>Just over 2 yrs ago an area near Savannah, Georgia was rocked by a large explosion and fire at the Imperial Sugar facility. The ultimate cause of the explosion where several employees died was the apparently harmless dust that had accumulated in many places in the plant. That dust when, suspended in the air, became extremely explosive.
As a result of that one incident the focus was put on all industries that can generate dust. The first agency to make issue with combustible dust was the Georgia Fire Marshall’s office. Insurance Commissioner John Oxendine took the first swing at regulating dust in industrial facilities. That process hasn’t been completed but about the same time, Congress began to look into combustible dust and hearings started into a federal law that would govern combustible dust. In the mean time, OSHA has decided to look at combustible dust.
OSHA already has precedent in working with combustible dusts. All grain handling facilities have been subject to rules on dusts for nearly 30 years. Those rules speak a great deal to housekeeping and reducing accumulations of dust in the various parts of an elevator. These rules were developed in response to a rash of grain dust explosions in 70’s and early 80’s. It was developed with the joint work of industry and OSHA and has been hugely successful. Injuries and deaths from grain dust explosions in covered facilities has dropped to nearly zero thanks to those regulations.
The first outlines of a new OSHA rule dealing with combustible dusts is a very broad reaching rule that any facility that has any dust accumulations ,regardless of agriculture or general industry, would be subject to. OSHA officials have held a number of listening sessions across the country over the past several months and we are awaiting the next draft. After attending one of those sessions, I can say it appears they are going to rely heavily on the National Fire Protection Association (NFPA) for guidance. NFPA has had standards in place as part of the fire code and OSHA may bring those regulations in as OSHA regs or they my write their own. We’ll have to wait for a proposed rule to find out.
In the mean time, cotton gins certainly have dust but we’ve never had an explosion in a gin. Fires are much rarer than they used to be in fact. Nonetheless, it appears that OSHA could specifically include gins in this new regulation because of a mis-identified fire in California a number of years ago. An incident was called an explosion and it was just a lint fire. If OSHA uses similar reports to define the scope of the new rule, we could indeed be brought in under it.
So where does that leave us? At the Beltwide Cotton Conference this year, attendees heard that tests performed at Texas A&M showed that dusts found around a gin would not support combustion at any concentration. Southeastern Cotton Ginners Association joined with the National Cotton Ginners and others in writing comments asking that this information be considered and that gins be excluded from the scope of any new rule that is developed. We are attempting to get the report in CA changed and other measures to attempt to stay out from under this unnecessary and potentially burdensome regulation.
We’ll be monitoring OSHA for more information and expect movement sometime this summer.