Combustible Dust Seminar. Paul M. Sullivan, CIH Compliance Supervisor NCDOL/OSH Division - Charlotte Field Office (704)

Transcription

1 Combustible Dust Seminar Paul M. Sullivan, CIH Compliance Supervisor NCDOL/OSH Division - Charlotte Field Office (704)

2 Objectives 2 Review the basics of combustible dust Primary / secondary dust explosions Recent dust explosions Discuss OSHA enforcement activities Directives Applicable NFPA regulations Examples of citations issued

3 From 1980 to 2005: combustible dust fires and explosions in general industry. 44 different states affected. 119 workers killed, 718 injured. Seven of the explosions were catastrophic, involving multiple fatalities and a significant community economic impact. Source: CSB Report 2006-H-1

4 4 Dust Explosion Pentagon

5 OSHA NEP Definition 5 A combustible dust is: A combustible particulate solid that presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations, regardless of particle size or shape.

6 Combustible Dust 6 Dusts specifically identified in the NEP: Metal dusts such as aluminum and magnesium Wood dust Coal and other carbon dust Plastic dust and additives Other organic dusts such as sugar, paper, soap & dried blood.

7 Composite Decking

8 8

9 Combustible Dust 9 These very small particles become airborne and settle on surfaces and in crevices throughout the manufacturing area. Lighting, pipes, dust collectors, other equipment. When disturbed, they can generate potentially explosive dust clouds.

10 Ignition Sources

11 Ignition Sources 11 are often during atypical activities.

12 The Typical Explosion Event Initial Internal Deflagration Process Equipment Time, msec.

13 The Typical Explosion Event Initial Internal Deflagration Shock Wave Process Equipment Time, msec.

14 The Typical Explosion Event Initial Internal Deflagration Elastic Rebound Shock Waves Process Equipment Time, msec.

15 The Typical Explosion Event Initial Internal Deflagration Dust clouds caused by Elastic Rebound Process Equipment Time, msec.

16 The Typical Explosion Event Containment Failure from Initial Deflagration Dust Clouds Caused by Elastic Rebound Process Equipment Time, msec.

17 The Typical Explosion Event Dust Clouds Caused by Elastic Rebound Process Equipment Secondary Deflagration Initiated Time, msec.

18 The Typical Explosion Event Process Equipment Secondary Deflagration Propagates through Interior Time, msec.

19 The Typical Explosion Event Process Equipment Secondary Deflagration Vents from Structure Time, msec.

20 The Typical Explosion Event Secondary Deflagration Causes Collapse and Residual Fires Time, msec. Diagrams Courtesy of John M. Cholin, P.E., FSFPE, J.M. Cholin Consultants, Inc.

21 Where is the Primary Explosion? Initial Internal Deflagration Process Equipment

22 Explosible Range IH Range Explosible Range Dust Deposit MASS OF POWDER/DUST PER UNIT VOLUME [g/m 3 ] Source: Dust Explosions in the Process Industries, Second Edition, Rolf K Eckhoff 22

23 Equipment Involved in Dust Explosions US ( ) UK ( ) Germany ( ) Material Number of Incidents % Number of Incidents % Number of Incidents % Dust Collectors Grinders Silos/Bunkers Conveying Systems Dryer/Oven Mixers/Blenders >12 > Other or Unknown Total Source: Guidelines for Safe Handling of Powders and Bulk Solids, CCPS, AICHE 23

24 Cyclone Grinder 24

25 25Ventilated Electrical Cabinet

26 West Pharmaceuticals 26 Kinston, NC January 29, 2003 Facility manufactured rubber drug delivery components Such as syringe plungers and vial seals. Explosion & fire killed six workers and injured 38 others, including two firefighters. One student was injured when windows were broken at a school 0.7 miles away.

27 27

28 Simplified Automated Rubber Compounding System Process Raw materials from Kitchen Mixer Concrete Slab Drop Ceiling Rubber Batch off Antitack Slurry Dip Tank Mill

29 Source: CSB Report I-NC

30 30 Due to the amount of damage, investigators were not able to establish what dispersed the dust or what ignited it.

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33 Cause of Primary Explosion? 33 Not known for sure, but there are several theories: Deflagration of vapors emitted by decomposing rubber (overheated batch of rubber + static spark). Ignition of dust by overheated electrical ballast or fixture. Ignition of dust by an electrical spark Ignition of dust in a motor cooling duct.

