osha combustible dust nep inadequacies -...

Combustible Dust Policy InstituteCombustible Dust Policy Institute

Mary Kay OMary Kay O’’Conner Process CenterConner Process CenterInternational SymposiumInternational Symposium

OSHA Combustible Dust NEP OSHA Combustible Dust NEP InadequaciesInadequacies

John John AstadAstadCombustible Dust Policy InstituteCombustible Dust Policy Institute


Learning ObjectivesLearning Objectives

Overview of NAICS in the NEPOverview of NAICS in the NEP

How NAICS were developedHow NAICS were developed

OSHA utilization of NAICSOSHA utilization of NAICS

National Industries not referenced in National Industries not referenced in OSHA Combustible Dust NEPOSHA Combustible Dust NEP

Combustible Dust Hazard Awareness Combustible Dust Hazard Awareness of Nonof Non--NEP industriesNEP industries


Combustible Dust National Emphasis Program (NEP)

Policies and procedures

Inspecting workplaces

That create or handle combustible dust

Deflagrations, fires, or explosions

State plan participation not required


Combustible Dust RelatedCombustible Dust Related Explosions & FiresExplosions & Fires

Combustible Dust National Emphasis Program (NEP)- Appendix D-1 More Frequent or High Consequence- Appendix D-2 Potential of Incidents


154+ combustible dust related fires and explosions in the manufacturing, utility, and

non-manufacturing sectors (2008)


Who assigns NAICS?Who assigns NAICS?

U.S. Census Bureau assignsU.S. Census Bureau assigns

Based on its primary activity Based on its primary activity

Activity that generates the most Activity that generates the most revenuerevenue


North American Industry Classification North American Industry Classification System (NAICS)System (NAICS)

•Collecting•Analyzing•Publishing statistical data •Related to the U.S. business economy


How are NAICS used? How are NAICS used?

Designed for Designed for statistical purposesstatistical purposes

Various administrative purposesVarious administrative purposes

Regulatory Regulatory

Contracting Contracting

Taxation Taxation

Other nonOther non--statistical purposes statistical purposes


OSHA Use of NAICSOSHA Use of NAICS

Economic activity into twenty industry Economic activity into twenty industry sectors sectors

Five sectors are mainly goodsFive sectors are mainly goods-- producing sectors producing sectors

Fifteen are entirely servicesFifteen are entirely services--producing producing sectors. sectors.


NAICS and the OSHA Dust NEPNAICS and the OSHA Dust NEP

Understanding the NAICSUnderstanding the NAICS

Results in understanding the Dust NEPResults in understanding the Dust NEP

Most facilities are not covered in the Most facilities are not covered in the NEPNEP

OSHA State Plans voluntary NEP action OSHA State Plans voluntary NEP action


Getting the Knack of the NAICSGetting the Knack of the NAICS


What is the NAICS structure?

•First two digits- Economic sector •Third digit – Subsector •Fourth digit - Industry group •Fifth digit - NAICS industry•Sixth digit - National industry (311211 Flour Milling)


NAICS ExamplesNAICS Examples

Subsector 325 Chemical MfgSubsector 325 Chemical Mfg

Industry group 32513251 Basic Chemical Basic Chemical

NAICS industry 32513 Synthetic Dye 32513 Synthetic Dye and Pigment Manufacturingand Pigment Manufacturing

National industry 325188 All Other Basic 325188 All Other Basic Inorganic Chemical ManufacturingInorganic Chemical Manufacturing


IS your Facility NAICS IS your Facility NAICS Listed in the OSHA Dust NEP?Listed in the OSHA Dust NEP?

• OSHA Dust (NEP) program• Not required in State Plans• State OSH Plans (strictly voluntary)• Explosions and fires reoccurring • NAICS not listed in the NEP


Appendix DAppendix D--11

More Frequent and/or

High Consequence

Combustible Dust Explosions/Fires

18 NAICS (National Industries)



Utilities (1)Utilities (1)

Food (Food (44))

Wood Product (4)Wood Product (4)

Chemical (3)Chemical (3)



Plastics/Rubber Product (Plastics/Rubber Product (1 ) 1 )

Primary Metal Product (2)Primary Metal Product (2)

Fabricated Metal Product (1)Fabricated Metal Product (1)

Transportation Equipment (1)Transportation Equipment (1)


