Chemical Safety Board (CSB) Chairman Rafael Moure-Eraso wrote an opinion piece, which appeared in Saturday’s New York Times where he chronicled a number of horrific manufacturing accidents in recent years that had significant fatalities and worker injuries. All were attributed to combustible dust. The most recent example was an explosion in a metal products factory in China this month that claimed the lives of 75 people and injured 185. He voiced his frustration about a lack of action to prevent these tragedies.
I share his frustration for two reasons. First, while combustible dust is a normal by-product of the manufacturing process for a variety of items, if it is effectively managed it will reduce deaths and injuries should a fire or explosion occur. Second, NFPA codes and standards provide the means to manage combustible dust but are not being adopted and/or enforced to the extent they should be.
NFPA has published fire protection standards for various solids processing industries that generate combustible dusts, for over 70 years. The similar fundamental approach exists within our standards today to that first established in the 1920's - limit the generation and release of the combustible dust (fuel side of fire triangle), identify and control ignition sources, and if an explosion still occurs, limit its spread by construction, isolation, housekeeping and explosion prevention methods (like suppression).
Over the years investigations by CSB concluded that if existing NFPA standards had been followed incidents would have not occurred or certainly results mitigated. The issue was further highlighted in a CSB comprehensive dust study in 2006 showing the problem was more than an isolated series of events and continued to call on the Occupational Safety and Health Administration (OSHA) to develop federal standards and initiate increased inspections.
OSHA did initiate the National Emphasis Program (NEP), which includes policies and procedures for inspecting workplaces that create or handle combustible dusts. The NEP states that NFPA combustible dust standards should be consulted to obtain evidence of hazard recognition and feasible abatement methods. Unfortunately, the movement to establish the mandatory regulation of combustible dust in all industries has stalled.
NFPA combustible dust standards are included in fire codes; so, in theory, our standards are referenced and adopted; but awareness within segments of the industry lags and overall enforcement is inconsistent. OSHA should initiate the process to adopt NFPA standards as the national standards.
Standards developed through NFPA’s voluntary consensus process provide a practical, cost-effective solution for better fire, life and electric safety. There is a long history of government agencies and jurisdictions on all levels adopting privately developed standards. These standards then must be enforced. It takes the complete package – develop, adopt, enforce - to better protect individuals and property from hazards, including fires and explosions from combustible dusts.