34 Imperial Sugar 34 Port Wentworth, GA February 7, people killed / 40+ injured Explosion of sugar dust in a building used to store refined sugar prior to packaging and two of three 100-foot tall silos adjacent to it.

35 Imperial Sugar 35 The Imperial Sugar manufacturing facility housed a refinery that converts raw cane sugar into granulated sugar. A system of screw and belt conveyors, and bucket elevators transported granulated sugar from the refinery to three 105-foot tall sugar storage silos. It was then transported through conveyors and bucket elevators to specialty sugar processing areas and granulated sugar packaging machines. Sugar products were packaged in four-story packing buildings that surrounded the silos, or loaded into railcars and tanker trucks in the bulk sugar loading area. CSB Report No I-GA

36 Imperial Sugar 36 CSB believes the primary dust explosion was in the silo tunnel, inside the enclosed (and unventilated) conveyor system. Conveyor system was enclosed in Ignition source was mid-way along the steel belt, likely from an overheated bearing. OSHA believes the primary explosion most likely occurred inside and near the base of the East Packaging/Production Bucket Elevator, located at the east side of Silo #1 in the "Silo Shaft just east of the tunnel under the silos where the steel belt conveyor under Silo #1 and #2 feeds granulated sugar into the base of the bucket elevator.

37 CSB Report No I-GA

38 CSB Report No I-GA

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40 40

41 CSB Report No I-GA

42 CSB Report No I-GA

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44 44 CSB Report No I-GA

45 Dust Explosion Accidents on OSHA Database 03/05/ Combustible Dust Explosion 12/29/ Grain Dust Explosion 07/28/ Dust Explosion 02/07/ X 2062 Combustible Sugar Dust Explosion 08/29/ Metal Dust Explosion Injured Three (3) Employees 06/14/ X 2499 Fire 09/12/ Coal Dust Explosion 10/14/ X 2421 Employee Is Killed in Wood Dust Explosion 06/10/ Three Employees Injured in Dust Explosion 02/18/ Employee Suffers Second and Third Degree Burns in Explosion 10/29/ X 3365 Aluminum Dust Explosion Injures Six Employees and Kills One 08/10/ X 2041 Explosion Kills Two Employees and Injures Three Others 07/09/ X 1795 One Employee Dies Another Injured, in Dust Explosion 05/23/ Two Employees Burned in Dust Explosion

46 How is OSHA handling combustible dust hazards? 46

47 47

48 What does the NEP Cover? 48 Inspection Scheduling Based on SIC/NAICS code Inspection Resources CSHO Safety & Health Inspection & Citation Procedures Hazard recognition (History of fires, dust accumulation) Sampling methods Typical citations

49 49 NEP Results October 2009

50 Combustible Dust? 50 OSHA inspectors will rely on various sources to determine if the dust is combustible. MSDS s, employer s testing, literature searches Sample may be sent to Salt Lake City for analysis if necessary (~ $750)

51 51 NEP Results October 2009

52 Housekeeping/Dust Layer 52 1/8 requirement in grain standard NFPA 654 (Annex D) guidance 1/32 over 5% of the building floor area Thickness of a paper clip

53 53 From NFPA 654 Annex D

54 50 feet 50 feet 50 x 50 = 2500 ft 2 room floor area 5% = 125 ft 2 ONE fluorescent light (40 x 0.5 ) = 20 ft 2 of surface area

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61 61 Preventing Secondary Explosions

62 Primary Explosion Hazards 62 Addressed via the General Duty Clause

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64 64

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68 68

69 GDC Citations 69 A search of the OSHA database for GDC citations containing the language of NFPA 654, 664, 484, or 61 showed 186 citations, 24 of which were in NC. May be some overlap if the compliance officer referenced multiple NFPA regulations. NFPA 654 and 664 were the most often referenced with 68 and 67, respectively (12 and 11 in NC).

70 GDC Citations 70 The following examples are verbatim from actual citations and are provided to assist in identifying and controlling similar hazards at other establishments. While citations have been issued, many are not final order. They may be amended or deleted after an informal conference or through contestment proceedings.

