I enjoyed participating on July 11 with my friend Brian Edwards PE of Conversion Technologies in an FP Webinar on Combustible Compliance. The archived webinar is an excellent overview of combustible dust challenges. I prepared this handout as an accompaniment to Brian's slides. The piece represents the lawyer's practical observations on this thorny compliance issues and compliments Brian's slides and presentation.
In our competitive environment, every manufacturer struggles to do more with less and to find capital for “nonproduction” areas, such as maintenance, safety, training, housekeeping and HR. If done in a shortsighted fashion, the employer learns through painful experience the sacred law of “unintended consequences.” Plant Engineering magazine (yes, a lawyer can read such stuff) ran a brief instructive story on harm to production and profits resulting from gradually shifting almost all maintenance functions to production employees. You’re probably thinking that “I wouldn’t do that,” but many employers have eliminated certain housekeeping workers and relied upon production employees to clean up their area or machine. One of the contributing factors to the deadly Imperial Sugar combustible dust explosion was accumulation of material in work areas … in part because operators were supposed to clean up after their shift, and did not do so.
These are the links I sent to F P attorneys after recently conducting an in-house session on our workplace safety practice. The focus of the links was not on building a safety culture, which is my favorite topic, or on the various labor and employment topics I regularly write upon.
These posts only deal with 2013 OSHA enforcement issues. These posts also do not include other attorneys' posts or great stuff from sites such as TLNT, EHS, etc.
One of my focus areas is combustible dust in the workplace. As I have written before, an extraordinary range of common products can cause an explosion and deflagration (pressure wave) under the right circumstances. One occasion is when a well meaning employer decides to clean that dust accumulation on overhead beams, ductwork and lights. This material is difficult to reach and has never presented a problem, so the employer decides to use pressurized air to blow off the dust. The dust cloud ignites and we have a combustible dust event. And any combustible dust event will be bad.
I enjoy articles that I discover in Plant Engineering because one of my (many) goals is to obtain more coordination between the safety, engineering, maintenance and purchasing functions. Management of Change (MOC) affects far more than PSM, combustible dust and guarding and interlocks. We should all try to understand the plant engineers approach and work to better integrate safety and sustainability into those decisions. The following article is one of several on Plant Engineering's site.
Although OSHA's Process Safety Management (PSM) standard may be the most challenging of OSHA's regulations, the PSM standard, along with NFPA consensus standards about combustible dust have raised the importance of management of change (MOC) outside of refineries and chemical plants, and for the HR professional.
I have linked to an Interview by the good folks at Chem.Info.com, an excellent publication and provider, especially for food processors and related businesses.
We represented construction employers at the 2008 Port Wentworth Sugar Plant (Imperial Sugar) explosion and both before and since that explosion, we have handled many combustible dust matters in food processing, wood and paper, coal products, plastics, foundries and for numerous other manufacturers. Combustible Dust compliance remains one of the most understood and most dangerous of safety compliance areas. For more information on the Imperial Sugar explosion, which remains highly instructional, go to the Savannah Daily News archived special coverage