DSS169: Adding Combustible Dust Information to Material Safety Data Sheets with Keith Plumb

In today’s episode of the Dust Safety Science podcast, Keith Plumb, process safety and equipment consultant and owner of Integral Pharma Services in Cheshire, UK, goes over the process involved in adding combustible dust information to material safety data sheets. During the discussion, we answer the following questions:

What is an MSDS or an SDS sheet?
Is it common for combustible dust to be mentioned on these types of process safety information?
How would it be helpful if combustible dust is included?

We’ll also talk about some of the MSDS regulations and what can be done to improve this sort of information moving forward.

What is a Material Safety Data Sheet / Safety Data Sheet?

Keith explained that combustible materials supplied in the open market are legally required to come with a data sheet that provides health and safety information about the product. Is it toxic in any way? Is it a problem for the environment? Is it something that would burn or cause an explosion? These questions aren’t really answered in the Global Classification System used in the Globally Harmonized System (GHS).

“The lack of information to me is a problem because I immediately get a response from my client [who asks]“Well, how do you know it’s combustible?” The standard answer- “Any finely dispersed organic chemical is probably combustible” -doesn’t actually move you that far forward. We’re looking for something to build a safety case on. That’s really what these sheets should be doing. But they’re not. They don’t seem to be helping.”

This omission is unusual because if a material is flammable or toxic, you’re likely to find those details on a Material Safety Data Sheet. With combustible dust, you don’t have comparable information, which is concerning.

Is Combustible Dust Ever Referenced on These Sheets?

Keith said that he has only ever seen one Material Safety Data Sheet with a comprehensive list of properties for combustible dust. Others usually refer to a ‘finely divided powder’ or state ‘this could constitute an explosion risk.’ The problem is acknowledged but not always explored in the detail it deserves.

“There are three categories of flammable liquids: Category 1 and Category 2 basically are low flashpoint liquids and Category 3 is high flashpoint liquids,” he explained. “There’s a subtle difference between boiling points and things which are used to indicate the volatility of the solvent, so you can immediately see more of what you are doing with a solvent. [However], what is a combustible solid? Does that mean a huge, great big piece of timber that would catch on fire [if ignited]?”

One IEC standard defines a combustible dust as anything with a particle size of less than 500 microns. In Keith’s opinion, if you have a solid with material that is 5% in the combustible range, it should be considered combustible, but many facility owners tend to take the opposite outlook- that it is 95% noncombustible.

“When it’s in that EN standard, it’s a piece of firm ground I can stand on,” Keith says. “We just don’t have that in the dust. We don’t have that equivalent of “Okay, where am I in the problem?””

Who Regulates the Global Harmonized System?

The Global Harmonized System was originally designed for material safety during transportation. Keith explained that in the US, the Global Harmonized System is an OSHA regulation. In Canada, it is covered by the Canadian Centre for Occupational Health and Safety (CCOHS). In the EU, the GHS is addressed by the Reach Legislation, which deals with chemical safety.

The Reach Regulation legally requires that chemicals be registered and that there is a Safety Data Sheet to go with it, but, as Keith put it, “I don’t actually imagine the situation that anybody in the EU is going through Safety Data Sheets with a fine-tooth comb.” What’s more likely is that people complain now and again and say “Come on, this is just ridiculous. This doesn’t meet what we’re supposed to do.”

Episode #165 addressed the question of whether blood meal is combustible and, after reviewing the applicable safety data sheet, concluded that it was. In the general information section, the sheet notes “Prevention: Keep away from heat sparks, open flames, hot surfaces. Prevent dust accumulation to minimize pollution hazards.” Other notes include:

Under firefighting measures, it states, “Specific hazards arising from the chemical dust may form explosive mixture with air. Avoid generating dust. Fine dust dispersed in the air and in sufficient concentrations and in the presence of ignition sources is a potential dust explosion hazard. ”
Under handling storage precautions, it says, “For safe handling, use vent-equipped ventilation. Eliminate all sources of ignition. Minimize dust generation and accumulation. Avoid significant deposits of material, especially on horizontal surfaces which may become airborne and form combustible dust clouds and may contribute to secondary explosions. Handling and processing operations should be conducted in accordance with best practices, for example, NFPA 652.”

This is an example of a well-versed safety data sheet with a lot of good general information like the dimensions, overhead hazards like overhead deposits, and ventilation information that points to NFPA standards.

Conclusion

“There are standards that tell you how you work out a flashpoint so that each time you get a flashpoint report, you know they’re done the same way,” Keith says. “So if we could do the same thing with dust properties, then maybe we could do something that makes it equivalent. But all it’s doing is saying “Actually, it’s obvious we’ve got a problem that we need to properly investigate.” It still isn’t good enough for design. But it makes you go away and think about it.”

If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Keith Plumb directly:

Email: [email protected]
LinkedIn: https://www.linkedin.com/in/eur-ing-keith-plumb-b482797/
Website: https://www.integpharma.com/

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.