Industrial dust collection systems are a crucial tool in ensuring workplace safety, sustainability, and environmental compliance. These systems are not just equipment needed for your processes and facilities to produce effectively; they are state-of-the-art safety measures. However, to maintain their effectiveness they require modern validation and certification methods. Regular assessments are essential, especially when process conditions change.
The Consequences of Non-compliance
Extraction systems that handle explosive dust are made up of numerous vital components. These components must work in harmony to provide the expected safety. When a system malfunctions or doesn’t perform as intended, it can lead to a host of issues:
Production Impacts: Malfunctioning extraction can disrupt the production process, resulting in downtime and decreased productivity.
Health Concerns: Operators exposed to dust due to inadequate extraction can face significant short and long-term health problems, leading to absenteeism, reduced workforce efficiency, reduced worker morale and productivity, and sickness and injury among your team. One example is silicosis, a lung disease caused by long-term exposure to fine silica dust.
Increasing Costs: Neglected preventive maintenance, monitoring, and operational tasks result in unplanned costs for repair and replacement of worn and broken equipment.
Safety Risks: Failure to ensure your equipment is up to date increases the risk of dust explosions, which can have catastrophic consequences, endangering lives and property.
Compliance and Inspections
For all ATEX equipment (equipment used in explosive atmospheres), regular inspections are mandatory. The specific intervals and requirements vary based on the manufacturer and notified bodies responsible for type approval. Compliance checks must include the following…
Explosion Isolation System Inspection Requirements:
A clear description of the intended use of the explosion isolation system.
Operational requirements.
Installation requirements.
General arrangement plans.
Commissioning requirements.
Maintenance guidelines.
Periodic Inspections
Regular inspections are crucial to ensure that the explosion isolation system maintains its capability and reacts as originally designed in case of an explosion. Procedures after an explosion are also a vital part of compliance.
Inspection Points
Specific inspection points are listed in user manuals, and in most cases, only authorized engineers can perform these inspections. Even when end users are allowed to inspect, it’s strongly recommended to engage knowledgeable companies like Baghouse.com for an annual inspection. Book Now Your Baghouse System Audit.
Inspectors can identify issues beyond the checkpoints. For instance, they can uncover dust deposits on valve seats, which, if not cleared, can render safety components ineffective in the event of an explosion. Safety is contingent on the entire system functioning correctly, not just individual components.
Documenting the Inspection
A documented inspection or maintenance, conducted by an authorized company, is the formal way to prove compliance with OSHA and NFPA standards. Documentation is essential in case of accidents or incidents to demonstrate that regular maintenance occurred. When individuals without adequate training or authorization conduct inspections, they bear full responsibility for any faults. Conversely, following instructions and maintaining proper documentation shifts responsibility away from the end user.
We can assist by providing annual safety inspections for Dust Collection Systems in various industrial applications. These inspections include a comprehensive functional test of the entire system and a summary of recommendations based on our on-site survey for each dust collector.
Training for Safety
Regular training for key personnel is crucial. This includes not only personnel directly involved with the equipment but also those responsible for emergency procedures, such as Building Management System (BMS) operators. Having an accessible emergency checklist is vital for quick, effective responses during alarms, ensuring everyone knows what to do in critical situations. Read more about our Training for Maintenance and Safety Personnel.
In conclusion, compliance with safety and environmental regulations is non-negotiable in industrial dust collection systems. Regular inspections, documentation, and expert assistance are your best allies in maintaining a safe, compliant, and efficient dust collection operation. Our experts are ready to help you evaluate, diagnose, and improve the safety and efficiency of your dust collection system, ensuring a secure and sustainable workspace for all.
If you have any questions or need assistance with your dust collection system compliance, feel free to reach out to us. Your safety and peace of mind are our top priorities!
https://www.baghouse.com/wp-content/uploads/2023/09/Audit.jpg538910Andres Biancottihttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngAndres Biancotti2023-09-12 23:08:492023-09-13 16:12:25Dust Collection System Compliance – Ensure Your System Will Pass an Audit
Introduction: The Importance of Dust Collection Compliance
Maintaining a safe and healthy workplace environment is a top priority for any business, and for industrial facilities, effective dust collection is a critical component. Not only does proper dust collection help protect workers from respiratory hazards and potential dust explosions, it also ensures compliance with regulatory requirements.
The Occupational Safety and Health Administration (OSHA), the Mine Safety and Health Administration (MSHA) and other government organizations set standards and guidelines to safeguard employees and minimize the risks associated with airborne particulates.
In this guide, we will explore the key aspects of dust collection compliance, covering everything from OSHA regulations to combustible dust hazards, design considerations, emissions monitoring, and more. By understanding and adhering to these essential requirements, businesses can create a safer working environment, mitigate potential hazards, and maintain regulatory compliance.
Occupational Safety and Health Administration (OSHA) Regulations
OSHA regulations apply to most private sector employers and their workers. Formed as a result of the Occupational Safety and Health Act of 1970, OSHA’s mandate is to ensure safe and healthy working conditions. If you are located in the US, it is likely that your facility is subject to OSHA standards.
OSHA provides guidance documents, fact sheets, and publications to help you understand and comply with their regulations. You can find these by searching the OSHA website. While you should be familiar with all OSHA requirements (consult your site EH&S expert), here are some key OSHA standards and regulations that are relevant for dust collection and control:
General Duty Clause: The General Duty Clause (Section 5(a)(1) of the Occupational Safety and Health Act) requires employers to provide a workplace free from recognized hazards that can cause serious harm or death. This clause serves as a broad requirement for employers to address dust hazards and implement effective dust control measures.
Respiratory Protection: OSHA’s Respiratory Protection Standard (29 CFR 1910.134) establishes requirements for the use of respiratory protection when employees are exposed to dust that exceeds permissible exposure limits. It includes guidelines for selecting, fitting, and training employees on the use of respiratory protection equipment.
Hazard Communication: OSHA’s Hazard Communication Standard (29 CFR 1910.1200) requires employers to properly identify and communicate the hazards associated with dust and ensure that employees are trained on the safe handling, storage, and disposal of hazardous substances.
Walking-Working Surfaces: OSHA’s Walking-Working Surfaces Standard (29 CFR 1910 Subpart D) includes requirements for maintaining clean and safe working surfaces, free from accumulations of dust or debris that could create slip and fall hazards.
Electrical Safety: OSHA’s Electrical Standard (29 CFR 1910 Subpart S) includes requirements for electrical equipment used in areas where combustible dust may be present. It addresses measures to prevent ignition sources and the potential for electrical hazards in dust collection systems.
Machine Guarding: OSHA’s Machine Guarding Standard (29 CFR 1910.212) establishes requirements for safeguarding machinery to protect workers from moving parts, including dust collection equipment. It ensures that appropriate guards are in place to prevent employee contact with hazardous machinery.
Combustible Dust: Although OSHA does not have a specific standard solely dedicated to combustible dust, they have issued guidelines and directives related to combustible dust hazards. OSHA’s Combustible Dust NEP (National Emphasis Program) provides guidance for inspecting facilities that handle combustible dust, emphasizing compliance with existing standards and the identification of potential hazards. See below for more information on combustible dust requirements.
It is important to note that OSHA requirements may vary depending on specific industry and location. Consult your relevant OSHA standard and your local EH&S professional to ensure compliance with all applicable regulations.
OSHA’s Combustible Dust National Emphasis Program (NEP)
OSHA’s NEP program is a directive aimed at addressing the unique hazards associated with combustible dust in various industries. The NEP provides guidance to OSHA compliance officers regarding the inspection, enforcement, and compliance activities related to facilities that handle combustible dust materials. The program aims to increase awareness, promote compliance with existing OSHA standards, and reduce the risk of dust-related incidents including fires and explosions.
