By Rich Christianson
ROSEMONT, IL – Not all dust is created equal and, thus, all dusts should not be regulated equally by a federal combustible dust standard.
That fact was echoed by many of the participants of today’s Combustible Dust Stakeholder Meeting organized by the Occupational Safety and Health Administration and held at the Crowne Plaza Hotel in west suburban Chicago.
Approximately 150 stakeholders attended the morning session, including about 20 who actively participated in the three-hour informal discussion. Participants and observers represented a wide variety of interests, including those involved in wood products, steel, sugar refining, feed and grain, dust collection and safety consulting.
The "informal" meeting was an opportunity for interested persons to speak their minds and possibly influence the nature and scope of OSHA’s combustible dust rule without worrying about having them attributed by their name to a federal record.
In her opening remarks, Dorothy Dougherty, director, directorate of standards and guidance for OSHA, said she could not assign a date to when a federal combustible dust rule would be issued, but hastened to add, “This is a key priority of (the Obama) administration.” She also said OSHA planned to address this matter as quickly as possible while making sure it “gets it right” in hopes of avoiding the potential for a lawsuit.
Much of the meeting’s discussion centered on the potential costs manufacturers would bear by a likely combustible dust standard. The assumption is that the standard will mimic or at the very least incorporate many aspects of the voluntary standards crafted by the National Fire Protection Assn. (Most of the comments at today’s opposed adoption of the NFPA standards.)
These associated costs include testing of dust samples to determine their characteristic risk to ignite; outfitting new plants with compliant dust collection, spark detection and fire suppression systems versus the presumably higher cost of retrofitting existing plants with improved ComDust abatement systems; and training employees to identify and eliminate combustible dust hazards.
Participants commenting on the cost of testing, suggested prices ranging between $500 and $600 per sample. In the case of woodworking, consider the number of species of wood or brands of composite panels used to get a hint at what such a requirement might cost a company.
A couple of participants suggested that OSHA should consider adopting tables of approximately 3,200 types of dust and their ability to combust, developed in Europe so that individual companies would not have to conduct their own dust characteristic testing.
Throughout the proceedings, some of the participants suggested that some dusts that pose no or a very minute risk to combust be exempt from the standard. For example, a representative of the metal industry said silicon used in the casting process be exempt. It may create a dust plume, but being inorganic sand, it will not combust, he said.
Representatives of the grain industry suggested that current OSHA rules governing grain dust are sufficient and have helped create a safer workplace as indicated by far fewer combustible dust incidents and injuries and deaths since they were adopted.
Additional discussion revolved around whether small shops should be exempt or on how much the standard should consider ignition sources in a workplace that would influence the risk of a ComDust incident. Woodworking explosions, for example, are usually triggered by a spark created by a mechanical process where metal strikes metal.
More Education Required
Several participants pointed out the need to educate companies about combustible dust issues so that they can do a better job of house cleaning to mitigate them. Training should be required under OSHA’s Hazardous Communication Standard, but more burdensome ComDust certification is not necessary, according to those who addressed this topic.
In addition, several noted that too often, companies that have never experienced a combustible dust incident, might be lulled into the false sense of security that their operation is full-proof. As one participant noted, “Just because you have a 40-year track record of never having an explosion, doesn’t mean you won’t have one tomorrow.”
“None of us want to have a ComDust incident or put our workers at harm,” added another participant. “But none of us want to go out of business meeting (an overly burdensome) regulation.”
The Chicago-area meeting was the third time and place OSHA held such ComDust stakeholder meetings. The first was held in Washington, DC, and the second in Atlanta.
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