Do you know the major difference between combustible grain dust and combustible manufacturing dust? Even though both provide potentially explosive atmospheres in the workplace, OSHA regulations for grain dust hazards have been in existence for two decades while there have been no comprehensive regulations for combustible dust in the manufacturing, non-manufacturing, and utility sectors
You are right John. There has been a disconnect between OSHA grain standards, combustible dust standards, and PSM. I would not be surprised if OSHA eventually merged com dust into PSM. This can be done with a simple letter of interpretation.
I am guessiing a bit here but I suspect this anomaly may be explained because the grain industry in North America is huge and has been for a very long time,this fact contributes to the number ,frequency and publicity of dust explosions in the grain industry.
Speaking as a Grain Milling professional ,we millers pride ourselves on our safety record and understanding of the explosion hazards in our industry,we are educated in dust explosion hazards early in our training and have been for decades. I don't know what other industries do ??
As a young flour mill apprentice my first text book "The Practice of Flour Milling Vol 1" ( first published1966 by the National Association of British & Irish Millers) has the best part of a chapter dedicated to Dust Explosions,Explosion mitigation,Explosion relief,prevention of explosion propagation ,and the importance of good housekeeping in preventing secondary explosions.
In fact having just looked at a copy I notice that the illustrations of examples of chokes and baffles in screw conveyors to prevent explosion propagation are identical to those illustrated currently in the NFPA codes -great to see consistency we should have more of it and better communication across industries.
Hopefully with feedback from concerned stakeholders during the soon to be published ANPRM OSHA rulemaking comment period, the topic of PSM will be evaluated. The NFPA combustible dust standards already have many element of PSM such as Management of Change (MOC).
Thanks Ged for the valuable input from the grain sector prospective. The other national industries (NAICS) in the manufacturing sector can learn from the grain sector on the prevention and mitigation of combustible dust hazards that is already occurring globally. Here is a helpful link to the "The Practice of Flour Milling Vol 1" ( first published1966 by the National Association of British & Irish Millers) that GED has shared with group members.
The Imperial Sugar catastrophy drove Georgia in 2008 to adopt a new state regulation; not perfect but,at least, a good start. It used NFPA 654 and defines: a “Combustible Dust” shall mean, for the purpose of this chapter, any finely divided solid material that is 420 microns or smaller in diameter (material passing a U.S. No. 420 microns or smaller in diameter (material passing a U.S. No. 40 Standard Sieve) and presents a fire or explosion hazard when dispensed and ignited in air. (From NFPA 654). It also "borrowed" from other NFPA guidelines.
Unfortunately, the federal government continues to be passive and retroactive in its approach to creating new regulations to prevent death and human suffering. Manufacturing lobbyists and the current USA economic state are not supportive of the much needed change at this point and time. Past history indicates that more blood, burns, and corpses shown on TV after each catastrophic dust explosion occurs will have to be shown before our representatives in Congress enact the required regulations. Just remember what actually happened before 1910.119 was enacted: Bhopal, Pemex Mexico, Piper Alpha, Flixborough, Phillips Pasadena, Arco, Seveso, Carbide Nitro, etc., etc., etc..
The public is still not aware of the dangers and the potential presented by combustible dusts versus that of toxic,flammable and combustible chemicals. First strategic step,in my opinion, is to educate the public of the dangers of combustible dust.
Keep up your valued leadership efforts in this area.
Thanks for your valuable input Antoni. Hopefully the OSHA combustible dust rukemaking will address combustible dust related fires, which are the precursors to eventual dust explosions. According to media accounts, over 80% of incidents last year were combustible dust related fires
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