OSHA Releases Hazard Communication Guidance for Dust Explosion Risk
October 2, 2009 by Benjamin Hunting
Filed under Chemicals, Dust, Front Page
Risk managers are often aware of the dangers that excessive dust at a job site or facility can pose to the respiratory health of workers. However, there are other, less obvious dangers also related to dust buildup, which can pose a serious hazard not only to the safety of employees, but also to the integrity of a building itself. Specifically, the single largest of these concerns with regards to dust is the increased risk of explosion that can occur in areas that are most heavily affected by buildup.
In order to ensure that risk managers are fully updated as to the potential for disaster that dust explosions hold, as well as how this danger can be properly mitigated, the Occupational Safety and Health Administration (OSHA) released a new publication in 2009 on the topic. Entitled Hazard Communication Guidance for Combustible Dusts, the document focuses specifically on chemical manufacturers and importers, and offers guidance on how they can reduce the chances of a catastrophic dust explosion in other industries.
One of the primary points made by the publication is that ignorance of risk is a primary contributing factor when it comes to dust explosion hazards. It is difficult for precautions to be taken if employees are not informed that the dust-producing materials that they are working with warrant such caution. OSHA has discovered that 41% of the Material Safety Data Sheets (MSDS) associated with materials known to be dust explosion risks fail to mention this critical information. Unfortunately, analysis has revealed that dust explosion information is poorly conveyed in almost every MSDS.
OSHA’s Hazard Communication Standard (HCS) can be put to good use in the proper identification of chemicals which post a dust explosion risk. HCS requires that chemical manufacturers undertake hazard determination and evaluation of the products they generate, and follow that with appropriate MSDS updating in order to reflect the evidence gathered during the evaluation phase. Manufacturers must consider both standard and non-standard use of their products, especially with regards to processing after they have reached end of life status, Recycling or processing can easily create explosive dust from materials which are considered safe in their “shipped” form, and this must be noted on their related MSDS.
A material’s MSDS should be as verbose as possible concerning the explosion risks it poses. While a simple “explosion hazard” warning is better than nothing at all, a detailed explanation of the circumstances under which ignition of dust could occur greatly improves the chances that it will be handled safely. This explanation can include tips on storage and transportation, as well as specific information regarding what types of dust accumulation are the most common and which pose the greatest threat. Since the act of merely sweeping a layer of dust from the area surrounding a spilled container can be enough to cause a hazardous situation, it is far better for chemical manufacturers to err on the side of providing too much information than it is for them to assume that workers interacting with a material will automatically be aware of the dangers it poses.
Great post Benjamin. There is a problem in the OSHA Hazard Communication Guidance for
Combustible Dusts. Specifically it is intended to help manufacturers and importers of chemicals recognize the potential for dust explosions and to identify appropriate protective measures as part of their hazard determination under the Hazard Communication Standard (HCS). There is no emphasis on other substances like wood, paper, textiles, etc that is not a chemical
Additionally, once the raw product leaves the initial manufacturer and is used by the end-user in operations such as abrasive blasting, cutting, grinding, polishing or crushing of materials; in addition to conveying, mixing, sifting or screening dry material the particle size changes while being broken down. Thus the explosion severity and ignition sensitivity changes from what it was initially.
What the document should of stated is that the end-user has so conduct an additional hazard evaluation according to the specific process that causes the breakdown of the raw product. This evaluation must include costly lab testing for explosion severity and ignition sensitivity. It’s troubling that the document did not even mention minimum ignition temperature (MIT).
The three main HCS components must be changed to include all stakeholders that handle combustible particulate solids that generate combustible dust. Not just chemical manufacturers and importers. As it stands now, readers of the document will get a false impression whether a hazard exists by solely relying on the MSDS that was developed by the initial manufacturer of the raw product. An accident waiting to happen.
Thank-you for such a thoughtful comment, John. As you have pointed out, it is indeed important for risk managers to perform their own analysis on the hazards posed by the materials that are worked with at their facility, and not rely exclusively on MSDS data.
This is an area of safety that OSHA should perhaps consider exploring to a greater degree – I agree with you that the Combustible Dusts document’s scope is unfortunately limited, which could have unintended safety consequences if it is used as the primary guideline when sculpting a risk analysis policy.
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