The most critical Requirements of the NEP include:
Inspections: OSHA compliance officers conduct inspections of facilities that handle combustible dust. These inspections focus on identifying potential dust hazards, evaluating compliance with applicable standards, and determining the effectiveness of dust control measures.
Employee Training: Employers are required to provide adequate training to employees regarding the hazards of combustible dust, safe work practices, and emergency response procedures. Training should cover topics such as dust control measures, housekeeping practices, proper equipment operation, and the use of personal protective equipment (PPE).
Hazard Assessment: Facilities must conduct a thorough hazard assessment to identify potential sources of combustible dust, assess the severity of the hazard, and implement appropriate control measures. This assessment should consider factors such as dust generation, accumulation, dispersion, and ignition sources.
Housekeeping Practices: Proper housekeeping practices play a critical role in controlling combustible dust hazards. Facilities must establish regular cleaning procedures to minimize the accumulation of dust on surfaces, equipment, and ventilation systems. Vacuuming, sweeping, and other methods should be employed to prevent excessive dust buildup.
Ignition Source Control: Facilities must implement measures to control potential ignition sources that could ignite combustible dust. This includes proper electrical equipment selection and installation, grounding and bonding procedures, and isolation of ignition sources from dust-handling areas.
Engineering Controls: Employers are required to assess and implement appropriate engineering controls to minimize the risk of dust explosions. This may include the installation of explosion venting, deflagration suppression systems, spark detection systems, and deflagration venting ductwork.
Written Programs: Facilities must develop and maintain written programs that address combustible dust hazards, including procedures for dust control, equipment maintenance, inspections, employee training, incident reporting, and emergency response.
Understanding Combustible Dust Hazards
Combustible dust hazards pose a significant risk where fine particles of solid materials can become suspended in the air and create a potentially explosive atmosphere. Understanding the nature of these hazards is crucial for maintaining a safe working environment and implementing effective control measures. Combustible dust can arise from a wide range of materials, including organic substances like wood, grain, and food products, as well as inorganic materials such as metals, chemicals, and pharmaceuticals.
OSHA’s Dust Combustion Pentagon
The hazard potential of combustible dust arises when several factors, commonly known as the Dust Explosion Pentagon, come together. These factors include the presence of:
Combustible dust particles
An ignition source
Oxygen in the air
Dispersion of dust particles
Confinement of the dust cloud.
When these elements combine in the right proportions, they create a potentially explosive environment. Ignition sources can range from sparks, open flames, hot surfaces, electrical equipment, friction, or static electricity.
To mitigate combustible dust hazards, several preventive measures should be implemented:
Effective housekeeping practices are essential to minimize dust accumulation on surfaces, equipment, and ventilation systems, as excessive dust buildup increases the risk of ignition. Regular cleaning, including vacuuming and sweeping with appropriate equipment, can help control dust levels and prevent potential incidents.
Proper ventilation systems should be installed to control dust dispersion and maintain a safe working environment.
Potential ignition sources, such as electrical equipment, must be properly designed, installed, and maintained to minimize the risk of igniting combustible dust.
Explosion protection measures, such as explosion venting or suppression systems, can help mitigate the severity of explosions if they do occur.
Understanding combustible dust hazards is essential for identifying potential risks and implementing appropriate control measures. By conducting thorough dust hazard assessments (see below), implementing effective housekeeping practices, controlling ignition sources, and employing engineering controls, employers can significantly reduce the risk of dust-related incidents as well as fines and violations, and ensure the safety of their workers and facilities.
National Fire Protection Association (NFPA) Standards
The NFPA (link to NFPA site) is a non-profit organization dedicated to eliminating death, injury, property, and economic loss due to fire, electrical, and related hazards. You should familiarize yourself with all requirements applicable to your site, but here are the most commonly referenced NFPA standards related to dust collection and control:
NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids: NFPA 654 provides guidelines for preventing fire and dust explosions in facilities that handle combustible particulate solids. It covers various aspects of dust control, including hazard identification, assessment, and mitigation measures. The standard emphasizes the importance of conducting a Dust Hazard Analysis (DHA) to identify potential hazards, implementing effective housekeeping practices, and using appropriate explosion protection systems.
NFPA 68: Standard on Explosion Protection by Deflagration Venting: NFPA 68 focuses on the design, installation, operation, and maintenance of deflagration venting systems. It provides guidelines for venting combustible dust explosions to minimize damage and protect personnel and equipment. The standard outlines requirements for calculating vent areas, selecting venting devices, and establishing proper vent duct designs.
NFPA 69: Standard on Explosion Prevention Systems: NFPA 69 addresses explosion prevention systems used to protect industrial processes and equipment. It covers various protection methods, including deflagration venting, flameless venting, explosion suppression, and explosion isolation. The standard provides requirements for designing and installing these systems to mitigate the risk of dust explosions.
NFPA 70: National Electrical Code (NEC): While not specific to dust collection, the NEC provides guidelines for electrical installations, including those in areas where combustible dust may be present. It covers proper electrical equipment selection, wiring methods, grounding, and bonding to prevent ignition sources in dust-handling environments.
NFPA 91: Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids: NFPA 91 focuses on exhaust systems used to convey air, vapors, gases, mists, and noncombustible particulate solids. While primarily addressing general ventilation systems, it includes provisions for dust collection systems, including requirements for ductwork, air velocity, explosion venting, and spark detection systems.
NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities: This standard is applicable to wood shops and wood processing facilities.
These are just a few of the many NFPA standards related to dust collection and control. Consult the specific NFPA standards applicable to your industry and operations to ensure compliance with best practices and industry guidelines for preventing dust-related hazards.
Contact us to consult with a baghouse expert and receive guidance on how to comply with NFPA requirements.
Dust Hazard Analysis (DHA): Identifying and Mitigating Risks
NFPA 652 (Standard on the Fundamentals of Combustible Dust) provides details on conducting a DHA in accordance with the NFPA requirements. However, hear is a summary of the process:
Scope and Team Formation: Determine the scope of the DHA, identifying the areas, processes, and materials to be included in the analysis. Form a multidisciplinary team that includes individuals with expertise in engineering, safety, operations, and maintenance.
Hazard Identification: Identify potential sources of combustible dust and assess the likelihood and severity of a dust explosion or fire. This includes reviewing material safety data sheets (MSDS), conducting facility walkthroughs, and analyzing historical incident data.
Dust Hazard Assessment: Evaluate the characteristics of the dust, such as particle size, particle shape, combustibility, and explosibility. Consider the dust’s ignition sensitivity, explosion severity, and any potential secondary hazards. Assess the effectiveness of existing control measures and housekeeping practices.
Risk Evaluation: Determine the level of risk associated with identified hazards. Evaluate the likelihood and potential consequences of a dust-related incident, considering factors such as ignition sources, dust concentrations, ventilation systems, and equipment design.
Control Measures and Recommendations: Develop recommendations to mitigate identified hazards and reduce the risk of dust explosions or fires. This may include implementing engineering controls, such as improved ventilation or explosion protection systems, enhancing housekeeping practices, modifying equipment or processes, or providing training and personal protective equipment (PPE) for employees.
Documentation and Review: Document the findings, recommendations, and actions taken during the DHA process. Maintain clear records of the assessment, including the scope, team members, hazard identification, risk evaluation, and control measures. Regularly review and update the DHA to reflect any changes in processes, materials, or regulations.
