Disqus - Latest Comments for comdust

Re: http://www.calgarysun.com/2012/05/06/smouldering-blaze-could-cost-calgary-taxpayers-plenty

comdust — Mon, 07 May 2012 10:17:46 -0000

Another example of Auto Shredder Residue (ASR) fire that burned for a week in the Texoma Region September 2011. http://g.co/maps/prp6b Real-time air monitoring will not identify the airborne toxins as it will require air samples to be analyzed in a lab...very costly.

Re: http://www.calgarysun.com/2012/05/06/smouldering-blaze-could-cost-calgary-taxpayers-plenty

comdust — Sun, 06 May 2012 23:46:45 -0000

Dioxins, furnan, PAH's, and heavy metal emissions from auto shredder residue (ASR) fires is an international problem and not just a local issue. See Google Map http://g.co/maps/ahq8z

Re: http://www.calgarysun.com/2012/05/06/smouldering-blaze-could-cost-calgary-taxpayers-plenty

comdust — Sun, 06 May 2012 22:52:25 -0000

"air quality remains at acceptable levels" So nobody told officials about auto shredder residue (ASR) toxins emitted from the fire? http://goo.gl/ZSpBN EPA Report CHARACTERIZATION OF EMISSIONS FROM THE SIMULATED OPEN-BURNING OF NON-METALLIC AUTOMOBILE SHREDDER RESIDUE

Re: The Chemical Safety Board Continues Investigation of Gas Explosion in Woods Cross, Utah | EHS Today

comdust — Sun, 22 Nov 2009 11:09:14 -0000

CSB discovered that significant percentage of the pipes and vessels had no documented thickness readings at all. So why was it not discovered in the earlier OSHA inspection 01/13/2009 that PSM Mechanical Integrity program was deficient following the earlier January 12 explosion? http://www.osha.gov/pls/imi...

This incident highly amplifies the need that all states must adhere to OSHA's Petroleum Refinery Process Safety Management National Emphasis Program (RNEP). Currently state-plan states such as Utah that have refineries within their jurisdiction, participation in the RNEP is not required (voluntary).
http://www.osha.gov/OshDoc/...

Without the requirement of participation, OSHA inspectors (CSHO's) do not receive the required intensive training in understanding the comprehensive elements of PSM, which also includes Mechanical Integrity (MI).

OSHA Training Institute's (OTI) on PSM/CPI as outlined in the RNEP:

Course 3410, Advanced Process Safety Management
Course 3300, Safety and Health in the Chemical Processing Industries
Course 3400, Hazard Analysis in the Chemical Processing Industries

So did the CSHO's that conducted the inspection activity following the earlier January 12, 2009 explosion have any training concerning PSM and CPI?

Re: OSHA Issues Proposed Rule to Adopt the Globally Harmonized Hazard Communication System | EHS Today

comdust — Tue, 13 Oct 2009 21:39:20 -0000

Another move forward to the New World Order. The GHS does nothing in communicating the fire and explosion risk in substances, such as combustible dusts, that are not considered chemicals. OSHA should first get it's house in order with the multitude of deficiencies in the OSHA HAZCOM Standard before taking the easy way out with global harmonization.

Re: OSHA Releases Combustible Dust Guidance Document | MHM Online

comdust — Sat, 03 Oct 2009 10:06:32 -0000

There is a problem in the OSHA Hazard Communication Guidance for
Combustible Dusts. Specifically it is intended to help manufacturers and importers of chemicals recognize the potential for dust explosions and to identify appropriate protective measures as part of their hazard determination under the Hazard Communication Standard (HCS). There is no emphasis on other substances like wood, paper, textiles, etc that is not a chemical

Additionally, once the raw product leaves the initial manufacturer and is used by the end-user in operations such as abrasive blasting, cutting, grinding, polishing or crushing of materials; in addition to conveying, mixing, sifting or screening dry material the particle size changes while being broken down. Thus the explosion severity and ignition sensitivity changes from what it was initially.

What the document should of stated is that the end-user has so conduct an additional hazard evaluation according to the specific process that causes the breakdown of the raw product. This evaluation must include costly lab testing for explosion severity and ignition sensitivity. It’s troubling that the document did not even mention minimum ignition temperature (MIT).

The three main HCS components must be changed to include all stakeholders that handle combustible particulate solids that generate combustible dust. Not just chemical manufacturers and importers. As it stands now, readers of the document will get a false impression whether a hazard exists by solely relying on the MSDS that was developed by the initial manufacturer of the raw product. An accident waiting to happen.

Re: OSHA Publishes New Combustible Dust Hazards Document | EHS Today

comdust — Sat, 03 Oct 2009 10:03:09 -0000