Combustible_dust_NIU_3_20_09

Slide 1: 

Combustible Dust Compliance audits, hazards, testing, and citations March 4, 2009 John Newquist MS, CSP, CFI

The Long and Winding Road : 

The Long and Winding Road History of Hazards Osha Inspections Testing Issues Citations

Safety Origins : 

Safety Origins 1884 Pennsylvania Mine Safety Act (PMSA) was passed into law.

Cherry Coal Mine Disaster : 

Cherry Coal Mine Disaster November 13, 1909 259 Died Hay bales sent down to feed mules caught fire from burning oil from kerosene torch. 21 men survived in a pocket 500 feet underground and were rescued after 8 days. Outcry over tragedy lead to fire safety rules for mines and the Illinois Liability Act which lead later to the IL Worker Compensation Act.

Corn Products Explosion : 

Corn Products Explosion Jan 3 1924 42 died Starch Dust Pekin IL Explosion in starch packing house. Dumping buggies of starch Low moisture due to cold.

Texas City : 

Texas City April 16, 1947 Cargo Ship of Ammonium Nitrate Exploded Neighboring Monsanto plant caught fire 561 died

Brach’s Candy : 

Brach’s Candy Sep 7, 1948 18 died Spark from electrical equipment ignited suspended starch dust Open storage of starch.

1970’s : 

1970’s Westwego, LA Grain Elevator Explosion, Dec 1977 Spark ignited grain dust. The explosion killed 36 people.

1980’s : 

1980’s 1984 Bhopal Explosion kills 2000+ OSHA Starts CHEMSEP Grain Dust Standard

Buffalo Rock : 

Buffalo Rock 4 dead Bullet filling machine misfires. Housekeeping Electrical

Ford River Rouge Power Plant : 

Ford River Rouge Power Plant 2/1/1999 Dearborn , MI General Duty egregious, 1.5M Natural gas boiler explosion triggered secondary coal dust explosion that had accumulated on building and equipment surfaces No flame sensing interlock for the gas lines

BP : 

BP Mar 23 2005 15 died 170 injured $50M fine EPA $21M Fine OSHA 2.3B est loss.

Imperial Sugar : 

Imperial Sugar Feb 7, 2008 14 died 60 injured $180-220 est. loss $7.7M Fine – OSHA

Reg III LEP on Dust : 

Reg III LEP on Dust 100+ Inspections before 2006

Slide 15: 

Types of Dust Involved in incidents

Slide 16: 

Types of Industries Involved in Dust Incidents

Slide 17: 

Dust Incidents, Injuries, and Fatalities

CSB Recommendations To OSHA : 

CSB Recommendations To OSHA 1) Issue a standard 2) Clarify that the HCS covers combustible dusts Amend the Globally Harmonized System (GHS) to address combustible dust hazards Provide training on recognizing and preventing combustible dust explosions. Implement a National Special Emphasis Program (SEP) on combustible dust hazards in general industry

Safety and Health Information Bulletin : 

Safety and Health Information Bulletin Purpose Background Elements of a Dust Explosion Facility Dust Hazard Assessment Dust Control Ignition Control Damage Control Training References

CSHO Training : 

CSHO Training Region V Class in Dec 07 OTI Combustible Dust Class in Dec 07 Combustible Dust Webinar 1 day Alliance training and Outreach on Combustible Dust Culture of Hazard Recognition

OSHA NEP : 

OSHA NEP

Purpose : 

Purpose Inspect facilities that generate or handle combustible dusts Metal dust such as aluminum and magnesium. Wood dust Coal and other carbon dusts. Plastic dust and additives Biosolids Other organic dust such as sugar, flour, paper, soap, and dried blood. Certain textile materials Birquetting creates dust

NFPA References : 

NFPA References 654 General 664 Wood 61 Agriculture 484 Metal

NFPA References : 

NFPA References 70 National Electric Code 499 Classification of Combustible Dust 68 Deflagration Venting Systems 69 Explosion Prevention Systems 91 Exhaust Systems 2113 Flame Resistant Clothing

Explosions Mentioned : 

Explosions Mentioned Ford River Rouge Rouse Polymerics West Pharmaceutical Services CTA Acoustics Hayes Lemmerz Loss of 25 lives Numerous injuries Substantial property losses West Pharmaceutical Services

Class II locations : 

Class II locations Locations where the combustible dust atmospheres are present

Inspection Scheduling : 

Inspection Scheduling Office of Statistical Analysis (OSA) will prepare a list (based on a random number table) Other facilities with a known pattern of combustible dust hazards (with SICs/NAICS other than the ones listed in Appendices D-1 and D-2) may be added

