We recently discussed in this blog OSHA’s revised Combustible Dust National Emphasis Program.  Along with that revision OSHA’s shared its instructions to inspectors on what how to conduct the inspection, what to look for, how to build a case for a citation and which standards they could cite in a citation.

In this article, we’ll list out exactly what an inspector will be looking for if they arrive to your site for a combustible dust inspection, the information you’ll need to provide, and which standards you can be cited under.  There is no official OSHA combustible dust standard, so inspection instructions can help serve as a guidance to help you determine what you need to have in place not only to do well in an inspection, but to keep your people safe.

How Will OSHA Determine Who Gets Inspected?

First, will you be on the target list?

The NAICS codes who are likely to have combustible dust hazards are gathered together on Appendix B of the emphasis program.  OSHA will pull a list of all companies who qualify and generate a random order list.  Each company will be assigned a number and OSHA inspectors who have had specialized training in combustible dust hazards will be assigned to conduct inspections. This list will remain active for 3 years before a new one is generated. Between 2013 and 2017, OSHA conducted approximately 500-600 per year between programmed (planned) and unplanned inspections.

Your company can be deleted off the list if you have been inspected within the past 5 fiscal years, were inspected for combustible dust hazards and no citations were issued, or if you were inspected for combustible dust hazards, was cited but a follow-up inspection verified you did abate the hazards. Also, if you are a VPP or SHARP company, you can be deleted off the list.

If you’re not on the list for programmed inspections, you can still be inspected if there has been a complaint or if you have had a fatality or catastrophic incident related to combustible dust.

What Will Inspectors Be Looking for in a Combustible Dust Inspection?

This is the list of items that OSHA will be evaluating and the potential documentation they will be looking for:

1. History of Fires and Explosions

Inspectors will be determining if your plant has a history of fires, flash fires, deflagrations of process vessels and inside buildings, and explosions of vessels.  They’ll be conducting employee interviews, looking at OSHA logs, looking at insurance claims, accessing local fire department records, and conducting onsite visual inspections to look at the condition of your equipment.  They’ll be placing special attention to discoloration, bulging, repairs and missing/damaged pieces or appendages of your equipment.

2. Safety Data Sheets (SDSs)

Inspectors will go through your SDSs, looking for combustible dusts.

3. Electrical Area Classification Drawings/Documents

Inspectors will be looking at your classification documents to find areas marked Class II, Division 1 or 2 to ensure electrical equipment is approved for that hazardous location.

You are required to have these drawings per 29 CFR 1910.307, which is the Hazardous (Classified) Locations Standard.

4. Dust Hazard Analysis

Inspectors have been instructed to do a dust hazard analysis toward the end of the inspection to help them in determining your citation, rather than at the beginning of the inspection to determine the scope.  This analysis includes observations of all areas of the facility for accumulation issues to determine overall potential for fire, flash fire or explosion.

They’ll be looking at:

• Horizontal structures
• Conduits and pipe racks
• Cable trays
• Floors
• Above suspended ceilings
• On or around equipment, especially on elevated horizontal surfaces

They will be taking measurements of depth, determining physical area sizes, and may be bringing cameras and video cameras on poles to help take photos of high places.

5. Control and Suppression Systems

Inspectors will be looking to ensure:

• Dust collectors and dust handling equipment has explosion prevention/suppression systems and deflagration propagation prevention devices;
• Dust systems that return clean air to buildings have proper protections;
• There are no hazardous levels of combustible dust accumulations outside of equipment;
• Number and sizes of horizontal surfaces are minimized and designed to prevent dust accumulation;
• Equipment that produces, transports, stores or handles dust (mixers, silos, mills, ducts, dust collectors, etc.) are designed and maintained to prevent dust leakage/escape/clouds;
• Material transport systems (conveyors, elevators) are designed to prevent dust leakage/escape/clouds;
• The method of cleaning and the tools you use to clean are proper. Are you using specialized vacuums to clean up combustible dusts, what are you doing to clean up dust, and if you use compressed air is it under 30 psi with the right chip guards and PPE?
• Electrical equipment and lights are proper for use in those areas;
• Powered industrial trucks are approved for use in those locations;
• Hot work, welding, cutting and grinding is not performed in those areas;
• Ductwork from dust generation, handling and collecting systems is conductive, bonded and properly grounded to dissipate static accumulation;
• Maintenance of mechanical equipment is conducted to prevent generation of heat and sparks;
• Process systems have magnetic separators and/or tramp metal separators installed;
• Your ductwork has proper transport velocity to prevent accumulation in the ducts and that ducts have inspection and cleanout ports/hatches;
• Housekeeping procedures are in place; and,
• You have ignition control programs for:
  • Hot work and hot surfaces
  • Bearings
  • Self-heating materials
  • Open flames
  • Fuel-fired equipment
  • Heated process equipment
  • Heated air
  • Frictional sparks
  • Impact sparks
  • Electrical equipment
  • Electrostatics or other similar sources in dust handling equipment.

