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OSHA Combustible Dust NEP Services

To request a quotation regarding “OSHA Combustible Dust National Emphasis Program (CPL-03-00-008) Services”, please click below:
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The Occupational Safety and Health Administration, OSHA, has issued a directive (CPL 03-00-006) effective March 11, 2008, with re-issue on October 1, 2015.

Previously, the US Chemical Safety and Hazard Investigation Board (CSB) had found that “...combustible dust explosions are a serious hazard in American industry, and ... existing efforts inadequately address this hazard” (ref: “Investigation Report – Combustible Dust Hazard Study”, Report No. 2006-H-1, November 2006). The CSB study examined the record and literature to assess the magnitude of the dust explosion hazard and found that 281 combustible dust incidents were reported in the 25-year period ending in 2005. These incidents were responsible for 119 fatalities, 718 injuries, and millions of dollars in lost facilities and productivity.

You are a target of the OSHA National Emphasis Program (NEP) if:

  • You are covered by the OSHA Safety and Health standards,
  • You handle or process combustible dusts and powders including (but not limited to):
    • Metal dust, such as aluminum and magnesium,
    • Wood dust,
    • Coal and other carbonaceous dust,
    • Plastic dust and additives,
    • Biosolids,
    • Other organic dusts, such as sugar, paper, soap, and dried blood,
    • Certain textile materials

OSHA is creating an all-inclusive listing of facilities that handle combustible dusts from its facility-classification lists, including specific Standard Industrial Classification (SIC), and North American Industry Classification System (NAICS) codes. These applicable classification codes are provided in a Table included in the OSHA NEP document; a download is available here.

Many types of industrial activities will be listed, including: chemicals, pharmaceuticals, textiles, agriculture, forest and furniture products, metal processing, tire and rubber manufacturing, coal dust, and recycling operations.

When inspecting a site as part of the NEP, OSHA inspectors will focus on using specific guideline documents from the National Fire Protection Association (NFPA 68, 69, 85, 484, 499, 654, and 664) and FM Global Loss Prevention Data Sheet 7-76. These NFPA codes and standards were discussed in a previous Chilworth Inc. “Focus” article available here. Your knowledge and good faith application of these standards will be critically important to the NEP inspection.

OSHA Combustible Dusts NEP Inspection and Citation Procedures

The procedures include:

  • Assessment of the combustible dust threat to employees:
    • Do Safety Data Sheets indicate a combustibility or explosibility hazard of powders or dusts?
    • What is the site history of fires and explosions involving dust?
    • Are there accumulations greater than 1/32 inch (0.8 millimeter) anywhere?
  • Audit of the adequacy of dust management practices:
    • Containment within equipment
    • Local exhaust ventilation at dust-release locations, to dust collectors
    • Housekeeping program, with appropriate methods and frequencies
    • Appropriate classification for vacuum cleaners and vacuum-cleaning systems
  • Audit of the program for ignition source control:
    • Bonding and grounding of equipment, ductwork, and hoses
    • Electrical classification (Class II) and appropriate Division (1 or 2) or Zones 20, 21, or 22
    • Separation devices for foreign materials
    • Hot work program
    • Smoking prohibitions
  • Audit of the design and protection against fire and explosion:
    • Equipment such as dust collectors, bucket elevators, silos and bins, mixers and blenders
    • Isolations between equipment items and operating areas
    • Rooms and buildings
  • Collection of samples of combustible dusts for laboratory analysis:
    • From high places, on structural members, on ductwork, on lighting fixtures, above ceilings.
    • From floors and on equipment surfaces
    • From accumulations within ductwork, and from dust collectors
  • Citation of facilities based on the above and test results using one or more of the following OSHA standards:
    • General Duty Clause Section 5(a)(1) Provide a workplace that is free of recognized fire and explosion hazards.
    • If grain facility: 29 CFR 1910.272 grain handling standard
    • Ventilation standard 29 CFR 1910.94 covering abrasive blasting, grinding, polishing and buffing operations
    • Housekeeping if not a grain facility, 29 CFR 1910.22 or 1910.176 for storage areas
    • If coal handling: 29 CFR 1910.269(v)(11)(vii)
    • Personal protective equipment standard 29 CFR 1910.132(a) if personnel could be exposed to a flash fire hazard.
    • Process Safety Management violations under 29 CFR 1910.119
    • Electrical area classification violations for Class II (dust) or Class III (flock) areas, by 29 CFR 1910.307 or 1910.399.
    • Other standards as listed in the NEP document

To request a quotation regarding “OSHA Combustible Dust National Emphasis Program (CPL-03-00-008) Services”, please click below:
REQUEST A QUOTE