osha's+combustible+dust+nep+presentation may+3 2011

8/2/2019 OSHA's+Combustible+Dust+NEP+Presentation May+3 2011

http://slidepdf.com/reader/full/oshascombustibledustneppresentation-may3-2011 1/35

1

Combustible Dust

National Emphasis Program

And Rulemaking Efforts

May 3, 2011

Ignition Source

Confinement

Oxygen in Air/Oxidizers

Dispersion

Combustible Dust

Deflagration

Explosion

FIRE

Sanji Kanth, Safety EngineerOffice of General Industry EnforcementDirectorate of Enforcement Programs



2

Overview

• Combustible Dust NEP

• Combustible Dust Rulemaking



3

Combustible Dust NEP Status

• Number of Inspections

• Total Number of Violations

• Types of Industries Inspected

• Penalties Issued

•

Combustible Dust Related Violations



4

Number of Inspections

1841

481

0200

400

600

800

10001200

1400

1600

1800

2000

Federal State



5

Total Number of Violations

8388

24790

1000

2000

3000

4000

5000

6000

7000

8000

9000

Federal State



6

Number of Violations

6199

1779

10031416

0

1000

2000

3000

4000

5000

6000

7000

Serious Other Than Serious

Federal

State



7

Willful, Repeat and Failure to Abate

Violations

201

159

50

7

38

15

0

50

100

150

200

250

Wilful Repeat FTA

FederalState



8

Penalties

$21,740,508.00

$1,427,342.00

0

5000000

10000000

15000000

20000000

25000000

Federal State



9

Types of Industries Inspected

436

228

14

76

5017

138158

111

163

42

66

37

5954

70

0

50

100

150

200

250

300

350

400

450

500

F o o d P r o d

u c t s

T e

x t i l e

W o o d / L u m

b e r

F u r n

i t u r e

P

a p e r

P r i n t i n g

C h e m i c a l / P h a r m a c e u

t i c a l

R u b b e r / P l a s t i c

P r i m a r y M

e t a l

F a b r i c a t e d M

e t a l

M a c h i n e r y

T r a n s p .

E q u i p m e n t

M i c s . P

r o d

u c t s

E l e c t r i c / S a n

i t a r y

D u r a b l e G o o d s

N o n D u r a b l e



10

Types of Industries Inspected byPercent

14%

1%

26%

4%

3%

1%

8%

10%

6%

9%

2%

4%

2%

3%

3%

4%

Food Products

Textile

Wood/Lumber

Furniture

Paper

Printing

Chemical/Pharmaceutical

Rubber/Plastic

Primary Metal

Fabricated Metal

Machinery

Transp. EquipmentMics.Products

Electric/Sanitary

Durable Goods

NonDurable



11

Violations --Federal

791745

683643

548

461428 412

337295

267

179151 135

0

100

200

300

400

500

600

700

800900

H a z C o m

R e s p .

P r o t e c t i o n

H o u s e k e e p i n g

E l e c t r i c a l

1 9 1 0 . 3

0 5

L o c k o u t / T a g o u t

E l e c t r i c a l

1 9 1 0 . 3

0 3

5 ( a ) ( 1 )

P o w r d

I n d . T r u c k s

E l e c t r i c a l ( H a z

L o c )

P P E

F i r e

E x t i n g u i s h e r s

E g r e s s

F i r s t A i d

C o m p . A

i r



12

Distribution of Violations

HazCom

13%

Resp. Protection

12%

Housekeeping

11%

Electrical 1910.305

11%Lockout/ Tagout

9%

Electrical 1910.303

8%

5(a)(1)

7%

Electrical (Haz Loc)6%

PPE

5%

Fire Extinguishers

4%

Egress

3%

Pow rd Ind.Trucks

7%

Comp.Air

2%

FstAid

2%



13

Some Combustible Dust NEP Findings



14

Dust collectors were located inside buildings without proper explosion protectionsystems, such as explosion venting or explosion suppression systems.



15

Hazardous levels of dust accumulations in the workplaces due to poorhousekeeping practices.



17

Silos, legs of bucket elevators were not equipped with explosion relief venting.



18

The horizontal surfaces such as beams, ledges and screw conveyors atelevated surfaces were not minimized to prevent accumulation of dust onsurfaces.



19

Electrical equipment and Powered Industrial Trucks not approved forlocations handling combustible dusts.



20

Equipment (such as grinders and shakers) were not designed andmaintained to minimize escape of dust into the surrounding work area.



21

.

Portable Vacuum Cleaners were not approved for Class II locations



22

Hot work (open flame or sparks from welding, cutting,grinding) was performed in the combustible dust handlingareas without hot work procedures.

Welding on Outsideof Duct Wall

D u s t D e p o

s i t o n

I n s i d e o f

D u c t W a l l



23

Enclosureless systems were allowed indoors where they were connected tosanders having mechanical feeds; where they were not emptied at least daily;where they were located in areas routinely occupied by personnel; and wherethey were not separated by at least 20 feet.



24

Deflagration isolation systems were not provided to prevent deflagrationpropagation from dust handling equipment to other parts of the plant.



25

Compressed air was periodically used to clean up the combustible dustaccumulation in the presence of ignition sources.



26

Air from dust collector was recycled through duct work back into the workarea without the protection of a listed spark detection system, high speedabort gate and/or functioning extinguishing system.



27

Magnetic separators and tramp metal separators were not installedor not functioning to prevent foreign material entering into processstream and potentially cause a spark.



28

Ductworks used in transporting combustible dust were not constructed of metal(conductive) and were not bonded or grounded to minimize generation andaccumulation of static electricity



29

Combustible Dusts RulemakingsStatus



30

Advanced Notice of ProposedRulemaking (ANPR)

• Issued in October 2009

• Comment period ended January 2010

• Comments can be viewed at

www.regulations.gov • Comments have been compiled

• Staff wrote summaries of the responses to

each question

http://www.regulations.gov/




31

Stakeholder Meetings

• Six meetings

• Web chat held on June 28, 2010, followedby a blog

• No additional meetings planned



32

Site Visits

• Eleven visits conducted.

• Completed reports can be viewed atwww.regulations.gov

• No more site visits planned





33

Regulatory Agenda

• Preliminary Regulatory text drafted

• Preliminary economic analysis conducted

• SBREFA Panel (Small Business) briefing postponed

• Expert Forum to discuss regulatory options to be heldon May 13, 2011

• Time frame for SBREFA briefing and the proposed ruleis not yet on Regulatory Agenda



34

OSHA Compliance AssistanceResources: Combustible Dust

• Safety and HealthTopics Page

• Fact Sheet• Poster

• Safety and Health

Information Bulletin (2005)

• HAZCOM dust guidance OSHA’s Combustible Dust Poster

http://www.osha.gov/Publications/combustibledustposter.pdf



35

Thank You!!!

Questions?

osha's+combustible+dust+nep+presentation may+3 2011

Documents