Combustible Dust: Performance and Specification Based Approaches

by admin on June 29, 2010 · 3 comments

During the stakeholder meetings, there was considerable discussion as to whether OSHA should take a performance versus a specification based approach towards regulating combustible dusts.  OSHA is aware that employers want compliance options but is interested in your opinions about how best to provide regulatory flexibility. OSHA is considering a balance of performance based and specification based requirements.

With that in mind, which administrative controls and engineering controls are better addressed by performance-based requirements and which are better addressed by specification-based requirements?

{ 3 comments… read them below or add one }

1 J Romine July 1, 2010 at 7:29 pm

I feel that employee training and housekeeping (specifically equipment allowed to conduct the housekeeping) need to be specification based if there is an expectation of compliance. The 1/32″ (dime or paperclip thinckness) while tough seems to be the best measure of an issue.

Risk assessment is better handled as performance based unless you can provide a specific assessment tool that can be used (which would be a wonderful thing).

2 Gordy Koch August 10, 2010 at 11:27 am

I participated in the web chat on June 28th, and in a response by the Comb. Dust Team (1:41) I was asked to provide input regarding training provisions. This is the best area of the blog that I could find to leave my comments.

I researched the OSHA regulations for a requirement to document combustible dust training under OSHA29CFR1910.1200(h), and do not specifically find it in this standard. I concur that it would be appropriate to provide detailed, chemical-specific training under 1200(h) for manufactured or imported chemicals that could be labeled, and for which a MSDS (under Hazcom) or SDS (under proposed GHS) is prepared.

Combustible dust is properly addressed by the National Fire Protection Association (NFPA) as a fire hazard, and the NFPA standards are the current consensus standards for combustible dust hazards. I encourage OSHA to align housekeeping fire hazards and training documentation logically under the Fire Prevention Plan, 29CFR1910.39(c), as quoted below:

1910.39(c)
Minimum elements of a fire prevention plan. A fire prevention plan must include:
1910.39(c)(1)
A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard;
1910.39(c)(2)
Procedures to control accumulations of flammable and combustible waste materials;
1910.39(c)(3)
Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials;
1910.39(c)(4)
The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires; and
1910.39(c)(5)
The name or job title of employees responsible for the control of fuel source hazards.

Thank you, Gordy Koch, CHCM

3 whatisthis April 4, 2011 at 7:17 pm

Thank you for this great piece of content. Best Regards

Leave a Comment

Previous post:

Next post: