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.

1. California Lower Rate of
Combustible Dust Related Incidents Due
to Required Fire Prevention Plans
(FPP)?
California Code of Regulations (CCR), Title 8, Section 3221
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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
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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.
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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
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5. Written Fire Prevention Plan (FPP)
Additional OSHA Requirement
Portable 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.
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6. Fire Prevention Plans (FPP)
29 CFR 1910.39
National Summary
Fire Prevention Plans (FPP) Requirements
Federal OSHA States Not Required at All Facilities
California State Plan Required All Facilities
California Code of Regulations, Title 8, Section 3221
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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
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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
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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 Products
Source: U.S Bureau of Economics
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10. Combustible Dust Related Incidents
Top 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
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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?
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12. Combustible Dust Related Incidents
National Fire Incident Reporting System (NFIRS)
 Item First ignited, #94 dust in NFIRS Fire
Module.
 Property Use, #700 manufacturing plant NFIRS
Basic Module.
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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.
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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.
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15. U.S. Chemical Safety Board (CSB)
2006 Dust Hazard Study
Recommendations
No Fire Prevention Plan (FPP) Recommendations
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16. OSHA Combustible Dust Hazards
Education, 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.
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17. 2013 Federal Congressional Action
Proposed 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.
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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.
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19. Thank You!
Have a Fire Safe Day
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