dust mitigation: housekeeping to avoid dust …...1980/01/24 · combustible dust nfpa 652...
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Dust Mitigation: Housekeeping to Avoid
Dust Hazards, Contamination and Fines
PART 1:
A FOCUS ON HOUSEKEEPING TO AVOID
COMBUSTIBLE DUST HAZARDS AND FINES
SCOTT C. BOERSMA, NILFISK, INC., BOOTH 9400
INTRODUCTIONS
• Scott C. Boersma, Business Development Manager,
Food Market Specialist, has more than 17 years of
experience in designing systems and solving
housekeeping challenges for Fortune 500 companies.
Currently, he works directly with food processing and
manufacturing customers and guides Nilfisk’s sales team
and engineers to better understand their housekeeping
and maintenance requirements.
Overview
Introduction to Combustible Dust Issue
OSHA & NFPA Regulatory Overview
Maintenance and Housekeeping Best Practices
Choosing the Right Housekeeping Equipment
Resources
Questions
1
2
3
4
5
6
Introduction to
Combustible Dust Issue
• OSHA: particulate solid that presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations, regardless of particle size or shape
• NFPA: any finely divided solid material that is 500 microns or smaller in diameter that presents a fire or explosion hazard when dispersed and ignited in air
COMBUSTIBLE DUST: DEFINITION
1) Fuel to burn (combustible dust)
2) Oxygen to sustain the fire (air)
3) Heat from an ignition source (spark)
4) Dispersion of a high concentration of dust into the air (deflagration)
5) Confinement of the dust within an enclosure or structure (explosion)
DUST EXPLOSION PENTAGON &
SECONDARY EXPLOSIONS
• The FOOD industry has the highest incidents of combustible dust issues.
• 771 Food Facility Inspections completed from 2007-2013
• $28 Million+ in Fines issued under the NEP
• Any dust with a Kst value greater than 0 is considered potentially
combustible
WHO’S AT RISK?
Furniture & Fixtures, 4%
Equipment Manufacturing,
7% Fabricated Metal
Products, 7%
Other, 7%
Electric Services, 8%
Rubber & Plastic
Services, 8%
Food24%
Wood, 15%
Chemical, 12%
Metal, 8% Material
-
Kst Value
(bar-m/sec)
Limestone 0
Act. Carbon 44
Wood dust 102
Flour 108
Sugar 138
Barley Grain Dust 240
Aluminum 415
Magnesium 508
OSHA & NFPA
Regulatory Overview
OSHA PROPOSED COMBUSTIBLE DUST
STANDARD
• OSHA National Emphasis Program (NEP),
created in 2008
• Continue to inspect facilities that
generate/handle combustible dusts which
pose a deflagration hazard that can lead to
an explosion
• OSHA penalty levels increasing by 78%
effective August 1, 2016
Source: OSHA, “Unified Agenda 2015”
Most Frequently Cited Violations During Inspections
1. Hazard communication (1910.1200)
2. Respiratory protection (1910.134)
3. Housekeeping (1910.22(a))
4. Electrical safety (1910.305)
5. Lockout/Tagout (1910.147)
6. Electrical safety (1910.303)
NFPA 652: FUNDAMENTALS OF
COMBUSTIBLE DUST
NFPA 652
Fundamentals of Combustible Dust
Effective September 2015
NFPA 61Agricultural & Food Processing Facilities
NFPA 484Combustible Metals
NFPA 664Wood Processing &
Woodworking Facilities
NFPA 654Other Industries
(i.e. Plastics, Pharmaceutical)
NFPA 655Sulfur
Source: NFPA 652, Origin and Development
Not Law, but violation of NFPA Standards is used as a
determining factor to identify risk and cite or fine
facilities under the General Duty Clause.
NFPA 652: APPLICATION (1.3)
• Applies to all facilities and
operations that manufacture,
process, blend, convey,
repackage, generate, or handle
combustible dusts or combustible
particulate solid (1.3.2)
***NOT JUST CLASSIFIED
(HAZARDOUS) LOCATIONS***
NFPA 652: SCREENING FOR COMBUSTIBILITY OR
EXPLOSIVITY (SECTION 5.2)
• Dust Test Required
• The absence of previous incidents
cannot be used as the basis for
deeming a particulate not combustible
(NFPA 652, Section 5.2)
– Owner/operator of a facility is
responsible for determining the
combustibility of material
– Test results, historical and published
data must be kept on file at all times
– Can use historical data if you can prove
the properties of your dust are the same
as previously tested dust
NFPA 652: DUST HAZARD ANALYSIS (7.1)
• Required at all operations that generate, process, handle or store combustible dusts/particulates
• For existing facilities, must be completed by September 2018 (3 years from effective date of standard)
• NFPA 652 offers a recommended method for and examples of DHAs
Dust Hazard Analysis (DHA)
(Verb)
A systematic review to identify and evaluate the potential fire, flash fire, or explosion hazards associated with the presence of one or more combustible particulate solids in a process or facility.
