Combustible Dust…
an Explosive Issue
WIC
May 2011
Presented by
Jamison Scott
jscott@airhand.com
www.airhand.com
More info on combustible dust:
http://www.airhand.com/combustibledust.asp
Combustible Dust
Topics Covered:
• What is It?
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Sawdust Cannon - http://www.vimeo.com/260680
Myth busters - Creamer Cannon - http://www.youtube.com/watch?v=yRw4ZRqmxOc&NR=1
Powdered Milk Container - http://www.youtube.com/watch?v=-yMOujZMXP8&feature=fvwrel
Flour Dust - http://www.youtube.com/watch?v=zKMPC2l80NU&feature=related
• Who’s in Charge?
• Can it Happen in My Facility?
• Prevention
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What is It – OSHA Fact Sheet
Combustible dusts are fine
particles that present an
explosion hazard when
suspended in air in certain
conditions.
Source: OSHA Fact Sheet.
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What is It – OSHA List
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What is It – Classic Fire Triangle
Fuel
(combustible dust)
Remove any one
element
eliminates the
possibility of fire.
Ignition
(heat, spark)
Oxygen
(air)
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What is It - Dust Explosion Pentagon
Ignition - fire
(heat, spark)
Fuel - fire
(combustible dust)
Dispersion
(explosion)
(Dust Suspension)
Remove any one
element prevents
explosion, but not
necessarily fire!*
*the concentration of suspended dust must be
within an explosible range, lowest amount of
dust in air that will explode, referred to as
Minimum Explosible Concentration (MEC) – (1)
Confinement
(explosion)
Oxygen - fire
(air)
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What is It – Particles & Layer
Combustible Fine Particles
– Deflagrable Wood Dust 420 micons (.425 mm, 425 um
micrometers, .0165”) or smaller (having moisture content of less
than 25%). Material that will pass through U.S. No. 40 Standard
Sieve. Size of fairly coarse sand. However will most likely
change in 2013.
“Dust Layer depth 1/64 in. (0.4mm) or less or the
underlying surface colors are readily
discernible.” Revised per NFPA 654 6.1.1.1 TIA March 21, 2011
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What is It – Primary & Secondary
Primary Issues
• Explosion
Secondary Issues
• Disturbing of dust on structural supports
can create a secondary source of fuel
• Video Clip: (3:20-5:28) http://www.chemsafety.gov/videoroom/detail.aspx?VID=33
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Who’s in charge
Regulatory Organizations & Agencies
• OSHA - Occupational Safety and Health Administration
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July 2005 - Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and
Explosions
February 2008 – Imperial Sugar, dust explosion and subsequent fire at a sugar refinery in
Port Wentworth, Georgia, caused 14 deaths and left many others seriously injured.
2007 – National Emphasis Program which targeted inspection efforts on facilities that create
or handle combustible dusts. Results from these inspections indicated that facilities had
unusually high numbers of general duty clause violations, indicating a strong need for
a combustible dust standard.
March 2008 - Hazard Alert: Combustible Dust Explosions. OSHA Fact Sheet
April 2008 – See Congress below
Spring 2009 - The Occupational Safety and Health Administration (OSHA) is considering
rulemaking to develop a combustible dust standard for general industry.
2009 - Hazard Communication Guidance for Combustible Dust OSHA 3371-08 2009
October 21, 2009 - Combustible Dust ANPR
Feb 2011 – WMMA Submits comment
October 2009 – Status Report on Combustible Dust National Emphasis Program
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Who’s in charge (cont.)
Regulatory Organizations & Agencies
• Congress
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110th Congress - April 2008 - The House passes the Worker Protection Against Combustible Dust Explosion and Fire
Act, H.R. 5522 by a vote of 247-165 and referred to the Senate.
111th Congress - H.R. 849 - Worker Protection Against Combustible Dust Explosions and Fires Act of 2009. Same as
H.R. 5522 from 110th Congress. Status: Referred to Committee.
112th Congress – U.S. Rep. John Barrow from Georgia reintroduced “Worker Protection Against Combustible
Dust Explosions and Fires Act” in the House in February, 2011
• SBA - U.S. Small Business Administration's (SBA) Office of
Advocacy
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Early 2011 OSHA was exploring creation of SBREFA for April 2011 (Small Business Regulatory
Enforcement Fairness Act) requiring OSHA to convene a task force of small business to review effects of
OSHA regulations. Per contact with SBA in late April 2011 – SBREFRA has been put off for a month or
so.
