Combustible Dust New Emphasis on an Old Hazard

2 Agenda l OSHA emphasis l Technical Information l BIW Findings l Conclusions l Recommendations/Suggestions

3 West Pharmaceuticals Services Nylon fiber explosion and fire fatalities

4 Hayes Lemmerz International Aluminum dust explosion and fire fatality 6 injuries

5 Combustible Dust Incidents

6 Fatalities Per Year

7 Question l Why is the trend on dust explosions and associated fatalities increasing? Is it... ä Lack of regulations? ä More companies reporting incidents? ä Introduction of new materials with unknown hazards? ä Industry apathy – lack of knowledge? ä Aging facilities and a very slow accumulation of dust? or ä All of the above?

8 The Catalyst for Change Imperial Sugar Refinery Savannah, Ga fatalities 37 injured

9 More Recently l Imperial Sugar Refinery Incident 2008 l CSB recommends that OSHA issue a General Industry Regulation for combustible dust ä Congress supported the recommendation l Interim measures include: ä OSHA re-issued their National Emphasis Program (NEP) on combustible dust (CPL ) n included outreach, training, and enhanced enforcement ä On March 11, 2008, Edwin Foulke, Assistant Secretary DOL, OSHA, issued a letter to Nicholas Chabraja, Chairman of the Board General Dynamics and other businesses

10 National Emphasis Program (NEP) l OSHA trained Compliance Officers to recognize combustible dust hazards (CPL & 008) l Between November 1, 2007 and February 24, 2009, OSHA inspected 813 sites with a focus on dust hazards (with another 148 inspections in states with OSHA-approved State plans) ä 3,662 violations ä OSHA inspection trend continues

11 Commonly Cited Issues l Dust collectors were located inside a building without proper explosion protection systems l Horizontal surfaces were not minimized to prevent the build up of dust – design phase l Air from dust collectors was recycled through ductwork back into the work area l Duct work from the dust collection system to other areas of the plant was not constructed of metal

12 OSHA Takes Action l OSHA doesn’t have a combustible dust standard, so they cite the General Duty Clause based on consensus standards such as: ä NFPA 484: Combustible Metals ä NFPA 654: Manufacturing, Processing and Handling of Combustible Particulate Solids ä NFPA 664: Wood Processing and Wood Working Facilities l A regulation is being developed ä ANPR was issued October 21, 2009 ä Comments were due by January 19, 2010

13 OSHA Takes Action (cont.) l OSHA Combustible Dust Expert Forum held May 13, 2011 in Washington, DC ä Scope of Combustible Dust Standard n Does it address only the extremely explosible dusts or all combustible dusts? n Does it include facilities with any amount of combustible dust or only large producers? n Does it exclude certain industries? ä Focus on Preventing Secondary Explosions n Should standard focus only on secondary events (fugitive dust) and omit requirements that address only primary explosions?

14 OSHA Takes Action (cont.) ä Applying Standard to Existing Facilities n How should a rule address high potential costs of engineering controls? n Are facilities already complying with NFPA Standards? n Grandfather clause? ä Use of Multiple Layers of Protection n Given costs and benefits, should multiple layers of protection (e.g., engineering controls plus housekeeping) be required? Comment: No consensus among the experts. OSHA will have a difficult time writing a regulation

15 Recent News l OSHA has been four years since the NPRM l Lawmakers are frustrated l May 1, 2013, the House Committee on Education and Workforce reintroduced a combustible dust bill ä Asks for an interim final standard that is based on existing NFPA standards

Technical Information

17 Typical Fire Triangle Liquids and Gases

18 Combustible Dust Pentagon Combustible Dust/Fuel Oxygen/Air Ignition Source Confinement of Dust Dust Explosion Oxygen/air Dispersion of dust

19 Conditions for a Dust Explosion l Dust must be explosible - dependent on: ä make-up of dust ä particle size (<40 mesh sieve or < 420 microns) l Dust concentration must be above the MEC (Minimal Explosible Concentration) – requires confinement

