No Nonsense Approach to Addressing the Combustible Dust Hazard

February 7, 2008, was the pivotal point where recognizing the severity of dust hazards was pushed to the forefront of industry concerns. This was the date that a huge explosion occurred at the Imperial Sugar refinery in Savannah, Georgia. There were 14 deaths and 38 injuries, including an additional 14 serious burns. Even though this was widely publicized, and many actions have occurred since this, many still struggle with execution to ensure the dust explosion hazard is controlled 16 years after this catastrophic event. The “Inferno: Dust Explosion at Imperial” video by the U.S. Chemical Safety and Hazard Investigation Board can be viewed at [https://www.youtube.com/watch?v=Jg7mLSG-Yws] [8]. Watch this video to learn valuable lessons about combustible dust hazards and how to prevent injuries or fatalities in your facility.

Many technical articles have been written about this subject, however, this paper offers a practical approach to reducing the challenge to a manageable level. The guidance presented will enable any facility to move toward an acceptable level of risk, as well as compliance with the most recently revised Occupational Safety and Health Administration's (OSHA) Combustible Dust National Emphasis Program (NEP), RAGAGEPs (Recognized and Generally Accepted Good Engineering Practices), and the National Fire Protection Association (NFPA) Standards on combustible dust. Dust explosions and flashfires are very real hazards. Addressing these hazards is a huge undertaking. If carried out in a practical manner, it is a very achievable goal to effectively manage the hazards, and substantially reduce the risk of such events. Taking action is critical so that no one will suffer the life-changing consequences of a dust explosion or flash fire in their workplace.

Key Changes

The Imperial Sugar Refinery explosion(s) [1] placed combustible dust hazards at the forefront of regulator’s minds at the time of the event. Prior to this tragedy, generally accepted standards associated with combustible dust were casually and inconsistently referenced. These same standards have now become embedded in the world of RAGAGEPs. Major changes are on the horizon with NFPA Standards, where NFPA 61, NFPA 484, NFPA 652, NFPA 654 (pertaining to sulfur fires), NFPA 655, and NFPA 664 will be consolidated under one standard ― NFPA 660 [See Appendix A]. In addition, OSHA issued updates to the Combustible Dust NEP [2], Directive CPL 03-00-008 [2], which became effective on January 30, 2023. An additional source is an OSHA inspector guidance document (Instruction CPL-02-00-164, Field Operations Manual) on how to inspect a facility with the potential for combustible dust hazards. OSHA citations are being issued for numerous general duty clause violations based on non-compliance with several NFPA Codes, the most referenced code being NFPA 654 [3]. Since initiating the Combustible Dust NEP in 2007, OSHA has conducted approximately 600 inspections per year under the program. While there is no specific OSHA standard for combustible dust, the Agency relies on multiple workplace health and safety requirements, as well as the General Duty Clause of the OSH Act found in Section 5(a)(1) to cite violations. In addition, OSHA pulls in several other industry codes and standards as law, most notably from the NFPA.