(81an) Preparing for An OSHA Combustible Dust NEP Inspection In Food Processing and NFPA® 61 Prescriptive Compliance: Timelines, Recommendations and Pitfalls

Howat, C. S. III - Presenter, C. S. Howat & Associates

The hazard of combustible dust in food processing has been often overlooked. The number of combustible dust accidents is over-represented in the statistics. OSHA has responded by over-emphasizing inspections of food processing facilities. OSHA has yet to develop combustible dust regulations. The ?regulations? are increasingly embodied in the accepted citations, the General Duty Clause and Housekeeping. OSHA does not appear to be establishing the four criteria for a GDC violation. The Certified Safety and Health Officer may not have experience with combustible dust and has little time for a detailed inspection. Facilities are vulnerable to superficial inspections with citations which, had they been mitigated in advance, may not improve the risk to the facility and, therefore, would be considered a poor use of capital and operating resources.

Food processing facilities generally do not fall under 29CFR1910.119. Consequently, most do not have a PSM program in place. Even so, the RAGAGEP for the Combustible Dust NEP as listed in the OSHA training document includes NFPA® 61 which provides standards for the food processing industry. This is largely a prescriptive document allowing little leeway for performance compliance supported by a PHA/RA program.

The moving target, potentially superficial inspection, lack of a PSM program and a prescriptive RAGAGEP will increase the exposure of facilities to citations.

This paper presents a history of an NEP inspection and response. Discussion includes the timeline, the PSM foundation, the recommendations for preparing for the inspection, recommendations for prescriptive mitigation and pitfalls into which a facility may fall from a risk perspective.