F

PART 1

NEW REGULATORY STANDARDS AND PRACTICAL SOLUTIONS

From 1980-2005, an estimated 119 deaths have occurred in the US alone, as a result of combustible
dust explosions, with feed and grain as one of the leading industries experiencing explosions

by W Brad Carr, President, SonicAire, USA

his is the first of a two-part series

to help grain and feed processors
understand the new actions proposed by
NFPA 652, the latest. The second part
of the series will examine the spectrum
of dust control options available, and
evaluate the strengths and weaknesses
of each alternative.
In all situations, it is always dangerous
if you dont know what you dont know. This is especially true of
combustible dust because in this case, ignorance is not bliss. In
fact, it is deadly.
The risks from fugitive combustible dust continue to remain
high for grain processors. Fugitive dust accumulates, forming
a combustible cloud that results in explosions that destroy
facilities and/or injure or kill employees. Unfortunately, this is
not an isolated event. The latest statistics on combustible dust
explosions is chilling. Over a 25-year period in the US from
1980-2005, there have been: 281 combustible dust incidents, 718
injuries and 119 deaths. From 2008-2012 there have been another
50 accidents reported.
Whilst these dust incidents occur throughout many industries,
feed and grain is one of the leading industries experiencing
explosions.
In February of this year, an explosion at the Rockmart Feed Mill

56 | October 2016 - Milling and Grain

in Atlanta, Georgia killed one person and injured five others. The
tragic irony of this incident is that the plant had been reviewed by
OSHA in 2013 after a small dust explosion, and had subsequent
annual on-site inspections.
Nevertheless, feed dust continued to accumulate between the
inspections and consequently caused the disastrous explosion. A
witness described to WSB-TV in Atlanta, that the sound was as
loud as a sonic boom or an earthquake.
Similarly, in June 2016, OSHA fined High Country Elevators
Inc. US$51,920 for several issues including combustible dust
accumulation above 1/8.
These are just two examples of unnecessary tragedy and
expense, as a result of a lack of collective knowledge or concern
for compliance or perhaps both.
Regulatory agencies have responded with issuing higher fines
and new standards. No one wants more accidents. But there
remains a gap in knowledge and I am writing to fill that gap.

NFPA releases new standards

In August 2015, the National Fire Protection Association

(NFPA) published a new standard on combustible dust: NFPA
652. It is designed to supply unifying standards and principles
across industries.
Currently, the draft of NFPA 652 is in review for possible edits.
Although a second revision is scheduled to be released in January

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2018, it is wise for us to consider the changes required in the
current version since it has been issued.
Therefore, what follows are the highlights of changes dictated
by NFPA 652 issues so grain processors can take action to best
protect their businesses and employees. There are significant
changes to processes that the grain industry must be aware of and
respond to.

Scope of standard

NFPA 652 defines its scope as the following: This standard

shall provide the basic principles of and requirements for
identifying and managing the fire and explosion hazards of
combustible dust and particulate solids.
In essence, it sets the standards that are fundamental
requirements for all industries with combustible dust hazards.
NFPA 654 was once considered the umbrella standard for all
industries not covered by other NFPA standards for specific
industries.
The new NFPA 652 sets a baseline for all industries. In
addition, NFPA 652 concentrates
more on specific management
and procedural requirements to
mitigate fire and explosions from
combustible dust. Together, NFPA
652 and the other industry-specific
standards provide a comprehensive
framework for managing
combustible dust hazards.

"The risks from fugitive combustible dust continue

to remain high for grain processors. Fugitive dust

accumulates, forming a combustible cloud that
results in explosions that destroy facilities and/or
injure or kill employees

Steps to designing a helpful DHA:

Step 1: Identify all processes connected with combustible dust.

List process lines where dust could exist. Identify all pieces of
equipment, such as bins, silos, tanks, bucket elevators, sifters,
dryers, ovens, conveys, screen augers and classifiers.

Combustible dust standards

During the development of NFPA

652, (Exponent, 8.11.15) there
was debate over how to interact
with existing commodity-specific
combustible dust standards, when
those standards contain differing
requirements. To accommodate
those differences, NFPA 652
contains a conflict section on
which standards take precedence
when there is a discrepancy in
requirements.
Overall, NFPA 652 emphasizes
the need to evaluate and manage
- not just measure. The main
changes lie in the need for a Dust
Hazard Analysis (DHA) and a
Management of Change (MOC)
plan.

How to develop an actionable

DHA

The Dust Hazard Analysis is

one of the biggest changes in
required activities for feed and
grain processors. In fact, a DHA
is required for all companies that
generate, process, handle or store
combustible dusts or particulate
solids. It is required and is
permitted to be phased in no later
than three years from the effective
date of the standard and is applied
retroactively.

