The drive toward new combustible dust regulations continues to pick up speed.

Last month the Occupational Safety and Health Administration (OSHA) put out an advance notice of proposed rulemaking and sought comments, data and other relevant information related to the hazards of combustible dust in the workplace.

According to a 2006 report issued by the Chemical Safety Board (CSB), there were 280 dust fires recorded over a period of 25 years, resulting in 119 fatalities and 700 injuries. But it took the massive explosion at the Imperial Sugar refinery in Port Wentworth, GA, killing 14 and injuring dozens of others in February 2008, to put combustible dust safety squarely on the front burner of rulemaking activity.

In September, the CSB concluded its lengthy investigation of the Imperial Sugar mill tragedy, ruling that the explosion could have been prevented. The CSB noted that the plant had inadequately designed and maintained dust collection equipment, conveyors and handling equipment. These mechanical and engineering flaws were compounded by inadequate housekeeping practices that allowed high accumulations of combustible sugar dust and granulated sugar to build up throughout the refinery’s packing buildings.

On top of all this, the CSB’s final report noted a lack of dust training for employees and a failure by the company to conduct evacuation drills.

OSHA Steps up Dust-Related Inspections
In October 2007, OSHA initiated its Combustible Dust National Emphasis Program in inspect facilities that generate or handle combustible dusts that pose an explosion or other fire hazard.

Following the Imperial Sugar tragedy, OSHA stepped up its combustible dust inspection efforts to focus on 64 types of industries, including wood products and furniture. Between October 2007 and June 2009, federal and state OSHA inspectors visited more than 1,000 facilities; 25% of them were wood products plants and 5% were furniture making operations.

The following list includes the top five recorded types of violations made during the combustible dust inspections. It makes the outline of a checklist for wood products managers to put together for their plants.
• HazCom, 27%;
• Housekeeping, 20%;
• Personal protective equipment, 11%;
• Electrical hazards, 11%;
• Fire extinguishers; 11%.

The next highest ranked type of violation related to OSHA’s general duty clause. This includes some examples that are certain to hit home with many woodworking shops, including:
• Dust collectors inside buildings without proper explosion protection systems;
• Rooms with excessive dust accumulations not equipped with explosion relief venting;
• Dust collection systems that did not maintain a velocity of at least 4,500 fpm to ensure transport of both coarse and fine particles;
• Interior surfaces where dust accumulations could occur, not designed or constructed to facilitate cleaning and to minimize combustible dust accumulation;
• Lack of regular cleaning schedules or not established for walls, floors and horizontal surfaces like ducts, pipes, hoods, ledges, beams, etc

Would your plant pass muster?
I think the question I asked in my column bears repeating: Would your plant pass muster if OSHA inspectors knocked on your doors unannounced looking for potential combustible dust hazards?

If you have any doubts, now is the time to audit your plant’s dust collection equipment, cleanliness, maintenance programs and dust training. Don’t wait for OSHA to hit you with a fine that averages $1,233 per violation. Do it for your employees, your product quality and the long-term viability of your business.

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