Combustible Dust… an Explosive Issue CBIA Wellness Health and Safety Conference March 31, 2011 Presented by Jamison Scott More info on combustible dust:

Combustible Dust Topics Covered: What is It? Sawdust Cannon - Myth busters - Creamer Cannon - Powdered Milk Container - Flour Dust - Who’s in Charge? Can it Happen in My Facility? Prevention Air Handling Systems - Copyright 2011 For informational use only

What is It – OSHA Fact Sheet Air Handling Systems - Copyright 2011 For informational use only Combustible dusts are fine particles that present an explosion hazard when suspended in air in certain conditions. Source: OSHA Fact Sheet.

What is It – OSHA List Air Handling Systems - Copyright 2011 For informational use only

What is It – Classic Fire Triangle Fuel (combustible dust) Ignition (heat, spark) Oxygen (air) Remove any one element eliminates the possibility of fire. Air Handling Systems - Copyright 2011 For informational use only

What is It - Dust Explosion Pentagon Fuel - fire (combustible dust) Ignition - fire (heat, spark) Oxygen - fire (air) Dispersion (explosion) (Dust Suspension) Confinement (explosion) Remove any one element prevents explosion, but not necessarily fire!* *the concentration of suspended dust must be within an explosible range, lowest amount of dust in air that will explode, referred to as Minimum Explosible Concentration (MEC) – (1) Air Handling Systems - Copyright 2011 For informational use only

What is It – Particles & Layer Combustible Fine Particles –Deflagrable Wood Dust 420 micons (.425 mm, 425 um micrometers,.0165”) or smaller (having moisture content of less than 25%). Material that will pass through U.S. No. 40 Standard Sieve. Size of fairly coarse sand. However will most likely change in “Dust Layer depth 1/64 in. (0.4mm) or less or the underlying surface colors are readily discernible.” Revised per NFPA TIA March 21, 2011 Air Handling Systems - Copyright 2011 For informational use only

What is It – Primary & Secondary Primary Issues Explosion Secondary Issues Disturbing of dust on structural supports can create a secondary source of fuel Video Clip: (3:20-5:28) Air Handling Systems - Copyright 2011 For informational use only

Who’s in charge Regulatory Organizations & Agencies OSHA - Occupational Safety and Health Administration July Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and ExplosionsCombustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions February 2008 – Imperial Sugar, dust explosion and subsequent fire at a sugar refinery in Port Wentworth, Georgia, caused 14 deaths and left many others seriously injured. March Hazard Alert: Combustible Dust Explosions. OSHA Fact SheetHazard Alert: Combustible Dust Explosions. OSHA Fact Sheet April 2008 – See Congress below Spring The Occupational Safety and Health Administration (OSHA) is considering rulemaking to develop a combustible dust standard for general industry.The Occupational Safety and Health Administration (OSHA) is considering rulemaking to develop a combustible dust standard for general industry Hazard Communication Guidance for Combustible Dust OSHA Hazard Communication Guidance for Combustible Dust OSHA October 21, Combustible Dust ANPRCombustible Dust ANPR October 2009 – Status Report on Combustible Dust National Emphasis ProgramStatus Report on Combustible Dust National Emphasis Program Congress 110 th Congress - April The House passes the Worker Protection Against Combustible Dust Explosion and Fire Act, H.R by a vote of and referred to the Senate.The House passes the Worker Protection Against Combustible Dust Explosion and Fire Act, H.R by a vote of and referred to the Senate. 111 th Congress - H.R Worker Protection Against Combustible Dust Explosions and Fires Act of Same as H.R from 110 th Congress. Status: Referred to Committee. 112 th Congress – U.S. Rep. John Barrow from Georgia reintroduced “Worker Protection Against Combustible Dust Explosions and Fires Act” in the House in February, 2011 Air Handling Systems - Copyright 2011 For informational use only