Training and Communication: Ensure that employees and relevant stakeholders are trained on the hazards associated with combustible dust, the control measures in place, and the actions to take in the event of an incident. Promote a culture of safety and provide ongoing communication and education regarding dust hazards and prevention strategies.
Designing Dust Collection Systems for Compliance
It is critical that your dust collector system is designed in accordance with all applicable regulations. We strongly recommend you consult with a dust collection expert before and during your system design and installation to avoid costly rework, mitigation, or safety and health incidents at your site. Here are some general considerations when specifying system requirements or designing a dust collection system:
Identify Applicable Regulations: Understand the specific regulations and standards that apply to your industry and location. This may include Occupational Safety and Health Administration (OSHA) regulations, National Fire Protection Association (NFPA) standards, local building codes, and environmental regulations.
Conduct a Dust Hazard Analysis (DHA): Perform a comprehensive analysis of the dust hazards present in your facility. Identify the types of dust generated, their explosibility characteristics, and potential ignition sources. Use the DHA findings to inform the design of the dust collection system and control measures.
Determine Airflow and Capture Velocity: Calculate the required airflow and capture velocity based on the dust generation rate, size and weight of dust particles, and the proximity of dust sources to the collection hood. Ensure that the system is designed to effectively capture and contain the dust at the source.
Select Proper Collection Equipment: Choose appropriate dust collection equipment that meets regulatory requirements and is suitable for the specific application. Consider factors such as filtration efficiency, dust handling capacity, explosion protection features, and compatibility with the type of dust being collected.
Ensure Adequate Ventilation: Design the ventilation system to maintain a safe and healthy working environment. Provide sufficient air exchange rates, taking into account the size of the facility, the number of dust sources, and the type of operations being conducted. Ventilation should effectively control dust dispersion and maintain breathable air quality.
Implement Explosion Protection Measures: If handling combustible dust, incorporate explosion protection measures as required by regulations. This may include explosion vents, flameless venting, explosion and fire suppression, or deflagration containment systems. Ensure that the design of the dust collection system integrates these measures effectively.
Consider Noise Control: Dust collection systems can generate significant noise levels. Take measures to minimize noise through proper equipment selection, ductwork design, and the use of noise-reducing features like silencers or sound dampening materials.
Provide Easy Maintenance and Access: Design the system with accessibility in mind, allowing for easy maintenance, inspection, and cleaning of components. Incorporate features such as access doors, cleanout ports, and quick-release mechanisms for filters or collection containers.
Labeling and Signage: Ensure that the dust collection system is properly labeled and includes appropriate warning signs to indicate potential hazards, emergency shutdown procedures, and any necessary precautions for personnel.
Documentation and Record Keeping: Maintain thorough documentation of the dust collection system design, including equipment specifications, airflow calculations, hazard analysis reports, maintenance records, and inspection logs. Regularly review and update documentation to ensure compliance with changing regulations.
It is crucial to consult with industry experts, compliance professionals, and relevant regulatory agencies to ensure that your dust collection system design meets all applicable regulatory requirements – YOU are responsible for ensuring that your site is in compliance.
Emissions Monitoring and Reporting Requirements
Emissions requirements are another topic that many industrial professionals need to understand and comply with to avoid fines, mitigation actions, and potential health issues.
Understand Applicable Regulations: Familiarize yourself with the specific regulations and reporting requirements related to dust emissions monitoring in your industry and location. This may include local, state, and federal environmental regulations, air quality standards, and permit conditions. Also review your equipment permits to understand what requirements each piece of equipment is subject to.
Determine Monitoring Frequency: Determine the frequency at which dust emissions monitoring should be conducted based on regulatory requirements and any specific conditions outlined in permits or compliance agreements. This may include continuous monitoring, periodic sampling, or a combination of both.
Select Monitoring Methods: Choose appropriate monitoring methods that are approved and recognized by regulatory authorities. Common methods include stack sampling, opacity monitoring, gravimetric sampling, and real-time particulate matter monitoring. Ensure that the selected methods are suitable for the type of dust being emitted and provide accurate and reliable data.
Establish Monitoring Locations: Determine the appropriate locations for dust emissions monitoring. This may involve identifying critical emission points, such as stacks, vents, or process equipment, where emissions are expected to be generated. Consider factors such as representative sampling, accessibility, and compliance with monitoring requirements.
Calibrate and Maintain Monitoring Equipment: Regularly calibrate and maintain the monitoring equipment to ensure accurate and reliable measurements. Follow manufacturer recommendations and any specific calibration protocols specified by regulatory authorities. Keep detailed records of calibration dates, results, and maintenance activities.
Record and Report Monitoring Data: Maintain comprehensive records of all monitoring data, including measurement dates, locations, sampling methods, and results. Ensure that the records are accurate, well-documented, and readily accessible. Prepare and submit reports in accordance with regulatory requirements, including specified timeframes and data formats.
Compliance with Emission Limits: Regularly compare the monitoring data with the applicable emission limits or standards established by regulatory authorities. Take prompt action if emissions exceed permitted levels, and implement corrective measures to bring emissions back into compliance.
Stay Updated on Changes in Regulations: Stay informed about any changes or updates to regulations related to dust emissions monitoring and reporting. Monitor updates from regulatory agencies and industry organizations to ensure ongoing compliance with the latest requirements.
Retain Records: Retain monitoring records, reports, and documentation for the specified duration as required by regulations. This may vary depending on the jurisdiction, but it is generally advisable to keep records for a minimum of several years to demonstrate compliance and facilitate future audits or inspections.
Seek Professional Guidance: If needed, consult with a professional to ensure compliance with regulations, proper sampling techniques, and accurate reporting.
Compliance Audits and Inspections
Compliance audits and inspections are important processes to ensure that dust collection systems meet regulatory requirements and operate in a safe and environmentally responsible manner. Here is a summary of compliance audits and inspections that dust collection systems could be subject to:
Regulatory Compliance Audits: Regulatory agencies such as the OSHA and MSHA may conduct compliance audits to assess whether the dust collection system meets the relevant regulatory requirements. These audits may involve a review of permits, records, operational procedures, maintenance logs, and emissions monitoring data.
Safety Inspections: Safety inspections focus on identifying potential hazards and ensuring that appropriate safety measures are in place. Inspectors may check for proper installation and maintenance of equipment, compliance with electrical and fire safety codes, adherence to lockout/tagout procedures, and the presence of proper safety signage and personal protective equipment. These audits may be conducted by your site EH&S team or by external authorities (your local fire marshal, etc.)
Emissions Testing: Emissions testing is performed to measure the level of pollutants emitted by the dust collection system. This may involve the use of sampling equipment to collect dust samples, which are then analyzed to determine the concentration of specific contaminants. The results are compared against regulatory emission limits to assess compliance. The permits for your equipment may specify your emissions testing requirements.
Operational Audits: Operational audits evaluate the performance and efficiency of the dust collection system. They may include assessing the system’s airflow, pressure drop, filter cleaning efficiency, and energy consumption. These audits aim to identify any operational issues or opportunities for improvement. com conducts thorough audits of your dust collection system equipment.
Internal Audits: In addition to external audits and inspections, organizations may conduct internal audits to assess their own compliance and identify areas for improvement. These audits can be valuable for ensuring that all aspects of the dust collection system are operating effectively and in compliance with internal policies and procedures.
Training and Employee Awareness
Training is a critical component of operating dust collection systems, both to ensure your systems operate efficiently and for ensuring you stay compliant to all environmental, health, and safety requirements. Training should be conducted regularly for your maintenance, operations, engineering, EH&S, and management staff that are involved with dust collection.
