Has the Dust Settled?

Spring is around the corner. For many, spring marks a time when we are glad that those dreary winter skies are replaced with partial cloudy, rainy ones. In some areas, it is the rain that washes away salt, ash, and residues from roadways and aids in suppressing pollen in the air from blooming flora. Spring cleaning often occurs to ensure our house is in order. Plant outages are in bloom, and workers say farewell to wintertime blues.

As our seasons transition, so may the fire and deflagration hazards from coal and combustible dust that once were visible and now may be out of sight. Yet often, what is out of sight presents the greatest hazard and risk. So has the dust settled?

The Dangers of Combustible Dust

The U.S. Chemical Safety and Hazard Investigation Board (CSB) started reviewing the hazards associated with combustible dust after a series of lethal fires and explosions occurred in 2003. In 2006, the board published a study that found at least 281 dust explosions and fires occurred in the U.S. between 1980 and 2005. They killed 119 workers and injured 718. As part of the report, the CSB urged the Occupational Safety & Health Administration (OSHA) to enact regulations for controlling dust hazards. OSHA, however, did not begin the process of developing regulations until 2009.

Recently, the CSB released its new findings based on its latest review of serious industrial events. According to its review, there has been no change in the frequency of deaths and injuries from dust accidents, despite more inspections and the implementation of an OSHA education program.

The CSB report points out that there appears to be a trend related to many of these incidents. Often, personnel are not sufficiently trained in hazard recognition and analysis techniques. In addition, there frequently is complacency about the hazards of combustible dust. When these conditions exist, history repeats itself and new industrial accidents happen.

OSHA’s Combustible Dust Standard: Still a Work in Progress

OSHA continues down the path toward enacting a combustible dust standard that would require many industries to better control combustible dust hazards. It’s a long, winding, and tiring pathway, and it may take years before the standard is enacted.

Recently, OSHA officials moved the proposed combustible standard to its long-term agenda, despite pleas from the CSB to put it on the fast track. In January, when OSHA published its twice-yearly regulatory agenda, it included a note about combustible dust regulations that reads “next action undetermined.”

One hurdle OSHA has to overcome in passing the new standard is to document its economic impact. Part of OSHA’s rulemaking process under the Small Business Regulatory Enforcement Fairness Act (SBREFA) review is to give small businesses the ability to participate in the process and give their feedback about the financial impact of complying with the proposed rule. Improvements to dust control systems and other facility upgrades to help control combustible dust typically require significant financial investment, which can be a tough sell to businesses during these challenging economic times.

Meanwhile, OSHA’s Combustible Dust National Emphasis Program (NEP) is very much alive. Under the NEP guidelines, OSHA personnel are encouraged to inspect facilities that generate or handle combustible dusts that pose a deflagration or other fire hazard. OSHA can cite facilities using standards defined by its NEP CPL 03-00-2008, including electrical installations, housekeeping, hazard labeling, personal protective equipment hazard assessment, and the employer’s duty to provide a workplace free from recognized hazards.

Currently, the National Fire Protection Association (NFPA) has a number of combustible dust standards that are specific to certain industries or commodities such as metal or wood. However, the association has identified that there is a great need for an overarching fundamental combustible dust standard. Consequently, the NFPA has assembled a new technical committee that is focused on developing a new standard that deals with the fundamentals of combustible dust. Even though the proposed standard is likely to be fast-tracked, it may take several years before it actually comes to life.

Promoting Safe Practices in the Meantime

During the upcoming PRB Coal Users’ Group annual meeting, which will be colocated with the 2012 ELECTRIC POWER Conference & Exhibition in Baltimore in May, attendees will hear more specifics about the regulatory processes related to combustible dust, learn about actions that may be taken to prevent or control fire and deflagration hazards, and hear from those who have been impacted by serious incidents involving combustible dust. For example, attendees will be able to meet Tammy Mizer, whose brother died in a combustible dust event and find out how family, friends, coworkers, and communities are affected. Her story is real and personal, and it’s a springboard to why the subject of safety is so critical.

During the first 30 days of 2012, our industry was impacted by an average of one fire or deflagration per day. For many reasons, little is known about these incidents, let alone shared, but they continue to happen.

Is it time for spring cleaning? The dust hasn’t settled, and if it has, it’s likely to be a deflagration risk.

Bob Taylor is chairman of the PRB Coal Users’ Group (http://www.prbcoals.com).