OSHA NATIONAL EMPHASIS PROGRAM: FOCUS ON COMBUSTIBLE DUST

by Erin Long | May 15, 2019 | Uncategorized

In 2008, the OSHA National Emphasis Program on Combustible Dust became official. As a result, this left many people asking what a “national emphasis program” means. Does it require businesses to take any action? Moreover, does it create any new fines or penalties?

One thing has become clear since 2008: the National Emphasis Program OSHA instituted has some teeth. While businesses cannot be fined under the Combustible Dust NEP, OSHA inspectors are using other regulations to fine companies for combustible dust issues.

Why did they create the National Emphasis Program?

Safety organizations like the Chemical Safety Board have been pushing for an OSHA combustible dust standard. To this end, they cite several disasters related to combustible dust. In many of these cases, the obvious hazards should have been addressed.

The strongest push came after three major accidents that all happened in 2003. First, West Pharmaceuticals had plastic dust accumulated in the ceiling which ignited, killing six people. Second, CTA Acoustics had a buildup of resin dust which caught fire and caused seven fatalities. Third, Hayes Lemmerz suffered multiple explosions of aluminum dust. Aluminum dust is a well-known hazard that should be managed.

The OSHA NEP did not create any new standards. But it did inform federal and state inspectors how they could focus on combustible dust and standards that already existed. Companies should already be following these standards. So inspectors can issue fines for them.

The OSHA National Emphasis Program also creates educational materials about combustible dust. These are available on OSHA’s website. They explain the basics of combustible dust hazards and ways to reduce the risks.

What does the OSHA National Emphasis Program do?

The OSHA NEP puts a focus on inspecting companies that handle or create combustible dust. There is no specific combustible dust rule that OSHA can fine a company for violating. However, under this program, OSHA has been issuing some serious fines using existing rules.

Federal inspectors found over 4,900 infractions during combustible dust related inspections.  This is according to OSHA in the year after the National Emphasis Program was put into place. Since there is no specific combustible dust standard to violate, most of the violations fell into these categories:

• Hazard Communication (27%)
• Housekeeping (20%)
• Electrical (11%)
• Personal Protective Equipment (11%)
• Fire Extinguishers (11%)
• Other General Duty Clause hazards

How do these rules relate to the OSHA National Emphasis Program and combustible dust?

Hazard communication rules state that for any hazardous material, there must be plans in place for handling it. The employer must communicate this plan to all employees. Further, everyone must be aware of the steps for handling the material safely.

Employers may be in violation of this rule if they do not make their employees aware of a combustible dust hazard. In addition, they must implement a plan for managing the hazard.

Housekeeping rules and combustible dust make sense. The OSHA NEP can be enforced when a facility fails to keep up with housekeeping. For example, keeping dust off floors and flat surfaces. Allowing combustible dust to gather causes many dust explosions. At the same time, this provides fuel for secondary explosions.

Citations for electrical issues related to combustible dust focus on faulty electronics or wiring. As a consequence, these could provide an ignition source for combustible dust. Airborne dust that meets an electrical spark can ignite and cause an explosion.

Personal protective equipment (PPE) citations under the OSHA NEP happen when workers are exposed to various dust hazards without PPE. This might include respirators or skin protection.

OSHA has many rules involving the placement and inspection of fire extinguishers. Likewise, employers can be cited during an OSHA NEP inspection for breaches of these.

Hazard-free Workplace

The General Duty Clause states that an employer “shall furnish to each of his employees a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees”.

This is very broad.  Under this rule, the OSHA National Emphasis Program can cite employers for any situation that puts employees at risk, including combustible dust.

One major reason? “OSHA found that the majority of facilities inspected under the NEP had dust collectors located inside the buildings without proper explosion protection systems”.

What does the OSHA Combustible Dust NEP mean for employers?

The National Emphasis Program does not put any new rules on employers. However, it does allow OSHA inspectors to inspect based on possible combustible dust hazards. This means that any type of workplace handling combustible dust can face an OSHA NEP audit.

If you have no safety violations in any of the areas listed above, you probably will not be cited under the OSHA Combustible Dust NEP. Most of OSHA’s citations under this standard have been “serious”  or “willful.” In other words, putting employees in real danger or knowingly ignoring an existing hazard.

To make sure, now would be a good time to contact Imperial Systems, Inc about our ServiceMAXX program. We can inspect and review your existing dust collection system. Then you can address problems to make sure employees and the workplace are safe.

Environmental Air Quality: For the World’s Clean Air

by Erin Long | May 3, 2019 | Uncategorized

In honor of Air Quality Awareness Week, we’re focusing on environmental air quality, indoors and out. When talking about dust and fume collection systems, we often discuss OSHA regulations for exposure inside the building. However, EPA regulations on dust and fume control limit what can be released into the environment.