Subsector 221 UTILITIESSubsector 221 UTILITIES

221112 Fossil Fuel Electric Power 221112 Fossil Fuel Electric Power GenerationGeneration

D-1More Frequent and/or High Consequence

Combustible Dust Explosions/Fires


Subsector 311 Food ManufacturingSubsector 311 Food Manufacturing

311211 Flour Milling311211 Flour Milling

311221 Wet Corn Milling311221 Wet Corn Milling

311312 Cane Sugar Refining311312 Cane Sugar Refining

311313 Beet Sugar Manufacturing311313 Beet Sugar Manufacturing


Subsector 321 Wood Product MfgSubsector 321 Wood Product Mfg

321113 Sawmills321113 Sawmills

321213 Engineered Wood Members321213 Engineered Wood Members

321219 Reconstituted Wood Product321219 Reconstituted Wood Product

321920 Wood Container and Pallet Mfg321920 Wood Container and Pallet Mfg


Subsector 325 Chemical Mfg.Subsector 325 Chemical Mfg.

325412 Pharmaceutical Preparation325412 Pharmaceutical Preparation

325510 Paint and Coatings325510 Paint and Coatings

325998 All Other Miscellaneous 325998 All Other Miscellaneous Chemical Product and PreparationChemical Product and Preparation


Sub 326 Plastics/Rubber Products Mfg.Sub 326 Plastics/Rubber Products Mfg.

326291 Rubber Product Mfg. for 326291 Rubber Product Mfg. for Mechanical UseMechanical Use


Subsector 331 Primary Metal Mfg.Subsector 331 Primary Metal Mfg.

331314 Secondary Smelting and 331314 Secondary Smelting and Alloying of AluminumAlloying of Aluminum

331524 Aluminum Foundries (except 331524 Aluminum Foundries (except DieDie--Casting)Casting)


Sub 332 Fabricated Metal Product MfgSub 332 Fabricated Metal Product Mfg

332813 Electroplating, Plating, 332813 Electroplating, Plating, Polishing, Anodizing, and ColoringPolishing, Anodizing, and Coloring


Sub 336 Transportation Equip MfgSub 336 Transportation Equip Mfg

336322 Other Motor Vehicle Electrical 336322 Other Motor Vehicle Electrical and Electronic Equipment and Electronic Equipment


Utilities (1 national industry)Utilities (1 national industry)

Food Manufacturing (3)Food Manufacturing (3)

Textile Mills (4)Textile Mills (4)

Wood Product Manufacturing (4)Wood Product Manufacturing (4)

Chemical Manufacturing (6)Chemical Manufacturing (6)

Appendix D-2

Potential for Combustible Dust Explosions/Fires


Plastics/Rubber ProductsPlastics/Rubber Products

Nonmetallic Mineral Product (1)Nonmetallic Mineral Product (1)

Primary Metal Products (5)Primary Metal Products (5)

Fabricated Metal Products(6)Fabricated Metal Products(6)

Machinery Manufacturing (1)Machinery Manufacturing (1)

Appendix D-2


Appendix D-2

Electrical Equipment (2)Electrical Equipment (2)

Transportation Equipment (1)Transportation Equipment (1)

Furniture Related Product (3)Furniture Related Product (3)

Miscellaneous (1)Miscellaneous (1)

NonNon--Manufacturing (4)Manufacturing (4)

Support Activities for Agriculture and Support Activities for Agriculture and Forestry (2)Forestry (2)

What about the hundreds of other NAICS What about the hundreds of other NAICS not listed in the NEP ?not listed in the NEP ?

Over 50 % Explosions and Fires that Over 50 % Explosions and Fires that occurred in 2008 at facilities with NAICS occurred in 2008 at facilities with NAICS

not listed in the NEP not listed in the NEP


Food ManufacturingFood Manufacturing NonNon-- NEP 76% incidentsNEP 76% incidents

Dog and Cat Food ManufacturingDog and Cat Food Manufacturing

Breakfast Cereal ManufacturingBreakfast Cereal Manufacturing

Dried and Dehydrated Food MfgDried and Dehydrated Food Mfg

Dry, Condensed, and Evaporated Dry, Condensed, and Evaporated Dairy Product ManufacturingDairy Product Manufacturing


Dog and Cat Food ManufacturingDog and Cat Food Manufacturing

Grain dust explosion in a large storageGrain dust explosion in a large storagetank. One person was injured in thetank. One person was injured in theexplosion and airlifted to the burn unitexplosion and airlifted to the burn unit

Prior, 2006 fire caused an estimated $10Prior, 2006 fire caused an estimated $10million in damage.million in damage.


Breakfast Cereal ManufacturingBreakfast Cereal Manufacturing

Dust explosion.Dust explosion.

"A spark or a piece of hot metal got "A spark or a piece of hot metal got into the collector and ignited the into the collector and ignited the flour and cereal particles that get flour and cereal particles that get sucked up inside.sucked up inside.””


