Complying with NFPA 652 and AHJ s Recommenda(ons. OSHA Combus(ble Dust Na(onal Emphasis Program (NEP) Overview

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1 Dust Mi(ga(on: Housekeeping to Avoid Combus(ble Dust Hazards, Contamina(on and Fines Sco$ C. Boersma, Nilfisk, Inc. Overview Introduc)on & Overview Who s at Risk? Proper Maintenance and Housekeeping Prac)ces Choosing the Right Housekeeping Equipment Ques)ons Resources Combus(ble Dust Tragedies Introduc(on Between (last update by OSHA) 281 Dust Fires/ Explosions 119 Fatali)es 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 produc)on areas exploded February 7, 2008 BartleJ Grain Co. Atchison, KS 5 deaths $406,000 in OSHA fines Cause: Grain dust accumula)on inside the grain elevator October 29, 2011 OSHA Combus(ble Dust Na(onal Emphasis Program (NEP) Complying with NFPA 652 and AHJ s Recommenda(ons Issued in 2008 arer Imperial Sugar explosions ists of 18 different standards that can be used to cite against Next Step: SBREFA panel to review standard currently scheduled for Q Source: OSHA, Combustible Dust National Emphasis Program SBREFA: Small Business Regulatory Enforcement Fairness Act Applies to all facilities and operations that manufacture, process, blend, convey, repackage, generate, or handle combustible dusts or combustible particulate solid (1.3.2) NOT JUST CLASSIFIED (HAZARDOUS) LOCATIONS Facilities can no longer defer to lack of standard Very few exemp)ons or opportuni)es to be grandfathered Viola)on of NFPA guidelines can be used to enforce OSHA s General Duty Clause (GDC), which can result in a fine Authority Having Jurisdic(on (AHJ) Noun An organizacon, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installacon, or a procedure. Examples: Insurance Company, Internal EH&S Staff, Plant Manager, Local Government Inspector, State Fire Marshal, Federal Government Agency, etc. **If an AHJ feels that you are viola(ng that safety guideline, it can prevent them from approving permits and insurance coverage Source: NFPA 654 1

2 Complying with NFPA Dust Test Required: The absence of previous incidents cannot be used as the basis for deeming a par)culate not combus)ble (NFPA 652, SecCon 5.2) a) Owner/operator of a facility is responsible for determining the combus)bility of material b) Test results, historical and published data must be documented and provided to AHJ upon request c) If dust Kst Value is greater than 1, facility must proceed with DHA 2. Dust Hazard Analysis (DHA) required at all opera)ons that generate, process, handle or store combus)ble dusts/par)culates; completed by September 2018 (3 years from effec)ve date of standard; must show reasonable progress each year) 3. Recommends vacuums as best way to mi)gate combus)ble dust; Requires Class II, Div. 2 vacuums to manage spills and bulk materials Who is at Risk? Who s at Risk? The FOOD industry has the highest incidents of combus)ble dust issues. 771 Food Facility Inspec(ons completed from Industries with Highest Incidents of Combus;ble Dust Accidents Proper Maintenance & Housekeeping Prac(ces to comply with OSHA & NFPA standards $28 Million+ in Fines issued under the NEP Source: OSHA NEP 2008 Occupa(onal Hazards: Common Denominator Housekeeping broad term that 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 specifically requires good housekeeping practices in several General Industry Standards Did you know? OSHA recently held an expert forum on combustible dust, where one expert estimated that 95 to 99 percent of injuries and fatalities could be prevented through proper housekeeping. Risk Mi(ga(on Plant safety, maintenance and housekeeping must be top- of- mind for every company. OSHA has issued more than 12,000 combustible dust-related violations since 2008 and a new standard is imminent. NFPA & CSB continue to increase pressure for dust control. MSDS spill and handling requirements are being updated. Insurance companies are raising premiums for companies who are not prepared to meet regulatory standards. High profile plant explosions, product recalls, unsafe working conditions are in the news daily. 2

