Dust Explosion Consultants Leader CV Technology Participates in OSHA Stakeholder Meeting on Proposed Combustible Dust Standard

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In an effort to develop a national combustible dust standard for OSHA, international dust explosion protection leader, CV Technology Vice President, Bill Stevenson actively participated in OSHA’s most recent stakeholder meeting. His statements outlined some top considerations for OSHA’s effort as well as pledge the support of CV Technology.

OSHA, this week, held a Stakeholder Meeting to elicit input from qualified individuals as a formative step toward developing their own national combustible dust standard. CV Technology, Inc., a leader in dust explosion prevention and mitigation, participated in the meeting. Bill Stevenson, VP Engineering, a recognized authority on dust explosions applauded OSHA for this program and pledged the support of CV Technology to help OSHA in any way. Here is Bill’s opening statement:

1.     Time is of the essence. How long would it take to develop and promulgate a comprehensive new standard?
2.    The dust explosion phenomenon is an inexact science. How would the new standard be updated at reasonable intervals to reflect on-going research?
3.    Different industry segments face different challenges and the solutions required should reflect the unique requirements of each segment. How will the OSHA standard address this difference factor? Perhaps the HSE booklet for the food processing industry could provide a useful example of how a similar government agency is dealing with this issue?
4.    The area of dust testing is undergoing review and scrutiny at the moment. For example the OSHA Salt Lake Test is being given serious consideration by the ASTM E 1226 committee. But the jury is still out on adopting this or alternative screening methodologies. Just in the past few weeks I learned of an OSHA audit at a plant which had a dust explosion approximately 3 years ago. Dust was collected and screened at Salt Lake and the results came back negative. The dusts were known combustible dusts such as sugar, cocoa, whey, and coffee creamer. This puts into question the validity of alternative screening procedures that might provide a false sense of security. This story further points out the need to first acknowledge that we don’t know everything about dust explosions, and second to make provision for the inevitable change which must accompany any new standard.
5.    Another alternative screening methodology involves using a 1-m3 test vessel for dusts which do react in a Kuhner 20-liter sphere, but which do not do so in the larger vessel. Are these dusts a risk or not? I don’t know and would posit that here is yet another example of the limits of our current understanding. The standard should include provision for an expanding field of science as further scientific experimentation provides new insights.
6.    A new and far more comprehensive NFPA 654, 2011 edition is being voted on by the technical committee with the deadline being today. If all goes well this new Standard will be published mid-2010. OSHA has taken an active interest in this Standard and has had representation in attendance at some of our meetings. It is my strong recommendation that 654 be the NFPA Standard which OSHA should look to first as you try to come up with your own Standard. Since NFPA has the objective of refreshing all Standards on a 4 year cycle, 654 and similar documents should continue to be key references in any new OSHA combustible dust standard.
7.    Finally, I would like suggest that the current PSM program could be effectively expanded to include combustible dust. By using the same 14 point program OSHA could very quickly provide a meaningful and comprehensive methodology for both the short and long term requirement to ensure work place safety for industries handling combustible particulate solids.

Points made by other participants included concerns about cost, the impact on workers, how best to address small businesses, should there be different requirements for businesses with less than 50 employees, and what role will there be for consensus standards in the future. Several participants raised concerns about dust and how to determine if any given dust is combustible. Also there seemed to be a general concern that the current NFPA system of relying on several standards which interrelate can sometimes seem to conflict and are often awkward and confusing to use. Small business owners and even larger ones often don’t know what to do or even how to do it. There was a sentiment expressed that there is a need to simplify and put in plain language what the issues are and to provide a straight forward path to follow. The risk from dust collectors was explained by Bill Stevenson and the need for better housekeeping was raised and discussed by several participants.

Since dust explosions are rare, complex, and the issues vary from industry to industry, the desire for simplicity might be wishful thinking. For every complex problem there is a simple solution and it is generally wrong. To understand the risks and your available options, a thorough dust explosion risk analysis will help assign priorities for protection, and most importantly, help to ensure a safe work place. CV Technology Inc. is devoted 100% to the dust explosion problem. Bill Stevenson is a member of the technical committees that are responsible for NFPA 654, 655, 91, 68 and 69.

For more information: http://www.cvtechnology.com

CV TECHNOLOGY, INC
15852 Mercantile Court
Jupiter, FL 33478
USA

Phone (561) 694-9588
http://www.cvtechnology.com

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