Most facilities that are handling/producing combustible dusts are now familiar with the term “Dust Hazard Analysis” or “DHA” and understand that it comes from a standard issued by the National Fire Protection Association (NFPA), nfpa.org. The most referred to standard is NFPA 652 – Standard on the Fundamentals of Combustible Dust. This is the overarching standard that applies to all facilities and serves as a starting point for the commodity-specific dust standards (e.g., 61 for agricultural and food, 664 for wood products, 484 for metals, 654 for general processing). The requirement for all facilities handling and/or generating combustible dusts to conduct a DHA originated from the 2016 edition of NFPA 652. The 2019 edition of this standard did change the deadline for existing operations to have the DHA completed was updated to September 7, 2020 and several of the commodity specific standards made the same updates. However, the 2020 edition of NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities set a different deadline. The deadline for existing food and agricultural facilities to have their DHAs completed is January 1, 2022.
Why would NFPA 61 use a different deadline? This is the only commodity standard that changed the deadline. All other industries kept the September 7, 2020 date. The reason for this deadline comes down to cost and time constraints:
There are more affected food and agricultural facilities under common ownership than in the other standards;
The cost and time to have the DHAs completed for all applicable facilities under one company is greater; and,
The cost for implementing the recommendations for all applicable facilities under one company is greater.
On July 26, 2019, the Environmental Protection Agency (EPA) proposed revisions that would allow an operating facility to be reclassified from a major source of hazardous air pollutants under Section 112 of the Clean Air Act to an area source, thus removing the policy commonly known as “once in, always in”. This revision could take a lot of pressure for capital investments and permitting off of facilities that are eligible.
COMBUSTIBLE DUST SEMINAR | September 19TH | Kansas City, MO
Conversion Technology, Inc. has teamed up with the Fike Corporation and CST to co-host an educational seminar on the ever-growing topic of dust hazards, NFPA Compliance, design approaches and retrofit issues.
Breakfast and lunch will be provided. Immediately following the presentations there will be a LIVE EXPLOSION DEMO!
*Registered attendees who have completed, signed and returned the required forms will be transported to the Fike Corporation remote test site facility for the live demonstration.
Come say hello to Adam Haroz, one of CTI’s Engineering Managers, as he will be speaking at this year’s Region IV VPPPA Conference in Chattanooga, TN on June 19th.
Adam Haroz will be discussing how the regulations governing industrial machinery have shifted the need for conducting risk assessments on robotic systems from a good practice to now a mandatory requirement. The discussion will emphasize the benefits of conducting an on-site risk assessment. It will also highlight the need to identify the hazards and assess the potential risks associated with robot operations when selecting and designing safeguarding measures. He will review the methodology for conducting a risk assessment for different robotic systems, as well as other industrial equipment, how to assess the adequacy of current safeguards, and methods for determining the risk reduction measures required.
The Voluntary Protection Program (VPP) is designed to encourage cooperative efforts between employees, management and OSHA for the purpose of improving workplace safety and health. The VPP concept recognizes that workplace safety and health can be enforced in a compliance atmosphere and can be enhanced in a cooperative atmosphere. OSHA recognizes and partners with worksites that demonstrate excellence in Safety and Health.
Region IV VPPPA is the region that serves the eight Southeast states. (Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee)
It’s a beautiful morning in Phoenix, AZ, where we will soon begin the second draft meeting for NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities. I will be working with the other members of the Technical Committee to address topics such as Dust Hazard Analysis, spray dryer safety, and the ultimate organization of the standard that is set to come out towards the end of this year.
OSHA is now requiring employers to submit OSHA 300A information online.
The Occupational Safety and Health Administration (OSHA) has set up its new Injury Tracking Application (ITA). The online form allows employers to submit the injury and illness information from their completed 2016 OSHA 300A form.
According to the rule, establishments with 250 or more employees must electronically submit data from their OSHA 300, 300A, and 301 forms annually.
Establishments with 20 to 249 employees in industries that OSHA has deemed highly hazardous must submit information from their 300A form annually. (OSHA’s list of highly hazardous industries can be found here).
The data that is submitted, according to OSHA, will be made readily available to the public on OSHA.gov. OSHA’s goal for the transparency in employer injury and illness data is to encourage employers to improve their efforts for preventing occupational injuries and illnesses and to also allow industry groups and researchers to use the disclosed data to advance workplace safety.
The deadline for covered employers to submit their data is December 1, 2017.
See the table below for establishment guidelines and upcoming submission requirements:
To submit your injury and illness information online, go to the ITA page on OSHA’s website here.
With the end of 2016 came many things. Of course we say hello to 2017, but we also start this year with a new President of the United States and many new members of our government. Under President Obama, a number of regulatory initiatives were achieved, including a rule on crystalline silica, an electronic submission of injury/illness data, and an increase in penalties from OSHA citations. The election of now President Donald Trump brings questions of what 2017 will bring for industry, employers, and the occupational safety and health policies and regulations across the board. I will go over what OSHA has published as its plans going forward in 2017, without the unknowns of a new administration. Keep in mind that some items may be moved on aggressively by OSHA before the new administration has time to step in and negate them. Continue reading “What to Expect from OSHA in 2017”→
Assessing risk has always played a vital role in the development and implementation of industrial machinery. Industrial robots, in particular, and other machinery are evolving, and therefore so are the needs and regulatory requirements for the identification and understanding of the risks involved in working with these machines. Thanks to the passage and enforcement of regulations governing the use of industrial machinery by organizations such as the Robotic Industry Association (RIA), Occupational Safety and Health Administration (OSHA), the American National Standards Institute (ANSI), and the International Organization for Standards (ISO), conducting risk assessments on robotic systems and other machinery are not just good practices, they are mandatory.Continue reading “Risk Assessment Methodology for Robots and Other Machines”→