20 Dust Concentrations l Examples of a potential explosible concentration: (unit of measure is grams per cubic meter) ä You can’t see a 25-watt light bulb through a cloud 6 feet away ä You can’t see your hand held out at arm’s length

21 Dust Concentrations (cont.) l Even the dirtiest shipyard process (abrasive blasting) does not reach explosible concentrations l Problem – No real time measurement device to determine dust concentrations – Use IH gravimetric methods

22 Airborne Dust l Housekeeping is a key engineering control. Elevated surfaces are a priority and are often overlooked, especially in shipyards. l Overhead dust can dislodge if an initial disruption (primary explosion, earth quake, or collision) occurs. l Should the OSHA standard focus on the initial disruption, the secondary explosion, or both?

23 Airborne Dust (cont.) l Combustible dust that is airborne is a potential explosion hazard ä Usually related to process equipment, vent ducts or dust collectors ä Not easily inspected and no test equipment available to determine real time concentrations ä Most safety professionals do not have the ability to quantify the hazard ä CDEM (Coal Dust Explosibility Meter) has been developed. Measures percent rock dust to coal dust. Not applicable to other dusts

24 Laboratory Testing l Several labs can determine if a dust is combustible - use OSHA NEP for guidance l More difficult to determine if dusts are explosible and at what concentration ä 20-liter test sphere is called out in NEP and NFPA documents (being revised) ä Dust is air-injected into a cylinder that contains strong igniters (dual 5KJ) until a pressure increased occurs ä Screening test -$695 Go / No-Go test ä Chilworth, Fauske, Fike

25 Laboratory Testing (cont.) l Explosible dusts are classified in accordance with their Kst values (explosion severity) ä ST 0 = non-explosible (silica) ä ST 1 = ( Kst) weak explosion (sugar) ä ST 2 = ( Kst) strong explosion (flour) ä ST 3 = (>300 Kst) very strong explosion (Al)

26 20 Liter Test Chamber

27 Combustible Dusts l Areas in maritime industry that may have combustible dust include: ä Carpenter/wood working shops ä Composite fabrication shops ä Abrasive blast operations ä Powder coating operations ä Paper shredders ä Grinding dust – metal or paint ä Paint overspray – ventilation duct work ä Aluminum or titanium chips or dust ä Powdered metals in machine shops

28 BIW Internal Assessment l Inspected all areas of shipyard where a dusty process was occurring with a focus on ä Adjacent areas ä Overhead horizontal surfaces ä Inside vent ducting l Sampled dust in suspect areas to determine if it was combustible ä Steel dust (fines) from blasting operations ä Nomex composite dust ä Powder coat ä Paint overspray in filter plenums ä Industrial dust l Tested internally and externally l Reviewed dust collection equipment for compliance to OSHA NEP and NFPA standards

29 BIW Test Results l Six samples of very fine steel dust from abrasive blasting operations were sent for a screening test ä Results indicated an explosible dust ä Additional testing performed to determine Kst value - Kst = 13 (ST 1 dust – weakly explosible) l Based on test results all blast facilities were vacuumed from top to bottom ä S everal weeks of work and lost production time ä $$$$$ OUCH l BIW Lab continued to test the steel dust and could not make an explosion

30 Dust Collector Explosions l Dust collectors represent the most common piece of equipment associated with dust explosions (per Factory Mutual study conducted over a 10-year period prior to 1995) l 58 dust collector explosions were reported by three (3) insurance companies ä $14.73 million in losses (1995 dollar value) l The explosion hazard inherent in dust collection processes is widespread ä The dust being collected is the fuel, the airflow supplies plenty of oxygen, airborne dust particles and material clinging to filtration media provide the dispersion, and the collector itself is a vessel of confinement. The only element missing is the ignition source

31 Clearly there were no explosion vents installed on this dust collector Dust Collector Explosions Picture taken from the internet

32 Dust Collector Requirements l BIW inspected to ensure that dust collectors: ä Were located outside of buildings - oops ä Were equipped with explosion venting - oops ä Had explosion vents directed in a safe area away from personnel - oops ä Did not recirculate air back into the building – oops ä Verification that they are properly bonded and grounded - oops