6. Sampling Results

Inspectors will be collecting dust samples from each area they believe has a potential for a combustible dust hazard.  This could be from elevated surfaces, horizontal surfaces as high overhead as possible, floors and equipment surfaces, dust collection equipment and within process equipment.  They are not allowed to enter into your confined spaces, but they can use a non-spark producing scope or scoop on an extension pole to collect their sample.

Samples will be sent to the OSHA Salt Lake Technical Center which has specialized knowledge and experience with combustible dust hazards.

A good practice with all OSHA inspections is to make sure you conduct your own side-by-side sampling, that is, you sample what they sample and get your own independent results.  Be advised, combustible dust samples are going to be considerably more expensive samples to have analyzed by a laboratory than other types of materials.

7. Other Documentation

Inspectors will be gathering all kinds of other information including:

• How your equipment is connected and how the process flows;
• Piping and process diagrams;
• They’ll take photographs, videos and make diagrams or sketches documenting extent and depth of dust and condition of equipment;
• Room dimensions;
• Engineering controls used;
• Design information, make, model, serial numbers of dust collectors;
• Date of installation and operator manuals for dust collection system;
• Dirty and clean size/volumes for dust collection system;
• Warning signs and alerts on equipment regarding combustible dust;
• External ignition sources; and,
• Internal ignition sources.

What are Some Potential Standards You Could be Cited Under?

OSHA does not have its own dedicated combustible dust standard, but it can use a wide variety of other standards to cite you for these hazards.  These include:

Housekeeping Standard (Non-Storage Areas) – 29 CFR 1910.22

A little dust here and there wouldn’t be enough.  You can be cited under this standard if you have a visible volume of combustible dust in the workplace.  This is where that dust hazard analysis comes in.  They will use their measurements and observations for extent, depth and calculations of area.  If you have dust everywhere and it’s pretty significant, expect a violation of this standard.

Housekeeping Standard (Storage Areas) – 29 CFR 1910.176(c)

This is from the Handling Materials – General standard which says that storage areas need to be free from accumulation of materials that constitute hazards including explosion and fire.

General Duty Clause – Section 5(a)(1)

As with a lot of other cases, usually there’s always something within the tried-and-true General Duty Clause that could be included. In this case it will be related to the dust collection system or your dryers, mixers, material storage, bucket elevators and mills.  In addition to reviewing your safety and maintenance manuals, inspectors may do some research into your industry to find potentials for combustible dust hazards and also use NFPA 65 or other NFPA standards to find issues.

Some ideas for citations under the General Duty Clause listed for inspectors in their inspection guidance include:

• Problems with dust collectors;
• Ductwork-related problems;
• Improperly designed deflagration venting;
• Unprotected processing and material handling equipment (no deflagration suppression); and,
• Improperly designed or maintained blowers, collection systems and exhaust systems used at sawmills.

Ventilation – 29 CFR 1910.94

Paragraph (a) of this standard deals with abrasive blasting including fire and explosion hazards.  If your ventilation equipment is not constructed in accordance to NFPA 91 and 68, then you can be cited here.

PPE – 29 CFR 1910.132(a)

If employees are not wearing FR (flame-resistant) clothing around combustible dust areas where they could receive burn injuries from flash fires, you can be cited under the PPE standard.