Air quality control inside a facility protects worker health. It also protects the facility from combustible dust hazards. The same hazardous dust and fumes that could harm workers inside, though, could also contaminate environmental air quality outside.

Metal Contaminants from Industry

Many industrial processes produce heavy metal contaminants. Many people think of foundries, mining, and steel mills when they hear about environmental air quality. However, fumes released from many processes can cause contamination in the environment. For example, metalworking, battery manufacturing, and smelting can be added to the list of potential polluters.

Metals that are dangerous in very small amounts include:

• Lead
• Arsenic
• Cadmium
• Mercury
• Chromium (hexavalent chromium)
• Nickel
• Zinc
• Copper

Very fine metal particles produced by industrial processes are the most harmful for environmental air quality. They can be carried for long distances in the air. Moreover, this means they may contaminate soil and water a long way from the source.

Many of these metals are known or suspected to cause cancer. Further, others like lead and mercury cause damage to the nerves and brain.

Some companies may not realize that their fumes include these metals. However, metals like steel can contain nickel, zinc, chromium, or other materials as alloys. These are good reasons to have a dust and fume collection system to protect workers at the facility… but what about the environment?

Dust and Fume Control for Environmental Air Quality

Removing dust and fumes from a building doesn’t make them disappear. These materials are harmful because they can remain floating in the air for people to inhale. They can also end up in water supplies or contaminate the soil.

All manufacturing companies are responsible for air pollution control in their facilities. To prevent air pollution from industrial processes, dust and fumes must be captured with air filtration. Dust collection systems serve double duty: they provide clean air inside the facility and trap harmful materials before they can get outside.

Part of preventing air pollution is the quality of dust collector filters. Filters need to be efficient enough to capture the smallest particulates the process creates. DeltaMAXX nanofiber filters capture particles as small as 0.3 microns, enough for most applications. If higher filtration is needed, HEPA after-filters can be used.

By capturing dust and fumes instead of blowing them outside, companies take responsibility for preserving environmental air quality. People who live and work near industrial areas need to be protected from harmful air pollution.

Maintaining environmental air quality improves people’s lives. Companies who invest in a dust and fume collection system can be proud that they are protecting their workers and protecting the environment. The “we just open the doors and blow it outside” philosophy might get dust and fumes out of the shop, but it passes the danger on to others. We are all responsible for what we put into the air, water, and soil around us.

Skilled Trades in Our Industrial Fabrication Shop

by Erin Long | Apr 30, 2019 | Uncategorized

An industrial fabrication shop like Imperial Systems needs its skilled tradespeople. When you see pictures of our facility, you see lots of welders and other metalworkers. These people are certainly the backbone of any fabrication company. But pictures don’t always do justice to the many other skilled trades needed to keep our business moving.

Skilled Trades: Metalworking in Our Fabrication Shop

Our company would not exist without our metalworkers and other skilled tradespeople on the shop floor. In other words, our dust and fume collection equipment would just linger as a pile of sheet metal. Some of the skilled trades at work in our fab shop are:

• Welders
• Grinders
• Machine operators
• Plasma cutting operators
• Powder coating
• Maintenance and repair
• Assembly

Repair and maintenance also include our constantly traveling ServiceMAXX teams. These teams perform everything from filter changes to electrical work.

Things also wouldn’t get far on the shop floor without the managers. These include the plant manager, production manager, supply chain manager, and shipping manager. They are very experienced and skilled people. Above all, they keep fabrication going smoothly and orders going out on time.

Before a job makes it out for fabrication, it goes through the engineering team. These professionals transform the system that the customer wants into instructions for the fabrication shop to build it. Then our skilled tradespeople turn a drawing into a CMAXX or a BRF.

Other Skills: Keeping Things Running Behind the Scenes

A fab shop needs more than skilled metalworkers and shop managers to function as a business. For example, our accounting team handles money going in, money coming out, and any issues in between. They make sure we all get paid, obviously an essential task. They also do double duty handling many human resources functions like benefits and new employee paperwork.

You might not think that a fabrication shop would need a software engineer. But a person with this skill is essential to keeping things running. Everything from sales to shipping relies on a working computer system. In addition to his programming work, our software engineer is always willing to help keep computers and servers running.

You’re probably not surprised that a metal fab shop needs a team of salespeople. Without their work, the shop might not have dust collectors to build. While salespeople don’t go to school to learn sales, there’s a lot of training that goes into being good at this trade.

Our equipment salespeople and aftermarket salespeople must be experts in our products. Equipment salespeople travel frequently to meet potential customers. Aftermarket salespeople maintain our good relationships with customers and help them solve problems.

