Jason Reason. NFPA Technical Committees

Similar documents
3/20/2017. The Impact & Implications of NFPA 652 NFPA s Newest Combustible Dust Standard. Jason Reason. Jason Reason

Dust Hazard Assessments

Conducting a NFPA 652 Dust Hazard Analysis (DHA): Practical Tips & Approaches

PRIMATECH WHITE PAPER PROCEDURE FOR DUST HAZARD ANALYSIS (DHA)

Understanding. Combustible Dust Hazards: Basic Measures to Ensure the Safety of Combustible Dust Handling Operations

Combustible Dust Hazard Recognition and Control NFPA Standards for Combustible Dusts

Objectives. NFPA Dust Specific Documents. Combustible Dust Process Hazard Safety Overview of NFPA Standards for Combustible Dusts

Leading Trends in Chemical Processing

Dust Explosions. health & environmental sciences failure analysis & prevention

Combustible Dust Hazards- Awareness

Managing Combustible Dust

Aluminum Dust Management in a Metallizing Facility

Industrial Explosion Suppression Technology

COMBUSTIBLE DUST SAFETY PROGRAM

With CV Technology products and care, you ll be better protected from dust explosions.

Implementing a Combustible Dust Program. Presented by: Nick Miedema Amway EH&S For: Michigan Safety Conference

Combustible Dust 101: Understanding Combustible Dust Hazards

COMBUSTIBLE DUST HAZARD MITIGATION

Combustible Dust Resources OVERVIEW OF COMBUSTIBLE DUST. What is Combustible Dust? Where are Combustible Dusts found?

GEAPS Great Lakes Regional Conference 2017 Explosion Protection Overview & Market Drivers. April 6, 2017

Prevention of Fires and Explosions in Wood Pellet Facilities. Allen Wagoner, FLAMEX, Inc.

Preventing and Mitigating Combustible Dust Fires and Explosions

Another Means of Worksite Analysis NFPA 652 s Standard on Dust Hazard Analysis (DHA)

Protecting Facilities Against Explosions. Since 1956

WHITE PAPER Dust Hazard Analysis for Simple Dust Collection Systems

Combustible Dust Issues

Plant Issues in an NFPA 652 Dust Hazard Analysis

A Global Leader in Explosion Protection

GHS Dust Explosion Guidance. ANNEX 11 Guidance on other hazards not resulting in classification. September 2017

Protecting Critical Facilities Against Explosions

Guide - Basic Information

Combustible Dust Booklet

ADDITIONS TO NFPA 61, STANDARD FOR THE PREVENTION OF FIRES AND DUST EXPLOSIONS IN THE AGRICULTURAL AND FOOD PROCESSING INDUSTRIES

Property risk solutions

NFPA Overview. International Titanium 2014 Conference Chicago Kevin L. Kreitman

COMBUSTIBLE DUST HAZARD RECOGNITION

National Fire Protection Association. 1 Batterymarch Park, Quincy, MA Phone: Fax:

Before proceeding with the selection process, let s briefly look at the various explosion protection options:

Combustible Dust with FR Clothing June Service Experience Trust Quality Flexibility

Industrial Dust Explosions Causes & Case Studies. Presented by Geof Brazier at Expocorma, Concepcion, Chile 10th November 2017

Dust Explosion Hazard Overview

DUST EXPLOSION CODES AND STANDARDS: Ensuring Regional Compliance and Global Consistency

Identifying and Preventing Dust Fire and Explosion Hazards

Combustible Dust Awareness. David McEwan Business Line Manager Configured Products

This Second Correlating Revision effects correct usage. This also addresses one of the Affirmative Comments to Second Revision No. 28.

There are always options in the management of explosion risks!

The element is closed at one end and open at the other, and it s bolted onto the explosion vent opening on the equipment so that its open end overlaps

Combustible Wood Dust Management Program Development Guide


Rob Marvin Corporate Safety & Health Engineer April 23, 2009

OSHA - Enforcement Define the terminology Recognize a Dust Explosion hazard Learn hazard management methods

Special Occupancy Requirements

APPLICATION PROFILE EXPLOSIONS IN CEMENT PLANTS EXPLOSIONS IN CEMENT PLANTS CEMENT PLANT EQUIPMENT WITH HIGHEST EXPLOSION POTENTIAL. Form No.

