OSHA's Hot Topic: Combustible Dust

I was reading an article relating OSHA's Top 10 Safety Violations for 2009 and it struck me that there was no mention of an issue that I am certain ranks pretty high on OSHA's list of problems: Combustible Dust.

Who hasn't heard about the Chemical Safety Board's investigations regarding combustible dust? Since then, there have been numerous additional incidents contributed to combustible dust. OSHA reissued its Combustible Dust NEP in 2008 and Congress got into the act with the Combustible Dust Explosions and Fires Act of 2008. I'd definitely say that combustible dust is a hot topic for OSHA. So why isn't it in OSHA's Top 10 list?

Well, until OSHA develops it's own standard for combustible dust, it is citing employers on combustible dust issues under the General Duty Clause. As a result, combustible dust is invisible to a top ten list. However, in their Combustible Dust NEP Status Report OSHA found over 4900 violations during inspections conducted pursuant to the NEP. If you are a safety professional, and you have not yet read this report - DO SO NOW.

I have a client that has spent the last year addressing the violations with which they were cited under this NEP. We had discussed the issue previous to the inspection, but they were confident that their dust was non-combustible. Wrong. If you don't know, have your dust(s) tested to find out if it is combustible. If it is, you better start evaluating the hazards in your workplace and taking appropriate corrective actions. Itis going to take time, so get started now, and do your homework. Costs are high for corrective measures, but the costs of an incident are higher.

So, if you checked over OSHA's top 10 list and decided you were in good shape, think again. Combustible dust is a hot topic, and one you need to seriously evaluate in your workplace. OSHA has a decent resource page on combustible dust. NFPA 654 is the primary standard for general industry, and until OSHA develops their own standard, is likely the place to go for guidance. To keep up with the latest on combustible dust, visit the Combustible Dust Policy Institute blog.

Have you reviewed your workplace for combustible dust hazards?