CSB Pushes for Combustible Dust Standard
Originally published by: U.S. Chemical Safety Board — July 25, 2013
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On July 25, 2013, The U.S. Chemical Safety Board (CSB) approved a recommendation calling on OSHA to adopt a combustible dust standard for general industry. As adopted by the three-person panel, the CSB called on OSHA to – “Issue a standard designed to prevent combustible dust fires and explosions in general industry based on current National Fire Protection Association (NFPA) dust explosion standards (including NFPA 654 and NFPA 484), and include at least—hazard assessment,—engineering controls,—housekeeping,—building design,—explosion protection,—operating procedures, and—worker training.”
The CSB had previously called on OSHA to issue a standard for general industry in 2011. The recommendations were based on numerous incidents, including three separate incidents in 2003 that occurred in 3 separate states, involving 3 different types of combustible dust that first created a call for a new standard. In response to earlier calls and the 2008 Imperial Sugar incident, OSHA issued an Advance Notice of Proposed Rulemaking in 2009. The CSB was critical of OSHA’s inaction to actually proceed with the rulemaking process, including the interim step of convening the Small Business Regulatory Relief Act (SBRFA) panel. OSHA did re-issue its National Emphasis Program for Combustible Dust in 2009 and has issued over 1200 citations based on over 2500 inspections of facilities.
The call for a new OSHA standard is based on the following observations: 1) the reliance on a voluntary consensus standard as the National Fire Protection Association (NFPA) standards do not work because of a lack of adoption and enforcement consequences; 2) OSHA’s current authority and enforcement actions are not sufficient and are reactive, not serving a preventative role; and 3) the 1987 OSHA standard applicable to the grain industry that included combustible grain dust demonstrates that a specific standard can be effective.