Combustible Dust Hazards: Awareness & Safeguarding. Forest Industry Task Force on Mill Safety May 2012

Progressive Safety Services LLC 1

IECEx Certification of Dust Collection System Assembly. IECEx 2018 International Conference Split, Croatia 23 rd April 2018

M E M O R A N D U M. NFPA Technical Committee on Wood and Cellulosic Materials Processing

found" condition, you would need to request testing of your samples in that form rather than have them altered per the ASTM procedures.

BUILDING/FIRE CODE REFERENCES 2006 EDITION

Hoeganaes Corporation Iron Dust Flash Fires and Hydrogen Explosion

CPL Combustible Dust National Emphasis Program (Reissued)

Page 1 of /11/2016 2:36 PM. First Revision No. 30-NFPA [ Global Input ] Submitter Information Verification. Committee Statement

COMBUSTIBLE DUST AN EXPLOSIVE ISSUE NFPA 654

DEFLAGRATION FIRE MARSHAL PMAX WOOD

M E M O R A N D U M. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action.

NFPA 33 Standard for Spray Applica4on Using Flammable or Combus4ble Materials

Fire Prevention Plan Program

International Symposium. OSHA Combustible Dust NEP Inadequacies. John Astad

Introduction. Program Description. Section C.20 University of South Carolina Safety Program Guide FLAMMABLE AND COMBUSTIBLE LIQUIDS

We ve all heard about catastrophic combustible

Flameless Venting The New Technology for Safe Indoor Explosion Venting

Tampa, FL Fire Cause Classification Task Group Tue, 14 April 2011

Our Statement is not a problem - we are encouraging continuation of the standard as it is written without substantive changes.

NFPA Mexico Fire Expo April 20, Learning Objectives. Combustible Dust Explosions History

Fire Safety Plan (FSP) Review Checklist 1

Savard Labor & Marine Staffing, Inc. Fire Prevention Program Rev3/14

Soot Mitigation Strategies

THE PACESETTER IN EXPLOSION SAFETY INNOVATION EXPLOSION PROTECTION SOLUTIONS YOU CAN COUNT ON WORLDWIDE.

Combustible Dust Hazards- Awareness

HOW TO CHOOSE THE RIGHT PROTECTION FOR FIRES, FLASH FIRES & ARC FLASHES

INTRODUCTION TO DUSTS AND THEIR EXPLOSIVE PROPERTIES

1NFPA 68 has changed from a guideline to a

DUST COLLECTION TRAINING. Revision 2013

How to a Use Process Hazard Analysis (PHA) to Reduce Combustible Dust Explosion Risk

INVESTIGATION REPORT COMBUSTIBLE DUST HAZARD STUDY KEY ISSUES: U.S. CHEMICAL S AFETY AND H AZARD INVESTIGATION BOARD FEDERAL REGULATIONS

First Revision No. 1-NFPA [ Chapter 2 ]

Safety Considerations for Hydrogen Installations

PART 2. Basic Code Requirements - Semiconductor & Microelectronic Facilities using HPM s

Fire Safety Plan (FSP) Review Checklist 1

Essentials of Fire Fighting 6 th Edition Firefighter I

COMBUSTIBLE DUST HAZARD RECOGNITION

Re: Request for Comments on Advance Notice of Proposed Rulemaking on Issues Related to the Hazards of Combustible Dust in the Workplace

Second Revision No. 14-NFPA [ Global Comment ] Submitter Information Verification. Committee Statement 8/25/ :39 AM

First Revision No. 15-NFPA [ Chapter 2 ]

SEF Presents: Common Questions for a Chemical Safety Program. Wednesday September 20, 2017

Flammable Liquid Storage

OUTDOOR INSTALL NO RETURN AIR SINGLE MODULE COLLECTORS OUTDOOR INSTALL WITH RETURN AIR SINGLE MODULE COLLECTORS

Key Elements: Implementing a Combustible Dust Program Build Organizational Ownership? Building Organizational Ownership?

