Protecting Workers from Combustible Dust with FR Clothing June

Transcription

Protecting Workers from
Combustible Dust with FR Clothing
June 2010
Service • Experience • Trust • Quality • Flexibility
Agenda
•
•
•
•
•
•
•
•
•
Introduction: Combustible Dust & OSHA
What is Combustible Dust?
Combustible Dust Statistics
Case Studies
Hazard Analysis
Mitigation Strategies
FR Clothing: Background
FR Clothing
Cl thi
Can
C
Protect
P t t Workers
W k
Conclusion: Preventing and Protecting
Against Combustible Dust
Combustible Dust: Background
• Nearlyy 300 explosions
p
have injured
j
or killed over
•
•
•
•
800 workers since 1980.
Imperial Sugar Plant explosion in 2008 caused
OSHA to re
re-intensify
intensify a National Emphasis
Program targeting the hazard.
OSHA has cited over 1,000 firms for combustible
dust Of firms visited
dust.
visited, 87% have received
citations.
As yet, there is no enforceable standard to
regulate combustible dust.
The complexity of the combustible dust hazard
poses a challenge to standard
standard-makers.
makers.
What is Combustible Dust?
• There is no widely accepted definition of
•
•
combustible dust.
OSHA defines combustible dust as: “organic
or inorganic dust particles that are finely
ground and pose a deflagration or other fire
hazard when suspended in air or another
oxidizing medium over a range of
concentrations.”
C
Combustible
b tibl D
Dustt can consist
i t off any material
t i l
and varies in the dangers of its explosivity.
How does dust “combust”?
• Finely divided dust is disturbed from its
•
resting position and suspended in the air or
introduced to another oxidant.
oxidant
Ignition sources such as static, a spark, an
ember,, a hot surface,, friction heat or flame
come in contact with dispersed dust, causing
an explosion.
5 Elements of an Explosion
Vulnerable Industries
C
Common
Combustible
C
b tibl Dusts
D t
Known Injuries & Deaths Over Time
OSHA is
i Acting
i
• OSHA is working
g to create a Combustible Dust
•
•
•
•
Standard applicable to a variety of industries.
HR 849, requiring a combustible dust regulation
from OSHA following the 2008 Imperial explosion,
explosion
was passed but never signed into law.
OSHA is targeting dozens of industries, including
refineries, chemical companies, and
petrochemical companies, and delivering citations
at a rate of 87%.
An estimated 100,000 companies are at risk!
Go to OSHA.gov to keep up with the latest
rulings.
li
Combustible Dust Fines
• As part of its National Emphasis Program,
Program
•
OSHA is targeting industries with a known
combustible dust hazard.
The following are fines issued recently by
OSHA for combustible dust:
•
•
•
•
Plastics Manufacturer—$133,500
Manufacturer $133 500
Log Manufacturer—$215,000
Ohio LLC—$472,900
Food Processor—$1.1M
• Imperial Sugar—$8.8M (Largest fine in
OSHA history!)
y )
Current OSHA Dust Standards
d d
Some industry-specific standards already exist
b t are nott comprehensive.
but
h
i
• 1910.22(a)(1)—Housekeeping, allowable
dust accumulations
• 1910.22(a)(2)—Housekeeping, allowable
dust accumulation on floors
• 1910.178(c)—Classification in hazardous
environments
• 1910.307—Hazardous
1910 307 Hazardous Locations
• 5(a)(1)—General Duty
• 1910.272
1910.272—Grain
Grain Handling Standard
Current NFPA Dust Standards
d d
• NFPA 68—Guide for Venting of Deflagrations
• NFPA 85—Boiler and Combustion Systems
•
•
•
•
•
•
Hazards Code
NFPA 69—Standard on Explosion
p
Prevention
Systems
NFPA 499—Classification of Combustible Dusts
NFPA 654—Prevention
654 Prevention of Dust Explosions from
Manufacturing Processing, and Handling of Dust
NFPA 61—Prevention of explosions in agricultural
and food processing facilities
NFPA 484—Metal Dust Standard
NFPA 664
664—Wood
Wood Dust Standard
Challenges of Combustible Dust
• Combustible dust, as a flash fire hazard, is highly
unpredictable. Dust can collect in a wide variety of
materials and consistencies.