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"

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Step 2: Identify locations where dust can accumulate. This
means you have to inspect all areas where dust exists, and
identify the level of accumulation. You must pay particular
attention to overhead structures such as piles, joists, beams and
ductwork. You also have to examine drop ceilings and any area
where dust potentially could be released in abnormal conditions.
Step 3: Determine your ignition sources. This can come from
anywhere, but pay attention to process equipment, smoking,
static electricity, forklifts, welding or other high temperature
work, friction, electrical sparks or arching, radiant heat, and open
flames.
Step 4: Quantify the risk. Evaluate the deflagration and
explosion potential for each area and piece of equipment.
Determine the severity of risk for employees and processes. If the

to be protected by either performance-based or prescriptive

methods
Overhead fans to limit dust accumulation have been identified
specifically as a viable housekeeping solution
Engineering design controls are preferable for difficult to clean
areas (A.8.4.2.6.1)

What is new with OSHA?

The good intentions of NFPA do not necessarily translate into

good practice. Whilst all of these standards are developed by
experts in the field, they are are only voluntary.
OSHA regulations give legal teeth to these standards. Since
2006, the Chemical Safety Board (CSB) has been pushing
OSHA to announce and enforce a general industry standard for
combustible dust. This push occurred after the
CSB study that found there were so many dustFigure 1: Industries involved in dust related incidents
related incidents from 1980-2005.
At the beginning of the Obama administration, it
looked as if OSHA was going to do just that. They
were focusing on regulations that were as strong
as when they began to implement a National
Emphasis Program (NEP) in 2008, a program
FOOD
PRODUCTS
that encouraged Congress to develop two bills
24%
(HR5522 and HR 691) to regulate and enforce
these standards. Both bills died slow deaths in
committee.
OTHER
Bloomberg BNA reported (1.11.16) that OSHA
7%
is not likely to push for a comprehensive dust
standard based on NFPA 652. Their officials have
LUMBAR
ELECTRIC
not attended NFPA meetings in the last 18 months.
SERVICES
& WOOD
8%
PRODUCTS
However, OSHA is still enforcing the industry15%
RUBBER &
specific
standards for combustible dust hazards. In
This graph shows the
PLASTIC
breakdown according
PRODUCTS
November
2015, federal provisions were made for
8%
to Occupational
PRIMARY
OSHA
to
increase
its penalty fines; some industry
METAL
Safety and Health
CHEMICAL
INDUSTRIES
Administration
MANUFACTURING
8%
experts expect it to increase by as much as 82
12%
Combustible (OSHA)
percent.
Dust National Emphasis
But OSHA now allows the density of dust to
Program, 3-10-08
be considered when inspecting for accumulation.
Because not all dust is created as equal, the density
of dust has an allowable accumulation that is potentially higher
area/equipment is deemed hazardous, identify performance-based
(<1). To use a higher metric, plant managers must send their dust
or prescriptive methods for remediation.
to a laboratory for bulk density testing. The higher the number
Step 5: Examine and evaluate current safety measures. This
of the dusts bulk density, the lower the allowable accumulation
includes housekeeping, suppression, isolation, venting, facilitybecomes.
design and equipment selection.
However, even with these calculations, it is extremely rare
to
come across a bulk density number of less than 3lbs/ft3.
How to design a MOC
This
means that most industries remain unaffected by this new
A management of change (MOC) plan is now required for
measurement standard.
certain changes made in any facility. Logically, the plan will vary
The bottom line with OSHA in the real world is this: Keep
according to the specific change identified.
fugitive dust accumulations as low as physically possible. I
What is needed is a written MOC to comply with NFPA 652
know I dont want to find myself arguing about the density of my
recommendations. You must have one on hand if there are any
plants dust with an OSHA inspector. And lets face it, we all need
deviations from the original DHA.
to do what we can to keep danger out of the workplace wherever
possible.
Other NFPA 652 noteworthy changes
You cannot just look at the accumulation tolerances identified
in NFPA 652 alone. Instead, you have to consider 652 and the
So what do we do now?
industry-specific standard for dust level accumulations
The hard cold reality is that the risks still exist regardless of the
Each plant must have its own threshold level of allowable
governments action or inaction.
dust accumulations, set by owner or management. From there,
Clearly therefore, we have to implement solutions that could
housekeeping methods will be developed, with appropriate
provide the safest solution that makes the most business sense. In
documentation
order to do that, we need to know what is available, and evaluate
Operating equipment within an explosion hazard location must
the strengths and weaknesses of each option.
be isolated
I will address this in Part 2 of this Series in the next issue of
All buildings or areas with a dust deflagration hazard need
Milling and Grain magazine.
FURNITURE
& FIXTURES
EQUIPMENT
MANUFACTURING 4%
7%

FABRICATED
METAL
PRODUCTS
7%

58 | October 2016 - Milling and Grain