Baghouse.com offers a comprehensive training program geared toward educating your entire staff on dust collection principals including system design and selection, operation, maintenance and troubleshooting, special considerations for combustible dust, and other relevant topics. We offer this training both on-site and remotely (via Zoom, etc.) and it can be tailored to your specific site requirements.
Specific maintenance and housekeeping practices may vary depending on your situation (if you handle combustible or toxic dust, etc.) but there are some general best practices to ensure your site stays clean and safe when dust is present:
Regular Equipment Inspections: Conduct regular inspections of your dust collection systems to identify any signs of wear, damage, or malfunction. This includes inspecting filters for leaks, ductwork, fans, valves, and other components. Address any issues promptly to maintain system efficiency and prevent potential safety hazards including dust emissions or dust buildup in your system.
Scheduled Maintenance: Establish a daily, weekly, and monthly preventative maintenance schedule for routine tasks such as filter replacement, replacement of pulse valve diaphragms, door seals, fan belts, and other items that wear out. Adhere to manufacturer guidelines and recommendations for maintenance activities to maximize the system’s effectiveness. Contact Baghouse.com for a useful maintenance checklist that you can tailor for your site.
Cleaning Procedures: Develop and implement proper cleaning procedures for the dust collection system and surrounding areas. This includes regular cleaning of ductwork, hoods, and equipment surfaces to prevent dust accumulation and potential hazards. Use approved cleaning methods and equipment that minimize the release of dust into the environment.
Training and Education: Provide comprehensive training to personnel involved in operating and maintaining the dust collection system (see above). Ensure they understand the importance of compliance with environmental, health, and safety regulations, as well as the proper procedures for maintenance, cleaning, and safe handling of materials.
Housekeeping Practices: Implement effective housekeeping practices to minimize the generation and accumulation of dust. This includes regular sweeping, vacuuming, and dampening surfaces to prevent dust from becoming airborne. Dispose of collected dust properly according to applicable regulations. Generally, visible dust in the air or on surfaces in your facility is a sign that housekeeping is needed, or that your system requires inspection and maintenance.
Hazardous Material Handling: If your dust contains hazardous materials, ensure proper handling, storage, and disposal procedures are followed in compliance with relevant regulations. Label containers appropriately, store hazardous materials in designated areas, and work with certified disposal contractors as necessary.
Record-Keeping: Maintain accurate records of maintenance activities, inspections, cleaning schedules, and any incidents or corrective actions taken. These records demonstrate compliance efforts and can be useful during audits or inspections.
Employee Engagement: Foster a culture of environmental, health, and safety awareness among employees. Encourage reporting of any concerns, near misses, or incidents related to the dust collection system. Regularly communicate updates, provide training refreshers, and involve employees in safety committees or initiatives.
Industry-Specific Compliance Considerations
Every industry and site has its own particular considerations for dust collection and control. Here are a few points to consider for some specific industries:
Manufacturing and Industrial Facilities: These facilities often generate dust from processes such as metalworking, woodworking, or chemical manufacturing. Compliance considerations may include proper containment of dust, selection of appropriate dust collection equipment, compliance with hazardous material handling and disposal regulations, and adherence to specific industry standards or guidelines.
Construction Sites: Construction sites can generate dust from activities such as concrete cutting, grinding, and demolition. Compliance considerations may include implementing dust control measures such as wetting down surfaces, using dust collection systems for equipment, proper storage and handling of construction materials, and compliance with local air quality regulations.
Pharmaceutical and Food Processing Industries: These industries require strict adherence to cleanliness and hygiene standards. Compliance considerations may include utilizing dust collection systems designed for sanitary applications, ensuring the use of appropriate filter materials to prevent cross-contamination, compliance with Good Manufacturing Practices (GMP), and adherence to industry-specific regulations and guidelines.
Mining and Quarrying Operations: Mining and quarrying activities often generate significant amounts of dust. Compliance considerations may include implementing effective dust control measures such as water spraying or dust suppression systems, proper ventilation and exhaust systems, regular monitoring of air quality, and compliance with mining-specific regulations and guidelines. MSHA has specific requirements aimed at preventing and controlling exposure to hazardous levels of respirable dust that cause lung disease, including coal workers’ pneumoconiosis (CWP) or silicosis. MSHA regulates dust collection systems and has a process for equipment approval for use in mining operations, and conduct regular inspections of mining operations.
Energy and Power Generation: Power plants, including coal-fired facilities, face specific compliance considerations for dust collection and control. Compliance measures may include the use of high-efficiency particulate air (HEPA) filters, compliance with emission limits for particulate matter, proper handling and disposal of fly ash or other byproducts, and adherence to industry-specific regulations and guidelines.
There are multiple government agencies (federal, state, and local) that likely have regulations that apply to your site and your dust collection systems. It is critical that you understand and comply with all regulations to avoid costly fines, mitigation actions, and most importantly, environmental or safety incidents caused by a failure to comply. Baghouse.com has many years of experience working with customers in multiple industries, and provides consulting for customers to help ensure your systems are compliant.
British Columbia’s workplace regulatory body, WorkSafeBC, fined West Fraser Mills, a wood product firm that operates in both the United States and in Canada, $115,000 for having combustible dust present at several of their locations. Inspectors noticed the potentially combustible wood dust around several electrical fixtures, appliances, motors, and moving machinery parts. The flammable dust is supposed to be collected and cleaned up in the locations in which it’s produced. Places with heat and electricity become safety hazards quickly when the dust is not taken care of properly.
Key Takeaways:
West Fraser Mills was issued a hefty fine for letting wood dust accumulate in their warehouses.
Fine wood dust comes from milling different wood products and can build up in several places.
Fine would dust is susceptible to catching on fire and would not need much to get it started.
“British Columbia’s occupational safety regulator, WorkSafeBC, issued a CAD$150,000 (about $114,000) fine to wood products firm West Fraser Mills this November for accumulations of combustible dust in several buildings at its Quesnel, BC manufacturing site.”
According to local media, a dust collector at the Innotec LED factory briefly caught fire at 11:30 in the morning on 7 May. Five fire trucks were dispatched to the Zeeland, Michigan manufacturing facility. All ten of the Innotec workers present at the time were able to evacuate safely, and the blaze was suppressed in under ten minutes. Innotec, a company founded in the early nineties in Hudsonville, Michigan, is a producer of LED lighting used for heavy machinery, automotive uses and other applications.
Key Takeaways:
The Innotec Plant experienced a fire, fortunately without loss of life, on Tuesday, the 7th of May.
The Zeeland Plant fire in MI, on West Washington, was reported on by the Holland Sentinel.
The blaze ignited around 11:30 AM, followed by the safe evacuation of about ten workers on site.
“During that incident, flames were contained to the building where the dust collector was located and no one was hurt.”
https://www.baghouse.com/wp-content/uploads/2019/05/industrial-dust-collector-fire.png551900BHhttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngBH2019-05-21 13:00:002020-01-29 18:49:57Dust Collector Fire Doused at LED Lighting Plant
In July of 2016, the mismanagement of a heat exchanger led to an extensive series of explosions that resulted in damaging forest fires in Mississippi. The mismanagement was a result of Enterprise Products Pascagoula Gas Plant allowing the equipment to experience too much thermal fatigue. If there had been more extensive safety measures and inspection protocols set in place, these disastrous results may not have occurred, saving a plethora of vegetation and clean up funds.
Key Takeaways:
As regards a Mississippi gas leak explosion, a February 12 report points to thermal fatigue as the culprit.