• Even two scenarios with the exact same type,
volume and density of dust, ventilation source,
and ignition source may produce entirely different
explosions at different times.
• Practical and cost-effective mitigation strategies
can significantly diminish the possibility of an
explosion at your firm, including the use of flame
resistant clothing.
What
h Can Be Done?
• Multi-step safety processes will help to ensure
•
•
that combustible dust is mitigated.
Dust testing,
testing adequate housekeeping,
housekeeping
communication, training, and use of personal
protective equipment (PPE) can all be used to
ensure that combustible dust is kept at bay.
No mitigation strategy will ensure that dust
will be 100% prevented.
prevented It is safest to follow
as many precautions as possible.
Hazard Analysis by Lab Testing
• Though hazard assessment under these
•
•
•
circumstances
i
t
iis difficult
diffi lt att best,
b t testing
t ti
for
f
dust explosiveness is both possible and
p
practical.
No enforceable, set method for conducting
hazard analysis.
D
Dust
can b
be tested
d for
f a generall NFPANFPA
classified “KST” number to estimate the
anticipated
p
behavior of dust deflagration,
g
, or
explosion.
KST testing may be a good way to assess
combustible dust hazard.
hazard
What
h d
does KST mean?
• When a facility opts to have testing
performed, the following are
analyzed:
1. Minimum Dust Concentration
2. Minimum Ignition Temperature
3. Minimum Ignition Energy
• KST is a generalized number used to
estimate the anticipated behavior of
dust deflagration, or explosion.
How is KST Testing Conducted?
• Bulk samples of dust material in plastic bottles
between 2-2.5 lbs are tested for a general
NFPA-classified “KST” number.
• Samples of dust are taken from several
locations, such as ceilings, ductwork, and
corners.
• Labs assess the above factors to analyze
y the
“KST” number, or a dust’s approximate
explosive power and explosive probability.
KST Categories & Explosiveness
EXPLOSION
CLASS
KST Characteristic
ST 0
0 No explosion
ST 1
>0 and ≤ 200
Weak Explosion
ST 2
>200 and ≤ 300
Strong
g Explosion
p
ST 3
>300+
y Strong
g Explosion
p
Very
Common Dusts & KST Values
Common Dusts
KST Value
Aluminum Powder 400
y Grain Dust
Barley
240
Charcoal
117
Cotton
24
Magnesium
508
Soap
111
S lph
Sulphur
151
Tobacco
12
Wood Dust
102
Case Studies
Combustible Dust Case Studies
Y
Year
1999
1999
2002
F ilit
Facility
Iron
Casting
Foundry
Electrical
Generation
Rubber
Recycling
St t
State
MA
MI
MS
D t
Dust
Phenolic
Resin
Coal Dust
Scrap Tire
Grindings
Kill d
Killed
3
1
5
I j
Injured
d
Reasons
easo s for
o
Explosion
9
Inadequate
housekeeping,
Poor ventilation,
Poor oven
maintenance,
Inadequate safety
equipment
14
Lack of worker
awareness,
Inadequate
housekeeping
6
Lack of worker
awareness,
Improper building
construction
t
ti
Combustible Dust Case Studies
Year
2003
2003
2008
Facility
Rubber
Drug
Products
d
Fiberglass
Insulation
Sugar
Refinery
State
NC
KY
GA
Dust
Polyethylene
Phenolic
Resin
Sugar
Killed
6
7
14
Injured
Reasons for
Explosion
p
38
No hazard
assessment, No
hazard
communication,
i
i
Poor engineering
37
No hazard
assessment. No
hazard
communication,
Poor building
design
36
Poor equipment
P
i
t
design,
Inadequate
housekeeping,
Dust
accumulated
over MEC
M ld
Malden
Mills
Mill (MA)
F d River
Ford
Ri
R
Rouge (MI)
Rouse Polymerics
l
i
(MS)
(
)
W t Pharmaceutical
West
Ph
ti l (NC)
Rubber Dust Explosion at West
CTA Acoustics
A
ti
(KY)
I
Imperial
i l Sugar
S
(GA)
I
Imperial
i l Sugar
S
Incident
I id t
Weak Explosions?