71 NFPA 654 GDC Citations since 01 Jan 2009: 68 citations, 12 in NC 04/15/2010 5A0001 Dust&Fumes 2095 Sara Lee Food Service 04/15/2010 5A0001 Dust&Fumes 2431 H & H Woodworking, Inc. 04/13/ Dust&Fumes 3011 Oliver Rubber Company, Llc 03/31/ Dust&Fumes 2865 Dye-Chem International, Inc. 03/30/2010 5A0001 Dust&Fumes 2541 R & S Marble Designs, Inc. 03/30/2010 5A0001 Dust&Fumes 2821 Formosa Plastics Corporation 03/17/2010 5A0001 Dust&Fumes 5111 Deltacraft Paper Company Llc 03/16/2010 5A0001 Burns 3089 Csp of Ohio 03/10/2010 5A0001 Dust&Fumes 3089 Norwesco Inc. 03/03/ A Dust&Fumes 2066 Barry Callebaut U.S.A. Llc 02/19/2010 5A0001 Dust&Fumes 3085 Captive Plastics 02/17/2010 5A0001 Dust&Fumes 2434 Marshall Towne Millwork, Llc 02/05/2010 5A0001 Dust&Fumes 2679 Us Greenfiber, Llc 02/04/2010 5A0001 Burns 2493 Geneva Wood Fuels, Llc 02/04/2010 5A0001 Chemical 2895 American Aerogel Corporation 01/25/2010 5A0001 Dust&Fumes 5169 Toll Compaction Group, Llc 01/15/ Dust&Fumes 3535 Forbo Siegling, Llc 71

72 GDC Citation w/ NFPA 654 Reference Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to fire hazards: Location: Wood Cutting Department Date: on or about 10/21/09 a) The segments of duct work for the dust collection system were neither grounded, nor bonded to each other. Abatement Note: One feasible means of abatement, among others, is to comply with the requirements of NFPA 664 (Standard for the Prevention of Fires and Explosions in Wood Processing and Wood Working Facilities, 2007 Edition); and NFPA 654 (Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2006 Edition). 72

73 GDC Citation w/ NFPA 654 Reference Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to fire and/or deflagration hazard: a) On or about 01/07/10, in the production/small baler area, a dust collector (Kernic System, volume= 165cf) was located inside and it was not equipped with explosion protection per NFPA 654, exposing employees to fire and/or deflagration hazards. 73 Among feasible methods to abate this hazard is to provide fire/deflagration protection for dust collectors in accordance with National Fire Prevention Association (NFPA) 654, 2006 Edition,Standard for the Prevention of Fire and Dust Explosions from Manufacturing, Processing and Handling of Combustible Particulate Solids. Chapter 7, Section 7.13 Air-Material Separators (Air Separation Devices). Section Where an explosion hazard exists, air-material separators shall be located outside of buildings" or follow Section Section Explosion Protection for Equipment.

74 a) The Miko-Pulseaire dust collector, used to collect dust from grinding and drilling parts was located inside the building. b) The Miko-Pulseaire dust collector had no explosion venting or other explosion prevention or suppression system. c) No isolation device or system was installed to prevent explosions in the Miko- Pulseaire dust collector from propagating upstream to the dust collection ducts. Among other methods, a feasible abatement method to correct this hazard is: Relocate the dust collectors outside the building, install relief venting or other explosion suppression or prevention system on the dust collectors. Install isolation device to prevent propagation of explosions through duct work to employee occupied areas.

75 NFPA 664 GDC Citations since 01 Jan 2009: 67 citations, 11 in NC 04/20/2010 5A0001 Chemical 2451 Redman Homes, Incorporated 04/15/2010 5A0001 Dust&Fumes 2431 H & H Woodworking, Inc. 04/12/2010 5A0001 Burns 2434 Mountaineer Cabinet Co., Inc. 04/07/2010 5A0001 Crushing 2448 Coastal Pallet Corporation 03/31/2010 5A0001 Dust&Fumes 2434 Raymond Smith Cabinet Shop, Inc. 03/26/ A Dust&Fumes 2511 the Closet Factory 03/19/2010 5A0001 Explosion 2452 Haven Homes, Incorporated 03/04/2010 5A0001 Dust&Fumes 5211 Strait & Lamp Lumber Company, Inc. 03/03/2010 5A0001 Burns 2499 Superior Trim & Door, Inc. 02/23/2010 5A0001 Burns 2434 Plain & Fancy Custom Cabinetry 02/22/2010 5A0001 Burns 2511 Country Builders Furniture, Llc 02/18/2010 5A0001 Burns 3952 Larson Juhl