(Noun)
The review documents a facility keeps on file to document safe handling of combustible dust.
Proper Maintenance &
Housekeeping Practices
IMPORTANCE OF HOUSEKEEPING
Did you know?
During a 2011 expert forum on combustible dust held by OSHA, one
expert estimated that 95-99% of injuries and fatalities could be
prevented through proper housekeeping.
NFPA 652: HOUSEKEEPING (8.4)
• Requirement General Takeaways:
– Vacuuming is the preferred
method of cleaning (equipment
requirements laid out in 8.4.2.2)
– When vacuuming is impractical,
sweeping/water washdown is
permitted
– Compressed air blowdown used
for cleaning presents significant
hazards • Only use when other cleaning
methods present higher risk
• NOTE: this method does not remove
accumulated dust, it simply moves the
dust to another area
Choosing the Right
Housekeeping Equipment
OSHA VIOLATION FOR EQUIPMENT
• Selecting inappropriate equipment to clean combustible
dust can result in a fine
• Fragrance company fined $35,000 for:
“…failure to use approved electrical equipment to
clean up combustible dust.”
Source: https://ohsonline.com/articles/2016/06/06/combustible-dust-standard.aspx
NFPA 652: VACUUM CLEANING METHOD
(8.4.2.2)
• NFPA does not approve/certify vacuum equipment
• In classified (hazardous) locations vacuums must be 3rd party CERTIFIED for that specific location (Class II, Division 1 or 2, Group G)
• Vacuums MUST meet minimum NFPA design requirements to collect any type of combustible dust in non-classified locations!
NFPA-COMPLIANT VACUUMS
Design Requirements for portable vacuums collecting combustible dust in nonclassified(nonhazardous) areas
1. Non-combustible construction and meets requirements for construction and static electrical hazard controls (8.5.7.1)
2. Conductive or static-dissipative hoses including both suction and air delivery hoses
3. All conductive accessories, including wands and attachments, must be bonded and grounded
4. Dusty air should not pass through the fan/blower
5. Electrical motors must not be in the dust laden air stream unless listed for Class II, Division 1 locations
6. No paper filter elements for liquid/wet collection
7. Vacuum cleaners used for metal dusts must meet NFPA 484 requirements
• NFPA-compliant vacuums are designed to meet the requirements laid out in the standard, without requiring the 3rd party certification
• Only to be used when handling combustible dust in NON-classified locations
Additional Key Drivers
WHY INVEST IN HOUSEKEEPING?
• Eliminate risk of costly recalls, lawsuits and fines
• Improve air quality with certified HEPA and ULPA
filtration
• Good Manufacturing Practices (GMPs)
• HACCP
• Quality Assurance & Quality Control
• Cross-Contamination prevention (Allergens, Mold,
Microbacteria, Spores, Salmonella, etc.)
Combustible Dust Mitigation
• Compliance with OSHA & NFPA Guidelines
• Authorities Having Jurisdiction may require
compliance: Building Inspector, OSHA Rep., Fire
Marshall, Insurance Agent, Safety Manager at the
company, etc.
• Housekeeping – keep dust cover to less than 1/32”
• No more air blow down, per NFPA
• Insurance agencies mandating dust control plan
• Meet requirements for NRTL-certified equipment
OSHA resources:
Combustible Dust NEP:
www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=3830
Fact Sheet:
http://www.osha.gov/OshDoc/data_General_Facts/OSHAcombustibledust.pdf
Poster:
www.osha.gov/Publications/combustibledustposter.pdf
NFPA resources:
NFPA 654Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids
http://www.nfpa.org/aboutthecodes/
FREE NFPA Codes: www.nfpa.org
Click on “codes and standards,” then on the left hand side click “List of NFPA codes and standards.” Choose the standard you want to view.
Choose “view the standard online.”
You will be prompted to log-in or create an account. Follow the prompts to create an account. Once you validate your email address, you’ll be able to view electronic versions of the codes for free.
RESOURCES
Questions?