Thermal fatigue refers to the weakening of materials over time, due to the stress of heating and cooling.
Upon inspection, it was clear that small cracks had arisen over time, due to temperature fluctuations.
“The plant – which had repaired four heat exchangers nine times in 17 years, CSB found – was shut down for nearly six months.”
https://www.baghouse.com/wp-content/uploads/2019/02/Pascagoula-Gas-Plant.jpg492768Jeremyhttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngJeremy2019-02-25 13:00:052020-01-29 18:42:30Safety gaps led to explosions at Mississippi gas plant: CSB
Guest Post By Bevin Sequeira BS&B Safety Systems (Asia Pacific) Pte Ltd.
Introduction to Dust Explosions
A Dust Explosion is the fast combustion of dust particles suspended in the air in an enclosed location. Coal dust explosions are a frequent hazard in underground coal mines, but dust explosions can occur where any powdered combustible material is present in an enclosed atmosphere or, in general, in high enough concentrations of dispersed combustible particles in atmosphere.
Dust explosion at West Pharmaceutical Services, North Carolina took the lives of 6 people in 2003
Dust explosions can lead to loss of life, injury, damage property and environmental damage as well as consequential damage such as business interruption losses.
Dust explosions involve most commonly “dust”, i.e. fine material. This can be the product being handled or it can be produced as the result of the processing. However, in many cases fine dust is present in material that is otherwise too coarse to pose a dust explosion hazard, either as part of the product or generated by attrition during handling or transport. Therefore, while replacing a fine material by a granular one (such as pellets or flakes) will reduce the dust explosion hazards, this may not be sufficient to eliminate the hazards. Similarly, a user of a granular material may process it to a particle size that introduces dust explosion hazards.
Many dust explosions that occur in process plants are relatively small, leading to limited damage. However, under the right circumstances, even small explosions can escalate into major incidents. This is most commonly the case when secondary dust explosions happen. The typical scenario is that a small “primary” explosion raises a dust cloud, often from dust deposited over time on plant surfaces, and ignites the resulting dust cloud. This “secondary” explosion takes place where often people are present, placing them in immediate danger. Secondary dust explosions can form a chain reaction that can run through a facility as long as fuel is present, leading to widespread devastation.
Conditions for Dust Explosion
There are five necessary conditions for a dust explosion or deflagration:
1. Presence of Combustible Dust
2. Dust suspended in the air at a high concentration
3. There is an Oxidant (typically atmospheric oxygen)
4. There is an Ignition source ( Either Flames & hot surfaces, Spontaneous Ignition, Friction sparks, Static Electricity, Electrical Equipment’s, etc.)
5. Confinement (enclosed location)
Many materials which are commonly known to oxidize can generate a dust explosion, such as coal, sawdust. The dust can arise from activities such as transporting grain and indeed grain silos do regularly have explosions. Mining of coal leads to coal dust and flour mills likewise have large amounts of flour dust as a result of milling. A gigantic explosion of flour dust destroyed a mill in Minnesota on May 2nd, 1878, killing 18 workers at the Washburn A Mill.
To support combustion, the dust must also consist of very small particles with a high surface area to volume ratio, thereby making the collective or combined surface area of all the particles very large in comparison to a dust of larger particles. Dust is defined as powders with particles less than about 500 microns in diameter, but finer dust will present a much greater hazard than coarse particles by virtue of the larger total surface area of all the particles.
Sources of Ignition
There are many sources of ignition and a naked flame need not be the only one: over one half of the dust explosions were from non-flame sources. Common sources of ignition include electrostatic discharge friction arcing from machinery or other equipment or hot surfaces such as overheated bearings. However it is often difficult to determine the exact source of ignition post-explosion. When a source cannot be found, it will often be cited as static electricity. Static charges can occur by friction at the surfaces of particles as they move against one another, and build up to levels leading to a sudden discharge.
Combustible Dust Concentrations:
As with gases, dust is combustible with certain concentration parameters. These parameters vary widely across the spectrum. Highly combustible dust can form a flammable mixture with less than 15 g/m3.
Mechanism of dust explosions:
Imperial Sugar Explosion: Wentworth, GA 17 February 2008: 14 Fatalities
Dusts have a very large surface area compared to their mass. Since burning can only occur at the surface of a solid or liquid, where it can react with oxygen, this causes dusts to be much more flammable than bulk materials. For example, a 1 kg sphere of a material with a density of 1g/cm3 would be about 27 cm across and have a surface area of 0.3 m2. However, if it was broken up into spherical dust particles 50µm in diameter (about the size of flour particles) it would have a surface area of 60 m² This greatly increased surface area allows the material to burn much faster, and the extremely small mass of each particle allows it to catch on fire with much less energy than the bulk material, as there is no heat loss to conduction within the material. When this mixture of fuel and air is ignited, especially in a confined space such as a warehouse or silo, a significant increase in pressure is created, often more than sufficient to demolish the structure.
Even materials that are traditionally thought of as non-flammable, such as aluminium, or slow burning, such as wood, can produce a powerful explosion when finely divided, and can be ignited by even a small spark.
Terminology:
Dust explosions may be classified as being either primary or secondary in nature.
Primary dust explosions: occur inside process plant or similar enclosures and are generally controlled by pressure relief through purpose-built ducting to atmosphere.
Secondary dust explosions: are the result of dust accumulation inside the factory being disturbed and ignited by the primary explosion, resulting in a much more dangerous uncontrolled explosion inside the workplace.
Historically, fatalities from dust explosions have largely been the result of secondary dust explosions.
Best engineering control measures which can be found in the National Fire Protection Association (NFPA) Combustible Dust Standards include:
• Oxidant Concentration Reduction
• Deflagration venting
• Deflagration pressure containment
• Deflagration suppression
• Deflagration venting through a dust retention and flame-arresting devices
• Spark Detection & Extinguishing Systems
Many reported dust explosions have originated in common powder and bulk solids processing equipment such as dust collectors, dryers, grinders/pulverisers, and blenders. Electrostatic discharges are frequently cited as the ignition source for dust collector explosions, whereas particulate overheating is the most common ignition source in dryer explosions, and friction/impact heating associated with tramp metal or misaligned parts is probably the most frequent ignition source in grinder/pulveriser explosions.
Dust explosions are often exacerbated by propagation through ducting between process equipment, frequently via dust collector pickup and return ducting. Moe widespread use of effective deflagration isolation devices in such ducting would clearly be beneficial in mitigating the damage and injuries from these propagating dust explosions. (See article Dust Collector Fire and Explosion Highlights Need for Combustible Dust Considerations In System Designs)
Secondary dust explosions in processing buildings probably cause the largest numbers of dust explosion fatalities and injuries. One crucial aspect of secondary dust explosion prevention and mitigation is greater awareness of good housekeeping and maintenance practices to prevent particulate leakage from equipment and subsequent accumulations of dust deposits in large areas of the buildings.
About the Author
Bevin Sequeira holds a B.E. (Mechanical) degree & a MBA (Marketing) specializing in business development & enhancement of virgin markets all over the globe. With over two decades of international working experience in the industry, Bevin’s knowledge of the industry spans various sectors like Iron & Steel, Foundry, Chemicals & Fertilizer, Power, Food, Pharma, etc. He is currently serving as Regional Sales Manager at BS&B Safety Systems (Asia Pacific) Pte Ltd. specialising in Combustible Dust Explosion Protection Systems & Risk Management. In his spare time, Bevin likes to read, travel, socialise & collaborate with business houses for M&A, Management Consultancy, etc.
https://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.png00dominickdalsantohttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngdominickdalsanto2013-10-15 09:54:192018-12-27 03:45:58Introduction to Combustible Dust Explosions Common to Baghouses
A massive fire and explosion in the dust collection system of a New Hampshire wood pellet manufacturer demonstrates the need for adequate system design to prevent combustible dust explosions in general industry.