NEW ENERGY IN THE BATTERY INFRASTRUCTURE

Transcription:

Jason Reason Education & Certifications B.S. Industrial Hygiene Purdue University MBA University of Indianapolis CIH, CSP, CHMM Experience 12.5 years as OSHA Compliance Officer Performed over 50 combustible dust inspections Assisted Federal OSHA & State Plan OSHAs on numerous combustible dust inspections and issues Instructor for OSHA Combustible Dust Course at OTI

Jason Reason NFPA Technical Committees Chair of Committee for Wood & Cellulosic Materials (NFPA 664) Principle Member of Committee for Handling & Conveying of Dusts, Vapors and Gases (NFPA 91, 654 & 655) Principle Member of Committee for Fundamentals of Combustible Dusts (NFPA 652) Principle Member of Flash Fire Protective Garment Committee (NFPA 2112 & 2113) Member of Correlating Committee for Combustible Dusts (Over all NFPA combustible dust committees)

Overview Hazard Identification Dust Explosion History Definition & Description of Combustible Dusts Hazards Associated with Combustible Dusts Combustible Dust Testing Combustible Dust Standards Hazard Assessment Dust Hazard Analysis (DHA)

Overview Hazard Mitigation and Prevention Engineering Controls Explosion Protection Systems Electrical Area Classification Administrative Controls Housekeeping Cleaning Methods

A HUGE Problem Between 1982 and 2007, there were 281 dust fires and explosions Between 2009 and 2013, there were 57 dust fire and explosions

Paarl Print Factory (South Africa)

FM Global Loss Data by Industry 4% 3% 3% 8% 7% 39% Woodworking Food Metals 11% Chemical/Pharmaceutical Paper/Pulp 16% Utility Rubber Plastics

FM Global Loss Data by Dust Group 2% 8% 8% 5% 42% Wood Food 9% Chemical Metal 10% 15% Coal Plastic/Rubber/Resin Paper Various

Key Factors Contributing to Incidents Dust collectors were inadequately designed or maintained to minimize explosions (> 40% of incidents Process changes were made without adequately reviewing them for the introduction of new potential hazards Outside parties inspecting the facilities failed to identify dust explosion hazards: Government enforcement Insurance underwriters Health and safety professionals

11 Combustible Dust Inspections (Federal OSHA) October 1, 2007 March 31, 2015

her-than-serious Serious Willful Repeat Failure to Abate Number of OSHA Citations 18,000 16,000 14,000 12,000 10,000 8,000 6,000 4,000 2,000 0 4,169 16,774 400 459 8

Other-than-Serious Serious Willful Repeat Failure to Abate Current Penalties Under The NEP $25,000,000.00 Total Penalty $20,000,000.00 $20,113,955.53 $15,000,000.00 $13,827,861.00 $10,000,000.00 $5,000,000.00 $843,674.55 $2,836,011.00 $114,290.00 $-

Types of Industries Inspected by OSHA 5% 14% 24% Woodworking Food Products 6% 7% 8% 10% 10% 16% Plastics & Rubber Paper Manufacturing Chemical Manufacturing Furniture & Fixtures Primary Metals Equipment Manufacturing Other

How Do Combustible Dust Fires and Explosions Occur?

Combustible Dust A finely divided combustible particulate solid that presents a flash fire hazard or explosion hazard when suspended in air or the process-specific oxidizing medium over a range of concentrations Plastic Dust 99% 420 μm K st = 340 b.m/s Corn Starch Dust 100% 420 μm K st = 144 b.m/s 16

Combustible Particulate Solid Any solid material composed of distinct particles or pieces, regardless of size, shape, or chemical composition that, when processed, stored, or handled in the facility, has the potential to produce a combustible dust Includes dusts, fibers, fines, chips, chunks, flakes, or mixtures of these

Dust Explosion Pentagon Confinement Fuel Dispersion Ignition Oxygen

Sources of Ignition

Combustible Dust Hazards Flash Fire Fire that spreads by means of a flame front rapidly through a diffuse fuel without the production of damaging pressure Deflagration Propagation of a combustion zone at a velocity that is less than the speed of sound in the unreacted medium Explosion Bursting or rupturing of an enclosure or a container due to the development of internal pressure from a deflagration

The Typical Explosion Event Initial Internal Deflagration Process Equipment 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

The Typical Explosion Event Initial Internal Deflagration Shock Wave Process Equipment 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

The Typical Explosion Event Initial Internal Deflagration Elastic Rebound Shock Waves Process Equipment 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

The Typical Explosion Event Initial Internal Deflagration Dust clouds caused by Elastic Rebound Process Equipment 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

The Typical Explosion Event Containment Failure from Initial Deflagration Dust Clouds Caused by Elastic Rebound Process Equipment 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

The Typical Explosion Event Dust Clouds Caused by Elastic Rebound Process Equipment Secondary Deflagration Initiated 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

The Typical Explosion Event Process Equipment Secondary Deflagration Propagates through Interior 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

The Typical Explosion Event Process Equipment Secondary Deflagration Vents from Structure 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

The Typical Explosion Event Secondary Deflagration Causes Collapse and Residual Fires 0 25 50 75 100 125 150 175 200 225 250 300 325 Time, msec.