Hazardous (Classified Locations) – 29 CFR 1910.307

This is in the Electrical Subpart S area of the standards.  If sample results show you have combustible dust in a Class II area and it’s not safe for it to be there, you would be cited under this one.  They can also cite Class I and III electrical-related issues here too if they find them along the way.

Powered Industrial Trucks – 29 CFR 1910.178

If you have a forklift that’s not rated an EX (explosion proof) in the area where there’s combustible dust, you can be cited here.  Also be aware that many jurisdictions still have Powered Industrial Truck emphasis programs so they can conduct an additional separate inspection regarding your trucks while they are there for combustible dusts.

Welding, Cutting and Brazing – 29 CFR 1910.252

Under the general requirements, if you are conducting cutting and welding in explosive atmospheres, you can be cited here.

Warning Signs – 29 CFR 1910.145

This comes from the standard for Specifications for Accident Prevention Signs and Tags under Subpart J, General Environmental Controls.  If you have safety instruction signs missing from equipment or missing from entrances where there are explosive atmospheres, expect a citation here.

Hazard Communication – 29 CFR 1910.1200

Did you know that combustible dust is considered a hazardous chemical?  This needs to be incorporated into your hazcom program.   All equipment containing combustible dusts, including drums and containers used to collect dusts from dust collectors and cyclones must be properly labeled just like any other hazcom container.

You should also document notifying and training employees on its hazards.

SDSs are now supposed to include combustible dust as a not otherwise classified hazard with the signal word “warning” and the hazard statement “may form combustible dust concentrations in the air.”

Others and Specialty Standards

• Means of Egress – 29 CFR Subpart E
• Portable Fire Extinguishers – 29 CFR 1910.157 (no emergency action plan or fire prevention plan)
• Fire Brigades – 29 CFR 1910.156
• Spray Finishing – 29 CFR 1910.107
• Bakery Equipment – 29 CFR 1910.263
• Sawmills – 29 CFR 1910.265
• Pulp and Paper Mills – 29 CFR 1910.261

Do you need help with combustible dust?  iSi can help with programs, audits and hazard assessments, sampling, PPE determinations, training and more.  Contact us today!

OSHA Considering Changes and Updates to the PSM Standard

OSHA has been accepting comments on several proposed changes to its Process Safety Management, or PSM standard.

PSM is an OSHA regulation that is concerned with processes at your facility that use highly hazardous chemicals.  PSM provides a compliance framework to evaluate each process with the end goal of no spills, fires, explosions, reactions, releases or other incidents arise from their use.  The official standard can be found at 29 CFR 1910.119.

PSM hasn’t been updated since its creation in 1992.  OSHA has been reevaluating PSM, and EPA has been similarly been reevaluating their Risk Management Plan, or RMP standard since the 2013 West, Texas fertilizer storage facility explosion.  Just like the difference between OSHA and EPA, PSM is meant to protect workers while RMP is meant to protect the environment.

Potential changes to PSM could include:

• Clarifying the exemption for atmospheric storage tanks;
• Strengthening employee participation and stop work authority;
• Requiring the development of written procedures for all elements specified in the standard, identification of records required by the standard, and a records retention policy (previously referred to as “Written PSM Management Systems”);
• Including oil-well and gas-well drilling and servicing as part of the standard and resuming enforcement for oil and gas production facilities;
• Expanding coverage and requirements for reactive chemical hazards;
• Updating and expanding the list of highly hazardous chemicals in Appendix A;
• Requiring continuous updating of collected information (paragraph (d));
• Requiring formal resolution of Process Hazard Analysis team recommendations that are not utilized;
• Better defining what critical equipment means, what equipment deficiencies are, and expanding paragraph (j) to cover the mechanical integrity of critical equipment;
• Clarifying the scope of the retail facilities exemption;
• Defining the limits of a PSM-covered process;
• Better defining recognized and generally accepted as good engineering practices (RAGAGEP) and requiring evaluations of any updates to them;
• Requiring safer technology and alternatives analysis;
• Requiring consideration of natural disasters and extreme temperatures;
• Amending paragraph (k) of the Explosives and Blasting Agents Standard to cover dismantling and disposal of explosives and pyrotechnics;
• Clarifying that paragraph (l) covers organizational changes;
• Amending paragraph (m) to require root cause analysis;
• Requiring coordination of emergency planning with local emergency-response authorities;
• Requiring third-party compliance audits; and,
• Including requirements for employers to develop a system for periodic review of and necessary revisions to their PSM management systems (previously referred to as “Evaluation and Corrective Action”).

