Understanding the dangers of combustible dust
Paper shredding is growing into a big business. Recycling and the green movement certainly planted the seeds, but regulators have added the fertilizer. Industry-changing laws have been passed to govern document security in accounting, healthcare and banking, and shredders of many varieties are becoming the tools of those trades.
Five or six years ago Warde Comeaux knew only a few people who shredded documents for a living. Most businesses he knew relied on recyclers to get rid of their unwanted paper—including documents. With regulation proliferation, clients began coming to him for advice on getting into the document destruction business. Comeaux is principal of Fire Protection International Consortium, Inc., a consulting firm with locations in California and in Florida. The more entrepreneurs who build their companies around paper shredding, the greater the need for safety consciousness—paticularly fire safety.
Many of these entrepreneurs may not know, or they may forget, that paper shredding produces dust, and dust is combustible. Fires are quite common in shredding operations, and Comeaux has investigated his share. Two were recent. One was a regular fire (they oiled the machinery too much), and the other was a dust conflagration.
Paper dust in a paper shredding operation can catch fire from a spark generated by metal entering the process. Paper clips, notebooks, and other metal parts can set off a dust explosion or ignite loose fibers of paper.
“Dust can build up in a cloud and if the cutters hit something and you get a spark you get a flash and a small fire,” Comeaux says. “If you don’t stop the machine and clean it of dust periodically, combustible dust can build up throughout the building. That can lead to a worse loss.”
A small fire can even travel from the shredder, up a conveyor and into a baler, and the fire could smolder inside that bale until it is delivered to the mill or recycling center.
Regulators’ radar screens
The problem starts with poor housekeeping. If you leave a footprint in the dust on the floor of your facility, you’re at risk. A dust suppression system installed with a paper shredder can help contain the problem. Ten or 15 years ago such equipment was considered a cost, but with the developing OSHA regulations surrounding combustible dust, shredding operations may actually save money by avoiding fines from OSHA or the NFPA.
“NFPA Code 654 (see sidebar) is our reference for all this stuff,” says Brian Richardson, field service manager for Camfil FARR Air Pollution Control, providers of dust control systems. “There’s an increase in the sale of dust collectors on any type of equipment. In fact old equipment is often put back into commission after sitting in a corner for a while.”
John Dauber, North American Sales Manager for Camfil FARR APC, adds that headline-making dust explosions in other industries have put paper shredding operations on OSHA’s radar screen.
“We get calls daily about OSHA threatening to come in and shut them down because OSHA is doing a better job training its people on what to look for when they walk into a plant,” he says.
Regulators need improvement
OSHA may be on the job with enforcement and inspection activities, but John Astad, director and research analyst for the Combustible Dust Policy Institute in Santa Fe, TX, thinks it could do a better one. In 2008 OSHA reintroduced a national emphasis program (NEP) on combustible dust in response to a dust explosion at Imperial Sugar's Port Wentworth Georgia facility that killed 14 workers and injured many more. The reissued NEP focuses on 64 different national industries, including those that handle paper products in refuse, scrap, and waste materials industries. Explosions get attention, but to Astad, the big problem is fires, precursors to potential dust explosions.
“Too many stakeholders are keen on certain national industries, but it’s not so much the process material as process situations and conditions,” he says. “We need to look at all shredders that have a commonality throughout the industrial subsectors. All these diverse types of dusts when ignited result in a high rate of pressure and heat [deflagration].”
Most paper shredder events are fires and are caught early, before there are injuries or fatalities. That’s why these operations rarely get on the regulators’ radar screens. Although such fires are precursors to dust explosions, Astad contends they’re ignored because OSHA lacks both resources and a comprehensive understanding of this complex situation.
He believes that as recycling increases so will these incidents. He cites the wood pellet industry as an example. It sells these pellets as an alternative fuel and heating source. Over the last two years more than ten percent of the Pellet Fuels Institute’s (PFI) member companies on the east coast of the US had combustible dust related incidents.
“Before, the majority of inspectors had no specialized training on combustible dust hazards,” Astad explains. They would visit these facilities and not cite them for combustible dust hazards, so the facilities thought they were fine. [Since Imperial Sugar] and the recently reissued Dust NEP these facilities are now being cited because they have process equipment that doesn’t have fire and explosion mitigation equipment on it.”
Need for shredder ed
For Astad, citations and enforcement won’t be enough to avoid paper shredding fires as this industry grows. What’s missing is education, information, and outreach. While OSHA focuses on sanctions after the fact, the National Institute of Occupational Safety and Health (NIOSH) takes a sector based approach through the National Occupational Research Agenda (NORA) in developing intervention strategies in accident prevention.
Some see such a lack of collaboration between governmental agencies as the reason dots aren’t connected among related incidents.
“Why don’t NIOSH and OSHA work in parallel together on these occupational safety issues as the OSH Act intended?,” Astad asks. “I would also like to see OSHA and NIOSH work collectively with the U.S. Fire Administration because they have an excellent National Fire Reporting Incident System (NFIRS) that collects data on fires in industrial and manufacturing properties. This would help in understanding trends in specific industries. The infrastructure is there but they’re just doing their own thing.”
Jerry Schultz, Warde Comeaux’s partner at the Fire Protection International Consortium, notes that as the fear of liability and the need for document confidentiality grow, the records management industry will take more of the shredding process away from recyclers. This could mean trouble.
“A lot of the people opening these facilities don’t recognize the hazards associated with shredding,” he says. “Dust is not recognized as a hazard. The onus is on the equipment providers, the fire inspectors, and the people permitting these facilities. Shredding is growing, we have shred trucks out there on the street, but the shred plant itself is not being targeted.”