On December 27th, 2013, OSHA distributed an internal memo
to its compliance officers intended to clarify the Administration’s standards regarding combustible dusts.
What Is Combustible Dust?
When OSHA amended the Hazard Communication Standard (HCS) to align with the Globally Harmonized System for the Classification and Labeling of Chemicals (GHS), the Agency amended the definition of “hazardous chemical” to include “combustible dust,” a hazard that the international GHS does not address.
Combustible dust is commonly accepted to be a type of atmospheric hazard made up of fine grains of solid material that are capable of catching fire or exploding. However, OSHA did not define the term “combustible dust” in its revised Standard. As an interim measure, the Combustible Dust National Emphasis Program (NEP) includes an “operative definition.” There are also several voluntary consensus standards (ASTM, NFPA, etc.) for assessing combustible dust hazards by simulated testing or measuring particle size.
Recognizing Combustible Dust Hazards
The guidance memo is intended to help compliance officers determine whether manufacturers/importers of chemical products have properly classified combustible dust hazards. The memo is not meant to apply to inspections of end-users of combustible dusts.
The memo directs compliance officers to rely on the existing consensus standards, related laboratory tests, and actual experience when enforcing the HCS.
According to the memo, the hierarchy for determining whether a chemical product has a combustible dust hazard is:
- There is evidence that the product has been involved in a dust explosion event.
- When test data is available from a recognized consensus standard test, classify the product in accordance with that data.
- In the absence of test data, rely on published data for similar materials or classify based on the particle size of the product.
Transitioning to the Revised HCS
The deadline to update employees’ hazard communication training to inform them of new hazard classifications, labels, and Safety Data Sheets was December 1, 2013. As new criteria are phased in over the next few years, employee understanding is critical to workplace safety at facilities where hazardous chemicals are handled. To help employers understand the revised HCS and prepare their employees, Lion Technology offers the Managing Hazard Communication Online Course
for site or EHS managers and the Hazard Communication Online Course