OSHA Responds to CSB on Explosive Dusts

Shawn Boone was only 33 years old in 2003 when he was fatally burned from several violent explosions at the Hayes Lemmerz plant in Huntington, Indiana.  The plant manufactured cast aluminum automotive wheels.  These firey blasts, which also severely burned two other workers, were fueled by aluminum dust which had accumulated in the plant.  That same year, chemical dust-fueled explosions at CTA Acoustics in Corbin, Kentucky and at West Pharmaceuticals in Kinston, NC took the lives of 13 workers and injured dozens of others.  The death toll from these workplace disasters compelled the U.S. Chemical Safety and Hazard Investigation Board (CSB) to launched a study of dust fires and explosions in U.S. industries, and make a series of recommendations in November 2006 to prevent them. 

On October 19, OSHA responded, in part, to the CSB's recommendations by issuing formal instructions to OSHA managers and inspectors on conducting inspections in facilities where combustible dust hazards may exist.

As the instruction notes:

"...a chemical dust deflagration occurs when the right concentration of finely divided chemical dust suspended in air is exposed to a sufficient source of ignition to cause ignition (combustion) of the dust.  If the deflagration is in a confined area, an explosion potential exists.  These materials can also cause other fires.  ...Types of dust include, but ar not limited to: metal dust such as aluminum and magnesium; wood dust; plastic dust; biosolids; organic dust, such as sugar, paper, soap, and dried blood; and dust from certain textiles."

OSHA's news release announcing the new instruction describes a "national emphasis program" focusing on fire and explosion hazards.  When the CSB made issued its recommendations late last year to OSHA, it described five specific tasks, including a "special emphasis program" to identify the industries at risk of the combustible dust hazards for targeted inspections.  The other CSB recommendations are still "Open, and Awaiting Response or Evaluation or Approval of Response," according to the CSB's website.  The four remaining recommendations are:

• "Issue a standard designed to prevent combustible dust fires and explosions in general industry. Base the standard on current National Fire Protection Association (NFPA) dust explosion standards (including NFPA 654 and NFPA 484), and include at least hazard assessment, engineering controls, housekeeping, building design, explosion protection, operating procedures, and worker training."
• Revise the Hazard Communication Standard to clarify that it covers combustible dust.
• "Require Material Safety Data Sheets (MSDSs) to include the hazards and physical properties of combustible dusts, as well as clear information on safe handling practices and references to relevant consensus standards."
• "Communicate to the United Nations Economic Commission for Europe the need to amend the Globally Harmonized System to address combustible dust hazards by defining combustible dusts; specifying the hazards that must be addressed in chemical information sheets, and addressing the physical properties that must be included on a chemical information sheet pertinent to combustible dusts."
• "Provide training through the OSHA Training Institute on recognizing and preventing combustible dust explosions."

According to ICIS News, Daniel Horowitz of the CSB said, "Weâre certainly pleased that OSHA is paying increased attention to this area of deadly accidents. We certainly are going to study the OSHA action closely."

Tammy Miser of United Support and Memorial for Workplace Fatalities, and the sister of the late Shawn Boone, was less willing to give OSHA a lot of credit for simply sending an "instruction" to its inspectors, rather than issuing a more protective regulation to protect workers from these explosion hazards.  [How many inspections will OSHA conduct anyway?]   Tammy says:

The CSB has fought long and hard to gain regulation for combustible dust with no real response from OSHA.  ...The CSB has been a hero of sorts to families who have had a loss due to combustible dusts.

She feels so strongly about the need for a regulation because of her brother's death from a combustible dust explosion. 

My brother Shawn was directly in front of the furnace during the first blast at Hayes Lemmerz and not much further during the second which was much more intense. Believe it or not he was a tough cookie and survived only later to be taken off of life support. His internal organs were burnt beyond repair, his eye sight was gone and his limbs damaged beyond repair. There were several reports as to how much of his body was burned and it ranged from 95-98% which at that point it really doesn't matter because much of it was 3rd degree burns.

Besides taking Shawn off of life support the most reoccurring image was of the priest who spoke to us and visited the burn unit on a regular basis he stated, "I am sorry sorry, I have really never seen anything quit this bad since the war so prepare yourself before you go in."  This was the second warning I had received before walking in and seeing him.  But there is no preparing to see a loved one in that position.  ...It is haunting experience that reoccurs and never gets less painful, never fades and no one should have to endure. No family should have to deal with this and no person should have to die in this manner just to make a living.