Update from USMWF on Combustible Dust Standards  

Just got an update this morning from the Weekly Toll Blog on a bunch of workplace issues on their site, however, the combustible dust standards information is what I wanted to draw readers to today:

I wanted to make a note that with all the combustible dust talk there has been I have came across a few issues surrounding the HR 5522. One being that companies are not able to find the resources for testing so for that I have found two places (in the States) one is the longstanding Chilworth Technology located at http://www.chilworth.com/ and the other recently brought to the combustible dust scene EMSL Analytical, located http://www.emsl.com/

Next there are a few issues that the bill did not seem to strongly address.
Most know the Fire Triangle.
1. Fuel
2. Oxygen
3. Heat

For combustible dust the fuel is dust, oxygen is a gimmy and then there is the heat or ignition source, which is commonly know as a spark or heat from near by equipment possibly even an individual. The problem is most do not consider the dust itself as and ignition source. This is possible in many ways such as product transfer. Transferring the product manually or through a process can build up a static charge a charge can also be obtained by dust rubbing against piping so there a few more variables to consider. Most variables are simple fixes such as clean up, containment and not using anything glass lined, the right type sweepers and bags. Now these issues are addressed in part but emphasis are not put on why and how. Most of this however should be common knowledge to those in the field but just incase it is a heads up.

In case you don't recall, you can read previous information on this site in relation to combustible dust. And for those more visual, I suggest you take a miute and watch the CBS piece on combustible dust.

What's most interesting in the update is that the fuel that really starts the chain reaction is Dust. Dust. And USMWF notes that this is barely being addressed. Where grain was concerned, these dust issues were addressed and the standards have proven to be helpful in saving lives all over this country. So, why should anyone in a manufacturing setting not have the same sort of protection?

Come on Congress, We Need A Combustible Dust Standard.

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  • John Astad  
    9:32 AM

    If the fire codes were adhered to such as the NFPA, Uniform Fire Code or the ICC, International Fire Code. Which both make reference to NFPA combustible dust codes then most combustible dust fires and explosions would not occur. This is not an OSHA issue, which is mistakenly portrayed in the media with the political spin but instead a local jurisdictional issue. Are the fire inspectors knowledgeable of the complex aspects of combustible dust?

  • The Union Girl  
    10:39 AM

    Gotta disagree on that one. You're implying that the local fire inspectors aren't doing their jobs, are you also then inferring that the same was the case for grain explosions?

    When it deals with workers and the lives and safety of those workers, it's not just a local issue especially where the commerce of these industries is international in nature rather than between states.

    I think of this issue much the way USDA regulates the meat industry (and that's an entirely other topic) or how the EPA regulates environmental hazards. OSHA is charged with workplace safety and combustible dust is a workplace hazard.

  • John Astad  
    11:00 AM

    Thats okay, go ahead and follow the spin that it's primarily an OSHA problem. Blame OSHA for everything that will fix the problem.

    Is OSHA the first-responder to arrive at a plant explosion or fire in conjunction with conducting fire inspections for life safety, structural integrity, and mission continuity? Of course not. This is a local and state jurisdictional issue, not federal.

    Mixing apples and oranges when comparing agricultural grain facilities to manufacturing plant facilities. They are separate entities that have similar combustible dust issues.

    Read the CSB Dust Hazard Study, which concludes that many fire inspectors have no specific knowledge concerning combustible dust as outlined in the fires codes that the States have adopted,which all make reference to the NFPA combustible dust codes

    Confusing workplace safety with building life safety and structural integrity deviates from the prevention of future combustible dust fires and explosions.

  • Joe638NYC  
    2:04 PM

    Hi John,

    I have been an avid reader of your blog, and have read your recent post OSHA Combustible Dust Blame Game, and agree that the NFPA standard should be the utmost regulation that employers must adhere to, unfortunately their combustible dust standards are not, and when one agencies standard is neglected and there are employees who's well being are a direct responsibility of their employers, OSHA should hold the governance in such matters.

    It is understandable that OSHA is quite underfunded and does not have enough inspectors, but if that is the case then we need to do more work to change that fact.Same with matters of local governance. So the question is who needs to do more to prevent this from happening? Even in your conclusion in the article I linked to above you leave off with 2 questions. This is a confusing issue and we need change to stop this from happening again, not scapegoats.

    "Would combustible dust explosions occur if current fire codes followed the references to the NFPA combustible dust codes?"

    Maybe OSHA should be the body that makes sure those codes are enforced. They still are the Government overseer of employee health, if a job site were to have shootings once a week, where workers were at risk, would that be a local issue? Eventually I would expect OSHA to be involved there also. It would be easy to grant OSHA a hands off on any such job risk, if you can point the finger to a different agency, why have OSHA investigate construction accidents in New York when there is a NYC Department Of Buildings?

    And I understand there is a tremendous difference between a flour and a Acetylene explosion, one standard does not cover both fuels.

    Please don't take this as arbitrary, just trying to help people same as uniongal and yourself.


  • John Astad  
    2:37 PM

    Hi Joe,

    You bring up some excellent points. In the big picture, yes OSHA should ensure that the NFPA combustible codes are enforced that are referenced in the ICC, International Fire Code and the NFPA, Uniform Fire Code.

    The current OSHA General Duty Clause will achieve this through industry standards of care referenced in the NFPA combustible dust codes.

    Yet at the local jurisdictional level this is where the problem arises with the combustible dust aspect of the facility not being addressed by the building and fire inspectors concerning life safety and structural integrity of the building. Workplace safety is under the umbrella of the it's parent, life safety of the building.

    The issue of workplace safety is currently confused with building and fire safety concerning combustible dust. Especially when topics of explosion venting, spark suppression and detection are suppose to be incorporated into the building design of the manufacturing facility that utilizes combustible particulate solids that generate combustible dust

    Same with shootings at workplaces, this is a local law enforcement/crime prevention jurisdictional issue. Not OSHA, but thats a whole topic of debate in itself

    Cranes are an entirely different situation. OSHA needs to be involved there since the crane is not part of the building when the project is completed.

    Thanks for your feedback. Constructive thought-provoking debate like this is what needs to be pursued in the prevention of future preventable combustible dust fires and explosions that plague our nation's economically troubled manufacturing sector.

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