Workplace Incident Data: Fact or Fiction?

It’s been an interesting path taking the leap from writing an occasional guest column in the local newspaper to blogging, where all of sudden there is a global audience. Yet even though readers are out there searching the web for useful content, a Blogger never knows if their writing has any impact since comments to initial posts are few and far in-between. After left-clicking that send button with the mouse and wondering, “Did I get it right”?

Welcome to the sometimes lonely world of blogging where a passion for researching and finding gems of information to share with others is the intimate reward. Yet while at the same time, learning about the world around you, as if taking apart a intricate watch with all the springs and coils and trying to figure out how it goes back together.

Imperial Sugar Refinery Dust Explosion

Mainstream media is mostly concerned with the who, what, where, when, and why. The unique aspect of Blogging is that the author can discover the “how” on their own utilizing the powerful search engines of the web.  Like dissecting the innards of a watch, a Blogger discovers the “how” through intensive research of facts. Last year on February 7, 2008 a catastrophic dust explosion occurred at the Imperial Sugar Refinery in Port Wentworth, Georgia resulting in 14 fatalities and several dozen injuries.  After reading the media accounts immediately following the explosion, many Americans including myself, wondered how a manufacturing plant could explode due to sugar as the source of the explosion.


Imperial Sugar Refinery explosion

From a regulatory historical perspective, three decades ago the grain industry was plagued with dust explosions in grain silos, which resulted in dozens of injuries and fatalities in a short tome span. Subsequently, the Occupational Heath and Safety Administration (OSHA) developed an OSHA Grain Facility standard to minimize the severity and likelihood of future dust explosions in protecting workplaces that handle grain.

Basically any substance that is a combustible particulate solid is a candidate for evolving into a combustible dust where a reduction in particle size in the manufacturing process increases its surface area, making the dust easier to ignite. A good example would be log that you throw in the fireplace that does not burn easily, yet if cut into smaller kindling, like many youngsters are taught in the Boy Scouts on the first camp out, the wood burns much faster. 

Elements of a Dust Explosion

Many are already familiar with the basic fire triangle where you need fuel, heat, and oxygen to start a fire. Add suspension of dust particles under the right concentration in addition to confinement and you have the ingredients for a potential dust explosion, quite similar to a deadly vapor cloud explosion. Both are propagating explosions which have a high instantaneous release of pressure and temperature like the Space Shuttle lifting off the launch pad. But in stark contrast an unwanted deflagration at a manufacturing facility produces damaging overpressure, harmful thermal radiation, and ensuing deadly projectiles.

Prior to blogging on combustible dust related fires and explosions in the manufacturing sector, I had no idea of the basics as noted above of what constitutes a combustible dust related fire or dust explosion (deflagration). For the next 20 months, following the Imperial Sugar Refinery dust explosion in February 2008 that would rapidly change. For instance, last year, immediately after the Imperial Sugar incident I began collecting data from news accounts of combustible dust related fires and explosions in the United States.


Combustible Dust incidents

Congressional Committee Hearing

Subsequently, a week before the first combustible dust hearing was held by the House Committee on Education and Labor on March 12, 2008, over a dozen combustible dust related fires and explosions had occurred in the manufacturing sector, since the previous Imperial Sugar incident a few weeks earlier. The numbers just didn't add up? Especially with the governmental Chemical Safety Board Dust Hazard Study reporting to congressional committee members and OSHA that 281 incidents occurred from 1980-2005, or an average of 12 incidents annually.

Thinking geez, this is something that could help provide an enhanced awareness on the volatile subject. I eagerly contacted the House Committee on Education and Labor and offered to share this important incident data. Well things didn't work out. A staff member informed me that the data couldn't be used at the Combustible Dust hearing, as congressional committee members would not find it acceptable, since it was coming from some guy in Texas on his computer. After hanging up the phone, the Combustible Dust Policy Institute was founded and went into action in providing a proactive awareness on the subject though blogging.

Proposed OSHA Combustible Dust Standard

The results of the hearing assisted Congress in developing a combustible dust bill that passed in the House yet stalled in the Senate. Now with the Democrat administration, with new leadership at OSHA, a proposed combustible dust Advanced Notice of Proposed Rulemaking (ANPRM) has recently been issued and is open for public comment. Ironically, it was amazing that finally the incident data that I profusely blogged about, and was not acceptable to Congress earlier, was now cited as a primary source of probability of occurrence for incidents in the Federal Register OSHA combustible dust ANPRM.

An OSHA combustible dust standard would explicitly address combustible dust fire and explosion hazards in the manufacturing workplace. Currently combustible dust hazards is only addressed in a several  sections of the OSHA general industry regulations, such as housekeeping, powered industrial trucks, and hazardous (classified) locations. The proposed regulation would address a few elements of the likelihood and severity of primary dust explosions that can be reduced through inherent safety principles, best engineering practices, administrative controls, and personnel protection equipment.

Additionally the proposed regulation will address secondary catastrophic dust explosions that can be prevented through good housekeeping, where the fuel source is removed from horizontal surfaces like rafters, overhead beams, ductwork, girders, etc. Overall a problem exists with the proposed OSHA combustible dust regulation since OSHA has yet to acknowledge that combustible dust poses a potential explosive atmosphere, like flammable liquids, gases, vapors, and mists. Until this aspect is addressed, all the regulations in the world will not provide the awareness and attention that combustible dust needs in the global workplace. In the European Union, the ATEX directives already acknowledge that combustible dust poses a potential explosive atmosphere.

A New Paradigm

In retrospect, it is odd, that nowadays unless one is represented by a million dollar lobby firm on K Street, then the voice of the average blue collar American working Joe on the street is initially worthless. That's the way things stand today in Washington, D.C. But the paradigm has changed. With the power of the Internet, one has the resources at hand as any Fortune 500 Corporation. All it takes from there is a deep desire to seek the truth in what is reality in contrast to sometimes questionable governmental data and commercial mainstream media.

I encourage all Americans to go behind the scenes, like Toto did in the Wizard of Oz, and pull the curtain back while the Wizard pulls the levers. Combustible dust is just a drop in the bucket in comparison to the myriad of social-economic issues that confront Americans, in which Congress and governmental agencies debate on a daily basis. Pick an issue that interests you and then go for it, researching topics that you hear about in the news.

Utilizing Web 2.0

Many news reports are solely commentary with supposedly facts and figures obtained from governmental press releases. After a few weeks of research, you just might find that the data in the governmental reports and mainstream media might not quite be reality. But once you do obtain information, start writing about the results of your research to share with others with similar interests. Be sure to include hyperlinks of your sources in your content, so readers can obtain a fuller understanding of the subject.

Now with Web 2.0, utilizing Blogs, Twitter, Facebook, Linkedin, etc your story is effortlessly shared across international borders. Just remember content is king. So the more you post, the more the Google spider will find in keywords that will appear when potential visitors are seeking information on the subject in their searches.

In regards to occupational health and safety I'm certain that the future in achieving a safe workplace throughout industry in a comprehensive manner can be enhanced immensely utilizing all the resources that the Internet offers.