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?

An Environmental Engineer's Journey

I apologize (to anyone who is listening) for the lengthy hiatus from this blog. Alas, life intrudes and I just haven't had anything interesting to blog about. That got me thinking: is there really anything about environmental work that is truly 'interesting?' Hmmm, why did I get into this field again?

I suppose it was vague ideas about making the world a better place to live . . . oh, that and it was definitely a leading edge career choice when I was in college. There wasn't even an 'environmental' engineering degree in those days. Sure you could get an 'environmental' subdiscipline with a Civil Engineering degree - which meant that basically you could design and run wastewater treatment plants - but that really didn't trip my trigger.

At the time, I was far more interested in environmental contamination and remediation. That could have something to do with growing up next door to the Chemical Corridor of Ashtabula, Ohio (once a booming part of the US war infrastructure), and having an NPL site almost in my back yard (Fields Brook). I suppose, too that the idea of carving out what I thought, in my young idealism, I needed in order to do 'real' environmental work held a certain appeal to my non-conformist side. I guess that's why I ended up in Agricultural Engineering at Ohio State (now called the Department of Food, Agricultural and Biological Engineering). At least there, they let me carve out my own path towards an engineering degree. I ended up in the soil and water engineering subdiscipline. For my MS, I did my thesis work on groundwater contaminant transport.

Of course, I was better off than my predecessors in the environmental field, who learned their job entirely on the fly (not to say that I didn't learn most of the real environmental work on the fly, mind you). Now there are degrees in Environmental Engineering. I've actually taken several courses toward a MS in Environmental Engineering through Findlay University. What I wouldn't have given to have some of these courses at the beginning of my career!

But back to my initial question, what is interesting in the Environmental field? Well, actually, looking back on my career, I've done some pretty neat stuff. My first job out of college was with a consulting firm. I got to do investigative drilling, and evaluate the results to determine the remediation path forward. When I moved back to Ashtabula County, Ohio, I got to be involved in some of the early work of the Ashtabula River Project, an innovative approach to cleanup coordination for the Ashtabula River Area of Concern (downstream of the Fields Brook NPL site) that has now been modeled in other places.

I worked at another facility where they treated hazardous waste (my introduction to a RCRA facility), and worked for several years on the program monitoring the contamination at old inactive units, and helping to develop the remedial action plans. Now, years later, as a consultant, I am actually witnessing those plans comes to fruition.

I also worked at a DOE decommissioning project. While I learned A LOT about environmental regulations while working on that project, I also vowed that I would NEVER work for the government again. Long story, probably mostly politically-incorrect, so I won't relate it here. While there, I did get to do some actual remediation project management work on one of the operable units associated with Fields Brook (not related to the DOE project, mind you). Completing the PCB cleanup, and certifying closure of the unit was probably one of my proudest achievements as an Environmental Engineer.

My foray into industrial environmental management was also frought with excitement, especially working for a reinforced plastic composites manufacturer (right around the time the Quad W MACT came out). There was a huge learning curve there, and the work was never really boring, but it was extremely demanding. If you've ever worked in industry, you know that in general it is always about efficiency. Unfortunately, I was doing the work of two people, with no end in site, and a sh**-load of 'new' work coming down the pike.

It definitely takes a dedicated person to become a career industrial environmental manager. I have since struck out on my own, and offer support services to those poor, over-worked, and generally over-looked environmental managers, many of whom are also tasked with managing the safety program. It is a career choice filled with challenges, and in the challenges are significant opportunities.

In fact, there are always new rules and regulations coming out, presenting new challenges, and new opportunities to demonstrate the rewards that environmental stewardship can have for a company. It is in facing these challenges head-on, and making the case for the business oppotunities present in the challenges that the excitement of an environemtnal management career reside.

Yes, the environemntal field is interesting - endlessly so!

So, does anyone else care to share their journey in the environemental field? I'd love to hear YOUR story!

Accounting and the Environment

“If all the accountants in the world were laid end to end – it would be a good thing.”

I used to tease my husband while we were in grad school with this quote. He was working toward a masters in economics, and at the time he was taking a series of honors accounting classes. His usual comeback was “I don’t want to be an accountant. I want to be the accounting boss. You have to understand what you manage.”

