ASSE not in favor of single, universal combustible dust standard (12/15)
ASSE federal representative Adele Abrams said, “ASSE can support a new combustible dust standard but only one that is no less effective than the NFPA’s voluntary consensus standard NFPA 654: Standard on Prevention of Fire and dust Explosions from the Manufacturing, Processing and Handling of Combustible Particulate Solids.
Abrams noted that managing combustible dust risks is a common responsibility for ASSE occupational safety, health and environmental professional members and their collective experience and training provide the basis for these comments.
“Any substantive diversion from what already is being used successfully now in industry can only lead to unneeded new complexities and confusion in the already complex set of risks that combustible dust poses to employees,” Abrams said. “The NFPA standards are updated and revised on a regular basis to reflect current conditions, allowing stakeholders in the voluntary consensus process, including ASSE members, to incorporate changes and advancements they learn directly from the front lines of managing combustible dust risks.”
Abrams went on to note that most importantly, the NFPA dust explosion standards are categorized according to industry.
“We do not see how a single standard or a standard that seeks to provide an overarching framework to the existing standards can work better than what has already been accomplished in the NFPA standards,” Abrams said. “Also, an industry-specific approach is more consistent with international approaches such as the European Union’s ATEX guidelines. This is an important consideration as OSHA moves towards global harmonization of hazard communications and other safety and health management systems.
“OSHA plays an important role in helping advance improved harmonization with international standards that help this nation’s employers compete better in global marketplaces, and this role cannot be overlooked,” she said.
Abrams also discussed possible outreach programs aimed at educating workers and employers on combustible dust as well as educating OSHA field staff on the complexities of the combustible dust issue in an effort to enhance safety efforts.
Abrams noted that NFPA 654 is being updated, with the current revision scheduled to be completed in 2011.
“We urge OSHA to work closely with the committee and approach a new standard deliberately so that a final rule can reflect the best and latest perspective on addressing combustible dust risks that the voluntary consensus process can produce,” Abrams said. Abrams also discussed the issue of how to update standards and other specific concerns involving combustible dust issues.
“That OSHA should base a standard on widely accepted voluntary consensus standards is fully consistent with the duty established under Public Law 104-113, the National Technology Transfer and Advancement Act of 1995. Congress ordered that all federal agencies and departments shall use technical standards that are developed or adopted by voluntary consensus standards bodies, using such technical standards as a means to carry out policy objectives or activities determined by the agencies and departments,” Abrams said.
In conclusion Abrams noted, “Through an effective standard based on what has been demonstrated to work and increased cooperative efforts to raise awareness and understanding, we can improve adherence to widely accepted practices of managing combustible dust risks.”
Interested parties have until January 19, 2010, to offer written comments on OSHA's combustible dust Advance Notice of Proposed Rulemaking. Combustible dusts are solids ground into fine particles that can present a fire or explosion hazard when suspended in air. Among the many materials that can become combustible dust are wood, plastics, rubber, metals, coal, grain, feed, soap, sugar and fertilizer.