In 2006, the Chemical Safety Board identified 281 combustible dust incidents between 1980 and 2005. One hundred and nineteen workers were fatally injured, and 718 were hurt plus facilities were damaged.
After 2006, the CBS has confirmed 106 more incidents up to today.
The following questions arise:
Are we aware of all the possible hazards involved in our manufacturing operations?
Do we have all the sources available to identified all the hazards involved?
Have you been aware of generating combustible dust?
Have you been aware that some of your raw materials in the solid state (powder) are combustible?
In 2018, The CBS launched a survey to assess the current state of combustible dust knowledge in various industries.
In this article, you will find my answers provided based on my experience in the pharmaceutical, chemical, manufacturing and food industry.
In real-world working conditions, where dust is an inherent aspect of the operation, can a workplace be both dusty and safe?
The answer is NO. We assumed that your dust is not combustible. The accumulation of it on top of motors and other equipment might cause overheating that can cause a fire.
Considering the dust is combustible, and your electrical installation and equipment are not rated according to regulations, codes and standards the risk of fire arise.
In such working environments — where the amount of ambient/fugitive dust cannot be wholly eliminated 100 percent of the time — how does an individual or organization distinguish between an acceptable or safe dust level and one that has been exceeded? How often does judgment or experience play a role in such decisions? Should it?
The NFPA 654” Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids” indicates the maximum allowable levels of accumulation in reachable and unreachable areas.
Companies should have inspections programs to verify dust accumulation levels.
How are hazards associated with combustible dust communicated and taught to workers? What systems have organizations successfully used to help their employees recognize and address dust hazards?
Some other questions come up to the table to answer this question:
- Do you generate fugitive combustible dust?
- Do you have raw materials in a solid state (powder) that are combustible?
- Do you have all the pertinent information to determine if the dust or powder is combustible?
- Have you conducted a process hazard analysis (PHA) of your manufacturing process?
- Have you collected all the process safety information?
All the questions asked before need answers to provide training to the workers involved in hose manufacturing operations.
Once the organization have all this information, the OHS department needs to establish the content of the training program, how to communicate action items from PHAs, and set the frequency of the training according to the OSHA 1910.119 “Process Safety Management of Highly Hazardous Chemicals.”
In Canada, the organization need to follow the OH&S Act and Regulations of the Province.
What are some of the challenges you face when implementing industry guidance or standards pertaining to dust control/management?
The primary challenge is not conducting the hazard and risk assessment that will help the organization to find out about combustible dust hazards present in their manufacturing operations.
Another challenge might be the organizational culture in general on quality and safety matters.
I am sure if the organization has a good quality culture, in consequence, the safety culture is there.
If companies/facilities need to use separate or different approaches in order to comply with both sanitation standards for product quality or food safety and those associated with dust explosion prevention, then how do you determine what takes priority? Is the guidance clear?
I like this question because it emphasizes the main challenges in the industry.
In my opinion, organizations do not need different approaches. For example, in the pharmaceutical industry, the company does not need to have a change control and management of change separated programs. You robust the change control program to follow the local health regulations such as FDA or Health Canada, and with OSHA at the same time.
How should the effectiveness of housekeeping be measured? What methods work best (e.g., cleaning methods, staffing, schedules)?
The OHS department can create PMs to follow schedules.
The OHS department should conduct the hazard and risk assessment to determine procedures, equipment and recommended training to perform the cleaning activities.
As equipment is used and ages, it requires mechanical integrity to maintain safe and efficient operability. How does inspection, maintenance, and overall mechanical integrity efforts play a role in dust accumulations, and how are organizations minimizing such contributions in the workplace?
The mechanical integrity program will let engineering and OHS department know if the efficiency of the equipment has been affected by dust accumulation, the effectiveness of the cleaning schedules or accumulation of dust have been found inside of equipment and cause a fire.
It is imperative to continue to follow the MI program effectively.
What are some of the challenges to maintaining effective dust collection systems?
One of the challenges is when the properties of the dust become different causing your dust collector is out of parameters. I have seen it many times.
Engineering should approach the manufacturer to find solutions. Manufacturers have been facing this challenge several times; therefore, they are a reliable source of information.
Cleaning is another challenge to maintain the effectiveness of the dust collector’s operation.
How common are dust fires in the workplace that do not result in an explosion? Does this create a false sense of security?
The organizations shall conduct PHAs, collect all process safety information, having cleaning and training programs implemented to avoid these occurrences.
Near misses must be investigated to identify root causes that will help us to prevent occurrences in the future.
Are workers empowered to report issues when they feel something needs to change with regard to dust accumulation? What processes are in place to make these concerns known?
They should be.
The organization should use their existing hazard and incident report system as a tool to report, investigate to establish CAPAs that will help them to have the same incident in the future. Also, it can be used for training purposes as well.
How can combustible dust operators, industry standard organizations, and regulators better share information to prevent future incidents?
The engineering and OHS department would subscribe to regulatory agencies and participate in the feedback process when regulations, codes and standards are in draft status. It is imperative to participate in this process to establish effective communication between both parties.
In conclusion, it is imperative to conduct some activities to identify potential deflagration scenarios. These are activities are:
- Know if your dust or powder is combustible.
- Conduct Process Hazard Analysis.
- Conduct the Dust Hazard Analysis.
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