Recently there has been a surge in fires caused by combustible dusts in the workplace. From 1985 to 2005 there were approximately 280 workplace dust explosions throughout the country. In an effort to reduce these incidents, OSHA has implemented a National Emphasis Program (NEP) on combustible dust.

Combustible dust is common and found in many different industries such as food processing, pharmaceuticals, metal processing, textile and agricultural operations.

Some dusts are obviously combustible such as wood and coal or other carbon dusts. Some are not so obvious, like organic dusts such as sugar, soap, and even dried blood. Plastic, biosolid, and textile material dusts also have combustible properties.

In a typical dust explosion event, an initial combustion (known as deflagration) occurs which sends out a shock wave in an area that is confined. The initial combustion usually occurs from a malfunction in a piece of process equipment. Next the shock wave rebounds throughout a confined area and disperses dust that has settled. If the initial deflagration is not contained within the piece of equipment or there are other sources of ignition such as open flames or heated surfaces, a secondary deflagration is initiated and propagates throughout the area. Because the secondary deflagration is confined, it has to find a place to vent from the structure, eventually causing a collapse and residual fires. This entire process from initiation to the final collapse of the structure takes only a stunning 325 milliseconds.

Currently there are no specific standards for combustible dust handling; however, there are many standards that are applicable to operations which create combustible dust hazards. In the event of an OSHA inspection, your housekeeping efforts will be thoroughly reviewed. As a rule of thumb, the NFPA 654 has determined that dust 1/32” thick (roughly the thickness of a paper clip) over at least 5% of an area is the point at which a dust explosion is possible. Regular and frequent clean up will easily mitigate the accumulation of dusts above this action level.

If you have concerns or questions about combustible dust hazards at your facility, we encourage you to contact our office to arrange a consultation. Our consultants will assist you with the procedures for performing a facility dust hazard assessment and control measures. You can visit the following website for more information about combustible dust.

http://www.osha.gov/dsg/combustibledust/index.html

There have been a lot of questions over the past year on Fall Protection Plans and job duties where the plan applies.  Let us look at the type of jobs and residential classes that allow a fall protection plan.

Fall protection requirements for residential construction are set out in 29 CFR 1926.501(b)(13).  In general, that provision requires conventional fall protection for work over 6ft.  However, OSHA instruction STD 3.1 modifies those requirements.  It permits employers engaged in certain residential construction activities to use alternative procedures instead of conventional fall protection.  A fall protection plan does not have to be written and isn’t specific to each jobsite.

There are four groups of residential construction activities for which alternative fall protection plans are available.  Each group has its own set of alternative procedures.  The groups are:

Group 1: Installation of floor joists, floor sheathing, and roof sheathing; erecting exterior walls; setting and bracing roof trusses and rafters.

Group 2: Working on concrete and block foundation walls and related formwork.

Group 3: This group consists of the following activities when performed in attics and on roofs:  installing drywall, insulation, HVAC systems, electrical systems (including alarms, telephone lines, and cable TV), plumbing and carpentry.

Group 4: Roofing work (removal, repair, or installation of weatherproofing roofing materials such as shingles, tile and tar paper).

For any additional information on specific procedures for the different groups and job duties don’t hesitate to give our office a call at 208-426-3283.

HAVE YOUR INJURY AND ILLNESS RATES LEFT YOU TARGETED BY OSHA?

By Olivia Cunningham

In late February, the Occupational Safety and Health Administration (OSHA) sent over 150 letters to businesses in Idaho notifying them that their injury and illness rates are above national averages and that their chances of an OSHA inspection have increased. Industries in Idaho that have made the list include manufacturers of trailers, RVs and manufactured homes; beverage distributors; retail sales; logging and forest products; food suppliers; and elderly care and adult assisted living centers.

Businesses with 10 or more employees are required to maintain OSHA 300 logs. These forms are used to record injuries and illnesses that occur in your work place. Each year the Bureau of Labor Statistics (BLS) randomly selects businesses to turn in their logs and compares their injury and illness rates to national averages. If you are selected to turn in your 300 logs and your rates are higher than the national average, OSHA could place you on a list called the Site Specific Targeting List (SST list). After the list is generated, OSHA will send a letter to notify your business of your elevated injury and illness rate. When you are placed on the SST list, your chance of an OSHA inspection increases. If you would like more information on injury and illness rates for your industry, please follow this link: http://www.bls.gov/iif/oshwc/osh/os/ostb1765.pdf 

You can access the national SST list at this link: http://www.osha.gov/as/opa/foia/hot-14.html. This website contains OSHA Freedom of Information Act requests. A copy of the letters that were distributed to companies making the list can also be found there.

If your SST letter has left you scratching your head and you would like assistance with safety and health compliance, please contact the OSHA Consultation office at (208) 426-3283. The OSHA consultation program will also gladly assist you if you have any questions about how to fill out your OSHA 300 logs.