This action is currently in the comments stage, and stakeholder meetings were held in October 2022 with comments accepted through mid-November 2022.  We will keep you updated when anything final is published.

Do you need help with PSM?  Does this apply to you?  iSi can help!  Contact us today for more information.

Safety regulations are enforced by OSHA, and in some states such as California and Indiana, by a state safety agency. How do you make sure you have your bases covered? A safety audit can determine your current status and what your vulnerabilities are. iSi’s general industry safety audits are conducted like a mock OSHA inspection for the 29 CFR 1910 general industry regulations. There is a wall-to-wall walkthrough, a records review of written programs, training programs, and past inspections, and interviews with employees.

Some of the below cited items start in the OSHA regulations, but detailed actions are prescribed by other regulations such as the National Fire Protection Association (NFPA) or American National Standards Institute (ANSI) Standards. Others are based on items we see our clients cited for in OSHA inspections which we have added to our audits.

The following are our top 12 specific findings we see most when we do our general industry safety audit.

12. Safety Showers and Eyewash Stations

Facility safety showers and eyewash stations are not being inspected on a regular basis.  1910.151(c) discusses suitable facilities, but ANSI standard Z358.1-2014 specifies weekly visual inspections of both showers and eyewash stations.

11. Lifting Slings

We find that often there is no formal program in place to conduct a periodic inspection of all lifting slings. This must be conducted annually. 1910.184 includes guidance on the use of slings and item (d) covers inspections.

10.  Machines

At number 10 is fixed machines. We find fixed machines are not securely mounted to the floor or the bench top to prevent them from “walking.” 1910.212 is the standard for all machines and machine guarding. Item (b) covers the anchoring requirements.

9.  Personal Protective Equipment (PPE)

PPE evaluations and hazard assessments must be conducted for each task. We find that these are either not conducted or not documented. The potential for workplace hazards must first be assessed and if PPE is needed, PPE must be selected, communication decisions must be communicated to affected employees and PPE must be fitted to each employee.

A written certification must be created which identifies the workplace evaluated, the person certifying the evaluation, the date the assessment was conducted, and signification that the document is a certification of hazard assessment.

These rules are found in 1910.132(d).

8. Fire Extinguishers

Are your fire extinguishers mounted too high, not mounted at all or are they blocked from access? 1910.157(c) is the standard which covers this issue.

7.  Emergency Lighting

Emergency lighting, in many locations, is not being tested every 30 days for 30 seconds or for 1.5 hours annually. Lighting can be found in Subpart E, Means of Egress, Maintenance, Safeguards, and Operational Features for Exit Routes, 1910.37(a)(4) and the NFPA 101 Life Safety Code 7.9.3.1.

6.  Lamps

We find that lamps less than 8 feet from the floor are not protected from accidental contact. Lamps need to be guarded and protected from accidental contact. This can be found in 1910.305(a)(2)(ix). Although a particular height requirement is not specified in this regulation, you should consider the reach of your tallest employees and length of the parts and/or tools being used in the area.

5.  Forklifts 

We see many issues with forklifts. The most common issue we find with forklifts no documentation of daily inspections, or no inspections being conducted. However, more recently we have been seeing issues with employees not wearing seatbelts, controls where the labeling has worn off, the use of non-factory attachments, and not updating data plates, tags and decals with revised capacity, and operation and maintenance data. Forklift standards are found in 1910.178.

4.  Grinder Wheels 

Machine guarding issues are a common item we see. One of the most prevalent ones relates to grinder wheels. The gap between the grinder wheels and the work rest plate should not be more than the maximum allowed 1/8 inch. The adjustable tongue guards shouldn’t be more than the maximum allowed 1/4 inch from the tongue guard. These regulations can be found in Subpart O, Abrasive Wheel Machinery, 1910.215(a)(4) and (b)(9).