• NFPA – National Fire Protection Association (Current Edition noted)
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NFPA 68 Standard on Explosion Protection by Deflagration Venting. (2007 Edition)
NFPA 484 Standard for Combustible Metals (2009 Edition)
NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and
Handling of Combustible Particulate Solids. (2006 Edition)
NFPA 664 Standard for the Prevention of Fires and Explosions on Wood Processing and Woodworking
Facilities (2007 Edition)
• Insurance CompaniesAir Handling Systems - Copyright 2011
•
Forofinformational
FM Global - Prevention and mitigation
combustible use
dustonly
Who’s REALLY in charge
Sugar Refinery Ignored Explosive Dust Before Blast
September 25, 2009 by Rruss Bynum, Associated Press Writer
http://www.impomag.com/scripts/ShowPR.asp?RID=11927&CommonCount=0
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Can it Happen?
(2) www.woodchuckles.com
Can it Happen - Explosion
Explosion
• 2008 Georgia sugar refinery explosion
The 2008 Georgia sugar refinery explosion was an industrial disaster that
occurred on February 7, 2008 in Port Wentworth, Georgia, United States.
Thirteen people were killed and 42 injured when a dust explosion occurred
at a sugar refinery owned by Imperial Sugar.
http://en.wikipedia.org/wiki/2008_Georgia_sugar_refinery_explosion
• Combustible Dust Explosion at Motorcycle Rim
Manufactured Factory
November 2010 - 8 workers were injured as a result of the dust explosion
and 2 of them received serious injuries. The explosion also caused damage
to buildings and manufacturing plant, the destruction of the dust collector
system and also broke windows of factories nearby.
http://www.dosh.gov.my/doshV2/index.php?option=com_content&view=artic
le&id=295%3Acombustible-dust-explosion-at-motorcycle-rim-manufacturedfactory&Itemid=118&lang=en
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Can it Happen – Inspection
OSHA Inspection - $617,000 in proposed fines!
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RY Timber (MT) cited by OSHA for worker ComDust exposure - $79,200
April 19, 2011 - BILLINGS, MT -- RY Timber Inc., a manufacturer of 2x4 studs, has been cited for five repeat and four serious violations for
exposing workers to combustible dust hazards by the U.S. Occupational Safety and Health Administration (OSHA). The repeat violations address
deficiencies involving inadequate housekeeping in areas where combustible dust build-up had exceeded allowable limits.
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Seating Company (NJ) Slapped with $117,600 in Fines for Combustible
Dust, Health Hazards - $117,600
April 15, 2011 - “Combustible dust, with its fine particulate composition, has the ability to create an explosive atmosphere and rapidly engulf a facility in
fire,” said Lisa Levy, director of OSHA’s Hasbrouck Heights Area Office. “The accumulations of combustible dust must be removed, and a program
must be put in place to prevent any potential build up from occurring.”
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Gov. Malloy tours Connecticut firm cited by OSHA - $83,400
March 29, 2011 - OSHA cited specific safety violations in its announcement on Tuesday. They include improperly designed combustible dust
collection system. – SEE NEXT SLIDE for DETAILS
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OSHA: Carolina Skiff (GA) cited for combustible dust and hexavalent
chromium exposure - $95,000
March 22, 2011 - US Department of Labor's OSHA fines Waycross, Ga., manufacturer more than $95,000 for safety and health violations
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Mississippi mill slapped with ComDust violations - $67,800
February 2011 - SILVER CREEK, MS -- The Occupational Safety and Health Administration has cited a Mississippi lumber mill for a variety of
violations, including for having an electrical junction box open in an area where combustible wood dust accumulates. OSHA cited Joe N. Miles &
Sons Inc. of Silver Creek with 19 willful and serious safety violations and associated proposed penalties totaling $67,800.
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Combustible Dust Exposure Leads to Georgia Company's $55,250 Fine
February 2011 – OSHA has cited Protech Environmental South Inc., doing business as U.S. Erosion Control Products Inc., following an inspection that
uncovered 46 alleged safety and health hazards including worker exposure to heavy accumulations of combustible dust. Proposed penalties total
$55,250.
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US Department of Labor's OSHA cites 2 Tuscumbia, Ala., companies
for 40 safety and health violations with $121,800 in penalties
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February 2011 – TUSCUMBIA, Ala. – The U.S. Department of Labor's Occupational Safety and Health Administration is proposing $121,800 in
penalties for 40 safety and health violations at two Tuscumbia companies with shared family ownership, Tri-Cities Manufacturing Inc. and Tool Masters
Inc.
