Today, during the Technical Meeting at NFPA’s 2015 Annual Conference, there were two certified motions up for a vote related to the new NFPA Standard on Fundamentals of Combustible Dust – NFPA 652.  One motion was to remove the requirement for a Dust Hazard Analysis, and the other was to delay the issuance of the Standard completely.  Both motions were defeated by an overwhelming majority of the NFPA voting members, including myself. These votes were the last hurdle in the issuance of the Standard later this year.

NFPA 652 is the first step in developing a single, overarching standard to deal with fire and explosion hazards associated with combustible dust of all types and in all industries.  Currently, there are several industry and commodity specific standards, such as NFPA 61 for agricultural dust and 664 for wood dust, that often lack consistency, leading to confusion among users, authorities having jurisdiction (e.g. OSHA), and safety professionals. The development of NFPA 652 intends to alleviate some of the confusion … eventually. Over the coming months, CTI will be writing articles, providing presentations at conferences and online, and consulting our clients with the specifics of the standard.  If you are interested in staying in touch with these developments and other news, please email cti@conversiontechnology.com and ask to be included on our Newsletter list.

When dealing with processes involving combustible dust, flammable liquids & gasses, and extremely toxic materials, understanding the hazards in the process is critical. This is true when designing a new process, as well as when a plant changes equipment, chemicals, and procedures. Many of the most severe industrial accidents have occurred because the facility failed to consider how changes would impact process safety. That is why a robust management of change (MOC) procedure that incorporates process hazard analysis (PHA) is so important. Continue reading “The Importance of Management of Change and Hazard Analysis”

Flame resistant clothing (FRC) has been used for years in a number of industries to protect workers from flash fires, arc flash, embers, molten metal, and other potential sources of ignition to clothing.  The reason FRC is so important is that many fatalities have occurred because a worker’s clothing has caught on fire, exposing him/her to burning heat for a much longer time than would have occurred during the initial event (e.g. arc flash, vapor flash fire).  Continue reading “Conversion Technology engineers to wear FRC when conducting Combustible Dust Hazard Analysis”

Over the Summer of 2012, Brian Edwards, PE, Director of Engineering for CTI, had the opportunity to speak at 5 regional conferences of the OSHA Voluntary Protection Program Participants Association (VPPPA), as well as the 2012 National VPPPA conference.   Video from the Region 4 conference in Chattanooga, TN has been posted on Youtube.

[embedyt]http://www.youtube.com/watch?v=PFi-RwNLkLM[/embedyt]

Please check out the presentation here:  http://www.youtube.com/watch?v=PFi-RwNLkLM

I will be speaking on Combustible Dust Safety at the following conferences:

  • Region 8 VPPPA 2012 Conference (May 2-3 @ Greenwood Village, Colorado) – website
  • Region 7 VPPPA 2012 Conference (May 8-9 @ Des Moines, Iowa) – website
  • Region 6 VPPPA 2012 Conference (May 17-18 @ Fort Worth, Texas) – website
  • Region 1 VPPPA 2012 Conference (June 11-13 @ Killington, Vermont) – website
  • Region 4 VPPPA 2012 Conference (June 19-21 @ Chattanooga, Tennessee) – website
  • 28th Annual National VPPPA Conference (August 20-23 @ Anaheim, California) – website

I spoke to an OSHA rulemaker who is working on the long-storied Combustible Dust Safety Rule that has been in the works for over 2 years now (Link to CTI’s Blog on the ANPR).  The latest news I was told is that the proposed rule is scheduled to move to a Small Business Regulatory Enforcement Fairness Act (SBREFA) review panel in December of 2011.    

Continue reading “OSHA Combustible Dust Rule Moving Forward”

As I have reported here on the CTI’s blog in the past, the Georgia Industrial General Permit for Storm Water Discharges (GAR0500000) is in the process of being reissued.  The format and requirements of the permit will be significantly modified, requiring facilities to update their Storm Water Pollution Prevention Plans (SWP3) and conduct additional actions required to comply with the new permit.

Continue reading “No Additional Hearings Likely for GA Storm Water Permit”

On May 13, 2011, OSHA held an Expert Forum on Combustible Dust to discuss possible options for developing a comprehensive rule to address the hazards associated with combustible dust.  OSHA’s stated intent was to both protect employees and be cost-effective for employers. The major topics for discussion included: Scope; Focus on Preventing Secondary Explosions; Existing Facilities; and Multiple Layers of Protection. The meeting was divided into these four topics for discussion, and OSHA posed questions from each to the panel of experts. Below are the highlights from the meeting.

Continue reading “Summary of OSHA Combustible Dust Forum”