Industrial Dust and Wood Dust

Wood dust has become an issue that is at the forefront of today’s public policy rule makers.

NEW! OSHA's Virtual Stakeholder Meeting on Combustible Dust

OSHA has scheduled a virtual stakeholder meeting on Monday, June 28, 1:00 p.m. EDT, to seek input about combustible dust workplace hazards. Comments from the meeting will be used to help the agency develop a proposed standard on combustible dust.

According to OSHA, this virtual meeting format will provide easy access to a broad audience, such as small businesses who would otherwise not be able to participate. The WMMA Dust Task Force encourages you to participate if you can.

Individuals can find information on the free Web chat by accessing http://www.dol.gov/dol/chat.htm. The live chat will be held for one hour, beginning at 1 p.m. EDT, on June 28. Afterward, individuals can access the site through July 7 to provide feedback and receive additional information.

ACTION ALERTS: Proposed Revisions in NFPA Standards Affecting Woodworking Facilities

New Requirements in Proposed NFPA 664 Revision
Action Requested: Deadline for comments is September 3, 2010.

The National Fire Protection Association (NFPA) Standard 664 for woodworking facilities is currently in its revision cycle and is actively considering proposed revisions.

The WMMA Dust Task Force encourages all interested parties to read the Report on Proposals (ROP) and make comment on the proposed revisions under consideration by the deadline of September 3, 2010. These documents are found on http://www.nfpa.org/aboutthecodes/AboutTheCodes.asp?DocNum=664.

There are a number of issues under consideration that the membership may find of interest which include:

• Required signage on all dust collectors (Log #19)
• Requirements for access doors on ducting (Log #3)
• Requirements for explosion isolation equipment on return air ducts (Log # CP13)

The latter issue may have serious economic ramifications for woodworking operations. One opinion that is shared by a number of members of the Dust Task Force is an objection to the inclusion of 8.2.2.6.5 ( Log #CP13). This which would mandate explosion isolation devices on all return air ducts from an outdoor dust collector. It is felt that this will place a new and unnecessary economic burden - particularly on the small woodworking operation. The need for this additional protection has not been demonstrated by any loss history study.

Proposed Combination of Standards
Please see the attached two page memo (Seeking Input on Combining Documents).

Read the WMMA comment letter to NFPA.

Many experts consider the combination of NFPA 664 with other standards will not be in the interest of the woodworking industry because it would likely eliminate the exemption for the small wood shop as defined in 1.1.2 and the goal to provide for a facility that is "reasonably protected…in a cost effective manner" as stated in 4.1 of the standard.

Combustibility
First, the Occupational Safety and Health Administration (OSHA) initiated rulemaking on combustible dust in October 2009. Stakeholders are currently providing feedback.

In addition, the National Fire Protection Association (NFPA) has two standards currently in review cycle: NFPA 654, the Standard for the Prevention of Fire and Dust Explosions for the Manufacturing, Processing and Handling of Combustible Particulate Solids, and NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities.

Health Impact
The International Agency for Research on Cancer (IARC) recently made a causal link between wood dust and sinonasal and nasopharyngeal cancer. As a start of the regulatory activity, the State of California, which has been looking at wood dust a potential item that would require labeling, is considering whether to lower permissible exposure limits.

Resources
Below are some links to materials that would be helpful in understanding the issues.

• New Resource! This OSHA presentation provides the basic knowledge to help:
  
  • Recognize some of the various types of combustible dust
  • Identify sources of ignition for combustible dust
  • Determine inspection evaluation methods
  • Describe the National Emphasis Program on combustible dust, including recent revisions
    
    
• 2010 January UPDATE - WOOD DUST EXPOSURE LAWSUITS (Note that the Alabama litigation that is discussed has been settled with no liability to the named remaining parties.)
  
  
• Report on the OSHA stakeholder meeting on December 14, 2009, "Manufacturers voice concerns at OSHA combustible dust meetings"
  
  
• Combustible Dust: Regulatory and Legal Challenges
  Presentation by Adele L. Abrams at the Small Business Legislative Counsel roundtable, Washington, DC, November 2009
  
  
• Combustible Dust…An Explosive Issue
  Presentation by Jamie Scott, Air Handling Systems, at The Dollars and Sense of Going Green conference, Schaumburg, IL, November 2009
  
  
• Combustible Dust Update: OSHA's Preliminary Rulemaking on Dust is Underway
  A November 2009 article by legal consultant Keller and Heckman LLP
  
  
• OSHA’s Advance Notice of Proposed Rulemaking, October 21, 2009
  
  
• NFPA 654, Standard for the Prevention of Fire and Dust Explosions for the Manufacturing, Processing and Handling of Combustible Particulate Solids
  
  
• NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities
  
  
• IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, IARC Monograph, Vol 62

WMMA has formed an Industrial Dust Task Force to monitor the situation. In addition, WMMA is a member of the Inter-Industry Wood Dust Coordinating Committee (IWDCC), organized by the American Forest & Paper Association (AF&PA) to help ensure that the woodworking equipment and the wood processing industry and related industries are represented in these public policy discussions and decisions.