33 Nomex Shop Dust Collector Recirc to bldg No explosion vents Recircs back to bldg No bonding verification

34 New Nomex Dust Collector Is equipped with explosion dampers with IR eyes so air can be recirced

35 Carpenter Shop Dust Collector External exhaust Prior to replacement, this wood dust collector was located and exhausted inside the building Explosion Vents

36 Torit Dust Collector – Blast Building Abrasive blasting dust collectors

37 Inside a Torit Dust Collector Banks of filter cartridges collect fine dust particles, then get shaken or pulsed to release the dust

38 BIW Test Results l BIW Lab still couldn’t get dust to explode – kept trying l Consulted dust expert who recommended we have Fike Industries retest in larger cylinder (1M 3 ) ä Results were non-explosible for all 6 samples ä Approximate cost: $5000 per sample l 20 L test results can be misleading ä ST 1 dusts with Kst less than 50 can produce a false-positive indication in a 20L test chamber ä Test anomaly is called “overdriving” ä Igniters cause the pressure increase, not the dust

39 1 M 3 Test Chamber

Hardings Powder Coat Booth Cleaning Process 5/5/10

Sweep floor and shelves into grated floor section of booth Grated Floor Sections

42 Blow down using 30 PSI nozzle – Vent is operating 10 feet from camera15 feet from camera Based on rule of general rule (hand at arm’s length) this process is not at a concentration near the MEC – Sample on 5/4/10 ( gms/M 3 ) MEC of powder coat is >26 gms/M3 per MSDS

43 Fugitive emmissions Fugitive emissions caused by blow down Dust from blow down exiting the booth

44 Process Changed l The goal of the powder coat team must be to reduce fugitive emissions from the booth ä Reduce the need for clean up of overhead beams ä Reduce potential for dust explosions l Potential methods ä Sweep first to get majority of dust, then vacuum rather than blow down ä Plug holes in booth

45 Conclusions l Primary concern for initial explosions is dust collectors ä Check their locations ä Make them compliant l Housekeeping is the key to preventing secondary dust explosions ä Must include a focus on elevated, often ignored areas ä Accumulations can occur unnoticed over long periods of time and this long latency period creates a situation where people don’t recognize it as a hazard

46 Conclusions (cont.) l Lack of a real-time testing device to determine if an explosible concentration exists results in inconsistent application of controls l Dust collector manufacturers are reluctant to warrant their equipment l Assessment of a potential explosible dust hazard is best left to the experts l Common sense may be the best prevention method - housekeeping

47 Conclusions (cont.) l Industry is not fully aware of the hazards l Businesses, fire departments, codes officers, and state regulators may not be educated on combustible dust hazards l Fire fighters’ initial response must be unique and contrary to normal firefighting procedures ä Do not shut down a dust collector on fire ä Let it burn and protect surrounding structures

48 Recommendations/Suggestions l Identify your dusty processes l Determine if the dust is combustible – testing l Inspect the adjacent areas with attention to overhead spaces l Assess your dust collectors ä Location – outside if possible ä Ducting – do not recirculate air ä Bonding/grounding – verify it ä Blow out panels installed l Develop a housekeeping program l Keep your eyes out for a proposed standard!

49 OSHA Schedule for Regulation l ANPRM 10/21/2009 l Stakeholder Meetings 12/14/2009 Washington D.C. l ANPRM Comment Period End 01/19/2010 l Stakeholder Meetings 02/17/2010 Atlanta l Stakeholders Meetings 03/09/2010 Chicago l A webchat for combustible dust was held on 6/28/10 l OSHA Combustible Dust Expert Forum held 5/13/11 l “Worker Protection Against Combustible Dust Explosions and Fires Act” was introduced by the U.S. House Committee on Education and the Workforce (3/2013) ä Bill suggests that the OSHA interim final std be based on NFPA stds l Initiate SBREFA 10/00/2013 (small business regulatory enforcement fairness act)