OK, entirely off-topic, right? Not really. There is a corollary to my husband’s philosophy: You cannot manage what you do not understand. Perhaps it is because I was in the throes of TRI (Toxic Release Inventory) report preparation that the topics of accounting and regulating came to mind. The vagaries of my interests tend to lead to some odd philosophical thoughts. This one caught my attention when it flitted through, and I decided that it was worth at least a brief essay attempt.

For those of you who do not know, TRI reporting is required every year for any industrial facility that ‘processes’ or ‘otherwise uses’ any of a list of 581 chemicals or 30 chemical categories above the reporting thresholds. If the threshold is exceeded, the facility must then account for what happened to that chemical through the facility processes that resulted in releases to each of the three environmental media:
• How much was emitted to the air?
• How much was released into surface water?
• How much was released to the land (i.e., managed in onsite waste management units or was sent off site for disposal)?

And my favorite: how much is projected to be released into the various environmental media in each of the next two years? Talk about polishing your crystal ball. After this past year, clients are quite uncertain about their production projections for the next month, let alone the next year!

Anyway, the data gathered is now submitted through the USEPA’s Central Data Exchange where it is compiled, validated, confirmed, and finally put out on TOXNET for perusal by the public. The TOXMAP feature is really quite interesting, and contains a phenomenal amount of data. You can, literally, see what is released in your back yard.

From an industry perspective, I know I anticipate the TRI reporting cycle with a dread akin to my annual visits to the OB/GYN (apologies to any male readers - you can insert dentist, if you prefer, but trust me, this analogy is more apt). It doesn’t matter how conscientious I am about my accounting practices, I always find something I’ve missed before. I spend so much time worrying about whether I’ve accounted for everything, I have little time, or energy, left over to actually make any headway on managing what I’ve measured, let alone understanding exactly why changes may have occurred.

Also, who selected the 581 chemicals and 30 chemical categories? Are these the worst, most toxic chemicals? Are there other chemicals that I should worry about? I always start with what I reported on the SERC (State Emergency Response Commission) report for the year, since its reporting requirements are much broader. But there isn’t always a lot of correlation, since the SERC reporting is based on the product, while the TRI reporting is based on specific chemicals, which may be in the products, some at low percentages. I also look at the air reporting, but it is done in even broader terms like volatiles and particulates (an exception being hazardous air pollutants, which generally do require individual emission tracking). In short, the TRI reporting really does end up being a process onto itself.

And while I applaud the collection and dissemination of data, I wonder, does it help to make our environment any cleaner? I fully adhere to the idea that you cannot manage what you do not understand (read as ‘measure’) but when has the measurement gone so far that we lose sight of the need to manage?

I finished the TRI reports for two clients on time (due July 1) – woot! For one client, I found a chemical that I missed last year. It’s a small percentage of a product, but they use enough of the product that the threshold was exceeded. We’ve made strides in reducing use of the nastier products at the facility. This particular one is really a fairly innocuous material, overall. It just happens to have a small percentage of a TRI chemical in it. Turned out that there was very little ‘released to the environment,’ but it was processed over the threshold so it has to be reported. Feels like the time I spent on this was a colossal waste.

I shouldn’t complain. This is what keeps me in business. But it irks me when it just seems like a bunch of busy work with no real benefit to the environment. Maybe that’s my general problems with the regulatory framework in the U.S. as a whole; a lot of busy work with little benefit; a self-sustaining bureaucracy that has lost touch with its intended purpose.

It is disheartening to me that picking up trash with my 4-year-old along the road feels more environmentally-relevant than performing my work as an environmental manager.

Go figure – literally.

Nature Always Rebuilds

It's been awhile since I updated. Life intrudes periodically, and the beginning of summer is usually when that happens. Once school is out, all five kids are underfoot, and it makes it hard to get work done, let alone anything extra. We took a wonderful vacation up to the family cabin on Tilden Lake in Ontario, Canada, and I was just looking at some of the pictures, and a topic came to mind that I decided to run with: nature rebuilds.

You see, this is my general problem with us humans; we're less interested in preserving the environment than we are in preserving the status quo. The honest to God truth is, the environment will do fine without us. It can rebuild, readjust, and recover from just about anything we humans can throw at it. It might look a little different, it might be less hospitable to us, and perhaps to other species, but it will go on.

