With all the recent attention this issue has received, it is still surprising how many facilities believe they are OK. That is until you start asking the right questions. You may not see the dust lying around waiting to be suspended and explode, but what about the ventilation system that has combustible dust suspended and creating some of the conditions needed for an explosion to occur. Some questions to ask are: How am I ensuring this ventilation system is always operating correctly? Has the ventilation been altered from its original design that may allow material to settle out? Are my detection or suppression systems going to work when needed? Are my air material separators (baghouses, cyclones, etc.) properly vented? What ignition sources could enter my ventilation system? The list goes on and on, so where do you get the answers?
While it remains to be seen what OSHA’s standard may look like, one thing is for certain, they are not waiting for their standard to be published before addressing combustible dust. Yet many manufacturers seem to be waiting to see what exactly is going to be required. Although there is no OSHA standard specific to combustible dust, several OSHA standards do currently pertain to the issue. Some common standards cited frequently among industries affected by combustible dust include, but are not limited to:
- General Duty Clause, Failure to comply to National Fire Prevention Standards (NFPA)
- Hazard Communications
- Housekeeping
- Electrical Safety (Hazardous Locations)
- Personal Protective Equipment
- Lockout/Tagout
- Ventilation
- Welding, cutting, brazing
- Fire Protection
- Egress
The current standards available, such as NFPA 654, 664, 484, 69, 68, as well as the others mentioned above, can be used as guidance to help mitigate the risk and set an action plan in place should OSHA come knocking. Most of these standards will likely be used in development of the standard or incorporated by reference and compliance with these standards will most likely ensure compliance when the OSHA standard finally arrives.
With typical cost of abatement of recent Indiana OSHA safety orders reaching well beyond the $300,000 range, on top of any fines, now is not the time to wait.