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How come California with more manufacturing facilities than any other state (approx. 40,000 establishments-U.S. Census Bureau-2010) yet has a lower rate of combustible dust related incidents than any other state? Could it be that they require fire prevention plans (FPP) for all facilities whereas other states don't? Shouldn't a state with the highest number of facilities also have the highest number of incidents? Quite interesting accidentally connecting the dots between combustible dust related incidents in a preliminary analysis of 2011 Natoal Fire Incident Reporting System (NFIRS) data and fire prevention plans (FPP) 29 CFR 1910.39.
It’s back to school for us all after coming across this helpful resource with the University of California Riverside's Fire Prevention Plan (FPP) providing an excellent framework with FPP key elements as required by the California Code of Regulations (CCR) Title 8, Section 3221. http://www.dir.ca.gov/title8/3221.html The detailed FPP document includes a section on Fire Extinguishers where "all faculty and staff are annually provided the opportunity to receive hands-on training and experience in using portable fire extinguishers."
California is one of the approved State Plan States http://www.osha.gov/dcsp/osp/index.html that went beyond minimum federal OSHA regulatory requirements concerning FPP's (Exemptions. 1910.157(b)(1)) http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9811 For example, California facilities not requiring the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal are required to have a Fire Prevention Plan (CCR Title 8, Section 3221).
Whereas Federal OSHA states don’t require a Fire Prevention Plan (FPP) in this scenario unless the facility follows under one of these three host standards: Ethylene Oxide, 1910.104, Methylenedianiline, 1910.1050, and 1,3 Butadiene, 1910.105. Additionally FPP required where the written fire safety policy requiring the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal. http://www.osha.gov/OshDoc/Directive_pdf/CPL_2-1_037.pdf
With a bit of imagination the University of California Riverside's Fire Prevention Plan (FPP) provides an excellent framework for a voluntary FPP’s which should include controlling ignition and fuel sources in the prevention of combustible dust fires and explosions.