As a testament to the tenacity and resilience of nature, consider the accompanying pictures, taken by my children during a canoe ride on Tilden Lake.

The first photo shows the rocky terrain of the area we visit. Tilden Lake is located in mid-Ontario province, where there is precious little soil. Highways have to be blasted through the landscape (a true wonder of human tanacity and ingenuity - really, I don't totally disdain my own kind). You can see in this first picture that the trees literally cling to the sides on the rocks, their roots reaching deep into the rock, and breaking it up to create their own 'environment' for life. It is truly amazing to see where things grow in this beautiful wilderness.

The second photo shows another strategy: rebuilding on the skeleton of the past. Here a dead, felled tree actually creates the start of a new island in the lake, providing a platform for new life. Honestly, how can you not be impressed by the ingenuity of nature itself.

So, admit it you measley human beings, what you're really interested in is preserving YOUR EXISTING ENVIRONMENT, not in preserving the environment itself. I mean, let's be honest with ourselves here, who doesn't believe that nature will come up with another species to take our place if we screw this up?

Web of Life and the Human Bias

I found the following explanation on an educational web site developed by the University of Illinois Extension:

Web of Life: An ecosystem is made up of all the living animals and plants and the non-living matter in a particular place, like a forest or lake. All the living things in an ecosystem depend on all the other things - living and non-living for continued survival - for food supplies and other needs. In some ways, the actions and reaction that take place within an ecosystem are like a spider web - when one strand is broken, the web starts to unravel. What affects one part of an ecosystem, affects the whole in some way.

I have always been fascinated by this analogy for an ecosystem. In fact, no defined ecosystem exists independent of another, so the analogy can be extended to encompass all life on the planet. NASA has even extended this concept beyond our planet to encompass space.

The one part of the description above that I take issue with is the broken strand analogy. A spider web, our apt web of life analogy, does not unravel if one strand is broken, or even if two strands are broken. Spider webs, and life, are much stronger, and more resilient than that.

The final statement, that what affects one part of an ecosystem affects the whole in some way, is very true. If something changes, the entire system must adjust, or adapt, to that change. Sometimes the adjustments are catastrophic for other parts of the system, sometimes beneficial, but the change itself is unavoidable.

This brings us to what I call the human bias in the web of life: avoidance of change. Change is an inevitable part of life. Ecosystems, like all living organisms, rise and fall, but life goes on. Perhaps not as we currently know it, but life does go on.

I look at it this way, if change did not occur, we humans, as a species, would never have come into existence. And try as we might, there is no way we can exist on this planet and not have an impact on the system of life in which we live. It is a fallacy to think we can.

Change is inevitable. Adapt or die - as a species this is our 'choice.' Trying to maintain the status quo is an impractical strategy. Instead we need to explore ways to bring our way of living into harmony with the ever-changing world around us.

So what's my point. Let's take the greehouse gas (GHG) regulatory-behemoth-in-the-making that is the current hot environmental topic. Is counting GHGs and creating a cap-and-trade system going to help us to live in harmony within our ecosystem? I have my doubts. It seems more about accounting than anything else (see the GHG calculators available everywhere online). I am pleasently surprised at the increasing focus on developing renewable energy sources - wave generators, wind farms, current turbines - these are all examples of human ingenuity tapping into the living energy available all around us. Maybe GHG regulation will accomplish something in moving us closer to the ideal.

I truly hope so.

CALEB'S CARNIVAL - May 23, 11am-5pm, by CCGM

This post isn't really environmentally related, but it is on a subject near and dear to my heart, so I hope you'll indulge me!

