Combustible Dust Hazards- call to action by US Chemical Safety Board

Washington, D.C., October 24, 2018 – Today, the U.S. Chemical Safety Board, as part of its investigation into the May 2017 Didion Mill explosion, issued “Call to Action: Combustible Dust” to gather comments on the management and control of combustible dust from companies, regulators, inspectors, safety training providers, researchers, unions, and the workers affected by dust-related hazards.

“Our dust investigations have identified the understanding of dust hazards and the ability to determine a safe dust level in the work place as common challenges,” said CSB Interim Executive Kristen Kulinowski. “While there is a shared understanding of the hazards of dust, our investigations have found that efforts to manage those hazards have often failed to prevent a catastrophic explosion. To uncover why that is, we are initiating this Call to Action to gather insights and feedback from those most directly involved with combustible dust hazards.”

This initiative asks for information from all individuals and entities involved in the safe conduct of work within inherently dust-producing environments at risk for dust explosions. The agency seeks input on a variety of complex issues, including: recognizing and measuring “unsafe” levels of dust in the workplace, managing responsibilities and expectations that sometimes are at odds with each other (e.g., performing mechanical integrity preventative maintenance while simultaneously striving to minimize dust releases in the work environment), and the methods for communicating the low-frequency but high-consequence hazards of combustible dust in actionable terms for those working and overseeing these environments.

Here is the full list of questions:

• In real-world working conditions, where dust is an inherent aspect of the operation, can a workplace be

both dusty and safe?

• In such working environments — where the amount of ambient/fugitive dust cannot be wholly eliminated 100 percent of the time — how does an individual or organization distinguish between an acceptable or safe dust level and one that has been exceeded? How often does judgment or experience play a role in such decisions? Should it?

• How are hazards associated with combustible dust communicated and taught to workers? What systems have organizations successfully used to help their employees recognize and address dust hazards?

• What are some of the challenges you face when implementing industry guidance or standards

pertaining to dust control/management?

• If companies/facilities need to use separate or different approaches in order to comply with both sanitation standards for product quality or food safety and those associated with dust explosion prevention, then how do you determine what takes priority? Is the guidance clear?

• How should the effectiveness of housekeeping be measured? What methods work best (e.g., cleaning

methods, staffing, schedules)?

• As equipment is used and ages, it requires mechanical integrity to maintain safe and efficient operability. How does inspection, maintenance, and overall mechanical integrity efforts play a role in dust accumulations, and how are organizations minimizing such contributions in the workplace?

• What are some of the challenges to maintaining effective dust collection systems?

• How common are dust fires in the workplace that do not result in an explosion? Does this create a false

sense of security?

• Are workers empowered to report issues when they feel something needs to change with regard to dust

accumulation? What processes are in place to make these concerns known?

• How can combustible dust operators, industry standard organizations, and regulators better share information to prevent future incidents?

The CSB will review all responses submitted by November 26, 2018, and use the information provided

to explore the conditions that influence the control and management of combustible dust in order to seek out a deeper understanding of the real-world challenges to preventing dust explosions and, more importantly, new opportunities for safety improvements.

Comments can be emailed to [email protected] now until November 26, 2018. The CSB will use the information provided to explore new opportunities for safety improvements.

Dust incidents continue to impact a wide swath of industries. In 2006, the CSB identified 281 combustible dust incidents between 1980 and 2005. One hundred and nineteen workers were fatally injured, 718 more were hurt, and industrial facilities were extensively damaged. The incidents occurred in 44 states, in many different industries, and involved a variety of different materials.

Since the publication of the study in 2006, the CSB has confirmed an additional 105 combustible dust incidents and conducted in-depth investigations of five, including most recently the Didion Milling dust explosion in Cambria, Wisconsin, that fatally injured five workers and demolished the milling facility.

The CSB has issued four recommendations to OSHA calling for the issuance of a comprehensive general industry standard for combustible dust, and combustible dust safety is on the agency’s Drivers of Critical Chemical Safety Change list. To date, there is no general industry standard.

CSB Investigator Cheryl MacKenzie said, “Our investigation of the Didion incident continues and we are analyzing evidence to understand the specifics leading up to the tragic event. However, this investigation reinforces what we are seeing across many industries—that there needs to be a more inclusive approach to creating and maintaining a safe work environment amid processes that inherently produce dust.”

For those who need training on hazardous areas, including combustible and explosive dust hazards, you can check out an excellent hazardous area training program by Abhisam here. This training is delivered online and has several animations, simulations and videos that helps easy learning of everything related to hazardous areas including dust explosion protection.