May 16 2012 – Baghouse.com Editorial | On October 20 2011, a combustible dust fire began in the wood pellet cooler, most likely caused by a spark or ember from the pellet hammer mill. The fire then spread through the ductwork throughout the plant, eventually reaching the dust collector causing it to explode. When the collector exploded, the explosion vented through the baghouse’s explosion vents into adjacent storage silos setting them ablaze further spread the fire throughout the plant. More than 100 firefighters and emergency personnel from at least 14 towns worked for over 15 hours to put out the blaze.
The OSHA report outlines specific areas where the plant lacked adequate spark detection devices, fire suppression systems, and explosion venting/protection within the dust collection system. The fact that the plant had been cited by OSHA for several of the same issues previously after a 2008 incident, led to OSHA assessing total fines of $147,000.
Examining what went wrong in this incident highlights the need for diligence on the part of plant management and operators regarding the dangers of combustible dust.
What Went Wrong?
The October 20 2011 fire and explosion at the Jaffrey, NH plant was not the first combustible dust related incident at the plant. In 2008 the plant experienced a similar fire and explosion that caused more destruction than the most recent one. After completing its investigation, OSHA at that time fined the plant over $100,000 for safety violations that led to the fire. Subsequently, the plant, in an attempt to prevent another such occurrence, “retained engineers and consultants, and spent over $2 million on various improvements to enhance worker safety at its Jaffrey facility” according to a release from the company. This apparently including the installation of some explosion isolation devices in the ductwork (Rembe explosion isolation device) and installed explosion protection (explosion vents) on the baghouse. However the company’s effort and expense failed to prevent another incident from occurring.
Fire fighters work to put out a massive blaze caused by a destructive combustible dust fire and explosion at the New England Wood Pellet Company’s Jaffrey, NH facility.
The OSHA report is quite thorough in its description each poorly designed, installed and operated part of the dust collection system either caused or intensified fire and subsequent explosion.
For example the report cites the plant for 2 main offenses. The first one is regarding poor housekeeping throughout the plant that led to large accumulations of combustible wood pellet dust forming on top of machinery (such as the pellet cooler where the fire began) and on elevated surfaces such as overhead rafters, ceiling joists, troughs, etc. Secondly, and more seriously, the plant was cited under the General Duty Clause of the OSHA Charter* for failing to take reasonable steps to prevent a combustible dust fire/explosion from occurring. OSHA cited several industry standards such as the National Fire Protection Association building code that the plant failed to heed in the design and construction of the plant’s dust collection system.
Ductwork Lacked Sufficient Spark Detection, Fire Suppression, or Explosion Isolation Devices
A major oversight in the ductwork system, was the lack of appropriate spark detection, fire suppression or fire isolation devices on all of the ductwork between the various machines throughout the plant. For instance, OSHA reported that the connecting ductwork between the pellet hammer mills, the pellet cooler, the bucket elevators storage silos and most of the dust collectors in the plant had no spark detection system, fire suppression system, or explosion isolation devices installed. The only control device the plant had was an explosion isolation device on the conveying duct between the pellet cooler and the pellet cooler baghouse. However, the device did not function properly and allowed the fire to propagate further downstream into the baghouse.
NFPA 664 (2012) Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities: 8.2.1. and Hazard Determination 8.2.4.1. – Conveying systems with fire hazards should be isolated to prevent propagation of fire both upstream and downstream (OSHA isolation can mean spark detection and suppression). 5.2.5.1 Prevention of Fire Extension: When limitation of fire spread is to be achieved the following criteria shall be demonstrated…(4) Particulate processing systems (dust collection systems) shall be designed, constructed, equipped and maintained to prevent fire or deflagration from propagating from one process system to an adjacent process system.
Additionally, the ductwork was not engineered and/or constructed to sufficient strength to withstand the maximum anticipatable explosive pressure resulting from a conflagration involving its intended payload (combustible wood dust). This led to the duct bursting open, releasing the explosion into the plant near firefighters and may have been a contributing factor in the fire by-passing the isolation device.
NFPA 664 (2012) 8.2.2.2.3, Sets forth alternative safety criteria for ducts with a deflagration hazard, to ensure that the ducts are builds with a sufficient strength and with appropriately sized/located protection devices to handle the maximum expected pressure generated by a dust explosion.
Baghouse Was Not Adequately Protected Against Explosion Hazards
The plant recently installed explosion vents on the baghouse explosion vents.* However, the design and installation of the explosion protection on this particular baghouse may actually made things worse than if there had been none at all.
When the fire reached the baghouse and caused the finely dispersed dust to ignite, the resulting pressure and fireball should have been vented outside the building. However, the explosion vents on the baghouse faced the direction of adjacent storage silos (containing wood dust). When the explosion was vented out it ignited the storage silos resulting in a major portion of the fire.
Additionally, OSHA’s investigation showed that the baghouse lacked an explosion suppression system, was not designed and/or constructed to withstand the maximum unvented pressure of a combustible dust explosion, and in the absence of proper explosion protection, was located indoors.
As a result of these failures, when the reached the dust collector, the resulting explosion: blew the dust collector’s door off its hinges, creating a missile hazard, blew backwards into the duct, which burst open, and blew out the dust collector’s exhaust muffler and roof stack, causing the pressure/deflagration to be vented inside the building near responding firefighters.
NFPA 664 (2012) 8.2.2.5.1.4. Requires an outdoor location for the dust collectors with fire or deflagration hazards, unless they are equipped with one of the following: (4) listed deflagration suppression system, (5) deflagration relief vents with relief pipes extending to safe areas outside the building and the collector meets the strength requirement of this standard (i.e. built with sufficient strength to withstand the maximum expected explosions pressure). NFPA 664 (2012) 8.2.2.5.3 requires dust collectors with deflagration hazards be equipped with an appropriate-sized explosion suppression system and/or explosion relief venting system designed per NFPA 68 (Explosion Protection by Deflagration Venting) and NFPA 69 (Explosion Prevention Systems), and also that such dust collectors be built to design strength that exceeds the maximum expected explosion pressure of the material being collected. NFPA 69, 12.1.2 requires “Piping, ducts, and enclosures protected by an isolation system shall be designed to withstand estimated pressures as provided by the isolation system manufacturer”. NFPA 69, 12.2.2.3 “System Verification” requires that systems shall be verified by appropriate testing under deflagration conditions to demonstrate performance.”
These design oversights directly increased the destructive power of what had until then been only a dust fire in the ductwork.
Lessons Learned From Wood Pellet Company Dust Explosion
Simply put, this disaster was bound to happen due to glaring design and/or construction flaws throughout the entire system.
The fact that multiple similar incidents have occurred at the facility demonstrates that the dust collection system, and perhaps even the entire production process requires modification to ensure this kind of incident does not occur again.
Under OSHA’s National Combustible Dust Emphasis Program, OSHA inspectors are on heightened alert for any combustible dust hazards in facilities in all industries. Indeed OSHA is under a federal mandate and its has as its own goal to issue a comprehensive combustible dust standard for general industry. In the meantime, OSHA has been citing plants under the general duty clause for having combustible dust hazards. In most cases, OSHA is informally requiring general industry to conform to the NFPA’s guidelines for combustible dust hazards. As seen in this case following they suggestions would have prevented this kind of incident from occurring.
