Combustible Dusts Legislation

[psafety]

I was just informed the Democratic House members introduced a bill that would require OSHA to issue an interim dust rule within 90 days and a final rule within 18 months and revise its hazard communication standard to warn workers of the dangers associated with combustible dust.

Isn't this really only addressing communication and training of the inherent hazards to workers?

Would it not address the root of the problem if OSHA simply classified combustible dusts as a highly hazardous chemical? This would mandate at least design changes, change control, and proper hazard analysis.

I would bet combustible dusts are responsible for more lives affected or lost than many of the chemical on the current list.

 

[stookeyfpe]

Poo poo on this. I love it when legislators don't ask anyone with any level of technical acumen when they write their legislation. Of course, OSHA is currently so out of touch on this issue that nothing suprises me.

What OSHA needs to do is adopt NFPA 664 by reference. This standard requires the business to initiate an MOC plan and communicate it to its employees as well perform the appropriate hazards analysis. Once this is accomplished, then the appropriate engineering controls can be designed and prescribed.

 

[JLSeagull]

Read the bill. It reads pretty much as stookeyfpe suggests.

... food industry ....
The CSB recommended that OSHA revise the hazard communication standard 29 CFR 1910.1000.

The CSB recommended that OSHA issue a standard ... based upon current NFPA explosion standards.

The Chemical Safety Board is a legitimate technical organization and their comments seem rational.

 

[stookeyfpe]

JL,

Thank you for the clarification. Since it was initiated by the CSB, it has merit. Let's hope this one is passed.

Can you post a link? I can't seem to find this on the CSB or OSHA website.

 

[psafety]

The Chemical Safety Board is making good points, but a new Standard?

If NFPA 61, 68, 69, 484, 499, & 654 were mandatory, engineering contols would be in place. If combustible dusts were considered a highly hazardous chemical regular reviews, change control, mechanical integrity, etc would be in place. Lives would be spared.

We don't need a new standard, implementation of current standards in my book, is the answer.

 

[amedik]

This is the link to the CSB's Chairman's statement:

"I call on all of industry to take this hazard seriously - during the winter months and throughout the year," Mr. Bresland said in the video. "And I urge the incoming leadership at OSHA to act upon the CSB's recommendations from 2006 to develop a comprehensive regulatory standard for combustible dust."

<

http://www.chemsafety.gov/index.cfm?folder=news_releases&page=news&NEWS_ID=460>

 

[cheute79]

Psafety is right. Why add more rules, more legislation, etc., when it already exists or existing rules with very minor adjustments, will do the job? This is just another example of piling on for the sake of piling on. It accomplishes nothing more than adding cost (and probably personnel). the existing standards and rules are already known and accepted by competent members of the safety and operations committee.

 

[psafety]

cheute79,

Exactly!! We are on the same page.

psafety