Illinois Manufacturers Best Practices January 2016 Webinar

Transcription

1 Illinois Manufacturers Best Practices January 2016 Webinar Combustible Dust Housekeeping: Stay Safe & Compliant January 28, 2016

2 Combustible Dust Housekeeping: Stay Safe & Compliant Andrew Luessenhop, Nilfisk, Inc.

3 Overview What is Combustible Dust? History of Industrial Explosions & Regulatory Overview Proper Maintenance and Housekeeping Practices Choosing the Right Housekeeping Equipment Resources Page 3

4 Page 4 What is Combustible Dust?

5 Definitions OSHA A solid material composed of distinct particles or pieces, regardless of size, shape, or chemical composition, which presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations NFPA 652 A finely divided combustible particulate solid that presents a flashfire hazard or explosion hazard when suspended in air or the processspecific oxidizing medium over a range of concentrations Page 5

6 Combustibility The absence of previous incidents cannot be used as the basis for deeming a particulate not combustible (NFPA 652, Section 5.2) Owner/operator of a facility is responsible for determining the combustibility of material HAVE DUST TESTED! Test results, historical and published data must be documented and provided to AHJ upon request Source: NFPA 652, Hazard Identification Page 6

7 Dust Explosions Conditions Secondary Explosions 1) Fuel to burn (combustible dust) 2) Oxygen to sustain the fire (air) 3) Heat from an ignition source (spark) 4) High concentration of dust into the air (dispersion) 5) Dust within an enclosure or structure (confinement) Page 7

8 Page 8 History of Industrial Explosions & Regulatory Overview

9 Combustible Dust Incidents by Industry Furniture & Fixtures, 4% Other, 7% Chemical, 12% Metal, 8% Electric Services, 8% Wood, 15% Food, 24% Rubber & Plastic Services, 8% Fabricated Metal Products, 7% Equipment Manufacturing, 7% Page 9

10 Combustible Dust Tragedies Between (last update provided by OSHA) 281 Dust Fires/Explosions 119 Fatalities 718 Injuries Over 12 catastrophic events in last decade: Apple computer manufacturing plant explosion Aluminum wheel finishing plant explosion Imperial Sugar Savannah, GA 14 deaths, 42 injured $6 million in OSHA fines, leading to new policies Cause: Sugar dust accumulated in production areas exploded Bartlett Grain Co. Atchison, KS 5 deaths $406,000 in OSHA fines Cause: Grain dust accumulation inside the grain elevator February 7, 2008 October 29, 2011 Page 10

11 OSHA Combustible Dust National Emphasis Program Issued in 2008 after Imperial Sugar explosions Purpose is to inspect facilities that generate/handle combustible dusts which pose a deflagration hazard that can lead to an explosion Consists of 18 different standards that can be used to cite against Most Frequently Cited Violations During Inspections 1. Hazard communication ( ) 2. Respiratory protection ( ) 3. Housekeeping ( (a)) 4. Electrical safety ( ) 5. Lockout/Tagout ( ) 6. Electrical safety ( ) Source: OSHA, Combustible Dust National Emphasis Program OSHALawupdate.com, 2011 Page 11

12 Current Penalties Under the NEP $28,769,376 $15,323,577 $10,594,163 $1,742,553 $658,926 $450,147 Page 12

13 OSHA Proposed Combustible Dust Standard Upgraded from a long-term action to the pre-rule stage in Spring 2015 Small Business Review (SBREFA) panel expected in February 2016 Most Wanted Safety Improvement by the U.S. Chemical Safety Board Source: OSHA, Unified Agenda 2015 Page 13

14 Combustible Dust Inspections Federal OSHA (October 1, December 31, 2013) Programmed, 1483 Unprogrammed, 1748 Page 14

15 OSHA General Duty Clause (GDC) Employers can be cited when workers are exposed to hazards not currently addressed in OSHA standards Conditions for a citation: there must be a hazard; the hazard must be recognized; the hazard causes or is likely to cause serious harm or death; and the hazard must be correctable Source: Section 5(a)(1) of the Occupational Safety and Health Act of 1970 Page 15