Dried and Dehydrated Food MfgDried and Dehydrated Food Mfg

Explosion at a sugar beet plantExplosion at a sugar beet plant

Machine exploded Machine exploded

Two workers injuredTwo workers injured

NonNon--NEPNEP


Dry, Condensed, and Evaporated Dairy Dry, Condensed, and Evaporated Dairy Product ManufacturingProduct Manufacturing

Explosion/fire. Building suffered Explosion/fire. Building suffered some structural damage. The some structural damage. The blaze was mostly contained by the blaze was mostly contained by the facility's safety system.facility's safety system.

1 Injury1 Injury


Wood Product MfgWood Product Mfg NonNon--NEP 36% incidentsNEP 36% incidents

Softwood Veneer and Plywood Softwood Veneer and Plywood

Other Millwork (including Flooring)Other Millwork (including Flooring)

Cut Stock, Cut Stock, ResawingResawing Lumber, and Lumber, and PlaningPlaning


Other Millwork (including Flooring)Other Millwork (including Flooring)

Fire broke out in the dust control unit.Fire broke out in the dust control unit.

The mill, was shut down because it The mill, was shut down because it cancan’’t operate without functioning dust t operate without functioning dust control devicescontrol devices

NonNon--NEPNEP


Softwood Veneer and Plywood MfgSoftwood Veneer and Plywood Mfg

Fire started in ducts that convey Fire started in ducts that convey sawdust from machines out of the sawdust from machines out of the building. building.

One machine malfunctioned and One machine malfunctioned and caught a small duct on fire and the fire caught a small duct on fire and the fire spread through the larger ducts.spread through the larger ducts.

NonNon--NEPNEP


Paper ManufacturingPaper Manufacturing NonNon--NEP 100% NEP 100%

Paper (except Newsprint) MillsPaper (except Newsprint) Mills

Corrugated and Solid Fiber Box Corrugated and Solid Fiber Box

Setup Paperboard Box Setup Paperboard Box

Coated and Laminated Paper Coated and Laminated Paper

Sanitary Paper ProductsSanitary Paper Products


Coated and Laminated Paper MfgCoated and Laminated Paper Mfg

Explosion/FireExplosion/Fire

Caused by a buildup of vapor Caused by a buildup of vapor

Oven used to heat adhesiveOven used to heat adhesive

Hybrid dust/vaporHybrid dust/vapor


Corrugated and Solid Fiber Box MfgCorrugated and Solid Fiber Box Mfg

Dust collected on top of duct workDust collected on top of duct work

Welding near the area Welding near the area

Sparks flew and ignited the dust.Sparks flew and ignited the dust.

Fire department responds to similar Fire department responds to similar calls at the plant anywhere from two calls at the plant anywhere from two to four times a year to four times a year


Paper (except Newsprint) MillsPaper (except Newsprint) Mills

Fire in the grinding room Fire in the grinding room

Shut down production of paper Shut down production of paper machines machines

Began in grinder motorBegan in grinder motor

Spread to nearby ductworkSpread to nearby ductwork


Setup Paperboard Box ManufacturingSetup Paperboard Box Manufacturing

Equipment, which grinds waste into Equipment, which grinds waste into a powder and sends it to a dust a powder and sends it to a dust collection bin. Paper Dust Explosion collection bin. Paper Dust Explosion

Malfunctioned causing it to heat up, Malfunctioned causing it to heat up, jam and send a spark through the jam and send a spark through the ductworkductwork


Chemical ManufacturingChemical Manufacturing NonNon--NEP 60% incidentsNEP 60% incidents

Petrochemical ManufacturingPetrochemical Manufacturing

Adhesive ManufacturingAdhesive Manufacturing


Adhesive ManufacturingAdhesive Manufacturing

ExplosionExplosion--Three workers escapedThree workers escaped

Auger motor inside a giant Auger motor inside a giant

hopper filled with finely ground hopper filled with finely ground wood chips.. Cause was believed wood chips.. Cause was believed to be from an electric motorto be from an electric motor

Prior explosion Prior explosion


Plastics/Rubber Products MfgPlastics/Rubber Products Mfg NEP Full Coverage NEP Full Coverage

UnlaminatedUnlaminated Plastics Film/Sheet Plastics Film/Sheet

All Other Plastics Product MfgAll Other Plastics Product Mfg


Primary Metal MfgPrimary Metal Mfg NonNon--NEP 50% incidentsNEP 50% incidents

Iron and Steel MillsIron and Steel Mills


Iron and Steel MillsIron and Steel Mills

Chemical powder explosionChemical powder explosion

No one injured in the blastNo one injured in the blast

Workers were in the plant at the Workers were in the plant at the time of the explosiontime of the explosion

