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January 07, 2010

Safety Alert: Combustible Dust

In late 2009, OSHA released an Advanced Notice of Proposed Rulemaking (ANPR) for combustible dust hazards, investigating regulatory methods of reducing the hazards associated with combustible dust at industrial facilities. In December 2009, stakeholder meetings were held in Washington, D.C. to allow industry’s voice to be heard on the issue. Now OSHA has set January 19, 2010 as the date by which all comments from interested or affected parties need to be submitted. All of these steps point to the fact that OSHA continues to progress in the rulemaking process, and the completion of formal regulations is not far away.

Even though this rulemaking process is incomplete, OSHA is already taking enforcement steps based on the Combustible Dust National Emphasis Program (NEP), which was reissued in March 2008 and is concerned with facilities at which combustible dust is likely to pose a hazard. OSHA officials are currently performing inspections to enforce this NEP, and nationally nearly 4,000 violations have already been issued during over 800 inspections. Therefore, industrial facilities do not have the option of passively waiting until OSHA rulemaking is finalized to take steps toward compliance. To ensure facility safety, as well as avoid costly fines, facilities should work to identify and eliminate combustible dust hazards as soon as possible.

Combustible dust, according to OSHA, is often either organic or metal dust that is finely ground into very small particles and presents a fire or explosion hazard when suspended in air. These dusts exist in a wide variety of industries, and a number of factors must be evaluated to determine a dust’s combustibility, including particle size, shape, and moisture content.

CTI is available to assist your facility in evaluating and mitigating hazards associated with combustible dust.

Posted by Brian Edwards at 11:30 AM |

Greenhouse Gas Reporting News Alert

A new year often brings new concerns for industries, as new laws and requirements often take effect at the change of the calendar. January 1, 2010 ushered in the EPA’s new Greenhouse Gas Reporting requirements which directly affect a large number of industrial facilities.

These new rules make mandatory the monitoring and reporting of greenhouse gas (GHG) emissions from facilities which exceed the threshold amount of 25,000 metric tons/year of CO2 equivalent. While greenhouse gas emitters are not required at this point to control their GHG emissions, sources which surpass the threshold level must begin monitoring immediately for the 2010 calendar year. Industries which are impacted include any general stationary fuel combustion sources which have a facility-wide heat input capacity of 30 MM Btu/hr, various industrial and chemical producers, fossil fuel and industrial gas suppliers, and electric generation facilities.

The first GHG reports are not due to EPA until 2011, but waiting to comply with these new regulations is not an option. A written GHG monitoring plan must be in place for all affected facilities by April 1, 2010. A few special provisions may apply for some facilities, but any extension requests to this April 1 deadline must be submitted by the end of January 2010. It is imperative, then, that industrial facilities immediately focus attention on calculating their greenhouse gas emissions and ensuring that appropriate monitoring equipment is in place and functioning, according to the proper methodologies established by the rule. These new regulations have caused a great deal of concern across industries, leaving many executives and managers uncertain whether their facility exceeds the GHG threshold and the steps to take if they do. Conversion Technology, Inc. (CTI) is prepared to assist your facility in determining exactly how these new greenhouse gas regulations apply to your facility, including calculating your total GHG emissions, as well as helping to discern and perform the steps that need to be taken to ensure compliance.

 

 

Posted by Brian Edwards at 11:22 AM |


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