California Lower Rate of Combustible Dust Related Incidents Due to FPP?


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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. 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 that went beyond minimum federal OSHA regulatory requirements concerning FPP's (Exemptions. 1910.157(b)(1)) 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.

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.

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California Lower Rate of Combustible Dust Related Incidents Due to FPP?

  1. 1. California Lower Rate ofCombustible Dust Related Incidents Due to Required Fire Prevention Plans (FPP)? California Code of Regulations (CCR), Title 8, Section 3221 Combustible Dust Policy Institute © 1
  2. 2. Written Fire Prevention Plan (FPP)California Requirements- CCR Title 8, Section 3221 All Facilities List of all major fire hazards; Proper handling and storage procedures for hazardous materials Potential ignition sources and their control; Type of fire protection equipment necessary to control each major hazard; Procedures to control accumulations of flammable and combustible waste materials Combustible Dust Policy Institute © 2
  3. 3. Written Fire Prevention Plan (FPP) California Requirements All Facilities-continued Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials Name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires; and Name or job title of employees responsible for the control of fuel source hazards. Combustible Dust Policy Institute © 3
  4. 4. Written Fire Prevention Plan (FPP) Federal OSHA Requirements 29 CFR 1910.39 Federal OSHA standards requiring fire prevention plans (FPP) are triggered by one of the following three host standards: -Ethylene Oxide, 1910.1047 -Methylenedianiline, 1910.1050 -1,3 Butadiene, 1910.1051 Combustible Dust Policy Institute © 4
  5. 5. Written Fire Prevention Plan (FPP) Additional OSHA RequirementPortable Fire Extinguishers, Exemption 1910.157(b)(1)Where the employer has established and implemented a written fire safety policy which requires the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal and which includes an emergency action plan and a fire prevention plan which meet the requirements of 29 CFR 1910.38 and 29 CFR 1910.39 respectively, and when extinguishers are not available in the workplace, the employer is exempt from all requirements of this section unless a specific standard in part 1910 requires that a portable fire extinguisher be provided. Combustible Dust Policy Institute © 5
  6. 6. Fire Prevention Plans (FPP) 29 CFR 1910.39 National Summary Fire Prevention Plans (FPP) RequirementsFederal OSHA States Not Required at All FacilitiesCalifornia State Plan Required All Facilities California Code of Regulations, Title 8, Section 3221 Combustible Dust Policy Institute © 6
  7. 7. Top Ten Manufacturing States USA Manufacturing Establishments Top Ten States State # Establishments California 38,937 Texas 19,593 New York 16,933 Ohio 14,729 Illinois 14,210 Pennsylvania 14,167 Florida 12,616 Michigan 12,378 Wisconsin 9,033 North Carolina 8,963 U.S. Census Bureau-2010 Combustible Dust Policy Institute © 7
  8. 8. California Manufacturing Establishments Approximately 40,000 establishments Over 1,000,000 workers 11.7% Manufacturing’s Share of Total Gross State Product Number of Manufacturing Establishments Leading State in the Nation Source: U.S. Bureau of Economic Analysis and U.S. Census Bureau Combustible Dust Policy Institute © 8
  9. 9. Top California Manufacturing Sectors (In Millions of Dollars in 2010) Computer & Electronic Products Petroleum & Coal Products Food & Beverage Products Chemicals Fabricated Metal Products Machinery Transportation Equipment Plastics & Rubber ProductsSource: U.S Bureau of Economics Combustible Dust Policy Institute © 9
  10. 10. Combustible Dust Related IncidentsTop Ten Incident States (2011 NFIRS) Combustible Dust Related Incidents (2011) Top Ten States State # Incidents # Establishments Wisconsin 50 9,033 Ohio 40 14,729 North Carolina 30 8.963 Virginia 29 5,313 California 26 38,937 Georgia 25 7,683 Minnesota 22 7,377 Texas 22 19,593 Illinois 20 14,210 Washington 19 7,050 2011 NFIRS Data-CDPI Analysis Combustible Dust Policy Institute © 10
  11. 11. Probability of Occurrence Fire Prevention Plans (FPP) California has over seven times (7X) more manufacturing facilities than the other Top Ten incidents states. Why doesn’t California have seven times more incidents? Are required Fire Prevention Plans (FPP) in California reducing the probability of occurrence of combustible dust related incidents? Combustible Dust Policy Institute © 11
  12. 12. Combustible Dust Related IncidentsNational Fire Incident Reporting System (NFIRS) Item First ignited, #94 dust in NFIRS Fire Module. Property Use, #700 manufacturing plant NFIRS Basic Module. Combustible Dust Policy Institute © 12
  13. 13. NFIRS Reporting Not all fire departments report incidents through National Fire Incident Reporting System (NFIRS). Many combustible dust related fires are extinguished at the incipient stage and not reported through NFIRS. Dust explosions resulting in no fire are not reported in the NFIRS Fire Module. Combustible Dust Policy Institute © 13
  14. 14. Fatalities and Injuries Combustible Dust Related Fires and Explosions Top Ten Incident States In 2011 worker injuries occurred in 50% of the Top Ten incident states according to a NFIRS preliminary analysis (OH, MN, WI, IL, GA). Since 1997 fire fighter fatalities and injuries have occurred in 40% of Top Ten incident states (OH, MN, WI, NC). U.S. Chemical Safety Board (CSB) completed catastrophic combustible dust accident reports in 20% of Top Ten incident states (NC, GA). Fire Prevention Plans (FPP) not required at all facilities in the above examples except in California. Combustible Dust Policy Institute © 14
  15. 15. U.S. Chemical Safety Board (CSB) 2006 Dust Hazard Study RecommendationsNo Fire Prevention Plan (FPP) Recommendations Combustible Dust Policy Institute © 15
  16. 16. OSHA Combustible Dust HazardsEducation, Outreach, Inspections, & Rulemaking No FPP content in OSHA 2008 Combustible Dust National Emphasis Program (NEP). No FPP content in OSHA 2009 Combustible Dust NEP Status Report. No FPP content in 2009 OSHA Combustible Dust Advanced Notice of Proposed Rulemaking (ANPRM). No FPP content in 2011 OSHA Combustible Dust Hazards Expert Forum No FPP content on OSHA Combustible Dust Hazards Webpage. Combustible Dust Policy Institute © 16
  17. 17. 2013 Federal Congressional ActionProposed Combustible Dust Legislation Worker Protection Against Combustible Dust Explosions and Fires Act of 2013 (H.R. 691). 40% of requirements in reintroduced proposed bill H.R. 691 are mirrored from the OSHA Fire Prevention Plan (FPP) 29 CFR 1910.39. 50% of requirements in reintroduced proposed bill are derived from OSHA Process Safety Management (PSM) regulations 29 CFR 1910.119. Combustible Dust Policy Institute © 17
  18. 18. Conclusion Fire Prevention Plans (FPP) FPP’s manages potential ignition sources. FPP’s manages fuel sources. Without FPP’s combustible dust related incidents will continue to occur in an unabated manner. Majority of ComDust incidents are “near misses” precursors to catastrophe. Combustible dust hazards are primarily a fire issue and secondarily an explosion problem. Combustible Dust Policy Institute © 18
  19. 19. Thank You!Have a Fire Safe Day Combustible Dust Policy Institute © 19