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Manufacturing Sector is Not General Industry

The absurdity of including the manufacturing sector in the OSHA General Industry Standards really hit home the other day while working the graveyard shift at the refinery. A co-worker and I were having a discussion concerning the Sub Parts of the General Industry Standards in which housekeeping, hazardous communication, ventilation, and PPE have the same requirements for refinery workers as they do for restaurant/fast food workers. This is were I had a bit of difficulty in justifying to Steve that the occupational hazards that we are exposed to in our 12 hour shifts our similar to food service workers as outlined in the General Industry Standards.

So why does construction, agriculture, and the maritime trades have separate OSHA Standards, yet manufacturing doesn't? Each of these sectors have their own unique occupational hazards in the workplace. In 2007 there were 400 fatalities in the manufacturing sector. Leading cause of fatalities in 2007 were from contact with objects and equipment (140), transportation incidents (102), and falls (48).

In 2008, Bureau of Labor Statistics (BLS) reported 689,700 recordable injury or illness cases in manufacturing industries with more than half of these requiring days away from work, job transfer or restriction.. The nearly 14 million workers in this sector had the highest numbers and rates of occupational illnesses with more than 25% of these were hearing loss. So what is so general about this, to be referred as General Industry?

Manufacturing workers have specific risks to hazards that others in General Industry are not exposed to. Such as contact with machinery and equipment, physical exertion, repetitive motions causing musculoskeletal disorders, hazardous exposure to toxic substances, organic solvents, pesticides, dust, isocyanates, chemicals, aerosols, nanoparticles, carbon monoxide, explosions, structural failures, and noise. For example, manufacturing sector fatal work injuries involving fires and explosions was up 14 percent in 2008.

What other General Industry sectors are exposed to as much risk? All the above are specific hazards that are not general in nature and must be addressed accordingly so as to minimize fatalities, injuries, and illnesses. Utilizing these General Industry Standards, relics of the 1970's when the Rubik's Cube was cool and the drive-in movie was still in fashion is not the solution for the 21st Century.

An earlier post with the example of the Ventilation General Industry Standard that is mostly occupational hygiene in nature and not occupational safety concerning inherent fire and explosions hazards in the manufacturing sector is only the tip of the iceberg. Currently OSHA's answer to address this inadequacies is to develop separate standards for different fire and explosion hazards such as combustible dust. So whats next, a Vapor Cloud Explosion Standard.?

After-all, there are many, many more fatalities and injuries as the result of these sort of incidents such as the BP Texas City Refinery incident. It's quite evident that Process Safety Management (PSM) has not had stellar results. So lets have a Vapor Cloud Explosion Standard next. Of course this is not the appropriate solution but only further illustrates the absurdity of the manufacturing sector referred to as General Industry.

The appropriate and most obvious solution is to revise the current OSHA Standards to reflect current occupational hazards that workers are exposed to on a daily basis. Manufacturing is vital to the economic health and security of our nation, which had gross output of $4.5 trillion in 2005, and the most important sector of the U.S. economy in terms of total output (Bureau of Economic Analysis 20081). It's long overdue for manufacturing to be have it's own OSHA Standard like construction, agriculture, and the maritime sectors. Until then all stakeholders can expect additional red-tape and bureaucracy of separate standards included in the OSHA General Industry Standards. Is that the course desired?

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Comment by John Astad on January 15, 2010 at 9:17am
Thanks Dave for the helpful hints on including a video or photo of sample collection and sample identifying markings. The main reason I mention FRC/PPE is due to the numerous burn injuries as the result of workers clothes catching on fire when exposed to combustible dust flash fires.

You bring up a good point on costly best engineering practices where stakeholders will find an alternative less expensive solution in moving their facility to another country. If you get a chance please visit the Combustible Dust discussion group on LinkedIn. It would be great to have your valuable input in the numerous discussions. Thanks
Comment by Dave Hunter on January 15, 2010 at 8:59am
John
I recently helped a client after an OSHA Inspection and Citation based on the Combustible Dust emphasis program. Here again, OSHA is relying on the NFPA standards. There are two NFPA Standards they cited in their violations. They also go tho the US Chemical Board for their expertise.

Currently OSHA doesn't much address PPE exept when cleaning the dust collectors, etc.

But there's a couple of things to remeber. First, the actual dust has to be determined by OSHA to be "explosible". So demand the OSHA lab results. The OSHA Lab uses old equipment and methods and many of the independent testing labs use the newest so you can successfully contest the violation armed with your lab data. Make sure you get a sample at the exact place(s) that OSHA takes theirs and I would include a video or photo of the sample collection and sample identifying markings. The fact there is dust is moot if it's non-explosible. If it IS explosible, then yor're going to spend BIG money for approved dust collection equipment. One of the two NFPA Standards quantify how much dust has to be present to support combustion. OSHA said that was "interesting" but any failure in the future to continue good housekeeping practices or a failure in the dust collection system could raise the amount or concentration to the explosible level so they shot down that defense. OSHA isn't just looking for major explosion hazards; simple duct fires or the possibility of fire is cause to issue citations. They'll deal with the severity in the citation penalty process. After all of this, my client simple quit manufacturing the products that created the dust and now those products are made in Mexico.
Comment by John Astad on January 15, 2010 at 8:10am
Thanks Dave, you bring up a good point that citations can hurt standing with insurance companies and securing new clients. NFPA- 70E is an excellent resource for Electrical Arc FlashArc Blast

I was referring to thermal radiation hazards from propagating events such as combustible dust flash fires and vapor cloud flash fires. Hopefully OSHA will address flame resistant clothing FRC/PPE this in the proposed ComDust rulemaking
Comment by Dave Hunter on January 15, 2010 at 7:38am
Morning, John.

OSHA addresses Thermal Radiation (ex, Arc Flash/Arc Blast) using a part of the OSHA Act of 1970 named "Standards Incorporated by Reference". In this instance such standards as the National Fire Protection Association (NFPA) addresses Electrical Arc FlashArc Blast in publication NFPA- 70E. There is a list of all of these standards in 1910.6. You can go to www.osha.gov to read the list. Pay particular attention to the publication dates because, although there are more current publications available, Congress hasn't approved OSHA to enforce them so even following the newest publication. Complying with the newest standard may still get you a "de minimus" citation, it's still an OSHA Citation and can hurt your standing with insurance companies and securing new clients. Most of these standards has to be purchased (some very costly) but I have found a neat little link where you can read the standards online for free. I found it in the OSHA "Combustible Dust" Directive on their site. Just scroll down the directive and you'll see a link for it. It may be only for NFPA Standards, maybe not. Let me know how you make out.
Comment by John Astad on January 14, 2010 at 3:28pm
Thanks Dave. I was reviewing the JHA Hazard Assessment for PPE and could not find anything for thermal radiation hazards from the effects of flash fires, which occur in the manufacturing sector.
Comment by Dave Hunter on January 14, 2010 at 2:17pm
As a former OSHA Compliance Officer, I offer the following: Do the required Job Safety Analysis and the PPE Job Hazard Analysis. Then the GI Standards will make more sense in their application.

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