“I just received test results showing that the dust accumulating in your facility is combustible,” said Alice, the compliance officer. “That means you should’ve developed a housekeeping program to eliminate hazardous dust, but you haven’t done so.”
“We have a housekeeping program, and it deals with combustible dust,” said Ralph, the safety manager. “Unfortunately, the dust you saw during your inspection was the result of a spill. We allow 48 to 72 hours to clean up spills, but in this case, you visited our operation before the spilled dust could be removed.”
“So you’re telling me that your housekeeping program addresses dust spills,” said Alice.
Yes,” said Ralph.
“I’ll buy that,” said Alice. “However, I also found dust buildup in other areas of your operation. The test results for that material showed it to be combustible. Do you have a plan for cleaning up hazardous dust that accumulates over time rather than just after spills?”
“Our housekeeping program is intended to address hazards that we actually could encounter,” said Ralph. “There’s no reason to develop procedures for accumulations not related to spills because it doesn’t happen much.”
“It seems to be happening more than you think,” said Alice. “I’m writing up a citation.”
“We’ll challenge your penalty,” said Ralph.
Did the company win?
No. The company lost. The OSHA Review Commission upheld the citation.
The commission ruled that the employer’s housekeeping program was deficient. While the program included provisions for handling spilled dust, it failed to address the problem of dust that built up over time.
Clearly, noted the commission, the dust accumulations were an issue because the OSHA inspector saw them and identified the dust as combustible with the potential for an explosion.
Without a plan for handling accumulations, the company’s housekeeping program came up short, said the commission.
What it means: Don’t let dust accumulate
Take another look at your housekeeping program for controlling combustible dust.
Does the program address any and all potential accumulations of dust that could be ignited by an ignition source?
If you’re not sure, consider a walk-through of your operation in order to determine whether dust is building up during normal plant operations.
If it is, work with your facilities manager to develop a program for cleaning up combustible dust accumulations. Make sure the program includes a specific schedule for removing accumulations as well as the methods to be used for safely removing the dust buildup.
Based on Secretary of Labor v. Gavilon Grain.
(From the Jan. 13, 2020, issue of OSHA Compliance News)