Make-Up (Return) Air System

Spark/Ember Infrared Detectors

Combustible Dust Standards

Relevant OSHA Standards for Combustible Dust 1910.22 Housekeeping 1910.36 Design and Construction for Exit Routes 1910.37 Safeguards and Features for Exit Routes 1910.38 Emergency Action Plans 1910.39 Fire Prevention Plans 1910.94 Ventilation 1910.119 Process Safety Management 1910.132 Personal Protective Equipment 1910.145 Specifications for Accident Prevention Signs and Tags 1910.146 Permit-Required Confined Spaces 1910.157 Fire Extinguishers 1910.165 Employee Alarm Systems 1910.176 Material Handling 1910.178 Powered Industrial Trucks 1910.252 Hot Work (General Requirements) 1910.261 Pulp, Paper, and Paperboard Mills 1910.272 Grain Handling Facilities 1910.307 Hazardous Locations 1910.1200 HazCom 38

Industry or Commodity-Specific NFPA Standards Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities Standard for Combustible Metals Standard for the Prevention of Fires and Dust Explosions in Wood Processing and Woodworking Facilities Standard for the Prevention of Fires and Dust Explosions from Manufacturing, Processing and Handling of Combustible Particular Solids

Standard on Fundamentals of Combustible Dusts (NFPA 652-2016) Effective Date September 7, 2015 Coexists with other NFPA industry specific standards Simplifies OSHA compliance and enforcement Provides the basic principles of and requirements for identifying and managing the fire and explosion hazards of combustible dusts and particulate solids

Retroactivity of NFPA Standards Where specified, provisions of the standards are retroactive For major replacement or renovation of existing facilities, all provisions of standards apply Where AHJ determines that the existing situation presents an unacceptable degree of risk, AHJ shall be permitted to apply retroactively ANY portions of standards deemed appropriate

2015 International Fire Code (IFC) 2204.1 The fire code official is authorized to enforce applicable provisions of the codes and standards listed in Table 2204.1 to prevent and control dust explosions. NFPA 61 NFPA 69 NFPA 484 NFPA 654 NFPA 655 NFPA 664

Uniform Fire Code (NFPA 1-2015) Equipment, processes, and operations that involve the manufacture, processing, blending, repackaging, or handling of combustible particulate solids or combustible dusts regardless of concentration or particle size shall be installed and maintained in accordance with this chapter and the following standards as applicable: NFPA 61-2013 NFPA 68-2013 NFPA 69-2014 NFPA 484-2015 NFPA 654-2013 NFPA 664-2012

The Magic Formula Identify Your Hazard Define the Scope of the Hazard in Your Process Identify Controls Identify Resources Commissioning & Documentation Sustain Performance

Step 1: Identify Your Hazard

Developing A Sampling Strategy Do you have every dust tested? What about if you have multiple dusts that may and may not mix? Do you test the dust buildup on surfaces, floor areas, or both? Do you test as received or prepared by sizing? Do you test at different stages of a process or at one location?

Importance of Test(s) Hierarchy of Combustible Dust Testing K st, P max, Particle Size MEC, MIE, MIT, LIT LOC, Charge Relaxation, Resistivity, Chargeability Specificity of Hazard

Step 2: Define the Scope of the Hazard in Your Process

Dust Hazard Analysis (DHA) Systematic review to identify and evaluate the potential fire, flash fire, and explosion hazards associated with the presence of one or more combustible particulate solids in a process or facility Determine the consequences of what could go wrong and to determine what safeguards could be implemented to prevent or mitigate those consequences Does not need to comply with the PHA requirements contained in OSHA s PSM Standard

DHA Methodology Identifies and evaluates the process or facility areas to determine if fire, flash fire, and explosion hazards exist Where such a hazard exists, identify and evaluate specific fire and deflagration scenarios: a. Identification of safe operating ranges b. Identification of the safeguards that are in place to manage fire, deflagration, and explosion events c. Recommendation of additional safeguards where warranted, including a plan for

DHA Methodology What s Normal? What Can Go Wrong? How Bad is Bad? What Protection Currently Exists? What Additional Protection is Needed?