16 Combustible Dust Violations 1,319 1, Page 16

17 NFPA 652: Fundamentals of Combustible Dust NFPA 652 Fundamentals of Combustible Dust Effective September 2015 NFPA 61 NFPA 484 NFPA 664 NFPA 654 NFPA 655 Agricultural & Food Processing Facilities Combustible Metals Wood Processing & Woodworking Facilities Other Industries (i.e. Plastics, Pharmaceutical) Sulfur Source: NFPA 652, Origin and Development Page 17

18 NFPA 652: Application (1.3) Applies to all facilities and operations that manufacture, process, blend, convey, repackage, generate, or handle combustible dusts or combustible dust particulate (1.3.2) Exemptions available such as warehousing of sealed containers of material when not associated with an operation that handles or generates combustible dust (1.3.3) Refer to Flow Diagram for Combustible Dust Hazard Evaluation (Figure 1.3.1(a)) Page 18

19 NFPA 652: Conflicts (1.4) Conflict Where a requirement in an industry/commodityspecific standard differs from the requirement specified in NFPA 652 Standard to be Applied Industry/Commodity-Specific Standard Where an industry/commodity-specific standard prohibits a requirement specified in NFPA 652 Industry/Commodity-Specific Standard Where an industry/commodity-specific standard neither prohibits nor provides a requirement NFPA 652 Where a conflict between a general requirement and specific requirement exists NFPA Specific Page 19

20 NFPA 652: Retroactivity (1.5) AHJ is permitted to apply retroactively ANY portion of the standard if unacceptable degree of risk is determined Authority Having Jurisdiction (AHJ) Noun An organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure. Examples: Insurance Company, Internal EH&S Staff, Plant Manager, Local Government Inspector, State Fire Marshal, Federal Government Agency, etc. Page 20

21 NFPA 652: Dust Hazard Analysis (7.1) Identify fire, deflagration and explosion hazards and document how hazards are managed Required at all operations that generate, process, handle or store combustible dusts/particulates For existing facilities, must be completed by September 2018 (3 years from effective date of standard) Page 21

22 NFPA Industry/Commodity-Specific Standards Future revisions of current standards will reference and be outlined similar to NFPA 652 The following standards are under revision with updated editions to be released in 2017: NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids Page 22

23 Page 23 Proper Maintenance & Housekeeping Practices to comply with OSHA & NFPA standards

24 Housekeeping Refers to the routine maintenance and upkeep of a workplace Proper housekeeping/maintenance is a recommended means of deterrence for dozens of workplace hazards OSHA requires good housekeeping practices in several General Industry Standards Did you know? During a 2011 expert forum on combustible dust held by OSHA, one expert estimated that 95-99% of injuries and fatalities could be prevented through proper housekeeping. Page 24

25 OSHA Maintenance Recommendations Clean dust residues at regular intervals Use cleaning methods that do not generate dust clouds, if ignition sources are present (such as blow-down methods) Only use vacuum cleaners approved for dust collection Regularly clean floors and horizontal surfaces (i.e. ducts, pipes, hoods, ledges, beams) to minimize dust accumulations within operating areas of the facility Keep dust accumulation to less than 1/32 inch thick Electrically-powered cleaning devices (i.e. sweepers or vacuum cleaners) used in dusty areas must be approved for the hazard classification Source: OSHA, Combustible Dust National Emphasis Program Page 25

26 NFPA 652: Housekeeping (8.4) Requirements applied retroactively Selected cleaning method should reduce the potential for creating a combustible dust cloud General takeaways: Vacuuming is the preferred method of cleaning (equipment requirements laid out in ) When vacuuming is impractical, sweeping/water washdown is permitted Blowdown is only permitted when other methods, mentioned above, have already been used Page 26

27 NFPA 652: Housekeeping Procedure ( ) Must be documented and include the following: 1. Risk assessment with the specific characteristics of the dust 2. Personal safety procedures 3. Personal protective equipment 4. Cleaning sequence 5. Cleaning methods to be used 6. Equipment including lifts, vacuum systems and attachments 7. Cleaning frequency Page 27

