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Just recently it was noted in a combustible dust rulemaking discussion that stakeholders do not believe Fire Marshals and Fire Chiefs have subject matter expertise on combustible dust related fires that occur in manufacturing facilities. This is an interesting train of thought. Especially since the professional fire service responds to combustible dust related fires on a daily basis throughout the United States.
Most of these fires are non-consequential (confined structures) with no fatalities, minor injuries, and no property damage. According to media accounts, over 80% of ComDust incidents are fires. In many instances ComDust fires are precursors to eventual catastrophic secondary combustible dust explosions. Currently, the U.S. Fire Administration has no involvement in stakeholder input regarding the OSHA Combustible Dust rulemaking process.
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For stakeholders needing additional information here is an article I'd like to share that provides a basic roadmap,"Better Identification of Fire Hazards Needed." This is an entirely new subject and will require futher study for those that have no prior knowledge of the US Fire Administration, National Fire Incident Reporting System (NFIRS 5.0), National Fire Data Center, and NFPA 901 Standard Classifications for Incident Reporting and Fire Protection Data.
The Fire Service reports incidents to the USFA through NFIRS 5.0. This statistical information is utilized to obtain a better understanding of where layers of protection and resources need to be directed so as to prevent and minimize future incidents. Problem is, that at the moment no data is collected on equipment involved of ignition, ignition sources, and specific types of dust concerning combustible dust fires. If this info is not collected then how can we effectively administer control measures? At the moment industry is relying solely on OSHA for guidance in maintaining a safe workplace in regards to fire and explosion hazards.