DSS019: Dust Hazard Risk Analysis After the Imperial Sugar Refinery Explosion with Courtney Turner

In this episode of the Dust Safety Science Podcast, we interview Courtney Turner, President of Process Risk Solutions in Birmingham, Alabama. He is also a member of the technical committee for NFPA 61 and speaks frequently at the American Society of Safety Professionals and committees and industry events.

Courtney’s experience in combustible dust safety covers many years and a variety of industries. Before becoming President of Process Risk Solutions, he was team leader for a combustible dust consulting organization and a safety manager for a sugar manufacturing operation and a tea and coffee manufacturer.

In this interview, he shares insights into the following:

Combustible dust safety at a time when the Imperial Sugar Refinery explosion occurred
Lessons learned after the incident
How the facilities he worked in changed many of their processes before and after the OSHA National Emphasis Program
What health and safety managers should know in these industries
Some of the biggest and outstanding issues in combustible safety today

Early Understanding of Combustible Dust Hazards

When Courtney entered the industry in early 2007 as a safety manager for a large operation in South Florida, combustible dust was, as he put it, “not very high on our radar.”

It wasn’t until October of that year that OSHA released their national emphasis program on combustible dust. Courtney reached out to his plant management to help identify some of the facility’s hazard areas and take appropriate action.

Soon afterward, the Imperial Sugar Refinery explosion occurred in February 2008 and OSHA reissued the national emphasis program. The sugar refinery where Courtney worked underwent a process hazard analysis that discovered multiple issues in the packaging department, namely:

A drop ceiling in some areas with up to a foot of dust above the packaging lines
Dust accumulation on some of the horizontal beams
Lack of proper venting
No suppression system

There were a number of administrative as well as engineering aspects that they had to improve upon in that facility. These steps served as the foundation for Courtney’s future work in dust hazard risk analysis.

Process Hazard Analysis vs. Dust Hazard Analysis

Courtney said that the industry is transitioning from process hazard analysis (PHA), which assesses the potential hazards associated with industrial processes, to dust hazard analysis (DHA). The former is a long-standing and highly formal tool in process safety management and, in his opinion, a dust hazard analysis is simpler while including many aspects of a PHA.

Approaching Dust Hazard Risk Analysis

Courtney found that it can be difficult to prioritize corrective actions after a dust hazard risk analysis. What is most important at that particular time? What needs to be addressed now and what can wait for another few weeks or months?

He recommended the following priorities:

Attention to housekeeping is a critical first step. This entails the identification and removal of potential fuel sources for a combustible dust incident.
The next step is identifying what can cause a catastrophic event. Are embers or static electricity potential ignition sources in this facility? What can be done to reduce or eliminate them?
A third key step is determining whether potentially reactive elements can be inerted.

Dust hazard analysis is basically a gap analysis of where a facility currently stands with its combustible dust program versus where it should be based upon standards like the NFPA. The process includes an assessment of its safety management programs for hot work, hazcom, and other processes. Once any deficiencies are noted, the facility can correct them and add more safeguards if necessary.

Safety Issues That Continue

In Courtney’s experience, lack of knowledge about combustible dust hazards continues to be a problem. He finds that management in a number of facilities are not aware and need to be educated.

Approximately two years ago he was conducting a dust hazard analysis and, upon talking to some of the employees, learned that product being run through a huge industrial oven caught fire on a regular basis. One operator actually told him, “You know, Courtney, we have a fire every Tuesday.”

When a fire is regarded as a routine event, it’s a sign that there is a lot more work to be done.

Conclusion

Many plant managers have hesitated about applying the recommended changes after a DHA, citing financial constraints, but this lack of foresight can cost them heavily. As Courtney stated, “You’ll save a lot more money on the front end by attacking it than on the back end having a catastrophic fire or explosion or something of that nature.” He also quoted Dr. Trevor Kletz: “If you think safety is expensive, try an accident.”

If you would like to discuss further, leave your thoughts in the comments section below.
You can also reach Courtney Turner directly:
[email protected]
1-205-790-0085