DSS089: The Role of Insurance Companies in Global Combustible Dust Safety with Kumar Rajasegaram

In this episode of the DustSafetyScience Podcast, Kumar Rajasegaram, fire safety risk analytics consultant with JTS Risk Engineering in Kuala Lumpur, Malaysia, about the role of insurance companies in global combustible dust safety.

Kumar has over 18 years’ experience in the technical side of combustible dust safety, including risk assessment and hazard identification in processing industries, and has frequently been involved with global insurance companies throughout Southeast Asia. In this interview, he answers the following questions:

What is your background in combustible dust safety?
How did insurance companies get so involved in advocating combustible dust safety?
Are there any regulations regarding combustible dust in Malaysia?
Does company size or ownership affect attitudes towards combustible dust hazards?
What are some of the challenges you are facing?

What is your background in combustible dust safety?

Kumar said that his first exposure to the hazards of combustible dust occurred 16 years ago when he was a new engineer with FM Global. He heard about the February 20, 2003 explosion and fire that damaged the CTA Acoustics manufacturing plant in Corbin, Kentucky.

“FM Global was actually the property insurer,” he recalled. “FM was cited in the OSHA investigation because there were no recommendations related to combustible dust that could have prevented the explosion. That was my first experience with combustible dust. Prior to that, I never knew sugar was so dangerous, and I had worked with another insurer before I joined FM.”

Today, Kumar is mostly involved with clients in the feed mill business. These facilities have a certain level of protection installed, but true understanding of the hazards is not always there.

“There (are) incidents where the hazards were not identified or they may have been identified before. But because of a lack of management of change, you know, that exposure now revealed itself. So that’s how we know. I realized that it’s a lack of understanding amongst the general industry, at least the feed mill segment, that dust hazards are a serious issue.”

Kumar uses the NFPA standards, primarily NFPA 61, which is the standard for the prevention of fires and dust explosions in agricultural and food processing facilities. He tells clients that they need to do a dust hazard analysis to understand the risks they face, but admitted that getting the dust tested is difficult.

“It’s becoming quite frustrating because there are not many laboratories out there (in Malaysia) and the cost of testing is prohibitive. You tell the client about the test, they spend a couple of thousand US dollars on testing one substance and, in a typical feed mill process, you have multiple substances as well as mixtures. As it goes through the process, the dust properties also change. You’re sending multiple samples out there and the cost escalates. That is a current obstacle in trying to get clients on board to conduct a proper dust hazard analysis.”

How did insurance companies get so involved in advocating combustible dust safety?

Kumar said that the CTA Acoustics incident drove FM Global to propagate awareness of combustible dust hazards in Southeast Asia, and other insurance companies followed suit. Interest became even stronger after the Imperial Sugar explosion in 2008.

“(Since) the requirements for a dust hazard analysis got into the NFPA documents, insurance companies have been using it to encourage clients to analyze their dust do a comprehensive evaluation of what level of protection they have and so on,” he explained. “It also lifts the burden of hazard identification off of the insurer, because if the client does a dust hazard analysis, it’s a document that can be easily read and understood.”

Are there any regulations regarding combustible dust in Malaysia?

Kumar said that he was not aware of any regulation in Malaysia that specifically addresses combustible dust. He did find an undated document produced by the DOSH (Department of Occupational Safety and Health) that summarizes a small number of dust-related incidents that occurred in the last 10 to 12 years.

“At the end of the document, it refers to NFPA guidelines, ATEX guidelines, and Australian and New Zealand guidelines. So in Malaysia, I feel (regulation) is still very much at its infancy level.”

He said that NFPA is the dominant regulatory framework in Malaysia, largely because the losses being reported worldwide are mostly happening in North America.

“Malaysia doesn’t have its own standards, so we are always looking outside for reference or guidelines and guidance and so on. So that’s probably one of the reasons why NFPA is quite widely used or referred to, especially in the combustible arena.”

Another factor is the influence of the North American companies that operate in the country. These large multinational companies use the NFPA codes, furthering their general adoption in Malaysia.

Does company size or ownership affect attitudes towards combustible dust hazards?

Kumar confirmed that attitudes towards dust safety can vary by company size. The small business enterprises (SMEs) are typically insured by local insurance providers while the multinational companies (MNCs) deal with larger and more established providers.

In the latter case, knowledge transfer within MNCs can be delayed due to the sheer company size while local insurance providers take more of a hands-on approach with their clients when it comes to hazard education. On the other hand, MNCs have the funds needed to properly address these issues and they tend to be more concerned about their safety reputation.

“Now, having said that, I have actually been involved with MNCs that take advantage of the lack of regulations,” he said.

He recalled one plant in Malaysia that used rated electrical equipment brought in from Europe. This equipment could no longer be used in Europe due to regulations changes, so it was brought to Malaysia, where the regulations were not as stringent.

“(That company) capitalized on those loopholes,” Kumar said. “So you large organizations that comply because of reputational risk and some that take advantage of the lack of regulations.’

What are some of the challenges you are facing?

Kumar said that one of his biggest challenges is making clients understand that proper zoning for hazardous areas is not a catch-all solution.

“I’m involved in the project now for a sugar refinery. They got a professional engineering consultancy to do the zoning for them and identify where they need to use rated equipment and so on. But when I asked them whether they had done any analysis on the venting requirements, spark detection, suppression and isolation and all that, they were a bit lost. They said those (issues) were addressed by the equipment supplier, so that’s that’s not their concern. They feel that by just eliminating the ignition source, they are good to go.”

Another challenge concerns equipment maintenance and testing. The general assumption is that once the equipment is installed, it’s good to go for as long as it’s needed. People also don’t fully understand the difference between active and passive protection systems, making it difficult to implement comprehensive solutions.

In his opinion, one of the biggest challenges in conducting dust hazard analyses is that there is no certificate of competency. In his opinion, anyone with knowledge of combustible dust hazards is qualified to talk about them and educate others, although some experts may be more proficient in certain environments than others.

“I’ve been in this industry for 20 years. I’ve seen a different range of competency levels between fire protection engineers. Does that mean someone who doesn’t have the same level of competency as I do shouldn’t be doing the job? If a sophisticated, integrated plan is needed to deal with multiple processes, then maybe you need someone who’s a bit more sophisticated. But if someone’s confident doing something more challenging, I guess that’s fine.”

Conclusion

Kumar said that authorities like the Department of Health and Occupational Health and Safety should be more proactive in disseminating safety information, so facilities understand the need for dust protection equipment. He also recommended that costs be made reasonable, to avoid using unsafe knockoffs, and experts be made available to help managers maintain their new equipment. This way, proper process safety in industries handling combustible dust will be the rule instead of the exception.

If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Kumar Rajasegaram directly via email: [email protected]

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