Editor’s note: Jamison Scott, chairman of the Wood Machinery Manufacturers of America’s Combustible Dust Task Force, attended one of the two Monday, Dec. 14, Combustible Dust Stakeholder meetings hosted by the U.S. Occupational Safety and Health Administration. Scott, who is a corporate officer of Air Handling Systems, was joined by WMMA Legislative Council John Satagaj and Niels Pedersen of Dantherm Filtration

By Jamison Scott

WASHINGTON – The Occupational Safety and Health Administration held a pair of meetings to solicit public comments concerning its proposal to create a national combustible dust standard.

The morning session I attended included about 15 OSHA representatives, including Jordan Barab, deputy assistant secretary of labor for occupational safety and health. Also in attendance were about 35 stakeholders, including representatives of small and large businesses, trade associations, the Small Business Administration, industry consultants, lawyers and labor unions.

Barab said the goal of a potential OSHA standard regulating combustible dust hazards is to “protect workers” and noted that the “rulemaking process is slow and painful.”

The three-hour meeting focused on four main points of discussion: National Fire Protection Assn. Standards, Scope, Economic Impact and Hazard Mitigation.

NFPA standards set the stage
The NFPA has established voluntary standards on combustible dust hazards that are widely recognized in state and fire prevention safety codes. The potential formal adaptation of NFPA standards for regulating combustible dust in the workplace created very good dialogue and focused on the benefits and challenges of using NFPA standards as sanctioned “compliance alternatives.”

Regulation exemptions debated
The “Scope” discussion focused on whether certain types of facilities should be exempt from the regulation. For example, it was suggested that operations that generate mineral dust should be excluded because it is not combustible. It also was pointed out that limestone is actually used to minimize coal dust’s potential to explode.

One of the stakeholders questioned whether small indoor unitary dust collectors should be excluded from the standard. Another stakeholder suggested that as long as there was a potential for even a small dust collector to explode, it should not be excluded. Yet another stakeholder recommended that operations with fewer than 50 employees should be exempt because they would be less likely to have the resources to employ staff to manage a combustible dust rule.

Cost concerns
“Economic Impact” also was a heavily debated issue. How could the rule be crafted to optimize benefits of safeguarding workers without creating economic hardships for employers?

Someone from the marine industry said he was very concerned about the potential economic hardship on five-man boat building shops in Maine. Come to think about it, that concern applies to thousands of woodshops throughout the country. I pointed out that the owner of a small shop has many things to juggle and that if OSHA wants to create a code that protects the employees they must make it simple and not overly burdensome.

Several stakeholders recommended that the potential rule include easy-to-understand language and that it be made readily available to manufacturers without cost. It was noted that the NFPA standards pertaining to combustible dust hazards can be viewed online, but that there is a charge for printing or downloading them from the NFPA’s Web site.

Time was running out as the discussion of “Hazard Mitigation” began - the last item on the agenda. One point of interest that came up was how an OSHA combustible dust rule would take into account technological improvements in dust abatement, considering that a regulation usually is updated every few years.

Click here to learn more about OSHA’s Advanced Notice of Proposed Rulemaking for Combustible Dust.


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