76 (a) the ductwork conveying Class II wood dust, did not have isolation devices to prevent fires and deflagrations from propagating from the dust collector back through the inlet ductwork to the woodworking equipment, on or about February 18, (b) Employees used a Jet horizontal edge sander, model HCS , to edge sand counter tops. The employer had the sander connected to a Grizzly enclosureless dust collector, serial number The dust collector, which contained a Class II explosive wood dust, got emptied only every few weeks, on or about February 18, ABATEMENT NOTE: Among other methods, one feasible and acceptable abatement method to correct this hazard includes following the National Fire Protection Association (NFPA) 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, 2007 Edition, including, but not limited to: *Isolate conveying systems with fire and deflagration hazards to prevent propagation of fire and deflagration both upstream and downstream into occupied areas or other critical process equipment (NFPA 664, Chapter 8, Section ). Examples of isolations methods include mechanical isolation (such as rotary airlock valves), chemical isolation (discharge of a chemical extinguishing agent into interconnecting pipe or duct), and flame front diverters. *Remove collected dust daily or more frequently from enclosureless dust collectors located indoors (NFPA 664, Chapter 8, Section (7)(e)).

77 Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish to each of his employees employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to a fire/explosion hazard from the usage of compressed air to clean in a class II dust location. a) In the production area, employees were exposed to fire and explosion hazards while performing cleaning of combustible dust that had accumulated on surfaces and other areas in the work station. The employer failed to ensure that combustible dust was not being removed from the area utilizing compressed air while other equipment was in operation, such as sanding and grinding equipment, radios, portable light stands, etc. 77 AMONG OTHER METHODS, A FEASIBLE ABATEMENT METHOD TO CORRECT THE HAZARD IS TO UTILIZE A VACUUM APPROVED FOR A CLASS II COMBUSTIBLE DUST LOCATION AND/OR REMOVE ALL SOURCES OF IGNITION AS SPECIFIED BY SECTION OF THE NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) 664 "STANDARD FOR PREVENTION OF FIRES AND EXPLOSIONS IN WOOD PROCESSING AND WOODWORKING FACILITIES", 2007 EDITION.

78 Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to severe burn injuries from the potential dust explosion that could have resulted from, or have been exacerbated by lack of isolation devices on the inlet side of the dust collector and on the recycled air side: (a) the dust collection system was used to collect wood dust and recycled the air back into the building. There were no isolation devices on the inlet and outlet sides of dust collect in the event of a fire or explosion, on or about December 18, AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THESE HAZARDS INCLUDES FOLLOWING NFPA 664, STANDARD FOR PREVENTION OF FIRES AND EXPLOSIONS IN WOOD PROCESSING AND WOODWORKING FACILITIES, 2007 EDITION, INCLUDING BUT NOT LIMITED TO: PROVIDE A HIGH SPEED ABORT SYSTEM ON THE RETURN AIR DUCTWORK AND INSTALL A BACK FLASH DAMPER OR A SUPPRESSION SYSTEM ON THE INLET SIDE OF THE DUST COLLECTOR. VERIFICATION REQUIRED

79 NFPA 484 GDC Citations since 01 Jan 2009: 25 citations, 1 in NC 04/01/ Dust&Fumes 3315 Odermath (Usa) Inc. 03/05/ Dust&Fumes 3471 Specialty Metal Processing Inc. 02/23/ Dust&Fumes 3316 Nucor Cold Finish Wisconsin, Inc. 02/19/ Dust&Fumes 3599 Ray Machine, Inc. 12/09/ Dust&Fumes 3398 Metal Improvement Company, Inc. 11/12/ Dust&Fumes 3363 General Die Casters Inc. 10/16/ Dust&Fumes 3365 Broward Casting Foundry, Inc. 09/28/ Burns 3499 Milford Fabricating Co., Inc. 09/17/ Dust&Fumes 3365 Boose Aluminum Foundry Company, Incorporated 09/02/ Dust&Fumes 3441 Kard Welding, Inc. 08/11/ Electric 3724 Gkn Aerospace New England, Inc /29/ Dust&Fumes 3484 Sturm, Ruger & Co., Inc. 05/11/ Burns 3471 Elite Finishing, Llc. 05/04/ Dust&Fumes 3365 Castek Aluminum, Inc.