Who’s in charge Regulatory Organizations & Agencies SBA - U.S. Small Business Administration's (SBA) Office of Advocacy Early 2011 OSHA was exploring creation of SBREFA for April 2011 (Small Business Regulatory Enforcement Fairness Act) requiring OSHA to convene a task force of small business to review effects of OSHA regulations. However per contact with SBA in March 2011 – speaking on condition of anonymity SBA contact said OSHA is rethinking priorities and he is working on getting clarity. NFPA – National Fire Protection Association (Current Edition noted) NFPA 68 Standard on Explosion Protection by Deflagration Venting. (2007 Edition) NFPA 484 Standard for Combustible Metals (2009 Edition) NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids. (2006 Edition) NFPA 664 Standard for the Prevention of Fires and Explosions on Wood Processing and Woodworking Facilities (2007 Edition) Insurance Companies FM Global - Prevention and mitigation of combustible dust Air Handling Systems - Copyright 2011 For informational use only

Who’s REALLY in charge Sugar Refinery Ignored Explosive Dust Before Blast September 25, 2009 by Rruss Bynum, Associated Press Writer Air Handling Systems - Copyright 2011 For informational use only

Can it Happen? (2)

Can it Happen - Explosion Explosion 2008 Georgia sugar refinery explosion The 2008 Georgia sugar refinery explosion was an industrial disaster that occurred on February 7, 2008 in Port Wentworth, Georgia, United States. Thirteen people were killed and 42 injured when a dust explosion occurred at a sugar refinery owned by Imperial Sugar. Combustible Dust Explosion at Motorcycle Rim Manufactured Factory November workers were injured as a result of the dust explosion and 2 of them received serious injuries. The explosion also caused damage to buildings and manufacturing plant, the destruction of the dust collector system and also broke windows of factories nearby. le&id=295%3Acombustible-dust-explosion-at-motorcycle-rim-manufactured- factory&Itemid=118&lang=en le&id=295%3Acombustible-dust-explosion-at-motorcycle-rim-manufactured- factory&Itemid=118&lang=en Air Handling Systems - Copyright 2011 For informational use only

Can it Happen – Inspection OSHA Inspection OSHA: Carolina Skiff cited for combustible dust and hexavalent chromium exposure - $95,000 March 22, US Department of Labor's OSHA fines Waycross, Ga., manufacturer more than $95,000 for safety and health violations Mississippi mill slapped with ComDust violations - $67,800 February SILVER CREEK, MS -- The Occupational Safety and Health Administration has cited a Mississippi lumber mill for a variety of violations, including for having an electrical junction box open in an area where combustible wood dust accumulates. OSHA cited Joe N. Miles & Sons Inc. of Silver Creek with 19 willful and serious safety violations and associated proposed penalties totaling $67, Combustible Dust Exposure Leads to Georgia Company's $55,250 Fine February 2011 – OSHA has cited Protech Environmental South Inc., doing business as U.S. Erosion Control Products Inc., following an inspection that uncovered 46 alleged safety and health hazards including worker exposure to heavy accumulations of combustible dust. Proposed penalties total $55, US Department of Labor's OSHA cites 2 Tuscumbia, Ala., companies for 40 safety and health violations with $121,800 in penalties February 2011 – TUSCUMBIA, Ala. – The U.S. Department of Labor's Occupational Safety and Health Administration is proposing $121,800 in penalties for 40 safety and health violations at two Tuscumbia companies with shared family ownership, Tri-Cities Manufacturing Inc. and Tool Masters Inc. Connecticut plant faces fines for fire and explosion hazards - of $90,500 in proposed fines February The manufacturer of composite manhole covers faces a total of $90,500 in proposed fines, chiefly for potential fire and explosion hazards. Air Handling Systems - Copyright 2011 For informational use only

Prevention Currently OSHA has National Emphasis Program (NEP) Using General Duty Clause Advanced Notice of Proposed Rulemaking (ANPR). ANPR is basically data collect from a series of questions. You will note there is overlap in the various sections. However, “Preparation is the best medicine.” Highlights include: Hazard Recognition/Assessment Engineering Controls Administrative Controls – Document, Document, Document Housekeeping Building Design Explosion Protection Operating Procedures Worker Training Source OSHA ANPR Air Handling Systems - Copyright 2011 For informational use only

Prevention - Hazard Assessment Hazard Recognition/Assessment Recognition/Assessment Determining if dust is combustible via Dust Testing - Explosion Severity Test, Minimum Explosible Concentration (MEC) Communication HazCom Standard, MSDS Industry Standards NFPA State and Local Codes AHJ (Authority Having Jurisdiction) – Fire Marshall, Building Inspector Insurance Company Source OSHA ANPR Air Handling Systems - Copyright 2011 For informational use only