3.  Electrical Panels 

With electrical panels, we often see the minimum required areas of clear space around the panels is not being maintained. Sufficient access must be maintained for safe operation, access, and maintenance. The rules, including a distance chart to help you determine proper clearances can be found in Subpart S, 1910.303(g).

2.  Hazard Communication

Within the hazard communication (hazcom) standard, there are requirements for secondary containers. We find many secondary containers of hazardous chemicals are not labeled correctly or have illegible writing on them. The regulation comes under the “labeling” section of 1910.1200. All containers, either primary or secondary, need to be labeled and contain product identifier and words, pictures, symbols or a combination of them. Portable containers, that is, containers you transfer chemicals to and intend for immediate use are not covered by this requirement.

1.  Access to Medical Records

The number one item we find in our audits relates to access to medical records. Employees are required to receive information on their access to medical records. This is required initially upon hire, and then annually thereafter. The regulations can be found in 1910.120(g)(1). Included with this requirement is notifying employees the existence, location and availability of records covered by 1910.120, the person responsible for maintaining and providing access to records, and each employer’s rights to access those records. As an employer, you need to keep a copy of 1910.120 and its appendices and make copies readily available, upon request, to employees.

This information can be covered within your annual training classes, or can be a written notice of information in an email, or a memo that is posted with your OSHA logs and other OSHA-required notices. The important part is that you document that you completed this requirement and how.

Where Do You Go From Here?

iSi can help you get a baseline on your safety compliance status by conducting a walkthrough. From there, we will create a matrix of issues we see with the corresponding regulatory standard. We can also help you prioritize the ones which are most critical to be taken care of.

Request a quote for a general industry safety audit today! Need more information about these issues?  Contact us at (888) 264-7050 or email us!

OSHA annually has a Stand Down for Falls in Construction.  If your company is not in construction, but in general industry, this is a good time to review fall protection issues at your own facility.  Falls can occur anytime you have workers at heights regardless of the type of work they are doing.  Here are some tips to remember for general industry:

• In general industry, the rule for fall protection is that it’s needed when you’re at or above 4 ft. or when someone is working over hazardous machines or equipment.
• When using scissor at 4 ft. or above, fall protection is needed. Even at lower heights, guardrails may be used, but still leave the potential for falling.  It’s a best practice to wear fall protection when using these machines and these machines have secure anchor points already ready to go for use.
• Use fall protection any time you’re using an aerial lift.
• Know your calculations on distance to know how to choose the right length of lanyard to protect your workers in a fall. You need to account for the fall, deceleration distance, harness elongation, swing hazards, the length of the D-ring to the bottom of the feet and a safety factor distance above the ground.
• Have a rescue plan to prevent suspension trauma and teach workers what they need to do to keep their blood circulating while suspended until help arrives. It only takes 5 minutes for them to become lightheaded, nauseous or unconscious.
• Only use anchorage points that have been designed to be so and have been certified to meet or exceed OSHA regulations. Engineered anchor point systems typically exceed regulations and are a safe option.  Do NOT use bad anchor points such as vents, stand pipes, railings, guardrails, air vents/ductwork, fixed ladders, skylights, light fixtures, electrical conduits, or air conditioning units.
• Use of ladders create fall injuries. Know how to properly use a ladder, keep 3 points of contact at all times, check ladders for damage, and set them on a solid, stable base.
• When was the last time you inspected your fall equipment? Make sure you are visually inspecting it before use and then conducting additional documented annual inspections.  If ANYTHING looks odd, remove it from use.
• Have your workers been trained in fall hazards? They must be trained prior to being exposed to that hazard, must understand the training and be retrained any time they exhibit inadequacies in knowledge or use of fall protection systems or equipment.

Below are some fall protection-related resources you can draw upon:

Toolbox Topic Material from the National Safety Council

OSHA’s Fall Protection Page:  https://www.osha.gov/fall-protection

Example Training Resources for Falls in General Industry

• • Fall Protection Powerpoint and Tests in English and Spanish
  • Fall Protection Powerpoint in English and Vietnamese

This Week’s OSHA’s National Safety Stand Down to Prevent Falls in Construction

• • Event Page
  • Resources

If you need help with fall protection safety compliance, contact us today!