In comments submitted May 19 to the Occupational Safety and Health Administration (OSHA) on proposed revisions to its hazard communication standard, the National Grain and Feed Association (NGFA) and other agricultural associations outlined problems with the proposed federal definition of “combustible dust.”
OSHA published a 256-page proposed rule on Feb. 16 to update the agency’s Hazard Communication Standard to align with the seventh revision of the Globally Harmonized System of Classification and Labelling of Chemicals.
The proposed amendment creates a federal definition of “combustible dust” that will have a direct impact on all grain, feed, processing and milling facilities.
The proposal defines combustible dust as “finely divided solid particles of a substance or mixture that are liable to catch fire or explode on ignition when dispersed in air or other oxidizing media.”
NGFA said the proposed definition is too broad and would classify dusts as combustible even in circumstances when they cannot combust.
“With respect, we submit … that the proposed definition uses inaccurate terminology and has an unexplained overlap with terms that describe other physical hazards,” NGFA’s comments state.
“These features of the proposed definition will cause avoidable confusion on the part of manufacturers, employees and the public.”
The proposed amendments to the standard also place a burden on the manufacturer (i.e., grain handling facilities) to anticipate downstream events.
For example, grain elevators could be liable if the grain self-combusted or rotted and produced carbon dioxide.
Signatories to the comments include: Corn Refiners Association, National Oilseed Processors Association, North American Millers Association, U.S. Beet Sugar Association and U.S. Chamber of Commerce.
On May 20, OSHA published a Federal Register notice announcing a virtual public hearing is scheduled for Sept. 21.
NGFA has participated in previous public meetings regarding combustible dust. According to senior agency staff, it will take at least two years before the proposed rule becomes final
— From the May 21 NGFA Newsletter
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