaceutical facility destroyed by polyethylene dust Which accumulated above the tiles in a dropped ceiling Ignition Source Control Electrical equipment Static electricity control Mechanical sparks & friction Open flame control Design of heating systems & heated surfaces Use of tools, & vehicles Maintenance Ignition Source Control Electrical equipment Class II, Division 1 and 2 Class I and Class III may also be an issue Consider equipment both inside dust handling equipment and outside Ignition Source Control Mechanical sparks & friction Rotating equipment bearing failure can lead to very hot surfaces (above the MIT) Sliding surfaces can develop charges Steel tools dropping onto concrete or steel A good mechanical integrity management system/vibration analysis system is needed to detect problems in advance with bearings and other surfaces Ignition Source Control Mechanical sparks & friction Open flame control Use of tools & vehicles Maintenance All require effective control of Hot Work Look for permit systems Ignition Source Control Design of heating systems & heated surfaces Know your materials Minimum Ignition Temperature (MIT) Maintain temperature controls Moisture content may be critical Primary Applicable OSHA Standards 1910.22 General – Housekeeping 1910.307 Hazardous (Classified) Locations 1910.178 Powered Industrial Trucks 1910.263 Bakery Equipment 1910.265 Sawmills 1910.272 Grain Handling General Duty Clause So What Should I Do? 1) Evaluate your workplace for the 5 points of the explosion Pentagon: a) Combustible Dust b) Ignition Source c) Confinement d) Dispersion e) Oxygen in Air/Oxidizers How? • a) Combustible Dust – Do you see “dust” in your workplace that is used in your process or is a by product of your process • (i.e. At a sawmill sawdust is a by product of the cutting of logs/boards into product) • b) Ignition Source -eliminate any possible sources of ignition, from electricity to static electricity - a minimum of Class II electrical features How? • c) Confinement – This will depend on the configuration of the workplace and can be difficult to eliminate • d) Dispersion - keep dust from suspension in air – Use dust collectors – When cleaning do not re-suspend accumulated dust in air (DO NOT use air to “clean” surfaces) How? • e) Oxygen in Air/Oxidizers • Oxygen in the air cannot be eliminated (unless workers are in SCBs) • Oxidizers, if present for process, should be isolated or replaced So What Should I Do? If you find that you do have the five elements or you know you have four and may not be quite sure about number 5 DO NOT DELAY Seek assistance We don’t want your site to look like this! –