3 OSHA Housekeeping Recommenda(ons for Environments with Combus(ble Dust Present NFPA 652, Sec(on 8.4: Housekeeping Clean dust residues at regular intervals Use cleaning methods that do not generate dust clouds, if igni)on sources are present (such as blow- down methods) Only use vacuum cleaners approved for dust collec)on Dust must be tested and DHA performed per NFPA requirements. Requirements applied retroactively Selected cleaning method should reduce the potential for creating a combustible dust cloud General takeaways: Regularly clean floors and horizontal surfaces (i.e. ducts, pipes, hoods, ledges, beams) to minimize dust accumula)ons within opera)ng areas of the facility Keep dust accumula)on 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 classifica)on Source: OSHA, Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions 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 Housekeeping Procedures must be documented as part of the DHA. Source: NFPA 652 Cleaning Methods: Mops and Brooms Choosing the Right Housekeeping Equipment Ease- of- use Readily available Inexpensive May form dangerous dust clouds in hazardous loca)ons, leading to a combus)ble dust incident Not effec)ve for fine powder collec)on Can disturb and spread dust, bacteria, allergens & insects Limited to floor cleaning Must be regularly cleaned and zoned for some areas Mops introduce water and can leave residue Cleaning water can become a source of contamina)on Cleaning Methods: Compressed Air Ease- of- use Useful in )ght areas OSHA and NFPA are PROHIBITING the use of compressed air in combus)ble dust applica)ons Does not remove the fine dust from the facility Blows dust into hard- to- reach areas Spreads fine dust, bacteria and allergens everywhere Distributes contaminants in compressed air system Compressed air just moves dust from point a to point b; it does not eliminate the dust Cleaning Methods: Shop- Style Vacuums Ease of use Many are designed for wet and dry collec)on Can be used to clean a variety of areas Inexpensive OSHA and NFPA are PROHIBITING the use of shop- style vacuums in combus)ble dust applica)ons Not effec)ve for fine powder collec)on, bacteria, or allergen control (poor filtra)on) Motor burn- up (not cost- effec)ve) Many do not hold up well in industrial environments Loud Sta)c electricity build- up Source: 3

4 Cleaning Methods: Industrial Vacuums Ease- of- use and efficiency Mul)- stage filtra)on / HEPA filtra)on captures bacteria Mul)ple filter op)ons Many are designed for wet and dry collec)on Can be used to clean a variety of areas (general maintenance and specialized applica)ons) Many have unique filter loading indicators and filter cleaning op)ons Low total cost of ownership Ini)al investment User training commitment Hazardous Loca(on Vacuums Hazardous Loca(ons Industrial Vacuums Explosion- proof / dust- igni)on- proof CSA- and ATEX- cer)fied Meet requirements for Class I, Group D and Class II, Group E, F and G environments Meet NFPA 652 Housekeeping recommenda)ons Conduc)ve accessories Combus(ble Dust Safe: Electric Vacuums Combus(ble Dust Safe: Pneuma(c Vacuums tructed of low-sparking metals (i.e. aluminum or stainless steel) Totally-enclosed fan-cooled (TEFC) motor tructed of low-sparking metals and/or fully bonded and grounded (i.e. aluminum or stainless steel) Conductive airline & accessories Grounding strap Data plate that clearly displays NRTL approval via CSA Antistatic main filter Antistatic main filter Grounding strap (yellow) Conductive accessories: Antistatic wheels Comply with a resistance rating at or below 1 M Ω (1x106Ω) (NFPA standards for ancillary equipment & components) Antistatic wheels Conductive accessories: Comply with a resistance rating at or below 1 M Ω (1x106Ω) (NFPA standards for ancillary equipment & components) Why Invest in Industrial Vacuums? Maintenance & Housekeeping Overview Combustible Dust Mitigation Compliance with OSHA & NFPA Guidelines Authorities Having Jurisdiction may require compliance: Building Inspector, OSHA Rep., Fire Marshall, Insurance Agent, Safety Manager at the company, etc. Housekeeping keep dust cover to less than 1/32 Additional Key Drivers Eliminate risk of costly recalls, lawsuits and fines Improve air quality with certified HEPA and ULPA filtration Good Manufacturing Practices (GMPs) HACCP No more air blow down, per NFPA Insurance agencies mandating dust control plan Meet requirements for NRTL-certified equipment Quality Assurance & Quality Control Cross-Contamination prevention (Allergens, Mold, Microbacteria, Spores, Salmonella, etc.) q Have dust tested and perform a dust hazard analysis (required by NFPA) q Develop and maintain a housekeeping program (required by NFPA) q Replace mops, brooms and blow guns where applicable q Limit/reduce the amount of overhead horizontal surfaces (racks, piping, ductwork, drop ceilings) q Make sure equipment is bonded/grounded and meets other NFPA guidelines q U)lize vacuums for source capture and as portable suc)on devices to prevent fugi)ve dust from accumula)ng. q Make housekeeping as easy and ergonomic as possible q Keep dust below 1/32 on horizontal surfaces q Inspect all equipment (especially older) for possible igni)on sources 4