Prevention – Engineering Controls Engineering Controls Fixed measures that are built into a facility or processing equipment to remove or minimize hazard. Primary (building, facility) Prevent accumulation of dust on surfaces, beams, etc. Flat surfaces are not good. Secondary (equipment) Dust Collection Systems Sprinkler system Source OSHA ANPR Air Handling Systems - Copyright 2011 For informational use only

Prevention – Admin Controls Administrative Controls Document, Document, Document Do you have a method to prevent escape of dust? Do you have a policy to remove fugitive dust from surfaces? OSHA wants written rules and procedures Document, Document, Document Source OSHA ANPR Air Handling Systems - Copyright 2011 For informational use only

Prevention - Housekeeping Housekeeping Fugitive Dust Control (NFPA 654, Chapter 8) Dust layers as thin as 1/64 of an inch or less or the underlying surface colors are NOT readily discernible. If you can see dust, don’t ignore it! Clean it up and examine where it’s coming from. Seal all openings in processing and conveying equipment to prevent the release of dust. When you inspect your workplace also consider overhead beams, electrical cable trays, lighting fixtures, and “invisible” areas such as areas above false or suspended ceilings. – Source NFPA Air Handling Systems - Copyright 2011 For informational use only

Prevention – Housekeeping Housekeeping (cont.) Dust Collectors – Clean it Up! NFPA 664 (combustible dust standard just for woodworking) applies to shops larger than 5,000 sq ft or collector greater than 1500 cfm) Essential in any size shop So when it comes to Combustible Dust - Size of shop doesn’t matter, size of dust does. Changing filters, bags, tightening clamps. Explosion Relief – Deflagration Venting NFPA 68 Example: Air Handling Systems - Copyright 2011 For informational use only

Prevention – Housekeeping Housekeeping (cont.) Dust Collectors – Clean it Up! (cont.) Hanging Air Filter for ambient dust. DO NOT blowing off machinery to clean Shop Vacuum or Vacuum Kit which attaches to your dust system for everything else. Using explosion proof vacuum? Sprinklers – Test, Test, Test Building Spark Detection system in Dust Collectors and Ductwork Air Handling Systems - Copyright 2011 For informational use only

Prevention – Finally Building Design Explosion Protection Operating Procedures Worker Training Do the worker know what to do? Have they read the operating procedures? Do they understand? Have they been tested? Air Handling Systems - Copyright 2011 For informational use only

Hot off the Press NFPA March 21, 2011 – TIA (Tentative Interim Amendment) to NFPA 654 March 25, 2011 – Report on Consolidation of the Combustible Dust Committees and Documents

Resources OSHA – Occupational Safety & Health Administration - Combustible Dust: OSHA Advanced Notice of Proposed Rulemaking: Congress - NFPA - NFPA 68: Standard on Explosion Protection by Deflagration Venting NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities US Chemical Safety Board - Imperial Sugar Company Dust Explosion and Fire Air Handling Systems - Copyright 2011 For informational use only

Resources Insurance Company - (registration required) Loss Prevention Data Sheet 7-73, Dust Collectors and Collection Systems Loss Prevention Data Sheet 7-76, Prevention and Mitigation of Combustible Dust Explosions and Fires Combustible Dust Policy Institute Linkedin - The Combustible Dust Forum Building Code Reference Library Air Handling Systems - Copyright 2011 For informational use only

Questions & Summary Jamison Scott More info on combustible dust:

Appendix A Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions Air Handling Systems - Copyright 2011 For informational use only

Appendix B Hazard Alert: Combustible Dust Explosions. OSHA Fact Sheet, (2008, March) Air Handling Systems - Copyright 2011 For informational use only

Appendix C Hazard Communication Guidance for Combustible Dusts OSHA Air Handling Systems - Copyright 2011 For informational use only

Appendix D OSHA ANPR Air Handling Systems - Copyright 2011 For informational use only

Appendix E Status Report on Combustible Dust National Emphasis Program Air Handling Systems - Copyright 2011 For informational use only

Appendix F FM Global – an Insurer’s View Air Handling Systems - Copyright 2011 For informational use only