In this episode of the DustSafetyScience Podcast, we’re doing a review of Occupational Safety and Health Administration (OSHA) combustible dust citations in 2018. Podcast listeners who have downloaded the 2018 Combustible Dust Incident Report will know that it includes a master list of all OSHA citations for combustible dust that we could locate through the general duty clause.
This research was done in partnership with Dalhousie University as part of an engineering student’s undergraduate research project. The student, Shamus McDonald Braun, was supervised by Dr. Paul Amyotte. He looked at the materials and equipment involved in different OSHA citations and pulled out some trends and information for 2018.
In this episode, we will-
- Explain the importance of the OSHA combustible dust citation data
- Talk about how the data was collected
- Provide a general overview of the materials and equipment involved as well as the penalties
- Discuss some of the trends that are apparent
Why Is The OSHA Data Important?
The OSHA combustible dust citation data is hugely important for several reasons, one of which is that citations typically have a lot more information than news reports. They may include details like:
- Equipment types and model numbers
- Very specific observations of employee behavior
- How things were set up in the facility
They are also prepared by OSHA inspectors who understand combustible dust hazards and the different industries affected, so they represent a reliable means of identifying trends and addressing hazards.
One of the problems with collecting incident data is that the information available through public portals is hard to sift through and the formatting makes it hard to read the citations. When Shamus did his undergraduate report, he pulled out every 2018 citation that he could find and reformatted them to make them easier to read.
How Was The Data Collected?
We collected the OSHA data by going to the agency website and doing a general duty clause search for combustible dust. This returns any citation where the employer did not furnish a place of employment or employment opportunity which is free from recognized hazards that are causing or likely to cause death or serious physical harm like a combustible dust flash fire, deflagration or explosion.
Searching for dust alone delivered all the incidents listed under the National Emphasis Program for Combustible Dust. This method yielded 48 citations in 2018 alone.
A General Overview
For the 48 citations listed under the general duty clause for the term ‘dust,’ the initial penalties ranged from just under $6,000 on the low end to over $680,000 on the high end, with an average of $49,000 per citation. The total penalties for all citations were $2.4 million in 2018; after arbitration, they’re generally reduced by half. At the time of reporting, a lot of the incidents were still open, so these may not be the final numbers.
Materials
In terms of what materials were involved, below is a list broken down by percentage:
- 25% of citations were in wood and pulp industries.
- 21% were in metals. This includes stainless steel, aluminum, chrome, chromium, titanium, nickel and cobalt handling operations.
- 17% were in food and agriculture, which includes grain, dried food, powder, dairy and cocoa.
- 17% percent were in plastics, which includes coatings, resins, polyester, polystyrene, polypropylene, pretty much anything has a polymer element to it. A lot of these plastics can be ground up and cause combustible dust issues.
Other materials that didn’t account for a large enough percentage to be grouped included paint, textiles, waste, and chemicals.
Equipment
In terms of equipment involved, there were 74 pieces of equipment mentioned in the 48 citations.
- 42 % were dust collectors.
- 15% were ductwork or conveying systems that were carrying combustible dust.
- 15% were in general workspace.
- 11% were in cyclones.
- 17% involved equipment that was only mentioned a handful of times.
Five Trends Identified By The OSHA Data
The undergraduate student’s report and a review of the OSHA citations at our end revealed five trends involving combustible dust hazards.
Improperly Protected Equipment
Trend number one was the range of improperly protected equipment. These are dust collectors, cyclones, mills, hoppers silos, sifters and other equipment that had limited or no protection. Examples include:
- Indoor dust collectors with no venting that are located near workers
- Dust collectors that vented indoors
- No isolation between equipment
- Outdoor dust collectors that could propagate a flame back indoors
- Obstructed or poorly maintained venting
- Absence of ignition control
Enclosureless Dust Collectors
Number two was the dangerous use of enclosureless dust collectors, These are generally dust collectors that the dirty air feeds into through the bottom or through one end, with the dust being captured by a big ‘sock’ with no frame or structure around it. These devices accounted for seven of the 48 citations.
The real danger is that the enclosureless dust collectors are often sitting right beside workers, located near ignition sources, or potentially capable of sucking in ignition sources. A flash fire could cause severe and even life-threatening injuries.
Insufficient Duct Velocity
Trend number three was insufficient duct velocity, allowing dust to accumulate in ducting or conveyance systems. This issue was mentioned several times, especially in metalworking industries. In one case, at an equipment manufacturing facility, the ductwork collapsed due to the amount of accumulated dust. What is probably more dangerous are the ducts that don’t collapse. If a primary event occurs, that metal dust could fuel an outcome that destroys the facility.
Housekeeping Challenges in Small Facilities
Trend number four was housekeeping challenges in small facilities. Small cabinet wood shops were mentioned three different citations because they didn’t have a collection system in place. Other housekeeping problems included:
- Enclosureless dust collectors
- Allowing metal dust to enter exhaust systems
- Damaged power cords in areas that accumulate combustible dust
Keeping these small facilities safe is an open challenge to our community and our industry because there’s so many of them and the knowledge of combustible dust hazards might not be there.
Keeping Workspaces Free From Combustible Dust
The last trend, which led to a number of injuries last year, is keeping workspaces free from combustible dust. Below are some examples of cases:
- A welder suffered second and third degree burns when an electrode from his welding torch fell into a chamber that had accumulated titanium dust in the bottom.
- Skid steers and excavators, neither of which was rated for use in hazardous areas, were used in the vicinity of airborne wood dust.
- An employee was injured when combustible dust ignited in a flocking room, where machines that apply flock to cloth
Unsafe gravity bulk unloading was also cited as an issue. In at least one case, titanium dust was being unloaded using a gravity feed that had no type of ignition control. Dust building up during these dangerous conditions can create a cloud that leads to a flash fire.
Conclusion
The undergraduate research project completed by Shamus McDonald Braun has yielded information and insights that could propel real change and greater safety in industries handling combustible dust. Those who would like to download a copy of the report may do so below.
If you have questions about the contents of this or any other podcast episode, you can go to our ‘Questions from the Community’ page and submit a text message or video recording. We will then bring someone on to answer these questions in a future episode
Resources Mentioned
The resources mentioned in this episode are listed below.
DustSafetyScience
Combustible Dust Incident Database
DustSafetyScience Podcast
Questions from the Community
Student Report
OSHA Dust Related Incidents of 2018
Organizations
OSHA
Databases
OSHA General Duty Search
Programs
National Emphasis Program for Combustible Dust
Explosion Testing Video
Remote Test Facility Demonstrations at ISHPMIE XII
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