Combustible Dust and Regulatory Compliance

Back in March 2008, OSHA reissued its National Emphasis Program (NEP) for combustible dust, which created policies and procedures for inspecting workplaces that create or handle combustible dusts. The stated purpose of the NEP was for OSHA to increase its enforcement activities and to focus on specific industry groups that have experienced either frequent combustible dust incidents or combustible dust incidents with catastrophic consequences." The NEP establishes specific inspection protocols for OSHA inspectors to ensure that inspections are thorough and uniform and inspectors are specifically looking for any red flags," such as a history of fires, any MSDS information indicating combustibility of dust, and dangerous dust accumulations at the facility.

The range of industries covered by the NEP is very broad and the food industry is particularly impacted by this program. Food manufacturers that are impacted by the program include; bakeries, snack foods, candy, powdered beverages, as well as any process that uses sugars, starch, milk powders, whey, flour, etc. In fact, the vast majority of natural and synthetic organic materials can form a combustible dust. NFPA's Industrial Fire Hazards Handbook states that "any industrial process that reduces a combustible material and some normally noncombustible materials to a finely divided state presents a potential for a serious fire or explosion."

Any company that uses dry powders as part of its manufacturing process is potentially at risk for an incident as well as OSHA fines, and companies must be aware that the NEP is already in effect. At this point it is clear that one of the industry groups that OSHA is targeting for increased enforcement is the food and beverage industry. Fines totaling in the millions of dollars have already been issued by OSHA, with nearly 4,000 violations issued in just the first year of the NEP's enforcement alone.

All manufacturers that use dry powders in their facilities should carefully analyze their operations to assess the potential for dust explosions. Specifically companies should:

• Identify any materials used that could become combustible as an airborne dust
• Inspect all areas where combustible dusts may build up including hidden areas where combustible dusts may accumulate. Accumulated dusts must be removed.
• Analyze operations to identify scenarios that could cause dust to become dispersed in the air
• Identify potential ignition sources in areas where combustible dusts may exist
• Inspect facilities and equipment to identify non-code compliance issues
• Develop strategies, policies and programs to mitigate risks and eliminate hazards.

Where combustible dust hazards exist potential mitigation strategies that should be considered include:

• Minimize the escape of dust from process equipment or ventilation systems
• Use code compliant dust collection systems and filters
• Deflagration venting of a building, room, or area
• Pressure relief venting for equipment
• Utilize surfaces that minimize dust accumulation and facilitate cleaning
• Provide access to all hidden areas to permit inspection
• Inspect for dust residues in open and hidden areas
• Clean dust residues at regular intervals and use cleaning methods that do not generate dust clouds
• Only use vacuum cleaners approved for dust collection
• Develop and implement a hazardous dust inspection, testing, housekeeping, and control program