DHA General Requirements The owner/operator of a facility where materials that have been determined to be combustible or explosible are present in an enclosure shall be responsible to ensure a DHA is completed Requirement applied retroactively Must be performed by a qualified person Absence of previous incidents cannot be used as the basis for not performing a DHA

Timeline to Complete DHAs For existing processes and facility compartments that are undergoing material modification, the owner/operator shall complete DHAs as part of the project For existing processes and facility compartments that are not undergoing material modification, the owner/operator shall schedule and complete DHAs of existing processes and facility compartments within a 3-year period from the effective date of the standard

Step 3: Identify Controls

Identify Controls to Minimize Hazards Use Information from DHA & Applicable Content from Consensus Standards to: Develop a Basis of Design (BOD) Overall process Individual aspects of the process Include in BOD Facility design concepts Equipment design concepts Electrical classification concepts (NFPA 499) Explosion & Fire Protection/Prevention (NFPA 68, 69) Administrative Controls/Processes

Risk Mitigation Controls Engineering Administrative Venting & Suppression Housekeeping Explosion Isolation Electrical Area Classification

EXAMPLES OF ENGINEERING CONTROLS

Explosion Protection Systems (Section 8.9.3.2 of NFPA 652-2016) Passive Deflagration Venting Deflagration Pressure Containment Deflagration Venting Through a Listed Dust Retention and Flame- Arresting Device Active Oxidant Concentration Reduction Deflagration Suppression Systems Dilution with a Noncombustible Dust

Explosions by Type of Process Equipment 6% 4% 4% 4% Dust Collector 7% 7% 53% Pulverizer/Mils Conveyor/Elevator Dryer/Oven 15% Silo/Bin Sander Electrostatic Precipitator Grinder

Suppression vs. Venting Equipment indoors & vent duct not practical Not enough vent area on equipment High K st or hybrid dust No safe place to vent Toxic dusts cannot be discharged to atmosphere via a vent Flame propagation through interconnection suppression on equipment - isolation suppression controlled by same controls

EXAMPLES OF ADMINISTRATIVE CONTROLS

The Truth About Housekeeping Good housekeeping alone WILL NOT prevent a fire or explosion, as well as injuries or fatalities Large dust accumulations are a secondary explosion hazard Cleaning methods associated with housekeeping can actually introduce significant hazards 66

HOW MUCH DUST IS TOO MUCH DUST???

Housekeeping Memorandum Issued on April 21, 2015 Provides guidance in calculating the levels of dust accumulations that may be allowed at workplaces for combustible dusts with bulk densities less than 75 lb/ft 3 Supplements the dust accumulation guidance provided in several sections of NEP, including IX.E.3.c and d; IX.E.8; and IX.E.9.c and d Very low bulk density materials, such as tissue paper dust, may not create a deflagration hazard even at an accumulation level of ¼ inch, covering over five percent of the floor area or 1000 ft 2, whichever is less https://www.osha.gov/dep/enforcement/combustible_ Dusts_04212015.html

72

Poor Housekeeping Can Affect Electrical Classification Emergency Egress Requirements Selection of Powered Industrial Trucks Use of Flame- Resistant Clothing

Step 4: Identify Resources to Execute Your Plan

Resources Internal External Operations Consulting Firms EHS Regulatory Authorities Engineering Insurance Reps Maintenance NFPA QA US Chemical Safety Board Procurement

Step 5: Commissioning & Documentation

Document EVERYTHING Dust Testing Data PHA (Review Every 5 Years) Basis of Design Facility Explosion Protection Administrative Controls Commissioning Documents Explosion Suppression & Isolation Systems Training Records Names & Qualifications of Resources Used

Step 6: Sustain Performance

Safety Program Integration Hazardous Energy/LOTO Fire Protection Hot Work Walking/Working Surfaces Combustible Dust Powered Industrial Truck PPE HazCom 82

Environmental Implications Loss of Building Containment Soil & Groundwater Contamination Emissions from Combustion By-Products Disturbance of Asbestos Containing Materials Permitting for Dust Collectors Firing Element for Chemical Suppression Tier II Reporting By-Products of Fighting Fires

Hazard Recognition Testing Dust Hazard Analysis Engineering Controls Administrative Controls Hazard Mitigation

Questions??? jreason@lewellyn.com 317-786-3561