All those product brochures and blog posts and logos don’t appear from nowhere, either. Graphics design experts are skilled tradespeople who create our brand’s image. Even an industrial fabrication company needs to look professional.

Our graphic design team works with the company content writer. She writes features like our company newsletter and articles published in magazines. Content writing is a mix of skills, including writing, researching, and optimizing website traffic.

Our Fabrication Shop: Many Skills, One Working Company

Our company needs a mix of skilled tradespeople and many other jobs. Industrial metal fabrication relies on its skilled trades metalworkers. Behind the scenes, though, there’s a team of other people working to keep the company running.

Get a professional degree, learn a skilled trade, or make your own career path. A company like ours has a place for you. Without our skilled tradespeople, products wouldn’t get built and our fabrication company wouldn’t exist.

Many industries, not just metal fabrication, owe much of their success to people in the skilled trades. From medical to construction to electronics, skilled trades drive industry. Remember: many supervisors, managers, and even company owners got their start in skilled trades!

National Welding Month: Welding Facts and Trivia

by Erin Long | Apr 15, 2019 | Uncategorized

Some Interesting Welding Facts As We Recognize National Welding Month

1. Welding started in the Bronze Age when people first began using different types of metals. Blacksmiths mastered the art of forge welding, or heating pieces of metal to red heat and then hammering them together.
2. Welding using electricity started in the 1800s, but the welds were often brittle because the metal oxidized. Welded seams at this time were prone to failure.
3. The 1920’s saw research into shielding the welding arc with various gases to prevent welds from becoming brittle from exposure to oxygen. Eventually, this research would lead to early versions of all shielded welding processes.
4. The first industrial robot ever put into use was a spot welder used by General Motors. It weighed two tons.
5. In space, there’s no oxygen. Because metals can’t form their usual layer of oxidation, two different types of metal that touch each other in space will instantly weld themselves together.
6. According to the Bureau of Labor Statistics, the average pay for welders across the United States is $19.35 per hour. Most welders have a high school education.
7. There are an estimated 410,000 welders, cutters, solderers, and brazers working today. The average age of these welders is 54 years old, suggesting that not as many young people are choosing it as a career.
8. Welding jobs are expected to grow at a rate of 6% to 10% over the next twenty years, not including the need to replace retiring workers.
9. 50% of all manufactured products, from bridges to computers, go through some type of welding during their manufacturing.
10. Welders with special skills, like underwater welding, can make up to $100,000 per year. These jobs require extensive training in the special challenges of the work.
11. Welding as an art form has led to some amazing metal sculptures that are on display all over the world. Welded art has become a growing industry.
12. Besides standard welding methods, some applications use ultrasonic vibrations to cause metal molecules to bond together. Others use explosions to create enough pressure to force metals to bond.
13. Many industries, including the automotive industry, use robot welders in their manufacturing process. While the robot welders can repeat the same welding tasks over and over, they are no substitute for an adaptable human welder.

Share your count!

So how many of these welding facts did you know? Share your answer in the comments of our Facebook post now.

Got a welding fume extraction problem in your shop? Contact us here at Imperial Systems!

The Dangers of Phosgene Exposure [Infographic]

by Erin Long | Apr 10, 2019 | Uncategorized

This brief infographic describes the dangers of phosgene exposure. Phosgene is a potentially deadly gas that should be avoided at all costs. Phosgene gas is created when heat is applied to brake cleaner, making it a potential hazard to welders. While a dust and fume collector will not eliminate phosgene, you can take proper precautions to avoid it.

Over 100,000 tons of various chemical weapons were used during World War I. One of these was responsible for 85% of chemical warfare-related deaths. Mustard gas is typically the first World War I chemical weapon that comes to people’s minds. However, it was another gas that was responsible for 76,000 Axis and Allied deaths.

Phosgene exposure was the deadliest chemical weapon used during World War I

The Geneva Protocol of 1925 prohibited the use of chemical warfare but did not totally eliminate the risk of phosgene exposure. The risk is now present in the welding community. When heat is applied to brake cleaner, it has the potential to produce phosgene. Cleaning metal with brake cleaner before welding can be potentially deadly.

Oftentimes, symptoms of phosgene exposure are not seen for 24 hours. These include burning of the eyes and throat, blurred vision, coughing, difficulty breathing, pulmonary edema, nausea, vomiting, low blood pressure, and heart failure. It is often assumed that chemicals sold over the counter must be safe, but phosgene exposure can be deadly. Make sure you read the safety data sheet for any chemical you use in your shop.

Imperial Systems cares about the health of our welders, as well as welders all around the world. That’s why we make equipment to help welders breathe better and work safer. Unfortunately, some hazards cannot be eliminated by the presence of a dust and fume collector.

Learn more about phosgene gas in this related blog post.