Inspections : 

Inspections Four per Area Office Complaint or referral Media

Termination of Inspections : 

Termination of Inspections if the CSHO determines that the employer's operation does not have combustible dust explosion, deflagration, or other fire hazards, then the CSHO may terminate the inspection

Safety and Health : 

Safety and Health Non-spark-producing clothing such as natural fiber (e.g., cotton). Recommended that CSHOs be provided with flame-resistant clothing as appropriate Dust collection Non Sparking

Documentation : 

Documentation Plant history of fires MSDS’s Dust Accumulation One liter of dust Photos Interviews – ees, ers

Warning Signs : 

Warning Signs Safety instruction signs Missing on equipment Entrance to places where explosive atmospheres may occur 1910.145(c)(3)

Sample Questions : 

Sample Questions Housekeeping program Is there dust accumulation of 1/32 inch thick? Dust collectors located inside of buildings? Explosion relief venting distributed over the exterior walls of buildings and enclosures?

Sample Questions : 

Sample Questions Does the facility have isolation devices to prevent deflagration propagation between pieces of equipment connected by ductwork? Does the facility have an ignition control program, such as grounding and bonding Fire through a duct is bad

Sample Questions : 

Sample Questions Vacuum cleaners used in dusty areas, approved for the hazard classification? Separator devices to remove foreign materials capable of igniting combustible dusts? Check the label for Class II

Sample Questions : 

Sample Questions Is the exhaust from the dust collectors recycled? Does the dust collector system have spark detection and explosion/deflagration suppression systems?

Sample Questions : 

Sample Questions Are ducts designed to maintain sufficient velocity to ensure the transport of both coarse and fine particles? Are duct systems, dust collectors, and dust-producing machinery bonded and grounded to minimize accumulation of static electrical charge?

Sample Questions : 

Sample Questions Is metal ductwork used? Are bulk storage containers constructed of noncombustible materials? Are employees trained in the hazards of the combustible dust? Are MSDSs for the chemicals which could become combustible dust under normal operations available to employees?

Afterwards : 

Afterwards Closing Conference Region Review Abatement

FY08 Inspections : 

FY08 Inspections 446 Inspections 300+ planned for next year (met already) Over 6.6 violations per Inspection 78% Serious $1116 penalty per Serious

Sample Accident 2008 : 

Sample Accident 2008 Transfer of metal dust into mixer What questions would you ask?

Sample Accident Jan 009 : 

Sample Accident Jan 009 The laminate panels pass on a conveyor underneath a curing UV light.  A panel jammed up underneath the UV light.  The panel heated up to the point where it charred, smoldered and eventually caught fire.  The charred pieces were sucked up into the local exhaust system, where they ignited the dust collector located outside the plant.  The dust collector blew up, sending a shock wave back into/through the plant. Several overhead doors were blown off, and one of these struck 4 employees, injuring them.

Slide 43: 

LABORATORY TESTING OF EXPLOSIVE DUSTS

Explosibility Testing Paths : 

Explosibility Testing Paths Two main branches of testing are available Class II Kst Note – the CSHO must pick ONE branch of testing

Class II Testing : 

Class II Testing Class II tests must be requested if electrical issues are in play Testing uses an electrical arc for ignition source (2.4 joules) Results must not be used for engineering calculations It is much more likely to prove that a dust is explosive, than class II ASTM is withdrawing ASTM E789

Class II Dust Chamber : 

Class II Dust Chamber

Dust Loaded : 

Dust Loaded

Class II Chamber Assembled : 

Class II Chamber Assembled

Kst Testing : 

Kst Testing Unless electrical considerations exist, this is the superior test Ignition source is a chemical igniter (2500 joules) Chamber configuration allows for some engineering calculations Note that the Lab uses a low turbulence chamber – results are lower than high turbulence by 4-5 X Use for rough comparisons only

20 Liter Chamber – KsT : 

20 Liter Chamber – KsT

Loaded : 

Loaded

Prepared for Firing : 

Prepared for Firing

Lab Criteria : 

Lab Criteria ASTM E1226 – KsT – For design ASTM E789 - 1.2L Hartmann Chamber for Class II– Not for design (Being withdrawn) NFPA 499 – Min Ignition temperature

Private Labs : 

Private Labs ~ $1800-2100 (ground to 75 micron or less) ~5%-25% Not Class II If KsT – is negative then in good shape, If over one Bar then Combustible Dust Class II 50% of Pmax and Rate of Pressure Rise of Pittsburg Coal Dust

