"Those supporting the concept see that many of the steps in the hazard assessment process are the same regardless of dust type and, once the explosibility properties are determined, the protective measures are the same in general and only become unique in their design due to those properties which become part of the design process. A single comprehensive standard makes enforcement easier and, thus, stronger," notes Colonna.
This changing regulatory landscape is driving increased interest in combustible dust hazards by all industry groups, says Bob Korn, director of sales for explosion protection products for Fike: "OSHA's NEP has pushed a new emphasis on OSHA inspections of U.S. manufacturing facilities. In October, OSHA chief Dr. David Michaels told a safety group that in the three-year-old combustible dust NEP, nearly 9,100 violations have been found, although not all of them have been for dust violations, with initial penalties totalling more than $19.5 million.
At a symposium, also in October, OSHA assistant secretary Jordan Barab said OSHA's inspections of refineries under the process safety NEP has resulted in an average of 17 violations per inspection with penalties averaging $166,000. He said 53 of 58 refineries have been inspected. At hazardous chemical manufacturing facilities, inspectors have averaged nine violations during each of 136 inspections."
This increase in inspection rates, coupled with OSHA's commitment to the creation of a combustible dust standard, has the U.S. chemical industry scrambling to understand the hazards and develop strategies to protect their facilities, Korn believes.
This scramble is reflected in the sort of queries he faced in the webinar question-and-answer session. These typically concerned equipment applications, code compliance issues and hazard assessment. For example:
• What is the anticipated timeline from OSHA on the implementation of its widely discussed combustible dust standard?
• Does your suppression equipment need to be inspected on a regular basis and, if so, how often and who can do the inspection?
• How do the operating costs of inert atmospheres compare with capital costs of suppression or flame-arrest systems?
• What type of explosion suppression/relief systems have you seen installed on direct-contact rotary dryer applications?
• What methods do you use to determine particle size and shape?
Overall, the best advice he can give to a chemical maker today is to perform a hazard analysis or risk assessment of its facilities and understand where it needs to improve housekeeping, add dust collection and provide protection for processes at risk.
"Organizations that are actively engaged in understanding the hazard and taking the necessary actions to provide a safe work environment will dramatically lessen the effect of an OSHA inspection and any resultant fines. The chemical industry is in the OSHA spotlight due to other recent serious accidents; consequently they are in the top three of industries inspected by OSHA under the combustible dust NEP."