Therefore, we can take away from this the need to be conscientious and proactive regarding combustible dust hazards in your facility. As we have seen, being reactive will simply not do.
Footnotes:
* OSHA General Duty Clause (a) Each employer — (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act.
* Baghouse Explosion Vents – Explosion vents are a form of explosion protection used on baghouses. During normal operation the vents are closed and maintain an air-tight seal. However, if an explosion occurs within the baghouse, the vents are designed to “strategically fail” being the weakest part of the baghouse structure, thus allowing the pressure from the explosion to vent out and away from other combustible materials and workers.
| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in dust collection systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Sales Director at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.
https://www.baghouse.com/wp-content/uploads/2018/03/New-England-Wood-Pellet-Fire-Web.jpeg169334dominickdalsantohttps://www.baghouse.com/wp-content/uploads/2018/03/BH-Logo-Alt-01.pngdominickdalsanto2012-05-18 11:47:482019-05-07 00:01:28Dust Collector Fire and Explosion Highlights Need for Combustible Dust Considerations In System Designs
Nine years after the first of a series of deadly combustible dust explosions in the U.S., the CSB (Chemical Safety Board) is imploring OSHA to take decisive action and finalize its court-ordered Combustible Dust Standard. Investments in plant dust collection systems will be vital to meeting the new proposed standards.
April 4, 2012 – Baghouse.com News | Fed. 20, 2003, CTA Acoustics plant in Corbin, Ky, 7 dead; Feb. 7, 2008 Imperial Sugar Refinery in Port Wentworth, Ga, 14 dead, 38 injured; various dates in 2011, Hoeganaes powdered iron metal manufacturing plant in Gallatin, Tn, 5 dead in 3 separate incidents in 5 months. These are just a few of the deadly industrial dust explosions to occur in the U.S. over the last decade. In each of these incidents, the lives of these workers were tragically cut short by the seemingly-innocuous dusts present in the facilities.
The Chairperson of the U.S. Chemical Safety Board (CSB) Rafael Moure-Eraso, in a recent article has called attention to the fact that despite several deadly incidents occurring in the nine years since the CTA explosions, OSHA still has yet to follow through with its pledge to issue a comprehensive combustible dust safety standard for general industry.
Chairperson Moure-Eraso relates the progression of events that lead to the CSB calling for OSHA to implement a comprehensive standard for combustible dust. “The safety board launched a study into the hazards of combustible dust. Our 2006 report revealed there is no national regulation that adequately addresses combustible dust explosion hazards in general industry. Although many states and localities have adopted fire codes that have provisions related to combustible dust, a CSB survey found that fire code officials rarely inspect industrial facilities to enforce the codes. The board clearly stated that American industry needs a comprehensive federal combustible dust regulation.”
While the explosion at the CTA Acoustics plant in Corbin, Ky did lead the CSB to issue a number of recommendations to both plant management, local and state regulators, it was not until the 2008 Imperial Sugar Refinery explosion in Port Wentworth, Ga, that left 14 dead and 38 injured, that the CSB made its recommendation to OSHA to issue a “comprehensive combustible dust standard for general industry”.
The CSB is an independent governmental agency charged with investigating industrial chemical accidents. And while they do have limited authority to investigate and issue recommendations, they do not have the power to enforce safety regulations.
Despite its repeated recommendations to OSHA for the urgent need for hazardous dust standards, he relents: “ Yet, nine years after the CTA catastrophe, and more than five years after our recommendation to OSHA, there is still no comprehensive OSHA standard to prevent these accidents.”
After the CSB’s recommendations, OSHA in April, 2009 announced that it planned on issuing a comprehensive dust standard for general industry. However, its recent 2012 agenda does not include any specific mention of goals or targets for the development of the standard during the course of this year.
Will There Ever Be a Comprehensive Combustible Dust Safety Standard?
While the U.S. is still struggling to prevent these kinds of incidents from occurring, the rest of the world is not immune from them either. In fact, major manufacturers such as China, which often lack extensive safety regulations, are even more prone to experience these kinds of incidents. According to recent reports, last year saw two electronics manufacturers in China that produce parts for Apple Computer products experienced dust explosions when fine particles of aluminum ignited, killing four workers and injuring dozens of others. Apple’s Supplier Responsibility documents state that the company is now requiring improved ventilation, inspections and cleaning methods for dust deposits.
Without a standard that comprehensively addresses the hazards of combustible dust, American workers will continue to be put at risk for future catastrophic explosions and fires.
“I don’t know what steps China is taking to prevent its dust explosions, but I do know what can be done here in the U.S. It’s time for OSHA to move on a comprehensive regulation to adequately address combustible dust hazards” – stated CSB Chairperson Moure-Eraso.
What Does This Mean For U.S. Manufacturers?
While the current status of combustible dust regulation is not fixed on a federal level, (i.e. OSHA) the dangers of combustible dust still present a clear and present danger to both the financial interests of U.S. manufacturers and the lives of U.S. workers.
As a result of the long history of combustible dust explosions in the U.S. many state and municipal fire codes and other regulatory agencies already have combustible dust regulations for most industries. In addition, many insurance providers are requiring plants as part of regular safety audits to improve dust hazard protection in their facilities as a condition of maintaining their coverage.
Maintaining a sufficiently-sized dust collection system is vital to prevent combustible dust explosions.
The first step to preventing these incidents is recognizing the dangers combustible dusts present in an industrial setting. Measures to control or mediate combustible dust hazards include maintaining a adequate dust collection system (i.e. a baghouse), good house-keeping practices and good facility design.
A main contributing factor in all of the above mentioned incidents was an improperly operated or maintained dust collection system. From inefficient collection pickup points, to bucket elevators that were not properly cleaned and sealed, to conveyor systems that were overloaded to baghouses of insufficient size and fire protection. A relatively minor investment in a facility’s dust collection system, such as changing to a sufficiently sized collector (i.e. larger CFM, larger baghouse with more dust collector bags) or additional baghouses will prevent the kind of massive capital loss and loss of life seen in these past incidents.
While governmental regulation will not ensure that these tragic incidents are the last of their kind, it is hoped that along with increase corporate awareness and ever-improving dust collection technology, these incidents will become rarer and rarer. Saving not only billions of dollars for companies, but safeguarding millions of workers in these industries.
Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs. Follow Meon
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The Chemical Safety Board issued a final report on a series of deadly combustible dust explosions in Tennessee. It highlights dust collection systems as the only way to prevent deadly combustible dust explosions. Recommends OSHA issue new comprehensive dust regulations within one year.
January 6th, 2012 Baghouse.com News | The Chemical Safety Board has issued its final report regarding a series of deadly industrial dust explosions accidents that occurred at the Hoeganaes powdered metals plant in Gallatin, Tennessee in 2011. The main cause of these three deadly explosions and fires that claimed five lives and injured many others was determined to be negligence regarding combustible dust hazards. The CSB further noted that a main factor in these accidents was the constant neglect of the plant’s dust collection system.
All three of the incidents occurred when large amounts of accumulated highly combustible iron dust where dispersed into the air and then ignited. The plant manufactures various metal powders for industrial use, the most produced of which is iron powder.
Picture of combustible dust accumulations near a bucket elevator that killed 2 workers when the dust was ignited by the motor.
The CSB investigation found that iron dust was present in high enough concentrations in the air to be clearly visible, and had accumulated on nearly all surfaces including elevated ledges, rafters, and other overhead spaces in amounts of 4 inches or greater. In addition the CSB clearly documented through photos and videos how dust handling equipment such as bucket elevators, conveyor belts, etc. were not adequately sealed, regularly leaking large amounts of dust into the air when in operation, and were not connected to the plant’s dust collection system. Additionally, plant workers told investigators that the dust collection system was regularly out of service due to maintenance.