How explosive was the dust at the above facilities?
•
•
•
•
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•
Phenolic Resin: 129
Coal Dust: 129
Polyethelyne: 134
Sugar Dust: 138
Ti Grindings:
Tire
G i di
139
All of these industries were ST Category
g y 1:
Weak Explosion, yet all six explosions resulted
in significant damage, injury, and worker death.
Mitigation Strategies
Mitigation: Communication is Key
Workers are always the first line of defense in
preventing and mitigating fires and explosions.
explosions
“If the people closest to the source of the hazard
are trained to recognize and prevent hazards
associated with combustible dust in the plant,
they can be instrumental in recognizing unsafe
conditions, taking preventative action, and/or
alerting management.” (OSHA, 2005).
Perhaps the most important component of
hazard mitigation is raising employee
awareness
awareness.
Mitigation: OSHA Recommendations
OSHA recommends guarding against the following:
• Materials that can be combustible when finely
divided
• Processes which use
use, consume
consume, or produce
combustible dusts
• Open areas where combustible dusts may
build up
• Hidden areas where combustible dusts may
accumulate
• Means by which dust may be dispersed in the
air
• Potential ignition sources
Mitigation: NFPA Recommendations
• Minimize escape of dust from process
•
•
•
•
•
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equipment or ventilation systems.
systems
Use dust collection systems and filters.
Utilize surfaces that minimize dust
accumulation and facilitate cleaning.
Provide access to all hidden areas to permit
i
inspection.
i
Inspect for dust residues in open and hidden
areas at regular intervals,
areas,
intervals
Clean dust residues at regular intervals.
Use cleaning
g methods that do not g
generate
dust clouds, if ignition sources are present.
FR Clothing: Additional Protection
• No mitigation strategy will provide 100%
•
protection against a combustible dust
explosion for an at-risk firm.
Choosing flame resistant clothing is an
effective method to protect at-risk
employees if primary mitigation strategies
are economically or practically ineffective—
and even if primary mitigation strategies are
effective and employers want to prevent or
minimize worker injury.
FR Clothing Reduces Injury
• Where
Wh
any flash
fl h fire
fi hazard
h
d exists,
i
using
i
•
flame resistant clothing is a common-sense
method to significantly
g
y reduce the chance of
worker injury in the event of an explosion.
On top of preventing the added burn injury
inherent in the melting and dripping of nonnon
flame resistant fabrics, the cost of flame
resistant clothing is minimal compared to the
devastation of a burn injury on a worker
personally and economically.
FR Clothing: Voluntary Protection
• Though flame resistant clothing is not yet
•
•
required for workers exposed to flash fire
hazards, its procurement may be the last
and
d mostt important
i
t t step
t
a company can take
t k
to insure the lives of workers.
Many companies exposed to flash fire have
already taken this preventative measure to
avert worker injury, especially in the refinery
industry.
industry
OSHA may require FR clothing in its
g
combustible dust ruling.
FR Industry Comparison
Electric
Utility
Refinery
Combustible
Dust
Hazard
Arc Flash
Flash Fire
Flash Fire
Relative
Accuracy
of Hazard
Analysis
High
Low
Low
OSHA
Regulated
Yes
Maybe*
No
Use of PPE
High
High
Low
Mitigation
Strategies
Simple
Complex
Complex
(New interp of OSHA 1910.132
may require FR as of March
2010))
The Statistics: FR Works!
• The most serious injuries
j
typically
yp
y occur
•
•
•
AFTER the flash fire, from non-FR fabric
burning against the skin.
N
Non-FR
FR clothing
l thi
burns
b
and
d melts
lt against
i t the
th
skin, increasing the risk of injury.
Flame resistant clothing self
self-extinguishes
extinguishes
once the source of heat is removed.
Until there is a unified, enforceable standard
regarding
di
this
thi hazard,
h
d voluntary
l t
compliance
li
with the current recommendations is
necessary
y to ensure worker safety.
y
Flash Fire Incident Video
FR Clothing Requirements
• All flame resistant clothing must be tested
•
•
for safety and durability.
NFPA 2112 is the best FR Clothing standard
to address flash fire hazards such as
combustible dust.
