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EDITOR’S NOTE: This is the third in a three-part series that excerpts the Chemical Safety Board’s (CSB) spotlight on the importance of safety guidelines, codes and standards to the manufacturing automation industry. This segment talks about dust hazards.

Three combustible dust incidents occurred over a six-month period in 2011 at the Hoeganaes facility in Gallatin, Tennessee. The first iron dust flash fire incident occurred on January 31, 2011, and killed two workers. The second occurred on March 21, 2011, and injured one employee. The third incident, a hydrogen explosion and resulting iron dust flash fires, occurred on May 27, 2011, and killed three and injured two other workers.

The Chemical Safety Board (CSB) reviewed pertinent safety codes and standards as a part of its investigation and found the State of Tennessee and the City of Gallatin had adopted the 2006 edition of International Fire Code (IFC), a product of the International Code Council (ICC), into law.

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The CSB noted that Chapter 13 of the IFC (2006), entitled Combustible Dust-Producing Operations, briefly addresses precautions for ignition sources and housekeeping in areas where combustible dust is generated, stored, manufactured, or handled. The IFC also references several NFPA standards, such as NFPA 484, Combustible Metals, Metal Powders, and Metal Dusts, and specifies that “the fire code official is authorized to enforce applicable provisions of the codes and standards listed … to prevent and control dust explosions.” This language did not specify, however, whether compliance with and enforcement of the referenced NFPA standards were mandatory or voluntary in the IFC.

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The CSB concluded had the Hoeganaes facility adhered to the requirements of this chapter, including the more detailed design and engineering requirements contained in NFPA 484, the January and March incidents may have been prevented, and the effects of the May incident could have been reduced. The CSB, therefore, issued a recommendation to the ICC to revise the language in Chapter 22 of the most recently published IFC: Revise IFC Chapter 22 Combustible Dust-Producing Operations; Section 2204.1 Standards, to require mandatory compliance and enforcement with the detailed requirements of the NFPA standards cited in the chapter, including NFPA 484.

In response to the recommendation, the ICC made the following changes to Chapter 22 of the 2018 edition of the IFC, entitled Combustible Dust-Production Operations:
• Section 2204.1 has been renamed with the title “Specific Hazards Standards” and the text has been revised to read as follows: “The industry- or commodity-specific codes and standards listed in Table 2204.1 shall be complied with based on the identification and evaluation of the specific fire and deflagration hazards that exist at a facility.”
• Table 2204.1 has been renamed “Specific Hazard Standards” and contains a listing of the following NFPA standards: 61, 69, 70, 85, 120, 484, 654, 655, and 664.
• Two new sections have been added to Section 2203 entitled “Precautions.” Section 2203.1, entitled “Owner Responsibility” has been added which states: “The owner or operator of a facility with operations that manufacture, process, blend, convey, repackage, generate or handle potentially combustible dust or combustible particulate solids shall be responsible for compliance with the provisions of this code and NFPA 652.” Section 2203.2 entitled “Dust Hazard Analysis” has also been added which states: “The requirements of NFPA 652 apply to all new and existing facilities and operations with combustible dust hazards. Existing facilities shall have a dust hazard analysis (DHA) completed in accordance with Section 7.1.2 of NFPA 652. The fire code official shall be authorized to order a dust hazard analysis to occur sooner if a combustible dust hazard has been identified in a facility that has not previously performed an analysis.”

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