Combustible Dust Standard Where are We?

1. Combustible Dust Standard Where are We? Larry Cox, CCM, CCT-I Structurlite Composites Consultants

2. Combustible Dust National Emphasis Program (March 2008) • Advanced Notice of Proposed Rule Making (October 2009) • No published standard on dust except grain – inspectors defer to General Duty Clause Sec. 5 (a)(1) In OSHA Activities:

3. NFPA 654 – 2006 Edition NFPA 652 - ??? National Fire Protection Association

4. What is combustible dust? a combustible particulate solid that presents a fire or explosion hazard when suspended in air or the process-specific oxidizing medium over a range of concentrations, regardless of particle size or shape (NFPA 654)

5. Dust Explosion: The bursting of rupture of an enclosure or container due to development of internal pressure from deflagration (NFPA 654)

6. Dust Layer Thickness 6.1.1.1 Those portions of the process and facility where dust accumulations exist shall be evaluated to determine if a dust deflagration hazard exists, unless the dust layer depth is 1/64 in. (0.4 mm) or less or the underlying surface colors are readily discernible. (NFPA 654, TIA 06-1)

7. Dust Layer Thickness 6.1.1.2 The layer depth criterion of 1/32 in. (0.8mm) shall be permitted to be increased according to equation 6.1.1.2 for materials with bulk density less than 75 lb/ft². (NFPA 654, TIA 06-1) Layer depth criterion (in) = (1/32 in)(75 lb/ft²) Bulk Density (lb/ft²)

10. How to avoid OSHA Dust Citation • Know dust hazards • Worker training and awareness • Risk audits/inspections (NFPA 654*) • Reduce dust emissions and surface dust buildup • Maintain dust collection systems • Eliminate/control ignition sources • Housekeeping (NNFPA 654*)

11. Where do I find help? OSHA Combustible dust hazard site: http://www.osha.gov/dsg/combustibledust/index.html OSHA On-site consultation programs for companies with 250 or less employees: http://www.osha.gov/dcsp/smallbusiness/consult.html NFPA: http://www.nfpa.org/ ACMA’s Dust Explosion Prevention & Protection CD

12. Combustible Dust Standard Where are We? THANK YOU Contact: Larry Cox, CCM, CCT-I Structurlite Composites Consultants Lcox1225@gmail.com 740-928-3286

13. GHSThe New Wave in OSHA Hazard Communication Barry Clayton, CIH Industrial Hygiene Manager Corporate EHS

14. What is GHS? • Globally Harmonized System of Classification and Labeling of Chemicals. • UN system developed to standardize the classification of chemicals and communication of hazards. • Revised every 2 years. Also known as the “Purple Book.”GHS (Rev.3) (2009) – UNECE. • Already adopted in Europe and many other countries (China, Japan, New Zealand, Brazil, etc.). • GHS framework uses a “building block” approach: • countries implement standardized elements they want • still have minor variations, but much less than in the past • Intended to facilitate international trade and improve the quality and consistency of hazard information provided.

15. What is the driver behind GHS? • Classification of a chemical with LD50 257 mg/kg/day • U.S. Toxic • Canada Toxic • Japan Toxic • Korea Toxic • Australia Harmful • Europe Harmful • Malaysia Harmful • Thailand Harmful • New Zealand Hazardous • China Not Dangerous • India Non-toxic • GHS Danger

16. U.S. OSHA and GHS • Federal OSHA is amending its Hazard Communication Standard (1910.1200) to align with GHS, 3rd rev. • OSHA issued a proposed rule on September 30, 2009. • Comments received and public hearings conducted. • Final rule is under review at OMB and is expected to be published in February 2012. • State OSHA programs will have 6 months to adopt a comparable standard at least as stringent as federal OSHA. • Will require new thinking, re-training of employees and changes to virtually all labels and material safety data sheets. • A two-year or three-year transition period is expected. • The long-term benefits should outweigh the short-term costs, particularly for global suppliers. • According to OSHA, the net savings are $754 million annually.

17. GHS Hazard Classification • Chemical substances and mixtures are classified according to 16 physical and 10 health hazard classes based on specific criteria and cut-off values/concentration limits. • Most hazard classes are sub-divided into hazard categories based on severity where, for example, 1 is high and 5 is low. • GHS does not require testing, but it can be helpful. • GHS allows for use of expert judgment and weight of evidence. • Classification determines the signal words, pictograms, hazard and precautionary statements used to convey information on labels and safety data sheets (SDS). • Adoption of GHS by OSHA does not affect DOT regulations as the classification and labeling of hazardous materials in transport have been harmonized for years.