28 Page 28 Choosing the Right Housekeeping Equipment

29 NFPA 652: Compressed Air Blowdown Method ( ) A Compressed air blowdown used for cleaning presents significant hazards Only use when other cleaning methods present higher risk NOTE: this method does not remove accumulated dust, it simply moves the dust to another area Page 29

30 NFPA 652: Vacuum Cleaning Method ( ) NFPA does not approve/certify vacuum equipment Portable vacuums meeting the minimum requirements are permitted to collect combustible dust in nonclassified (nonhazardous) areas Design Requirements for nonclassified (nonhazardous) areas Non-combustible construction and meets requirements for construction and static electrical hazard controls ( ) Conductive or static-dissipative hoses including both suction and air delivery hoses All conductive accessories, including wands and attachments, must be bonded and grounded Dusty air should not pass through the fan/blower Electrical motors must not be in the dust laden air stream unless listed for Class II, Division 1 locations No paper filter elements for liquid/wet collection Vacuum cleaners used for metal dusts must meet NFPA 484 requirements Page 30

31 Nationally Recognized Testing Laboratories (NRTL) Provides certification for electric equipment for hazardous locations in the United States and Canada Only products with a specific mark of a NRTL recognized to test and certify is considered certified NRTL certifications do not exist for pneumatic equipment Underwriter s Laboratories (UL) Canadian Standards Association (CSA) Factory Mutual (FM) Intertek Testing Services NA, Inc. Source: OSHA, Nationally Recognized Testing Laboratory Program Page 31

32 Classified Environments: Vacuum Requirements OSHA Standard (b) National Electric Code Article 500 NFPA 652 Section , Must be approved for the hazardous (classified) location Must be NRTL-approved for use in hazardous locations, more specifically approved for use in the environment Must be marked to show the class, group, and operating temperature or temperature range In a Class II environment, must match the environment classifications with a NRTL-approval or shall be a fixed-pipe suction system with a remotely located exhauster and AMS installed If flammable vapors or gases are present, then must comply with Class I and Class II Page 32

33 Certified Vacuum Cleaners An entire vacuum cleaner can be certified which is the safest for use in a hazardous (classified) environment Some vacuum manufacturers only advertise certain parts, like motors and switches, as having a classification (the entire vacuum was not NRTL approved) If you are unsure, ask your vacuum manufacturer for more information about their NRTL approvals Page 33

34 Combustible Dust Safe: Electric Vacuums Constructed of low-sparking metals (i.e. aluminum or stainless steel) Totally-enclosed fan-cooled (TEFC) motor Antistatic main filter Data plate - NRTL approval of entire vacuum Antistatic wheels Conductive accessories Page 34 Comply with a resistance rating at or below 1 M Ω (1x106Ω)

35 Combustible Dust Safe: Pneumatic Vacuums Constructed of low-sparking metals (i.e. aluminum or stainless steel) Conductive airline & accessories Antistatic main filter Grounding strap (yellow) Page 35 Antistatic wheels Comply with a resistance rating at or below 1 M Ω (1x106Ω)

36 Application: Paper Manufacturing Location: Class II, Group G Challenge: Overhead cleaning Considerations: Electric or air-operated HEPA/ULPA filtration Filter cleaning system Footprint Accessories (i.e. hose, dust brushes and nozzles) Page 36

37 Application: Food Manufacturing Location: Class II, Group G Challenge: General housekeeping around production lines Considerations: Dry only or wet/dry collection Single-phase or three-phase power Portability Collection capacity Accessories (i.e. overhead tools, floor nozzles, food grade brushes) Page 37

38 Resources OSHA resources: Combustible Dust NEP: Fact Sheet: Poster: NFPA resources: Review codes/standards online for free: Page 38

39 Thank you for joining us! For more information on combustible dust housekeeping: Andrew Luessenhop Nilfisk, Inc. Industrial Vacuum Division (708) Page 39