Is your air permit up-to-date, and are you in compliance? Did you file your Form-R report for the Environmental Protection Agency’s (EPA) Toxics Release Inventory? Do you conduct regular workplace safety audits and maintain the Occupational Safety and Health Administration (OSHA) logs for injuries and illnesses? Are gloves, respirators and other safety equipment being used where needed?
These are important, well-known and accepted components of the compliance programs employed by many composites manufacturers. However, the list has grown, and some recently identified hazards and required practices probably need to be added. Here are a few:
Following several fatal workplace accidents related to combustible dust, the U.S. Chemical Safety Board recently called on OSHA to improve the safety of operations that potentially generate combustible dust hazards. OSHA, under what it calls its national emphasis program, is actively inspecting workplaces for combustible dust and issuing citations where uncontrolled hazards are found.
Any material capable of oxidation – including, for example, grinding dust from finishing operations in composites shops – can explode if small particles are distributed in the air and an ignition source is present. When inspecting workplaces, OSHA looks for several measures to reduce the risk of combustible dust incident, including:
- Regular housekeeping programs to minimize accumulation of dust on surfaces, including rafters and other out-of-the way places.
- The use of listed electrical equipment in areas where dust is present, such as grinding booths.
- The location of bag houses, cyclones and other equipment outside of buildings and away from workers.
OSHA’s Hazard Communication Standard (HCS) requires employers to provide information, training and warning signs describing health risks and protective measures for many of the chemical substances employed in composites manufacturing. In most industries, including composites manufacturing, employers rely on safety data sheets and container labels provided by suppliers and largely do not conduct their own hazards and control assessment.
This approach however is not sufficient when a hazardous material is created during the composites manufacturing process. Such is the case with combustible dust. In shops where the grinding, sanding or cutting of molded composite laminate creates dust, OSHA has issued citations for failure to include combustible dust hazards in the employers’ HCS program.
Further, employers also are required to use safety data sheets and labels to warn downstream customers and their employees of combustible dust hazards if the customers are known to grind, sand, cut or otherwise work the composite product in a manner that creates dust.