18. GHS Terms • Classification – identification and evaluation of relevant data regarding chemical hazards and comparison to GHS criteria • Hazard class – the nature of the physical or health hazard • Hazard category – division of criteria within each hazard class • Hazard statement – statement assigned to a hazard class and category that describes the nature and degree of hazard • Pictogram – symbol plus other graphic elements intended to convey specific information about the hazards • Precautionary statement – phrase that describes measures that should be taken to minimize or prevent adverse effects • Safety data sheet (SDS) = Material Safety Data Sheet (MSDS) • Signal word – indicates the relative level of severity of hazard. Danger is more severe. Warning is less severe.

19. Physical Explosives Flammable gases Aerosols Oxidizing gases Gases under pressure Flammable liquids Flammable solids Self-reactive substances and mixtures Pyrophoric liquids Pyrophoric solids Self-heating substances and mixtures Substances and mixtures which in contact with water emit flammable gases Oxidizing liquids Oxidizing solids Organic peroxides Corrosive to metals Health Acute toxicity Skin corrosion/irritation Serious eye damage/irritation Respiratory or skin sensitization Germ cell mutagenicity Carcinogenicity Reproductive toxicity Specific target organ toxicity (STOT SE) – single exposure Specific target organ toxicity (STOT RE) – repeated exposure Aspiration hazard Environmental Hazardous to the aquatic environment Hazardous to the ozone layer GHS Hazard Classes

20. GHS Pictograms Oxidizers Gases under pressure Flammables Organic Peroxides Explosives Organic Peroxides Irritant Skin Sensitizer Acute Toxicity (Harmful) Narcotic Effects Respiratory Tract Irritation Hazardous to Ozone Layer Carcinogen Mutagen Reproductive Toxin Respiratory Sensitizer Target Organ Toxicity Aspiration Hazard Acute Toxicity (Severe) Corrosives Aquatic Toxicity (not in OSHA jurisdiction)

21. Shipped Containers Product identifier; Pictogram(s); Signal word; Hazard statement(s); Precautionary statement(s); and Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party Workplace Containers Product identifier; Pictogram(s); Signal word; Hazard statement(s); and Precautionary statement(s) OR Product identifier; and Words, pictures, symbols, or combination thereof, which provide general and specific hazard information Label Elements

22. Sample GHS Compliant Label Current OSHA Haz Com Proposed GHS

25. Identification Hazard(s) identification Composition/information on ingredients First-aid measures Fire-fighting measures Accidental release measures Handling and storage Exposure controls / personal protection Physical and chemical properties Stability and reactivity Toxicological information Ecological information* Disposal considerations* Transport information* Regulatory information* Other information, date of preparation/revision * Non-mandatory sections. Not be enforced by OSHA. SDS Requirements MSDS

26. What will be the impact of GHS? • The hazard classification of many chemical substances and mixtures sold in the U.S. will change. • GHS classifications may be higher, lower, identical, or new • No longer rely on specific lists or single positive studies • Classification will consider the full range of available scientific literature and other evidence concerning potential hazards • Downstream users can adopt classification of their suppliers • The format and content of SDS and labels will be different. • Manufacturers/importers have 3 years to revise SDS and labels. • Employees will need training regarding new labels and SDS. • Employers have 2 years to train employees. • Better understanding of hazard information down the supply chain. • Easier to classify, label, and ship chemical products internationally.

27. What will stay the same? • Employers: • Maintain a chemical inventory • Develop a written hazard communication program • Maintain and provide employee access to SDS • Label workplace containers • Manufacturers/importers: • Supply SDS with initial shipment and first shipment after update • Revise SDS within 3 months of receiving new hazard information • Can withhold trade secret information provided certain conditions are met • No change in state requirements such as California Proposition 65, Massachusetts or New Jersey RTK

28. What should I be doing? • Get organized! Review your chemical inventory. Prepare for the flood of new SDS, container labels, and questions that will follow. • Self-educate. Familiarize yourself with GHS, the HazCom final rule, new terminology, pictograms, and appendices. • Understand your role and responsibilities in the supply chain. • Know the current classification of your chemicals and be prepared to evaluate the impact of re-classified products. • Be alert for new or unclassified hazards such as combustible dust. • Revise written hazard communication program to reflect new OSHA requirements. • Provide information and training for employees and customers regarding new labels and SDS. • Look carefully at other regulations (PSM, flammable liquids, substance-specific health standards) impacted as a result of changes in terminology, hazards, or labeling due to GHS.

