Blog | Fauske and Associates, LLC

OSHA Combustible Dust Citations - Who Are They Writing Up?

Written by AnnMarie Fauske | Jul 23, 2014 3:00:00 PM

A quick look at Occupational Safety & Health Administration (OSHA)'s website can tell you this:  in the last 2 years, 154 establishments have been given citations for combustible dust, flammable dust and other explosible dust hazards alone (this does not include respiratory related citations).  What industries are still being cited, despite Section 5(a)(1) of the Occupational Safety and Health Act of 1970?  Pharmaceutical, Food, Agriculture, Cosmetic, Manufacturing, Plastics/Polymers, Wood, Paper/Pulp, Metals top the list.

Here's one citation at a large comic book manufacturing facility: "The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to powder coating dust explosion and deflagration hazards from dust collection equipment that was not adequately designed to prevent or minimize employee exposure in the event of an internal deflagration event: (a) On or about May 1, 2012, the ********* pneumatic pulse cartridge indoor dust collectors associated with powder coating dust collection had deflagration relief panels with discharge locations within employee occupied areas. (b) On or about May 1, 2012, the *********  pneumatic pulse cartridge indoor dust collectors associated with powder coating dust collection lacked a means of deflagration isolation protection to (1) the units collection drums and (2) upstream equipment. (c) On or about May 1, 2012, the cyclones associated with powder coating dust collection lacked a means of explosion protection.

Here's another for a well-known plastics manufacturer: "OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees. Employees working in the area of the recycle room were exposed to fire and explosion hazards in that the 8 dust collector cyclones were located inside the building and were not protected with deflagration or suppression protection. Among other methods, a feasible method to correct this hazard is to comply with the National Fire Protection Agency (NFPA) 654 "Standard for the Prevention of Fire and Dust Explosion from Manufacturing, Processing, and Handling of Combustible Particulate Solids" and NFPA 68 "Standard on Explosion Protection by Deflagration Venting", including but not limited to: a) Relocate the dust collector outside of the building (NFPA 654). b) If necessary to locate the dust collector indoors, direct vented material to the outdoors with appropriate vent ducting (NFPA 68)."

And, here's a poplular pet food manufacturing facility: "OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to combustible dust deflagration and explosion hazards while working at or near indoor dust collection systems involving combustible dusts such as flour, gluten, plasma, HAEC, and other combustible dries ingredients which were not designed to prevent or minimize employee exposure in the event of an internal deflagration: a. Silo Room: The indoor filter media-type Flex-Kleen silo #1 dust collector (model: 18-BV-9) lacked a means of explosion protection; including deflagration propagation protection (isolation) for the upstream flour silo #1 via the inlet, and for the downstream silo #1 weigh bin via the material discharge. b. Silo Room: The indoor filter media-type Flex-Kleen silo #2 dust collector (model: 36-BV-9/II) lacked a means of explosion protection; including deflagration propagation protection (isolation) for the upstream HAEC silo #2 via the inlet, and for the downstream silo #2 weigh bin and secondary filter sock via the material discharge. c. Dries Dump Area: The indoor filter media-type Premiere peas, wheat, rice (FMD) dust collector's (model: F/R-24-36) explosion protection system lacked deflagration propagation protection (isolation) for the upstream cyclones A & B for the cannery loaf mixers A & B scale hoppers, two reclaim cyclones, and five super sack stations via the inlet. d. South Rail Pit: The indoor filter media-type Kice dries area dust collector's (model: VR45-10) explosion protection system lacked deflagration propagation protection (isolation) for the upstream micro weigh bin systems 1, 2, and 3, day bin 1 weigh bin, VMP weigh bin, and all 14 super sack stations via the inlet. e. South Rail Pit: The indoor filter media-type Mac central vacuum dust collector (model: 54FRB14) lacked a means of explosion protection; including deflagration propagation protection (isolation) for the upstream vacuum system via the inlet, for the downstream open top tote via the material discharge, and for the downstream exhaust air outlet associated with the exhaust fan. f. South Rail Pit: The indoor filter media-type Kice pasta veggy dust collector's (model: VR14-6H) explosion protection system lacked deflagration propagation (isolation) for the the upstream pasta and veggies cyclones for the West, center, and East hoppers via the inlet, and for the downstream discharge reject pipe via the material discharge. g. Semco Room: The indoor filter media-type Mac HAEC dust collector (model: 72AVR14) lacked a means of explosion protection; including deflagration propagation protection (isolation) for the two upstream reclaim cyclones and five super sack stations via the inlet, and for the downstream tote via the material discharge."

There's a recurring theme among many who've been cited.  Just because a facility has dust collection equipment, it does not necessarily make them free of hazards.  A process hazards analysis (PHA) should be conducted on a regular basis to ensure equipment is meeting all requirements.  

A PHA is a systematic evaluation of the hazards involved in the process.  PHAs are required for initiation of a process and at least once every five years after that.  It is important to address normal operating conditions as well as start-up, normal shut down and emergency shutdown procedures during the PHA.  The PHA team should be multi-disciplinary, including operations, engineering and maintenance.  To properly conduct a PHA, the process safety information (PSI) must be as complete as possible.  A lab can provide PHA services including PHA auditing / review, revalidating PHAs and facilitating. 

Engineering and testing labs such as Fauske & Associates, LLC (FAI) perform PHAs for compliance to OSHA PSM requirements as well as combustible dust related PHAs for compliance per national National Fire Protection Association (NFPA) guidelines: NFPA 654, NFPA 664 and NFPA 484. 

FAI provides a full range of PHA services, using a variety of techniques including, hazard and operability (HAZOP) analysis, what-if, checklists, failure modes and effects analysis (FMEA) as well as quantitative risk assessments such as layer of protection analysis (LOPA). 

Be sure you are up on all your equipment and its safety risk.  For more information on PHAscombustible dust, gas and vapor flammability and other hazards such as chemical process, please contact: Zachary Hachmeister, Director of Operations, Fauske & Associates, LLC, 630-887-5223. www.fauske.com