DSS 006: A Call to Action on Combustible Dust from the US Chemical Safety Board - With Cheryl Mackenzie and Dr. Ivan Pupulidy

In this episode of the podcast we discuss the recent US Chemical Safety Board (CSB) Call to Action on combustible dust. On the call we are speaking with Cheryl Mackenzie, Team Lead of Investigations at the US Chemical Safety Board (CSB) about why the call to action is needed and Dr. Ivan Pupulidy, retired director of Innovation & Organizational Learning with the US Forest Services who is also helping with the project.

Background

Background on the project is given in the original call to action: CSB Releases Call to Action on Combustible Dust Hazards, which was released at the same time as the CSB’s summary of Combustible Dust Incidents from 2006-2017.

The call to action includes a request for comments on a set of questions developed to better understand the difficulties in industries handling, producing, or transporting combustible dust and to get to the underlying of the root-cause of why we still have deadly explosion incidents today. The questions can be found in the “Call to Action: Combustible Dust” document and responses can be sent directly to [email protected].

The CSB is asking for this feedback from companies, operators, regulators, inspectors, safety training providers, researchers and unions. Essentially, if you work in, around, or with combustible dust, they want to hear from you and have your opinion included in the project. The original submission deadline has been extended to December 31, 2108 for responses from community.

Partial responses, responses from individuals outside of North America, general thoughts about the combustible dust hazards unrelated to the questions posed, and any other questions you think are important to consider moving forward are all encouraged and would help the project.

At DustSafetyScience.com we created a cheat-sheet document that you can fill out and send directly to the CSB or email to us at [email protected] to forward on anonymously.

Goals of The US Chemical Safety Board

The US Chemical Safety Board (CSB) is an independent, non-regulatory, safety agency who is tasked with investigating large-scale accidents within US chemical industries, including those handling and producing combustible dust. Their goal is to determine the underlying causes of these accidents and generate knowledge to allow safety change in industry.

The vision of the CSB is “A Nation Safe from Chemical Disasters” and its mission is to drive chemical safety change to protect people and the environment. They have previously published the Combustible Dust Hazard Study in 2006 and Imperial Sugar Company Dust Explosion and Fire in 2008 which we covered in episode three of the podcast: DSS 003: Review of the Imperial Sugar Refinery Explosion from the US Chemical Safety Board Investigation Report.

Why is the Call to Action Needed?

One of the biggest findings from the Chemical Safety Board investigations over the last decade are that catastrophic loss incidents, those that cause multiple fatalities and large-scale facility damage, are not limited to one material or one industry. Cheryl mentions large-loss incidents involving grain, sugar, titanium, resins, plastics, carbon black, and iron as a small sub-set of the materials involved.

Although the materials and industries involved vary, some common themes have arisen across these incidents. One of the main themes is that the perceptions of both “how much dust” and “how safe the facility was operating”, vary drastically between groups at the same facility and often times individuals working in the same area of the facility.

Other common themes include difficulties determining safe levels of combustible dust, company proprietary information making it difficult to share accident information more broadly, a tradition of looking to “fill-holes” in the safety program instead of understanding the mindset of the operators, and previous low-consequence incidents such as small fires creating a false sense of security that a more serious incident will not occur.

In the interview Ivan discusses briefly the approach used in the US Forest Services where they moved from a “serious accident investigation process” to a process that looks at the context around decisions and actions. In brief, “why did it make sense for people to do what they did” in the lead-up to an incident? How does this tie in with the “normal” operating procedures and what are the potential pitfalls from this?

This approach is one of the things that has lead to the current call to action and the focus on getting responses from actual operators, facility owners, and managers in the facilities handling or producing combustible dust.

Questions From the Call to Action

In the interview, I broke the call to action questions into three groups. These are given below including the questions that fell into each category. Note that the categorization is mine (that of DustSafetyScience.com and not that of the Chemical Safety Board).

“Concept” Questions

These questions cover some of the “higher-level” issues we are seeing with combustible dust safety. In particular, can facilities be both dusty and safe, how should effectiveness of dust cleanup activities be measured, and how to comply with different approaches to product quality and process safety are discussed. The answers to these more subjective questions provide insights into what the current state of “normal” is in facilities containing combustible dust.

In real-world working conditions, where dust is an inherent aspect of the operation, can a workplace be both dusty and safe?
How should the effectiveness of housekeeping be measured? What methods work best (e.g., cleaning methods, staffing, schedules)?
If companies/facilities need to use separate or different approaches in order to comply with both sanitation standards for product quality or food safety and those associated with dust explosion prevention, then how do you determine what takes priority? Is the guidance clear?

“Real-World” Questions

These questions cover what employees, operators, and business owners are actually doing in their facilities today. What is working and what is not working to keep these facilities safe from combustible dust?

In dusty working environments — where the amount of ambient/fugitive dust cannot be wholly eliminated 100 percent of the time — how does an individual or organization distinguish between an acceptable or safe dust level and one that has been exceeded? How often does judgment or experience play a role in such decisions? Should it?
How are hazards associated with combustible dust communicated and taught to workers? What systems have organizations successfully used to help their employees recognize and address dust hazards?
What are some of the challenges you face when implementing industry guidance or standards pertaining to dust control/management?
As equipment is used and ages, it requires mechanical integrity to maintain safe and efficient operability. How does inspection, maintenance, and overall mechanical integrity efforts play a role in dust accumulations, and how are organizations minimizing such contributions in the workplace?
What are some of the challenges to maintaining effective dust collection systems?
Are workers empowered to report issues when they feel something needs to change with regard to dust accumulation? What processes are in place to make these concerns known?

“Open-Ended” Questions

We covered these two questions in closing, as I want the listener to think about how the answers apply to them.

In particular, are fires common in dust handling/producing facilities and does this cause a false sense of security, and how can the community better share information to prevent future incidents? These obviously tie back into our work with the Combustible Dust Incident Database but also provide information on a way forward for the combustible dust safety community.

How common are dust fires in the workplace that do not result in an explosion? Does this create a false sense of security?
How can combustible dust operators, industry standard organizations, and regulators better share information to prevent future incidents?

Closing Remarks

In closing the interview, I give my personal opinion that the current call to action will help to change the landscape for combustible dust safety, especially if the Chemical Safety Board is able to obtain insights from actual operators, health and safety managers, facility owners, and others who are closest to the combustible dust being handling. Unfortunately, this group has traditionally been the hardest to gain insights from in the past making this process even more important.

As stated in the closing, replying to the combustible dust call to action is not meant to be a time intensive process.

Partial responses, general thoughts on areas missed, and obviously answers to the questions posed will all provide valuable insight into the real-world hazards of combustible dust and into ways we can prevent these catastrophic loss incidents from happening in the future.

You can access the call to action questions here or here and send your responses directly to [email protected] or to me at [email protected] to forward them on.