Private Labs : 

Private Labs Dust may be combustible but not meet Class II requirements ASTM E1226 – KsT – For design 1.2L Hartmann Chamber for Class II ASTM E789 – Not for design (Being withdrawn) NFPA 499 – Min Ignition temperature

Issues : 

Issues

Aluminum Dry Dust Collector 484 : 

Aluminum Dry Dust Collector 484 Dry Type collectors located outside Explosive Dust Warning sign on collector Collectors or cyclone have temperature alarms No recycling of air from powder collectors Collector ductwork blanked before repairs Filter cannot be synthetic Dust removed AT LEAST once a day Dust put in sealed tight metal containers

Wood Dust Collectors 664 : 

Wood Dust Collectors 664 Pneumatics per NFPA 654 No spark producing connected in wood dust collection Dust collector located either -Outside (Not on roofs) - Indoor w deflagration system - Indoor w Fire protection - Indoor w designed relief vents to the outside - Indoor w restrictions (Only for wood processing no grinders/sanders, max air handling of 5000 cfm, fan motor totally enclosed and fan cooled, daily dust removal, collector 20 ft from means of egress, dust collectors separated 20 feet)

Sugar/Grains Dust Collectors 61 : 

Sugar/Grains Dust Collectors 61 Located outside w 2 exceptions - Collector located close to an exterior wall, vented to outside via straight ducts, and design w explosion resistant vents and collectors - Inside w explosion prevention system Separators may be inside Does not apply to bin vent dust collectors Alarm if dust collector shuts down

Dust Collectors 654 : 

Dust Collectors 654 Located outside w 3 exceptions (7.13) - Under 8 cuft - Collector protected – suppression, oxidant reduction, deflagration venting, pressure containment, or vent with flame arresting device - Collection equipped with deflagration ducts that vent to the outside,

Housekeeping : 

Housekeeping Maintain dust free as possible No blow down unless All electrical power and processes have been shutdown. No welding, cutting or grinding unless under hot-work permit Comfort heating equipment shall obtain combustion air from clean outside source.

Housekeeping NFPA 654 : 

Housekeeping NFPA 654 If unclassified locations w 1/32 to 1/64 inch Clean up during same shift If Class II, div 2 clean up to maintain below 1/16 If Class II, div 2 and it gets above 1/8”, then shut down and clean If Class II, div 1 and it gets above 1/8”, then clean to minimize accumulations

Is Wet Wood Dust Combustible? : 

Is Wet Wood Dust Combustible? ASTM test requires less than 5% moisture. Lab dry to less than 5% because it the ASTM test. It may not be representative of what the environment is, but….. What happens process fails and the dust is Drier? Over 99% of wood dust is combustible per class II test.

Combustible Dust Violations : 

Combustible Dust Violations Housekeeping violations 5(a)(1) Violations Electrical Violations

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Dust collectors inside No proper explosion protection systems such as explosion venting or explosion suppression systems.

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Systems were not provided to prevent deflagration propagation from dust collectors to other parts of the plant. October 29, 2003 - Hayes Lemmerz Manufacturing Plant Two severely burned (one of the victims died)

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Excessive dust accumulations in Rooms No explosion relief venting distributed over the exterior walls and roofs of the buildings. CTA Acoustics 2003 – 7 dead Fiberglass fibers and excess phenolic resin powder probably went to the oven while workers were using compressed air and lance to break up a cogged bag house filter

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Dust Collector and ducts do not prevent propagation to other parts of the plant From BS&B

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Ducts and system were not grounded

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Airborne fugitive dust

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations A means of tramp metal protection was not provided to keep any unwanted metal fragments out of the air-material separators. From Duramag

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Excessive dust

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Compressed Air for cleaning

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations No PVC or nonconductive ducts

Typical 5(a)(1) Violations : 

Typical 5(a)(1) Violations Not maintaining duct velocity Aluminum Conveyor velocity 4500 ft/min for pneumatic conveyor

Slide 76: 

Resources

Other Resources : 

Other Resources Eckhoff - Dust explosions in the Process Industry FM Data Sheets OSHA webpage on combustible dust. www.osha.gov www.csb.gov

The Future : 

The Future 300+ Inspection MSDS revisions Less explosions More eyes and awareness – insurance, S&H professionals, media, bloggers, Debate on a standard More Employer Self-assessment

Further : 

Further Any Questions? John Newquist 312-353-5977 Chicago Regional Office Newquist.john@dol.gov Disclaimer. Official Interpretations requests are through OSHA in Washington DC through Directorate of Enforcement Programs.