For more information:
Scott C. BoersmaNilfisk, Inc.
BOOTH 9400
PART 2:
UNDERSTANDING SILO CLEANINGROBERT VERDUGO, M.S.
• Senior Account Exec. – Action Duct Cleaning – Western region. Founded in 1978.
• AIB certified in Food Safety and Sanitation.
• Regularly visits food processing plants to review cleaning needs for silos, ovens, tanks and similar equipment.
• Consultant for food sanitation issues.
WHO’S ROBERT VERDUGO?
WHAT IS A SILO?
• Goes back to Latin sirus (sĭrūs).
• Latin word comes from Greek
siros.
• Meant a pit or underground
storage for keeping grain.
WHAT IS A SILO?
• No pallets of bagged material to store and keep from pests.
• No need to tear open 50-100 lb. bags and dump the contents into a hopper – and then clean up the overspray and deal with the empty bags.
• By simply opening a valve, the rate and amount of material can be regulated as it flows continuously from the silo into the manufacturing process.
ADVANTAGES OF A SILO
• The Code of Federal Regulations (CFR) is the code of rules and regulations (sometimes called administrative law) from the executive departments and agencies of the federal government.
• Title 21 covers food and drugs.
• Sec. 110.35(a) Sanitary operations: “Buildings, fixtures, and other physical facilities of the plant shall be maintained in a sanitary condition and shall be kept in repair sufficient to prevent food from becoming adulterated within the meaning of the act. Cleaning and sanitizing of utensils and equipment shall be conducted in a manner that protects against contamination of food, food-contact surfaces, or food-packaging materials.”
REGULATIONS RE: SILO MAINTENANCE
“Cleaning is done in a way that prevents contaminationof raw materials, products,
and equipment.”
AIB (American Institute of Baking) International Consolidated Standards for Inspection,
Section 3.1.1.1
REGULATIONS RE: SILO MAINTENANCE
• Mold
• Insects
• Contaminants (e.g., rust, paint
flakes)
• Environmental: Rain, dirt, etc.
• Rodents and other pests
SILO SANITATION ISSUES
• Mold
• Insects
• Contaminants (e.g., rust, paint
flakes)
• Environmental: Rain, dirt, etc.
• Rodents and other pests
SANITATION ISSUES
• Commonly seen at top of silo.
• Visible as shades of green or black, particularly on inside walls.
• Can be an inch deep on the walls.
• Moisture is key.
• Can occur when warm flour is pumped in and cools down.
• Dehumidifiers can reduce moisture.
MOLD IN SILOS
• Typical pests: Red Flour Beetle, Confused Flour Beetle.
• Lesser: Warehouse Beetle, Cigarette Beetle
INSECTS IN SILOS
• Typically have 28-day life cycle.
• Invasive insects tend to be seen a
month or so after cleaning.
• Cleaning breaks the 28-day cycle
and brings insect load back to
near zero.
INSECTS FOUND IN SILOS
• Holes in exterior – rusted out,
gunshot, impact damage.
• Interior rusting or flaking.
• Holes in filters and breather bags.
• Leaking gaskets.
• Poor-fitting doors or covers.
DAMAGED SILOS
• Access doors at
top
• Interior cage
• Interior stairs
• Tripod at top, lower
personnel into silo
ACCESS FOR CLEANING SILOS
• Falls
• Lack of oxygen
• “Drowning” in flour
or other material
• Explosive dust
hazard
CLEANING SAFETY ISSUES
• Confined Spaces (29 CFR
1910.146)
• Fall Protection (29 CFR 1926.501)
• Ladder Safety (29 CFR 1926.1053)
• Personnel Protective Equipment (29
CFR 1910.132)
• Combustible Dust (OSHA 3371-08)
SILO CLEANING SAFETY - OSHA
Explosion beneath sugar silos
IMPERIAL SUGAR FIRE, GEORGIA
• The Department of Justice requested that U.S. Attorney for the Southern District of Georgia pursue criminal prosecution against Imperial Sugar and its executives.
• OSHA cited Imperial with 124 safety violations, finding that the company acted with "plain indifference to, or intentional disregard for, employee safety and health."
IMPERIAL SUGAR FIRE, GEORGIA
• Clean silos two to four times a year or as needed.
• (Optional) Fumigate after each cleaning.
• Change filters monthly.
• Conduct a self-audit through your HACCP system (Hazard Analysis and Critical Control Points).
• Hire a third party auditor to perform a routine review.
SILO PREVENTATIVE MAINTENANCE
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