 John Astad |
By Tom Andel, contributing editorRecently, the manager of one of OSHA's Voluntary Protection Program regional offices sent out an email with the following subject line: "Safety Alert - Forklifts operating in Classified Areas". It was spurred by a rash of citations OSHA inspectors issued to managers of refineries that were using improperly classified forklifts in areas classified as hazardous. The concern is that this situation creates a potential fire/explosion hazard.
The Alert noted that this situation is not limited to refineries, but may also occur in other workplaces where flammable vapours and/or combustible dusts (such as, but not limited to, coal, wood, grain, paper, metals and others) are present.
How big a problem is this to average forklift users?
It's getting more play in Western states right now, particularly where diesel forklifts are used. A recent article in the Cal-OSHA Reporter described a condition called "diesel runaway", in which the engine runs out of control when it encounters an external fuel source. Under normal conditions, the engine would stop when the fuel supply is shut off. In a runaway condition, the flammable vapour from an outside source enters the engine's air intake, causing it to keep running and eventually overspeed, overheat and explode.
Rod Smith, an attorney with the Denver law firm of Sherman & Howard LLC, told
Forkliftaction.com News that a growing number of his clients are being affected because there are no good alternatives to the kind of forklifts they need, and they're asking his firm for help in defending their position.
"The problem is it's not easy or cheap to find replacements," he says. "For example, an electric forklift designed for heavy use in an outdoor location is not easy to come by. A number of my clients are concerned because they've been cited for having unapproved forklifts in their outdoor locations. We're not sure what the fix is but we know it will be pretty expensive. You can't use gasoline fired engines because of the various ignition sources. Now they're coming after diesel."
Safety experts acknowledge there is confusion regarding atmosphere classifications. These include:
- Class I flammable liquids, vapours, gases, mists
- Class II combustible dusts
- Class III Fibres and flings
Then there are divisions designating the types of environments in which these atmospheric elements are found:
Division 1 designates an environment where flammable gases, vapours, liquids and combustible dusts or ignitable fibres are likely to exist under normal operating conditions.
Division 2 is an environment where flammable gases, vapours, liquids and combustible dusts or ignitable fibres are not likely to exist under normal operating conditions.
OSHA's diesel designations include DS (with safeguards to the exhaust, fuel and electrical systems) and DY (with all the safeguards of DS units plus temperature limitation features). The only forklifts approved for Division 1 hazardous locations are electric-powered, designated EX (with safeguards for use in atmospheres containing flammable vapours or dusts). DS, DY, EE (enclosed electrical equipment) and EX are approved for Division 2.
The problem is that few - if any - electric forklifts have capacities greater than 8,000 pounds (3,628Kg) or can consistently manoeuvre under load on uneven terrain. That's when a manager may have to claim a "greater hazard defence". In a nutshell, this manager might say, "The industry doesn't make an electric forklift capable of performing this task, therefore it's not feasible for me to meet the standard."
John Astad, director and research analyst at the Combustible Dust Policy Institute, Santa Fe, Texas, has been researching global combustible dust-related fires and explosions in the industrial sector for a year and a half. He tells
Forkliftaction.com News that citations involving forklifts are on the rise now that OSHA has a Combustible Dust National Emphasis Program (NEP). The NEP, which began in 2007 and was reissued in 2008, characterises facilities with potential ignition sources where combustible dust is present. Most recently, Astad's incident data were utilised in OSHA's proposed combustible dust rulemaking (ANPRM), to help stakeholders understand the probability of occurrence in the industrial sector.
The real issue now, he says, is to educate stakeholders among forklift vendors and users alike. Astad is still concerned with the language of the proposed rulemaking and believes OSHA should include the words 'explosive atmospheres' in the OSHA General Industry Regulations (1910.178).
"Most of the reason for catastrophic secondary dust explosions is poor housekeeping," he says. "Remove the fuel (dust) and you will not have a secondary dust explosion. They already have a housekeeping section in the general duty clause. We're talking millions of dollars in fixes [with the proposed rulemaking] and we haven't even gotten to forklifts. That includes things like spark detection, isolation valves, explosion ventilation panels, etc. The small business owner might have to go out of business."
A Combustible Dust Policy Institute Group is available on
LinkedIn. The goal of this group is to minimise the severity and reduce the occurrence of combustible dust-related fires and explosions in the global workplace.
Astad is looking for more participants to discuss forklift-related challenges.