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COMBUSTIBLE DUST REGULATIONS OFF OSHA’S AGENDA, BUT DANGER REMAINS

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COMBUSTIBLE DUST REGULATIONS OFF OSHA’S AGENDA, BUT DANGER REMAINS

Part of the Trump administration’s push to support American manufacturers has involved cutting back on regulations. Several OSHA regulations in progress, including the new silica and beryllium exposure limits, have had their start dates pushed back so they can be reviewed. For industries that deal with the risk of combustible dust, one of the biggest changes may be that the administration has removed the proposed combustible dust regulations from OSHA’s agenda.

 

What was the plan for combustible dust regulations?

 

The delayed silica and beryllium regulations had already been put in place before the Trump administration requested review of them, and you can expect that they will still be implemented at some point. The combustible dust regulations, though, had been discussed, debated, and delayed for a long time before the current president took office.

 

The Chemical Safety Board (CSB) is an independent federal agency that investigates industrial accidents, including dust explosions. They have been pushing for combustible dust regulations for years, with one major push coming after the disastrous Imperial Sugar dust explosion in 2008, where one smaller explosion ignited sugar dust that had accumulated all over the building, killing 14 people and completely destroying the facility.

 Imperial Sugar dust explosion in 2008 with no combustible dust regulations

Another incident that prompted the CSB to push for combustible dust regulations was a titanium dust explosion in West Virginia that killed three workers in 2010. Throughout the next several years, the CSB kept combustible dust regulations on its “most wanted list” of new rules it considered necessary to prevent industrial accidents and deaths.

 

There are already combustible dust regulations for the grain industry, where explosions from dust in silos, elevators, conveyors, and mills is a constant hazard. The CSB and other safety organizations hoped to push this type of regulation to cover all types of combustible dust.

 

What kept the combustible dust regulations from happening?

 

Every year OSHA reviews laws and regulations they want to work on. Combustible dust regulations have been on that list for several years, but have been delayed or not decided on. The main problem is that such a regulation would affect nearly any industry that produces dust, since almost all dust is potentially explosive, and every process that causes dust to be produced.

 

With uncountable numbers of different types of dust and different processes, making combustible dust regulations that could cover all of these was a very difficult task from the beginning. This kind of regulation would have to cover industries from food to metalworking to plastics to pharmaceuticals. It would be a huge job to figure it all out and make it enforceable.

After math of a Dust Explosion

Facility on fire after dust explosion

Fire Dept at the scene of a recent Dust Explosion

Does that mean OSHA can’t fine you for combustible dust problems?

 

Except for the grain industry, OSHA does not have combustible dust regulations that they can use to fine violators. However, they have issued many guidelines and recommendations for combustible dust safety. These are not enforceable. However, that does not mean combustible dust can be ignored. OSHA does have enforceable regulations for fire protection, ventilation, general environmental controls, and hazardous materials. Uncontrolled dust in your facility may be a violation of any of these.

 

In addition to these rules, OSHA can enforce serious fines in situations where workers are injured or killed on the job because employers did not correct a dangerous situation. In the event of a combustible dust explosion with injuries or deaths, serious penalties could be enforced for letting a hazardous situation occur.

 

Even without concern for combustible dust regulations, lawsuits against a company for injuries or deaths in a dust explosion are quite likely, and they could cost much more than any OSHA fine.

 

 

What guidelines should you follow to prevent combustible dust hazards?

 

The National Fire Protection Association (NFPA) does not make combustible dust regulations. However, they do set standards for managing combustible dust and preventing dust fires and explosions. NFPA standards are often considered the industry standard, and many local and state building codes require that facilities meet NFPA standards. NFPA 652 and 645 deal specifically with combustible dust.

 

Even though OSHA does not have combustible dust regulations, state and local safety administrations or building codes may have regulations that are much stricter than OSHA’s. NFPA standards are the gold standard by which many state and local governments set their safety regulations.

 

Why are engineering controls such as dust collectors so important?

 

The only good way to keep combustible dust from creating an explosion hazard is to get it out of your facility. Since blowing industrial waste into the surrounding atmosphere tends to be frowned upon, a dust collection system that filters the combustible particles out of the air can be the best solution.

 

Even if a fire does occur in a dust collector, properly designed systems will have safety features such as fire suppression, explosion venting, and abort gates to safely control or divert a combustible dust explosion. While OSHA does not have a regulation to enforce dust collectors for combustible dust, they do strongly recommend them, and the NFPA also strongly recommends a well-designed dust control system as a key safety feature.

 

flame-arrestor

2 SECOND LEAN IS HAPPENING AT IMPERIAL SYSTEMS!

In our recent newsletter, we talked about the commitment that we’ve made to the 2 Second Lean program here in our company. It’s been exciting to see how people have embraced the idea of continuous improvement, and we’ve been making videos to record some of the ways we’ve applied lean principles to our office and shop areas!

