Recently, I opened an e-mail from Rich Christianson with a request to write a blog post on combustible dust for Woodworking Network. Immediately, my thoughts were wow, this is great, an opportunity to spread the word on combustible dust hazards amongst a professional trade group.
The primary problem is the status quo, warm, and fuzzy version of combustible dust is incorrectly communicated to stakeholders. This is not reality; the hazards are not solely dust explosions. For example, a 2009 Combustible Dust Policy Institute research study of media accounts determined 80% of combustible dust incidents throughout the manufacturing sector are fires not explosions.
Rafael Moure-Eraso, chairman of the U.S. Chemical Safety Board (CSB), recently stated that combustible dust fires involving metal dust can be more severe than other flammables. These fires are often precursors to dust explosions in a metal shop as well as a woodworking shop. Itâs beyond any logical reasoning why OSHA failed to include discussions about fire hazards in the stakeholder meetings and recent expert forum during the rulemaking process.
This data was in conjunction with CSBâs incident data in Table 1 of the ANPRM. Stakeholders may view this information in the OSHA Combustible Dust Standard Advanced Noticed of Proposed Rulemaking (ANPRM) published in 2009 located in the Federal Register.
OSHA hosted a Combustible Dust Expert Forum held in Washington, DC, on May 13. Yet, this only compounded the problem in understanding the depth and breadth of the complex combustible dust issue. For example, the OSHA press release issued two weeks prior to the event mentioned that representatives from various industries would comprise the 14 member expert panel.
Unfortunately this didnât happen as there was no industry representation from the wood, food, metal, paper, etc., industries. For example, where were the Wood Machinery Manufacturers of America experts? Instead, subject matter experts (SMEs) consisted of nine NFPA Combustible Dust Technical Committee members, two organized labor representatives, two insurance industry representatives, one academian, and a CSB investigator. A question arises of where is the diversity in the subject matter expertise?
OSHA did allow approximately 40 to 50 non-participant observers to attend the venue. From talking with my associates over at the LinkedIn Combustible Dust Policy Institute Group, I discovered the seats for the non-participants filled up the day following the press release. For a detailed overview of the topics discussed at the Expert Forum, check out Brian Edwardâs Blog at Conversion Technology.
In addition to no industry representation in the expert forum, subject matter expertise from the professional fire service was absent. So when the fire gets out of hand in your dust collector or ductwork, who you going to call?
Or maybe Iâm off base here. So I pose a question to the readership: Does the fire service have expertise on the heat source and equipment involved in ignition on combustible dust related fires?
If you get a chance please vote on this poll question at LinkedIn. Iâd like to thank Rich for the opportunity to share with you, a view from 30,000 feet on ComDust.
John Astad is Director/Research Analyst at the Combustible Dust Policy Institute in Santa Fe, TX. Since the 2008 Imperial Sugar Refinery dust explosion he has been researching global combustible dust incidents. Through the results of his research work, John has presented at numerous trade, professional, and governmental conferences and seminars. Reach him at firstname.lastname@example.org
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