Snare noted that the shift in power during the mid-term elections toward a Republican majority in the House will make it difficult for OSHA to achieve these objectives through legislation. He predicts OSHA will continue to implement policies through nonlegislative means. Without the support of the Congress, Snare suggests current law will be molded through the development of stricter regulations or make new interpretations of existing OSHA standards.
If this is the case, the combustible dust bill could be implemented as a regulation without a vote from Congress.
“The government shouldn’t have to impose these rules on the industry, we should already know what’s wrong and right and act accordingly,” says Delmar Mains, dust design sales representative, Rolfes@Boone.
Without imposed regulation vendors find it difficult to translate the cost of purchasing, operating and maintaining an efficient dust control system.
“On the surface, grain elevators do not perceive dust control systems to be a moneymaker,” explains Mains. “With a piece of equipment, like a conveyor, it’s easy to calculate ROI; however, with dust control, it’s harder to monetize.”
Scott Chant, president with Safe-Grain/Maxi-Tronic, Inc., agrees: “If you put in a new receiving pit and go from 15,000 bushels to 30,000, [operators] can justify the cost because you’ve doubled your capacity; you can see a payback. It is difficult to project a payback from adding a dust control system. Catastrophic event prevention and EPA compliance costs can be difficult to pencil in.”
Oftentimes, facility managers don’t know what to expect from a dust control system. This lack of interest or lack of knowledge can translate to poor decision making that could bear consequences down the road. The benefits go beyond simply showing the EPA or OSHA you are in compliance as dust control is more than a necessary evil.
“The general attitude should shift, [operators] should realize they should approach dust control like any other piece of equipment, and it should be operated and maintained accordingly,” Mains says.
When you know you are purchasing a good system, you are also investing in peace of mind.
“If you buy a cheap system, you’re going to get poor results,” Mains says.
The benefits of a quality dust collection system
Regulations aside, there are many secondary benefits to investing in a quality dust collection system:
• Safety: Awareness & prevention
The formula for a dust explosion is simple: oxygen + fuel + spark = the right conditions. Dust hazards also involve dust particles suspended in the air and containment of those particles. Knowing this, a responsible manager is cognizant of any activities that could potentially produce a spark, and will be diligent about enforcing the rules.
While even the best dust control may not be able to prevent an explosion, it will lessen the damage if the system is designed properly with explosion panels and if other preventive measures are taken.
“Any potential loss of life is a critical issue,” Chant says. “As an industry we’ve been doing a better job realizing the importance of managing hazardous dust issues. Considering the increased throughputs the last few years, we have seen a relative decrease in the frequency of explosions per million bushels.”
The goal should not only be explosion prevention, but it should reduce the risk of damage should an explosion occur.
“I’d never say a dust control system will prevent an explosion — even taking every precaution may not pay off — you can reduce the amount of damage done by the secondary explosion by reducing the fuel supply,” Mains says.
With or without a dust control system, management should make it a point to keep its facilities clean.
• Being a good employer
A safer and cleaner work environment fosters improved employee morale. Adopting a well maintained facility perpetuates a culture of compliance, but starts at the top and works its way down.
• Lowered operating costs
“Even if you have the best dust control system in the world, you’ll still need a broom and shovel in the facility,” Chant says.
No dust system will eliminate the need for housekeeping, but it will save on the amount of time housekeeping takes.
“Consider the opportunity cost savings: If you have a good dust control system, it can replace the times wasted by an employee doing extra cleaning,” he says.