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Can it Happen – Inspection CT Firm
Gov. Malloy tours Connecticut firm cited by OSHA - $83,400
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The employer did not furnish employment and a place of employment which were free from recognized hazards
that were causing or likely to cause death or serious physical harm to employees in that employees were
exposed to fire and explosion hazards caused by the presence of combustible dust:
Current Penalty:$5000.00
Aluminum and titanium aircraft engine parts were de-burred using pneumatic hand tools which generated
combustible dust. The Donaldson Torit Model VS1200 dust collection system provided was not designed and
installed to be used with combustible metal dust.
Specifically:
1. The collection hood provided at the de-burring workstation was not designed and maintained so that fine
particles would either fall or be projected in the direction of airflow. (NFPA 484, Section 6.3.2.2)
2. The dry-type dust collector was located inside of the building. (NFPA 484, Section 6.3.2.5)
3. The dust collection system was not dedicated to the collection of aluminum or aluminum alloy dust. It
was also used to collect nickel-based and steel based aircraft alloys and served a surface grinder used to
modify milling machine tooling. (NFPA 484, Section 6.3.2.6)
4. The plastic hose that connected the exhaust hood to the dust collector was not short, straight,
conductive and provided with a smooth interior surface, factors required to maximize free air flow and
minimize accumulations of combustible dust inside the ductwork. (NFPA 484, Sections 6.3.3.4, & 6.3.3.5.1 &
10.4.4.2)
5. The pneumatic hand tools provided for use were not interlocked with the dust collector to ensure that
the dust collector was on and properly functioning before deburring operations commenced. Also, a
time delay switch or equivalent device was not provided on the dust collector to prevent hand tools from
starting until the dust collector was in full operation. (NFPA 484, Section 6.3.4.7.1, 6.3.4.7.2, 10.4.4.6.1 &
10.4.4.6.2)
6. Exhaust air from the dust collector was recycled into the work area. (NFPA 484, Section 6.3.6 & 10.4.9)
7. A media type dust collector was used to collect titanium dust. The Donaldson Torit Vibra Shake dust
collector contained dry fabric-type collection media. (NFPA, Section 10.4.8.1)
Among other methods, one feasible and acceptable abatement method to correct this hazard is to design
and install a dust collection system that complies with generally accepted guidelines such as National
Fire Protection Association (NFPA) Standard 484 Standard for Combustible Metals.
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Prevention
OSHA
• Use NEP and ANPR as guidelines.
• National Emphasis Program (NEP) - Using General Duty Clause
• Advanced Notice of Proposed Rulemaking (ANPR). ANPR is
basically data collect from a series of questions. You will note there
is overlap in the various sections. However, “Preparation is the best
medicine.” Highlights include:
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Hazard Recognition/Assessment
Engineering Controls
Administrative Controls – Document, Document, Document
Housekeeping
Building Design
Explosion Protection
Operating Procedures
Worker Training
Source OSHA ANPR
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Prevention - Hazard Assessment
Hazard Recognition/Assessment
• Recognition/Assessment
• Determining if dust is combustible via Dust Testing Explosion Severity Test, Minimum Explosible Concentration
(MEC)
• Communication
• HazCom Standard, MSDS
• Industry Standards
• NFPA
• State and Local Codes
• AHJ (Authority Having Jurisdiction) – Fire Marshall, Building
Inspector
• Insurance Company
Source OSHA ANPR
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Prevention – Engineering Controls
Engineering Controls
• Fixed measures that are built into a facility
or processing equipment to remove or
minimize hazard.
• Primary (building, facility)
• Prevent accumulation of dust on surfaces, beams,
etc. Flat surfaces are not good.
• Secondary (equipment)
• Dust Collection Systems
• Sprinkler system
Source OSHA ANPR
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Prevention – Admin Controls
Administrative Controls
• Document, Document, Document
• Do you have a method to prevent escape
of dust?
• Do you have a policy to remove fugitive
dust from surfaces?
• OSHA wants written rules and procedures
• Document, Document, Document
Source OSHA ANPR
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Prevention - Housekeeping
Housekeeping
• Fugitive Dust Control (NFPA 654, Chapter 8)
• Dust layers as thin as 1/64 of an inch or less or
the underlying surface colors are NOT readily
discernible. If you can see dust, don’t ignore it!