80 Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish a place of employment which was free from recognized hazards that were likely to cause death or serious physical harm. Employees were exposed to the hazards associated with dust explosion, deflagration, or other fire hazards. a) On or about November 5, 2009, the employer did not have a hot work permit system to control all ignition sources in a Class II combustible dust area. Among other methods, a feasible abatement method to correct this hazard is to comply with NFPA 484, Standard for Combustible Metals, and develop and implement a hot work permit system that includes completing a hot work permit, ensuring that all hot work procedures are approved by qualified personnel, and cleaning combustible dust in the area prior to the commencement of work which has the potential to produce sparks. (Section , Control of Ignition Sources). 80

81 Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that caused or were likely to cause death or serious physical harm in that employees were exposed to the hazard of potential fire and explosion from dust collector for combustible metal dust being located inside the building with being designed to minimize damage that would occur in the event of a dust explosion. The dust collector for the brushing of low carbon steel metal operation was at increased risk of a fire or explosion in that it was: a) located inside of the building b) did not have deflagration venting c) portions of the ductwork were constructed with non-conductive flexible hose. AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD is to comply with the National Fire Protection Association (NFPA) 484 "Standard for Combustible Metals" 2006 edition; NFPA 91 "Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids," 2004 edition; NFPA 68 "Standard on Explosion Protection by Deflagration Venting" 2007 edition, NFPA 69 "Standard on Explosion Prevention Systems," 2008 edition. a) relocate dust collector to a safe location, outside of the building equip with deflagration venting. b) replace non-conductive ductwork with conductive duct

82 NFPA 61 GDC Citations. Since 01 Jan 2009: 26 citations, 0 in NC 04/15/ Dust&Fumes 2095 Sara Lee Food Service 04/08/ Dust&Fumes 2048 D&D Ingredient Distributors Inc. 04/08/ Dust&Fumes 2048 D&D Ingredient Distributors Inc. 03/15/ Dust&Fumes 2048 Fairview Mills, Inc. 02/18/ Dust&Fumes 2048 Endres Processing, Llc 02/17/ Dust&Fumes 2051 Joseph Campione, Inc. 01/14/ Electric 2041 Bona Via Inc. 12/17/ Dust&Fumes 0723 Birdsong Corporation 11/30/ Burns 2048 Endres Processing,Llc,Endres Processing Ohio, Llc 11/30/ Dust&Fumes 2048 Endres Processing,Llc,Endres Processing Ohio, Llc 11/02/ Electric 2087 Firmenich Incorporated 10/26/ Dust&Fumes 5149 Flex Pack 10/05/ Burns 2066 Gilster Mary Lee 10/05/ Burns 2048 All-Feed Processing and Packaging, Inc. 82

83 Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to dust explosion, deflagration, or other fire hazard from process equipment that was not protected by proper venting, inerting, or containment or suppression systems: (a) On or about October 19, 2009, the employer did not ensure that process equipment was protected with explosion venting, inerting, or containment or suppression systems, to include but not limited to, bucket elevators, silos, the hammer mills and their associated cyclone and dust collector. The fugitive dust in the hammer mill area, material conveyed in bucket elevators, material stored in silos and the sugar beet pulp processed in the hammer mills were explosive and Class II materials. Among other methods, feasible abatement methods to correct this hazard are to install appropriate explosion venting in compliance with National Fire Protection Agency (NFPA) 61, Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2008 edition, Chapter 6, Explosion Prevention, Relief, and Venting. 83

84 Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to fire and combustion, explosion, and deflagration hazards due to cleaning combustible peanut dust (in varying thicknesses, up to one inch thick) off equipment and surfaces with compressed air: a) In the oil stock loading area, on or about and at times prior to October 14, 2009, employees were exposed to fire and combustion, explosion, and deflagration hazards due to cleaning combustible peanut dust off equipment and other surfaces with compressed air. Among other methods, one feasible and acceptable means of abatement is to clean the areas using a vacuum system in accordance with NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2008 Edition. 84

85 Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to fire and explosion hazards associated with the buildup of combustible sugar dust: a) The horizontal and vertical surfaces around the silos had a buildup of more than 1/4-inch to 3/4-inches of a Class 2 combustible sugar dust, as observed on or about 07/09/2009. The surfaces included the beams, joists, equipment, west wall, and slightly on the floor. No explosion relief panels were distributed along the exterior walls and roof of the area. b) The dust collector was located inside of the building (5-feet from an exterior wall) and vented to the interior of the building, as observed on or about 07/09/2009. This allowed for the sugar dust to be exhausted inside the facility. No explosion relief venting was installed on the dust collector, and no explosion suppression system was in place in accordance with NFPA 69. c) The ventilation ducts for the two sugar silos were connected to the dust collector with flexible tubing which was not electrically conductive and bonded/ grounded with the rest of the system, as observed on or about 07/09/ Among other methods, means of feasible and acceptable abatement include compliance with National Fire Protection Agency (NFPA) 61 "Standard for the Prevention of Fire and Dust Explosions in Agricultural and Food Processing Facilities" (2008) edition, and NFPA 69 "Standard on Explosion Protection Systems" 2008 edition