OSHA has recently cited composites manufacturers for failing to employ rigorous housekeeping practices, for the use of unapproved electrical equipment and for failing to locate outdoors dust handing equipment such as cyclones. These citations are part of the agency’s Combustible Dust National Emphasis Program (NEP), designed to address the risk of dust fires and explosions in polymer, grain, metals and other industries.
OSHA institutes NEPs to call attention to an important workplace hazard while the agency prepares a comprehensive standard. OSHA expects to issue a proposed combustible dust standard by 2016, and in the meantime will collect information on industry practices and small business impacts of control options.
The National Fire Protection Association is also developing a new general standard for combustible dust (NFPA 652), and is updating the industry-specific standard that applies to composites manufacturing operations (NFPA 654). Building code officials and insurance companies use NFPA standards. OSHA is expected to rely on the NFPA standards, especially NFPA 652, as it develops its mandatory standard.
ACMA staff is not aware of any composites dust that did not test as hazardous using OSHA’s approved test methods. To reduce combustible dust hazards and avoid citations, composites manufacturers should employ regular housekeeping to keep dust levels below hazardous levels, use listed electrical equipment in dusty process areas, and locate cyclones and bag houses outdoors. More information on combustible dust for composites manufacturers is available on ACMA’s website.
In addition, if OSHA adopts NFPA’s general standard, composites manufacturers and other employers will conduct process specific hazards analysis programs, install process specific controls, and institute formal management of change programs. It is not clear that these practices are either necessary to address combustible dust hazards in composites manufacturing operations, or feasible for smaller companies.
ACMA expects to work with OSHA to ensure that the mandatory standard provides adequate protection for employees while fitting the technical and financial resources of composites manufacturers.