“I will show you fear in a handful of dust.” — T.S. Elliot OSHA does not have a combustible dust regulation. Instead, it relies on a hodge-podge of regulations combined with the General Duty Clause. If someone wants to understand what OSHA expects in terms of combustible dusts, they must turn to OSHA’s Combustible Dust [...]
“My life experience confirms that the U.S. government frequently overclassifies data.” — Michael Hayden When it comes hazardous (classified) locations—electrical classification—even seemingly sophisticated technical facilities often get it wrong. The issue isn’t with the class, or the group, but with the division. Getting the division wrong, though, can render a facility more hazardous than it should [...]
“The essential act of war is destruction, not necessarily of human lives, but of the products of human labor.” — George Orwell Yesterday afternoon, I was asked what I knew about the granary explosion that happened in Poland, killing two workers. I hadn’t heard of it, but my thoughts immediately went to NFPA 652, the [...]
“Take off your sweater in the darkness and static flares as a tiny lightning storm.” — John Geddes The dry air of winter makes it much more likely that we will be shocked by static sparks. So instead of visions of sugar-plums dancing in their heads, the thoughts of many of our clients turns to [...]
“Speed limit 55. It’s not just a good idea. It’s the law.” — Advertising Council and U.S. Department of Transportation (1977) Ever since the National Fire Protection Association (NFPA) published the 2019 Edition of NFPA 652, Standard on the Fundamentals of Combustible Dust, which states in §7.1.1.2 that a Dust Hazard Analysis (DHA) must be [...]
“Electricity can be dangerous. My nephew tried to stick a penny into a plug. Whoever said a penny doesn’t go far didn’t see him shoot across that floor. I told him he was grounded.” — Tim Allen When I was fresh out of grad school, I had a job in process development. One project involved [...]
“We have first raised a dust and then complain we cannot see.” — George Berkeley You don’t need to be convinced that combustible dusts are hazardous. You’ve seen the photographs of demolished grain elevators, of the Imperial Sugar plant in Port Wentworth, Georgia looking like the Dresden firebombing in World War II. You’ve heard about [...]
“If you do not expect the unexpected you will not find it, for it is not to be reached by search or trail.” –Heraclitus I work for a process safety consulting company and we often participate in community events that bring members of the general public through our door. The first question we always encounter [...]
“A mighty flame follows a little spark.” Dante Alighieri Sparks can cause fires. Good news if you want fire. Bad news if fires, or worse, explosions, are something you want to avoid. So, it should come as no surprise that the National Fire Protection Association takes a dim view of sparks. The Dust Hazard Analysis [...]
“Issuance of this Citation does not constitute a finding that a violation of the Act has occurred.” —from OSHA Citation and Notification of Penalty On October 29, 2011, a grain elevator explosion in Atchison, Kansas killed six men—four employees and two grain inspectors. OSHA cited the Bartlett Grain Company’s facility and proposed a fine of [...]