It’s spring at the Market, and besides veggies, flowers, and hanging baskets, it is time for our annual fund raiser for the Leukemia & Lymphoma Society: Caleb’s Carnival.
First, I thought it might be good to provide an abbreviated history of Caleb’s Carnival. It is named for a remarkable little boy from Conneaut, Ohio who has a disease called Chronic Myelogenous Leukemia or CML for short. He was diagnosed two years ago, in July 2007. He spent 5 days in the Pediatric ICU, followed by 10 days in the Immunodeficiency Ward, and during that entire time, he was unflagging in his cheerfulness, even given the poking, prodding and general discomfort of what he was going through.
Now, two years later, Caleb is in remission. All he has to do is take three little pills a day, and the leukemia that had distended his spleen to the point that it took up nearly his entire abdomen, is held at bay. It is a miracle; and would not have been possible without the hard work and dedication of the researchers at Novartis, and the funding from the Leukemia & Lymphoma Society (LLS).
So when Aunt Babe decided to become a very active participant in the LLS Light the Night Walk, we joined her whole-heartedly in forming Caleb’s Walkers. Brainstorming ways to raise money for this worthwhile and now very personal cause, Caleb’s Carnival was born. We held the first annual Carnival on Caleb’s birthday in 2008, and the event was a wonderful success. We think this year will be even better.
Heather Lindberg and Carnival’s for a Cause have put together a wonderful lineup of family fun for the day, including tug of war, egg toss and a sack race, as well as other games for the kids, with some great door prizes generously donated by local businesses and friends (I’ll get a list posted soon, thanking everyone – I’m constantly blown away by everyone’s generosity).
In addition, there will be food provided by Sav-a-Lot and the Conneaut High School Music Boosters, as well as barbecue from Smokin’ T’s. Brad’s Bouncy House in Erie will be providing a space for kids to work out some of their energy. There will be musical entertainment provided by the Erie Traveler’s and friends. And we are very excited to have two of the Cleveland Cavaliers’ Cheerleaders coming to sign autographs and join in some of the fun activities.
We hope you’ll be able to join us on May 23, 2009 between 11am and 5pm in Chapin’s lot, next to the City Center Garden Market. The Market will be donating 5% of the sales from that day to the LLS in honor of Caleb, and is accepting cash donations ahead of the Carnival as well. Or, you can donate online at our donations page.
But we really hope you’ll be there to wish Caleb a happy birthday and join in the festivities!

Nature Walk Photo Essay

Quin the explorer heading down the hill leading to Bluebell in Conneaut, Ohio.

This past spring has been hard on the road. The erosion channel cut into the road bed is up to a couple feet deep in some places.

Quin thinks it’s a great waterfall.

ODNR Property Marker related to the designation of Conneaut Creek as a State Wild & Scenic River.

Quin and I walked up the old road approach to the bridge. The wooden decking is long gone, and the grapevines are taking over. In the upper left hand corner of the photo (left) you can see where the bridge frame is propping up a large old sycamore – shown from below in this photo (below)

At the top of the bow of the Creek, the far bank is eroded by the faster-moving water, while on the side Quin and I were on, large deposits of alluvial material (in this case, sand) occur.

Around the bend, we found our old friend, Mr. Canadian Goose. He didn’t puff and preen at us today, though – he just took off!

Weathered shale is deposited all along Conneaut Creek, as it forms the Creek bed. Deposits like this are prime placed to find fossils!

Quin the archaeologist, in search of ‘pretty rocks.’

We found some cool stones, like this weathered coral fossil (I think?)

I call these ‘lake bottom’ fossils – not sure the appropriate term – it’s like the bottom a some long-ago lake was frozen in time in the shale.

In this particular section of the Creek, several layered oxbow ‘lakes’ (more like ponds) have been created. During high water, these oxbow may still carry water, but for the most part they are stagnant ponds, that may even dry up during the summer.

Quin the environmentalist helps with litter pickup. We have gotten into the habit of carrying a bag for garbage when we walk down here. It was full by the time we got back home.


Deer track, in addition to other wildlife, are fun to find.

This time of year, the signs of spring are just beginning to emerge, but the skeletal trees along the Creek are beautiful in their own right. The water in the Creek was muddy today. Rain and snowmelt carry sediment via overland flow, creating the muddy condition. When the Creek is at base flow the water is crystal clear, and COLD. The groundwater that contributes the base flow of the Creek stays right around 56 degrees F year round.

Quin took a little rest in this tree by the Creek –

but not for long. He was up and adventuring again, in short order!

Views of the Creek looking downstream, the way we’d come (left) and upstream towards home (above). Our home is only about 1500 feet upstream of here, but lies approximately 60 feet above the flood plain.

Quin the conqueror on a concretion weathered out of the shale at the edge of the water. We find small concretions, as well as quite a bit of flint, Ohio’s official gemstone.

The road home. Quin and I really enjoy our walks together. We’ll begin expanding our wanderings, and I will try to remember the camera so we can document our adventures!