OSHA’s New Push on Combustible Dust and Lint … and What Laundries Need to Know

WASHINGTON — The Occupational Safety & Health Administration (OSHA) has recently taken more action to impose fines and enforce regulations concerning combustible dust and lint in laundry facilities.

This extra attention has translated into a regulatory push for higher standards and the potential for significant fines for lack of compliance.

To avoid possible penalties, laundries should examine legislation such as House Bill H.R. 5522—the Worker Protection Against Combustible Dust Explosions and Fires Act of 2008—that pushed to mandate stringent new standards for this area to be enforced by OSHA. (Editor’s note: While passed by the House, this bill did not become law.)

SUGAR PLANT FIRE REIGNITES OSHA INTEREST

OSHA’s interest in this area was reignited in February 2008 when a tragic fire in a sugar plant—sparked by combustible dust—killed 13 employees and seriously injured 60. To prevent more disasters of this type, the U.S. House of Representatives required that OSHA enforce NFPA 654 Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids for all industries.

Essentially, OSHA is putting teeth to the National Fire Prevention Association (NFPA) standards last issued in 2006 in a systematic and rigorous way. OSHA is now required to look at combustible dust and lint issues even if the inspection is precipitated by other concerns (OSHA Directive CPL 03-00-008).

The House passed its bill to enforce a new standard on combustible dust buildup for overhead and walls for all industries. Let’s walk through the specifics to identify what portions affect laundries.

• The goal of NFPA 654, according to Chapter 1-1.3, is to “…provide safety measures to prevent and mitigate fires and dust explosions in facilities that handle combustible particulate solids.” The term “combustible particulate solids” includes combustible dust, which is defined in Chapter 1-3.34 as material that “…presents a fire or deflagration hazard when suspended in air…regardless of particle size or shape.”
• Annex A1.1 states, “…Examples of industries that handle combustible particulate solids, either as a process material or as a fugitive or nuisance dusts include…fibers and textile materials.” [Emphasis added]
• In Annex D.2 (1) A.3.34, it continues: “…it can be inferred that any particle that has a surface area to volume ratio greater than that of a 420µm diameter sphere should also be deemed a combustible dust. Any time a combustible dust is processed or handled, a potential for deflagration exists.”

It follows that it is imperative to reduce significant dust accumulation to reduce the risk of fire.

• 
  A specific requirement is made in Chapter 6.2.3.1: “When separation is used to limit the fire or dust explosion hazardous area, the hazardous area shall include areas where dust accumulations exceed 1/32 inch (0.8mm).” This is explained in Annex D.2. (1): “Dust layers 1/32 inch (0.8mm) thick can be sufficient to warrant immediate cleaning of the area...1/32 inch is about the size of a diameter of a paper clip wire or the thickness of the lead in a mechanical pencil.” [Emphasis added]
• Then another calculation is issued in D.2. (2-4): “The dust layer is capable of creating a hazardous condition if it exceeds 5% of the building floor area. Dust accumulation on overhead beams and joists contributes significantly to the secondary dust cloud…The 5% factor should not be used if the floor area exceeds 20,000 sq. ft. In such cases, a 1,000 sq. ft. layer of dust is the upper limit.” [Emphasis added]
• Still another factor is identified in Annex D.1: “…Rough calculations show that the available surface area of the bar joist is about 5% of the floor area. For steel beams, the equivalent surface area can be as high as 10%.”

The practical reality is that these requirements mean there is a zero-tolerance approach to dust and/or lint buildup in a plant. Laundries must find ways to deal with this issue or risk penalties for noncompliance.

RECOMMENDED HOUSEKEEPING

Implicit in H.R. 5522 is the adoption of the following NFPA 654 requirements:

• Chapter 8.2.1.2 — “Regular cleaning frequencies shall be established for walls, floors, and horizontal surfaces, such as equipment, ducts, pipes, hoods, ledges and beams and above suspended ceilings and other concealed surfaces to minimize dust accumulations within operating areas of the facility.” [Emphasis added]

• Chapter 8.2.2.2 — “Surfaces shall be cleaned in a manner that minimizes the generation of dust clouds. Vigorous sweeping or blowing down with steam or compressed air produces dust clouds and shall be permitted only where the following requirements are met:

1. Area and equipment shall be vacuumed prior to blow-down.
2. Electrical power … and other sources of ignition shall be shut down or removed from the area.
3. Only low-pressure steam or compressed air, not exceeding a gauge pressure of 15 psi (103 kPA), shall be used.” [Emphasis added]

Clearly, the imperative is to comply with these strict standards through frequent and regular cleaning.

But what are workable ways to accomplish that?

PRACTICAL NEXT STEPS FOR LAUNDRIES

There are different ways to address OSHA’s stepped-up enforcement.

One approach is to manage the dust/lint buildup with a localized filtration option in which a portion of the lint is captured with a sucking action of the equipment. Some type of manual or automated blow-down also needs to take place to comply with OSHA directives in this scenario.

The other approach uses enterprise-wide “clean fan technology.” With this type of system, blow-down is used exclusively. This approach is similar to the one used by textile plants 50 years ago when they were forced to find solutions to prevent the accumulation of lint and dust.

Management should evaluate the overall cost for any solution based on a range of variables, including initial cost, operating cost, ongoing labor cost, employee morale, and disruption to normal processing in the facility.

In addition, calculating the energy usage required of either the localized or enterprise-wide option is important. Vendors offering either solution should be ready to answer any questions regarding energy usage and associated operating costs.

Laundries need to be diligent to find the best solution to keep their facilities in compliance with safety regulations, avoid fines and protect their employees.