Three Combustible Dust Incidents At One Plant In Six Months
The CSB investigation begin after the first of the three incidents occurred on January 31st, 2011 when fine iron dust particles coming from a broken bucket elevator were ignited while two maintenance personnel were performing repairs. The airborne particles were ignited by a spark from the bucket elevator’s electrical motor when it engaged. The resulting explosion and fire severely burned both workers, and eventually proved fatal for both men.
Just two months later, while the CSB was still conducting an investigation into the first incident, another flash fire occurred on March 29th when a maintenance worker used a hammer while reconnecting a gas line on the side of one of the plant’s furnaces. When he struck the side of the furnace with the hammer it lofted accumulated iron dust into the air, which then ignited, severely burning him, and causing him to fall from elevated working position further injuring him. According to CSB officials, “the build up of so much iron dust near a furnace with open flames and hot surfaces was a recipe for disaster. A fire was basically inevitable the moment the dust was dispersed into the air.”
March 29, 2011 Combustible dust fire in Gallatin, Te Hoeganaes powdered metals plant. The second of two serious dust fires/explosions in six months at the plant
Even with two such incidents within two months of each other, Hoeganaes management and its parent company still failed to take action to address the combustible dust safety issues at the Gallatin, Tennessee plant.
This failure proved to be catastrophic as just a few months later on May 27th when the an even deadlier third incident took place. Workers were repairing a corroded furnace pipe containing extremely flammable hydrogen gas caught fire when workers used a forklift to raise a metal floorplate to access the pipe. Workers has assumed the leaking gas was non-flammable nitrogen. After the initial explosion, the leaking gas continued to burn as a continues jet fire. The force of the initial explosion shook loose largeamounts of accumulated iron dust from overhead rafters. As the large plumes of iron dust fell they were ignited by the jet fire causing massive explosions further injuring workers and damaging the plant. One worker stated that so much iron dust was lofted into air, that even with a flashlight he was only able to see two to three feet in front of him as he tried to escape.
The aftermath of the third Hoeganaes combustible dust explosion in 2011. Notice the dislodged metal floor grating.
Evidence of Danger Present Well Before
All of these incidents were easily preventable. However plant management refused to take appropriate action to improve dust collection at the plant.
Even before the series of incidents, the plant had twice tested its dusts for combustibility. They ever were warned of the potential for a dust explosion after an insurance audit, which cited the potential for a such an accident due to the plant’s poor dust collection system policies, and housekeeping.
In addition to these warnings, the plant had firsthand knowledge of the combustibility hazards present in the plant, when on several occasions flash fires had occurred when workers performed maintenance using welding torches on dust covered conveyor belts. In fact the Gallatin Fire Department Hoeganaes facility in the last 12 years. These included one in June of 1999 where an iron dust fire in the baghouse lead to the hospitalization of one worker for smoke inhalation.
The CSB found that part of the core problem was that the plant, which was built over thirty years ago, was not designed according to good practice guidelines for combustible dust hazards, such as those set forth by the NFPA (National Fire Protection Association). “During its decades of operation, [the plant] was never redesigned to address the serious dust hazards” states CSB investigator Johnnie Banks.
Accumulated combustible iron dust on rafters at the Hoeganaes plant lead to several deaths when a series of dust fires and explosions occurred in 2011.
The plant has numerous flat elevated surfaces that easily accumulate large amounts of dust, and are difficult or impossible to clean with regularity. NFPA 484, which covers combustible metals safety, recommends that “floors elevated platforms, and gratings be designed to prevent dust accumulations and facilitate cleaning.” The same standard also requires that any machinery that emits combustible dust be connected to a dust collection system. Both of these recommendations were not followed by the Hoeganaes plant.
Many have asked how is it that these accidents were allowed to happen, even when plant management had all of these warnings and was in clear violation of best industry standards?
The city of Gallatin requires industrial facilities, including the Hoeganaes plant, to comply with the International Fire Code, which includes a brief chapter on combustible dust standards and references the more detailed NFPA standards. However the code does not require compliance with the more stringent NFPA standards. As a result the plant was not directly in violation of the International Fire Code that it was mandated to follow.
CSB Recommendations Based On Its Investigation
As a result of the CSB investigation, the CSB has proposed several actions be taken to reduce the risk of more combustible dust incidents from occurring elsewhere.
First, the CSB recommended that the International Code Counsel “revise the International Fire Code to mandate compliance with the combustible dust safety standards set forth by the NFPA.”
Secondly, in its 2006 report on the dangers of combustible dust hazards in industry, the CSB recommended that OSHA (Occupational Health and Safety Administration) issue a comprehensive combustible dust safety standard for general industry. As a result in 2007 OSHA instituted a national emphasis program for combustible dust, with the stated goal of eventually issuing a comprehensive combustible dust standard in the near future. In 2009 OSHA announced that it would begin the rule making process for combustible dust hazards. However, in 2011 at the time of these accidents, no standard had yet been proposed, or completed.
As a result, in its final report on the incidents, the CSB recommended that OSHA issue its long awaited combustible dust standards “within one year”, and that the standard include combustible iron and steel powders. In the meantime, the CSB recommended that plants that manufacture steel and iron powders be included in the national emphasis program. for combustible dust.
What This Means For Facilities With Combustible Dust Hazards
The continued loss of life due to combustible dust hazards is no longer being ignored by the CSB, OSHA, or other governmental agencies. The only way to prevent the loss of additional lives is for industry to begin following best industry standards as set forth by the NFPA and eventually the comprehensive standard by OSHA.
In the meantime, plant mangers and operators can educate themselves on the dangers of combustible dusts by reviewing educational articles on the subject such as those published here on Baghouse.com (http://www.baghouse.com/2011/01/19/the-potential-for-dust-explosions-in-dust-collection-systems/). They can also seek the assistance of experts in the dust collection industry to identify areas where improvement can be made, and make suggestions of ways to increase dust collection efficiency at their facilities.
For more information about the dangers of combustible dusts, please see the following links:
The CSB video reports on the Hoeganes incidents:
The following LinkedIn groups work specifically to raise awareness of combustible dust hazards, and lobby for comprehensive standards for general industry:
| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.
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Performing any kind of work on a baghouse can be hazardous work. Often set in industrial locations, dealing with baghouse systems can present a number of dangers to personnel. Thankfully, these maintenance tasks can be accomplished safety if proper safety precautions are followed.
A new article authored by Baghouse.com that has been published on a leading environmental and safety magazine EHSToday.com that offers 5 often overlooked baghouse safety proceedures for performing any type of work on dust collection systems. You can read the article here: 5 Essential Baghouse Maintenance Safety Precautions I encourage all of our readers to take a moment and read this article and consider how well are you doing regarding baghouse safety.
Direct URL: http://ehstoday.com/industrial_hygiene/news/baghouse-safety-precautions/
About the Author
| Dominick DalSanto is an Author & Environmental Technologies Expert, specializing in Dust Collection Systems. With nearly a decade of hands-on working experience in the industry, Dominick’s knowledge of the industry goes beyond a mere classroom education. He is currently serving as Online Marketing Director & Content Manager at Baghouse.com. His articles have been published not only on Baghouse.com , but also on other industry related blogs and sites. In his spare time, Dominick writes about travel and life abroad for various travel sites and blogs.
A clear description of the intended use of the explosion isolation system.
A clear description of the intended use of the explosion isolation system.