5 Resources OSHA resources: Combus)ble Dust NEP: Fact Sheet: hqp:// Poster: Ques(ons? NFPA resources: NFPA 652 Standard on the Fundamentals of Combus)ble Dust NFPA 654 Standard for the Preven)on of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combus)ble Par)culate Solids hqp:// FREE NFPA Codes: Click on codes and standards, then on the ler hand side click List of NFPA codes and standards. Choose the standard you want to view. Choose view the standard online. You will be prompted to log- in or create an account. Follow the prompts to create an account. Once you validate your address, you ll be able to view electronic versions of the codes for free. For more informa(on: ScoJ C. Boersma Business Development Manager, Food Nilfisk, Inc. Early Timeline of Events Backup Slides (Not to be presented; for reference material only) First Recorded s Methane Gas, England 31 Casual(es Coal Dust, England NFPA Established Na)onal Fire Protec)on Agency interna)onal non- profit 1621 & Late 1800s 1896 First Recorded Mill Explosion Flour Dust, Italy Methane Gas, England 95 Casual(es Studies of Flour Mill Explosions begin in United States Early Timeline of Events (Con(nued) Coal Dust, Utah 246 Casual(es 1900 Studies of Coal Dust Explosions Begin in the Early 1900s in the United States Methane Gas - Monongah, WV 362 Casual(es - Darr, PA 239 Casual(es - Naomi, PA 34 Casual(es U.S. Bureau of Mines Established NFPA Creates Explosive Dust CommiJee OSHA Established Occupa)onal Health & Safety Administra)on formed by Congress Methane Gas, Ill. 199 Casual(es General Duty Clause (GDC) When workers are exposed to hazards not currently addressed in the OSHA standards, employers are cited under the GDC Each employer 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. If combus)ble dust is present, even in a non- hazardous (classified) environment, and not properly mi)gated according to OSHA and NFPA recommenda)ons, the inspector can assume risk is present and cite the employer for allowing the risk Source: Section 5(a)(1) of the Occupational Safety and Health Act of

6 Combus(ble Dust: Defini(on Dust Explosion Pentagon OSHA: par)culate solid that presents a fire or deflagra)on hazard when suspended in air or some other oxidizing medium over a range of concentra)ons, regardless of par)cle size or shape NFPA: any finely divided solid material that is 500 microns or smaller in diameter that presents a fire or explosion hazard when dispersed and ignited in air 1) Fuel to burn (combus(ble dust) 2) Oxygen to sustain the fire (air) 3) Heat from an igni)on source (spark) 4) Dispersion of a high concentra)on of dust into the air (deflagra(on) 5) Confinement of the dust within an enclosure or structure (explosion) Secondary Explosions Is My Dust Combus(ble? It is up to YOU, the manufacturer, to know the composi)on of the material(s) you process and all applicable laws MSDS sheets are a star)ng point, but most do not address exclusivity NFPA standards 664, 654, 499, 484 and 61 are helpful resources Ideally, have your dust TESTED Many states offer consulta)on through their Department of Labor s Division of Occupa)onal Safety eg. Private tes)ng labs (Fauske, Chilworth, Fike, Gexcon) OSHA can also provide dust tes)ng 6

7 NFPA 654: Standard for the Preven(on of Fire and Dust Explosions Safety measures for handling combus)ble dusts, fibers, flocks, flakes, chips, and chunks Addresses various ways to iden)fy and mi)gate risks in the manufacturing, processing, packaging and other handling of combus)ble dusts Next Edi(on: 2017 NFPA 652: Fundamentals of Combus(ble Dust Release Date: Summer 2015 General requirements for management of combus)ble dust fire and explosion hazards, and directs industry or commodity- specific standards (NFPA 61, 484, 654, 655, 664) Focus on hazard awareness Dust hazard analysis (DHA) provision to be applied retroac)vely A systema)c review to iden)fy and evaluate the poten)al fire, flash fire, or explosion hazards associated with the presence of one or more combus)ble par)culate solids in a process or facility For exis)ng facili)es, a DHA is permiqed to be phased in and completed not later than three years from the effec)ve date of the standard Source: NFPA 654 Source: NFPA Journal, Credible Risk 7