NonNon--NEPNEP


Fabricated Metal Product MfgFabricated Metal Product Mfg NonNon--NEP 50% incidentsNEP 50% incidents

Other Metal Valve and Pipe FittingsOther Metal Valve and Pipe Fittings


Other Metal Valve and Pipe Fitting MfgOther Metal Valve and Pipe Fitting Mfg

Explosion erupted inside an enclosed Explosion erupted inside an enclosed dust collector in a metaldust collector in a metal--grinding grinding roomroom

Small dust explosion occurred during Small dust explosion occurred during the fire.the fire.


Machinery ManufacturingMachinery Manufacturing NonNon--NEP 100%NEP 100%

Machine Tool (Metal Forming Types)Machine Tool (Metal Forming Types)

Conveyor and Conveying Equipment Conveyor and Conveying Equipment

Pump and Pumping Equipment Pump and Pumping Equipment


Conveyor and Conveying Equipment MfgConveyor and Conveying Equipment Mfg

(Demolition) Fire (Demolition) Fire

Two welders hospitalized for burns Two welders hospitalized for burns

Ignited dust in roof filtering systemIgnited dust in roof filtering system..

NonNon--NEPNEP


Pump and Pumping Equipment MfgPump and Pumping Equipment Mfg

Fire started in a yearFire started in a year--old dust old dust collector in the southwest corner collector in the southwest corner of the factoryof the factory

NonNon--NEPNEP


Furniture/Related Product MfgFurniture/Related Product Mfg NonNon--NEP 33% incidentsNEP 33% incidents

Institutional FurnitureInstitutional Furniture

Showcase, Partition, ShelvingShowcase, Partition, Shelving


Showcase, Partition, ShelvingShowcase, Partition, Shelving NonNon--NEP NEP

Fire involving a siloFire involving a silo--like structure like structure

Filled with sawdust and other Filled with sawdust and other highly combustible material.highly combustible material.

Flames and smoke spewing from a Flames and smoke spewing from a "dust collector"dust collector““

Inside duct work collapsedInside duct work collapsed


Institutional Furniture MfgInstitutional Furniture Mfg NonNon--NEPNEP

Dust collection in a silo had explodedDust collection in a silo had exploded

Sparking a fire that spread to other Sparking a fire that spread to other parts of the buildingparts of the building


Miscellaneous MfgMiscellaneous Mfg NonNon--NEP 75% incidentsNEP 75% incidents

Dental Equipment and SuppliesDental Equipment and Supplies

Gasket, Packing, and Sealing Gasket, Packing, and Sealing Device ManufacturingDevice Manufacturing


Gasket, Packing, and Sealing DevicesGasket, Packing, and Sealing Devices

Machine that grinds rubber, emitted Machine that grinds rubber, emitted sparks sparks

Dust collection system overheatedDust collection system overheated

Igniting fire Igniting fire

Migrated to ventilation unit Migrated to ventilation unit

Prior fire year ago, dust grindings Prior fire year ago, dust grindings from rubber tubes from rubber tubes


Dental Equipment and SuppliesDental Equipment and Supplies

Titanium dust caught on fire in an Titanium dust caught on fire in an interior dust collection systeminterior dust collection system


NonNon--ManufacturingManufacturing NonNon--NEP 70% incidentsNEP 70% incidents

Newspaper PublishersNewspaper Publishers

Solid Waste CollectionSolid Waste Collection


Newspaper PublishersNewspaper Publishers

Fire in the pressroom Fire in the pressroom

Caused apparently by a spark Caused apparently by a spark

Spark of unknown origin Spark of unknown origin

Ignited paper dust inside the dust Ignited paper dust inside the dust collector. collector.


OSHA NEP ComplianceOSHA NEP Compliance

or or

Industry Prevention & Mitigation ?Industry Prevention & Mitigation ?

Where Should Resources be Directed?


NFPA Combustible Dust Standards CoverageNFPA Combustible Dust Standards Coverage

NFPA 654 –Wood

NFPA 61- Food/Agricultural

NFPA 484 -Metals

NFPA 654 NFPA 654 –– Plastics, Chemicals, Plastics, Chemicals, otherother


Thank YouThank You

Questions?Questions?

John John AstadAstad

Combustible Dust Policy InstituteCombustible Dust Policy Institutewww.combustibledust.comwww.combustibledust.com

[email protected]@combustibledust.com

http://www.combustibledust.com/

mailto:[email protected]

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