29. Additional Information • Proposed HCS regulatory text [63 KB PDF*, 30 pages] • Proposed Appendix A: Health Hazard Criteria (Mandatory) [347 KB PDF*, 68 pages] • Proposed Appendix B: Physical Hazard Criteria (Mandatory) [130 KB PDF*, 28 pages] • Proposed Appendix C: Allocation of Label Elements (Mandatory) [350 KB PDF*, 75 pages] • Proposed Appendix D: Safety Data Sheets (Mandatory) [53 KB PDF*, 3 pages] • Proposed Appendix E (Existing Appendix D): Definition of Trade Secret (Mandatory) [21 KB PDF*, 2 pages] • Proposed Appendix F: Guidance for Hazard Classifications Regarding Carcinogenicity (Non-Mandatory) [62 KB PDF*, 4 pages] • Proposed HCS regulatory text (redline strikeout) [261 KB PDF*, 38 pages] • Side-by-side comparison of the current HCS to the Proposed Rule [327 KB PDF*, 45 pages] • Facts on Aligning the Hazard Communication Standard to the GHS

30. Update: New Rules Affecting Composites Plants David J. Lipiro Environmental Compliance & Risk Management Inc. ECRM February 21-23, 2012  Mandalay Bay Convention Center, Las Vegas, NV

31. What New Rules? • Multi-Sector Storm Water Permits • Emergency Generator Rules • Reproposed Boiler MACT

32. Storm Water Permits • SW discharges regulated since 1992 by EPA and delegated states under Clean Water Act. • Rules set up SW discharge permit system - most composite plants covered • What’s new: industrial site permit terms now vary by industrial sector

33. How General Permits Work • State issues permit after approval by USEPA • Plants sign on via Notice of Intent (NOI) – now must identify sector(s) • Plant must meet permit terms, and must develop SW Pollution Prevention Plan (SWP3) to manage compliance.

34. For All Sectors: • Permits may now require quarterly SW collection after storm for visual assessment • Annual compliance review must cover visual assessments – some states require submittal • Periodic inspections specified • SWP3 must be modified

35. Sector - Specific • Composites plants are Sector Y – includes Misc Plastic Products • Typically no additional requirements, and no monitoring (sampling SW for lab analysis) • Beware - other sectors may apply also!! • Consider No Exposure exemption

36. Emergency Generators • Diesel-fired at most industrial sites • Reciprocating Internal Combustion Engine (RICE) Standards: • MACT: 40 CFR 63 Subpart ZZZZ for major and now minor sources • NSPS: 40 CFR 60 Subpart IIII • Requirements vary by engine size and model year, must be included in Title V permits

37. NSPS IIII Compliance Keys • Confirm EG engines certified to meet EPA emission standards • Use ultra-low (15 ppm) sulfur diesel fuel, keep proper fuel certifications • Maintain engines per mfg recommendations • Limit run hr/yr: 500 total /100 test • Keep required records!

38. MACT ZZZZ Compliance • Meet NSPS IIII + minor maintenance • Submit all MACT-specific notifications • Submit semiannual compliance reports as required.

39. Need an EG? • DON’T BUY A USED EG UNLESS IT COMPLIES!!! • Rules specify the oldest model year engine that can be installed in any year. • Applies to replacement of engine on an existing generator as well!

40. Boiler MACT Standards • At typical composite plants, will regulate small gas-fired boilers/process heaters (<10 MMBTU/hr) • No size cutoff, though drinking water heaters exempted. • Standards much more stringent for other fuels

41. EPA “Reconsideration” • EPA stayed original major source (DDDDD) and minor source (JJJJJJ) rules for reconsideration of new industry information • Reproposal for small gas-fired units: • Tune-up to maintain burners per mfg specs • Have conducted a one-time energy audit by a certified professional

42. News Flash! • Jan 2012 - Court vacated EPA stay – unless reversed, original rules apply until EPA finalizes reproposal • Original rules: no requirements for small gas-fired units • Stay tuned …

43. QUESTIONS? ECRM 216-215-3921 dlipiro@ecrminc.com

44. Housekeeping Best Practices Marcus Bingham Clarion Bathware

45. Housekeeping • BLAH!!! • BLAH!!! • BLAH!!!

46. Housekeeping – WHY?

47. Advantagesof Good Housekeeping • First Impression • Better Place to Work • Reduced Fire Exposure • Reduced Injury and Accident Exposure • Reduced Insurance Cost • Quality Workmanship • Operational Efficiency

48. How to AccomplishGood Housekeeping • Set a Good Housekeeping Culture… • Lead by Example • Provide the Right Tools • Recognize Employees • Hold Supervision Accountable • Promote, Promote, Promote…

49. Wayne and Garth’sTop 10 Safety Tips 1. Safety Starts with You. • Spitting is Gross! • Lifting Starts with your head. • Use Correct working procedures. • PPE can save your life. • Be responsible (no screwing around) • First Aid means First Aid • Housekeeping (Keep it Clean, Dude) • Cell phones can be dangerous. • Tools used correctly can be your friend.

50. Wayne and Garth’sTop 10 Safety Tips