NFPA 2112 says that flame resistant clothing
must protect the wearer by, “not
contributing to the burn injury of the wearer,
providing a degree of protection to the
wearer, and reducing the severity of burn
injuries resulting from accidental exposure to
h d oca bon flash fires.”
hydrocarbon
fi es ”
Tests for FR in NFPA 2112
• The Vertical Flame Test determines whether a
fabric will continue to burn after the source of
ignition is removed.
• The Three-Second Manikin Test is the test
method for evaluating a garment’s
garment s flame resistance
using an instrumented manikin. A garment is
exposed to a heat flux of 2.0cal/cm2.sec for three
seconds.
seco
ds If tthe
e ga
garment
e td
displays
sp ays less
ess than
t a 50%
total body burn, the fabric achieves a passing
performance.
• The Thermal Protective Performance test (TPP).
(
)
The 2007 edition of NFPA 2112 requires the
Thermal Protective Performance test to be
performed both with the fabric against the sensor
and with a ¼” spacer.
Arc Flash Parallel: Proven Protection
• In the 1970s,, before OSHA required
q
utility
y
•
workers to wear flame resistant clothing, an
average of 9.5 burn accidents and 14.7 burn
injures per 100 workers resulted in
devastating personal and economic costs to
utilities.
After OSHA implemented 1910.269, the
Standard for electric generation, transmission,
and distribution in the 1990s
1990s, worker burn
injury rates in the 2000s decreased to 4
accidents and 6.2 injures per 100 workers.
NFPA 654 - 2011
• “Operators shall wear flame-resistant garments as specified
•
•
in NFPA 2113 and any other personnel protective equipment
required for protection against flash fire hazards during
charging operations”
“Operating Plans shall include the use of flame-resistant
garments as specified in NFPA 2112 for all exposed
personnel when the design dust mass / accumulation
exceeds the threshold value determined per section 6.1”
“Operating and maintenance procedures shall address
personal protective equipment (PPE) for tasks involving or
handling of combustible dust according to the following:
•
•
PPE shall include flame resistant garments in accordance with the
workplace hazard assessment required by NFPA 2113: and,
Where a dust explosion hazard or flash fire hazard exists, flame resistant
garments shall be required for all exposed personnel.
What Next? OSHA is Acting!
• OSHA will most likely consult current NFPA
•
•
•
standards
t d d iin its
it future
f t
combustible
b tibl dust
d t
regulation.
Hefty
y fines will continue to be delivered for
various violations of existing standards,
especially the “General Duty Clause.”
OSHA may require FR clothing as part of its
regulation.
Voluntary adaption of known mitigation
strategies will result in avoiding fines,
fines
maintaining productive working conditions,
and keeping workers safe until the ruling is
finalized
finalized.
Mitigation Strategies: Summary
• Company-wide hazard communication
•
•
•
•
•
and
d training
t i i
is
i key.
k
Proper housekeeping, such as using a dust
vacuum to collect dust
Proper building engineering (i.e. ensuring
that dust cannot accumulate in unmonitored
areas))
Proper ventilation systems
Removal or careful monitoring of potential
ignition sources
Use of p
personal p
protective equipment,
q p
such
as FR clothing, as a last line of defense
Last Line of Defense
• Flame resistant clothing is a secondary
•
•
protective strategy providing protection from
momentary burns and flames.
FR has been proven a cost-effective and
successful measure for employers to take in
protecting their employees from thermal
h
hazards
d in other
h industries.
d
Even companies that implement all known
mitigation strategies will find that cost
costeffective flame resistant clothing will offer
peace of mind in the event that an explosion
does occur.
occ
Want to learn more?
• Sign up now for more information about:
• Combustible Dust
• Mitigation
Miti ti
Strategies
St t i
• Current Standards
• OSHA Activity
• FR Clothing
• Tyndale will send you an email very soon with
these resources so that you can learn more
about this insidious hazard!
Questions?
i
Thank you for the opportunity to
meet with you today!
Rob
R
b Whittenberger,
Whi
b
President
P
id
Tyndale Company, Inc.
RWhittenberger@Tyndaleusa com
RWhittenberger@Tyndaleusa.com

Protecting Workers from Combustible Dust with FR Clothing June

Transcription

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