• Clean it up and examine where it’s coming from.
Seal all openings in processing and conveying
equipment to prevent the release of dust.
• When you inspect your workplace also
consider overhead beams, electrical cable
trays, lighting fixtures, and “invisible” areas
such as areas above false or suspended ceilings.
– Source NFPA
http://www.nfpa.org/publicJournalDetail.asp?categoryID=1691&itemID=40964&src=NFPAJournal
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Prevention – Housekeeping
Housekeeping (cont.)
• Dust Collectors – Clean it Up!
• NFPA 664 (combustible dust standard just for
woodworking) applies to shops larger than 5,000
sq ft or collector greater than 1500 cfm) Essential
in any size shop
• So when it comes to Combustible Dust - Size of
shop doesn’t matter, size of dust does.
• Changing filters, bags, tightening clamps.
• Explosion Relief – Deflagration Venting
• NFPA 68 Example: http://www.youtube.com/watch?v=af4IANnITeM&NR=1
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Prevention – Housekeeping
Housekeeping (cont.)
• Dust Collectors – Clean it Up! (cont.)
• Hanging Air Filter for ambient dust.
• DO NOT blowing off machinery to clean
• Shop Vacuum or Vacuum Kit which attaches to
your dust system for everything else.
• Using explosion proof vacuum?
• Sprinklers – Test, Test, Test
• Building
• Spark Detection system in Dust Collectors and
Ductwork
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Prevention – Finally
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Building Design
Explosion Protection
Operating Procedures
Worker Training
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Do the worker know what to do?
Have they read the operating procedures?
Do they understand?
Have they been tested?
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Hot off the Press
NFPA
• March 21, 2011 – TIA (Tentative Interim Amendment) to NFPA 654
• March 25, 2011 – Report on Consolidation of the Combustible Dust
Committees and Documents
• 61 Agricultural Dusts
• 484 Combustible Metals
• 654 Manufacturing of Combustible Particles
• 664 Wood Processing
OSHA
• May 13, 2011 - Occupational Safety and Health Administration invited
outside experts to participate in a Combustible Dust Expert Forum May
13, 2011. OSHA will gather experts' views on possible regulatory
options for addressing combustible dust hazards.
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Resources
OSHA – Occupational Safety & Health Administration - http://www.osha.gov/
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Combustible Dust: http://www.osha.gov/dsg/combustibledust/index.html
OSHA Advanced Notice of Proposed Rulemaking: http://edocket.access.gpo.gov/2009/pdf/E9-25075.pdf
Congress - http://thomas.loc.gov/
NFPA - http://www.nfpa.org
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NFPA 68: Standard on Explosion Protection by Deflagration Venting
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NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing,
and Handling of Combustible Particulate Solids
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http://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=68
http://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=654
NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking
Facilities
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http://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=664
US Chemical Safety Board - http://www.chemsafety.gov/
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Imperial Sugar Company Dust Explosion and Fire
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http://www.chemsafety.gov/investigations/detail.aspx?SID=6
WMMA - http://www.wmma.org
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NFPA 664 Combustible Dusts Overview is now available!
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Resources
Insurance Company - http://www.fmglobal.com (registration required)
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Loss Prevention Data Sheet 7-73, Dust Collectors and Collection Systems
Loss Prevention Data Sheet 7-76, Prevention and Mitigation of Combustible Dust Explosions and Fires
Combustible Dust Policy Institute
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http://dustexplosions.blogspot.com/
Linkedin - The Combustible Dust Forum
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http://www.linkedin.com/groups?gid=946657&trk=myg_ugrp_ovr
Building Code Reference Library
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http://www.reedconstructiondata.com/building-codes
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Questions & Summary
Jamison Scott
jscott@airhand.com
www.airhand.com
More info on combustible dust:
http://www.airhand.com/combustibledust.asp
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Appendix A
Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions
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Appendix B
Hazard Alert: Combustible Dust Explosions. OSHA Fact Sheet, (2008, March)
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Appendix C
Hazard Communication Guidance for Combustible Dusts OSHA 3371-08 2009
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Appendix D
OSHA ANPR
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Appendix E
Status Report on Combustible Dust National Emphasis Program
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Appendix F
FM Global – an Insurer’s View
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Appendix G
http://www.wmma.org
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Appendix H
TIA
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Appendix I
WMMA ANPR Comment Feb 2011
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