 

This before-and-after video shows one of our first big improvements based on the 2 Second Lean principles. Does your company have a supply or storage closet that’s become a collection area for assorted stuff that doesn’t have a home anywhere else? Justin will walk you through the improvements we made, and you’ll be able to see how this got turned from a room-sized junk drawer into a useful work and storage space.

 

 

As you can see, we’ve applied 2 Second Lean tools like labeling items, marking where things should be stored, and posting pictures of what the area should look like. It’s shined, sorted, and standardized, and there will be no more rummaging around to find the mop bucket or the paper towel rolls. It was a big project but it’s now a big time-saver.

 

In this video, you’ll see a messy tool box in the grinding area with everything thrown in together. You’ll also see how it gets turned into an example of a 2 Second Lean improvement. Instead of a pile of tools and supplies, we now have a perfectly organized cart.

 

 

With a clearly labeled spot for every tool, wheel, and other supplies, this cart can be moved to wherever in the work area someone needs it. No more wasted steps from people walking back and forth to get the tools they need. Tools get returned to their proper location, and it’s easy to see if you’re running out of wheels or belts. This 2 Second Lean project is just one example of the continuous improvement that’s been happening all over the shop.

 

Check out our YouTube channel to see all our 2 Second Lean improvement videos. Make sure you don’t miss the before-and-after video from our own famous “Good Luck with That” Charlie!

LEAN SOLUTIONS FOR DUST COLLECTION

If your company is following the principles of lean manufacturing, is your dust collection system keeping up? Lean is everywhere, eliminating waste and improving processes. However, many companies trying to find lean solutions haven’t taken a look at that ancient baghouse rusting away behind the building. Can you apply any of these lean solutions for dust collection?

In our last post we talked about an efficiently running dust collection system, and how this reduces waste and saves time and money. This time, we’re going to look at the system design and see whether yours is as lean as it could be.

 

SITUATION 1:

You have several pieces of equipment in your building that generate dust. The equipment doesn’t move around, and most of the dust or fume is generated at a particular point. Examples can be a plasma or laser cutting table, a blast booth, a mixing machine, or many others.

The leanest solution for this situation would usually be source capture. Hoods can be located directly over the equipment, or the equipment can be designed with dust collection built in. An example of this is a downdraft system on a plasma cutting table. These lean solutions for dust collection make sure the dust generated at certain spots doesn’t get out into the rest of the area.

Source Capture Dust Collection System diagram

 

SITUATION 2:

In your facility, welders and fabricators work on assembly of large steel items. The workers usually move around the piece they’re working on. It’s not practical to put hoods over the entire area: the sources of the dust and fumes are moving around, and you would need too many hoods. This would require a huge amount of air flow and huge fans, which is not efficient.

In this situation, the best lean solution for dust collection might be an ambient system. This type of system filters the air in the entire area. It is designed to change over all of the air inside that space within a certain period of time. As it does this, it removes dust and fumes, even if the sources are moving around and can’t be put under a hood. It will keep all the air clean, not just the air around particular machines or work areas.

Ambient Dust Collection System Diagram

SITUATION 3:

You have a machine shop with welders and fabricators working on different equipment at different times. Some of the machines might have hoods over them, and the cutting table might have a downdraft system on it. These are examples of source capture.

Another type of source capture often used in these situations is a fume arm. This flexible arm is situated near the welder, and he adjusts it as he works to capture the fumes. He needs to keep the hood of the arm positioned correctly so it’s catching the plume coming from the welding.

While in theory this is an effective method of source capture, it is not a lean solution for dust collection. Time is spent repositioning the hood. Welders deal with the issue of having the hood in the way of the work area, slowing down the process. It is difficult to position the hood correctly for maximum efficiency. These all create wasted time, worker frustration, and inefficient fume collection. The end result: the fume arms don’t get used, and your system is wasting airflow because it’s not collecting anything at those points. Check out the article where Imperial Systems Inc. President Jeremiah Wann tackles this issue directly. Click Here.

In this situation, your system may be able to do double duty as an ambient and source capture system. You can still have the dust collector attached to the cutting table for downdraft fume collection, and hoods over stationary work areas. However, you need a lean solution for dust collection from your welding or similar work areas.

Having ambient dust collection makes sure that the air in the entire facility is clean. It’s often said in lean manufacturing that the best solution is the one people will actually use. Considering that fume arms are often used wrong or not used at all, they’re not the best lean solution.

 

 

For each company or workplace, there are lean solutions for dust collection, but they are different for each situation. Contact us to talk to one of our systems specialists and figure out the leanest way to handle your dust collection.