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PART 2

NEW REGULATORY STANDARDS AND PRACTICAL SOLUTIONS

Last month, we outlined the new regulations that grain processors needed to be aware of. This
included the new NFPA 652 and OSHA initiatives. This month we delve into the array of options
available to control combustible dust. Grain processors need to be aware of the strengths and
weaknesses of each before choosing the smartest approach.
by W Brad Carr, President, SonicAire, USA
Managed vs engineered approach

These two strategies address how to control combustible dust

and even though the goal is the same, the principles undergirding
each approach are vastly different. Lets examine each approach,
and determine its strengths and weaknesses.

Managed approach

A managed approach is essentially manual housekeeping. In this

scenario, third-party cleaning services or plant employees remove
accumulated dust intermittently. The interval of cleaning depends
on the processing and the type of particles because the more dust
generated, the more frequent the cleaning required.
The approach looks like this: A person gets up on a ladder
(worst case scenario) or on a scissor lift and starts removing the
dust from overhead structures and processing equipment. Once
the dust settles on the floor it is then removed from the building.
The cost of cleaning for this approach varies widely. A range of
prices has been reported to me, including Larry Baker, president
of Fuzion Solution, who noted that one company in the paper
and pulp industry spends an average US$2.40 per square foot on
manual cleaning. Another cost is for one woodworking facility,
which amounted to US$0.40 per square foot. Another is a small
mill that reported spending US$10,000 monthly on manual
cleaning.
52 | November 2016 - Milling and Grain

So the cost is present at whatever level but the question

remains: Is that a good solution for the price?

Benefits

A managed approach is the status quo solution. Before

technological advances were made, manual housekeeping was the
only solution available.
Many people find that ongoing cleaning is an attractive option
because there are low upfront costs. You dont have to invest
a lot of money at one time to continue either using cleaning
services or using your employees to manage combustible dust
levels.
Whats more, manual cleaning for combustible dust can even
appear not to cost anything, as it is absorbed in operational
budgets. It costs, of course, but that cost is buried, which appeals
to some companies budgeting process. Continuing in this way
just seems like less of a hassle.
Manual cleaning also does not need a strategic plan, which
can be viewed as a benefit. If companies do not have a capital
investment plan, it can be extremely difficult to allocate the
funds needed for an engineered approach. Even if the engineered
solutions can show ROI for the installation, some companies
cant secure the initial investment needed. Within this
framework, ongoing manual cleaning is appealing.

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Weaknesses

A managed approach means that personnel or third party

businesses clean the overhead structures on a continuing basis.
This means that these personnel are at risk when cleaning
overhead areas, which is considered a mandatory activity. If
you have ever seen anyone on a ladder or scissor lift in those
high-ceiling plants, you will know exactly what I mean. This
seems to be a solution that uses dangerous practices to eliminate
a dangerous situation. Thats not a trade-off that makes sense to
me.
The second weakness in a managed approach is equally
problematic. Given the fact that people are scheduled to clean at
certain time intervals, it is axiomatic that there are times when
the facility does not comply with safety standards. As I said
earlier, there is basically a zero-tolerance approach to fugitive
dust buildup. The cyclical nature of manual cleaning allows for
too much accumulated dust, preventing the plant from being in
compliance with OSHA.
The third weakness is a monetary one. A managed approach
requires never-ending costs. You have to keep the cleaning
services forever because you are always cleaning up after the
fact.
Not only are there ongoing costs that continue for the duration
of the life of the plant, there is also lost production time when the
cleaning takes place. You cant clean safely when the machines
are operating. Inevitably, lost production means lost profits.

Engineered approach

Referred to as automated housekeeping, the assumption of

an engineered approach is that technology can be leveraged to
automate cleaning processes and continuously protect against the

risks of combustible dust accumulation.

Two types of engineering solutions exist and the first is
localized filtration. With this, the equipment captures the
combustible dust by either vacuuming or suctioning. This
approach is often needed, but the reality is that it cant be used
alone. Localized filtrations simply cant capture every particle of
dust. There is always fugitive dust.
The second technology is barrier technology, which prevents
fugitive dust from accumulating on overhead structures. With
barrier technology, a robotic clean fan automatically establishes
and maintains OSHA compliance throughout the plant. With this
approach, there is a one-time deep clean of fugitive dust, and
once that dust is removed, the barrier technology prevents new
dust from ever accumulating again.
Often there is a synergy between the filtration and the barrier
technologies for enterprise-wide compliance, because they can be
effectively used together in one facility.

Benefits

The value of using technology stems from its simple operating

principle: It is better to prevent dust from accumulating instead
of cleaning it up afterwards. An ounce of prevention is worth a
pound of cure, and only engineered solutions have a proactive
approach to prevent dust from accumulating.
The first benefit is that employees are not put at risk to clean.
No longer do people have to climb ladders, mount scaffolds or
scissor lifts to reach the fugitive dust in overhead areas. Often
in these cases, personnel have to extend their bodies beyond the
confines of the scissor lift to make sure all the dust is removed.
With an engineered approach, these safety hazards are eliminated.
The second benefit is that a one-time investment means a

Milling and Grain - November 2016 | 53

"we know we have to control

combustible dust, regardless
of the complications. If we
fail to do so, we will have to
deal with the consequences
of combustible dust
controlling us. So regardless
of where the regulations are,
we should do the right thing
to prevent an explosion."

also delivers consistently higher levels of clean to meet or exceed

those standards. Plants can avoid stiff fines and more importantly,
keep their employees safe continually.

Weaknesses

The most difficult part of an engineered approach is breaking

with the status quo because of budgeting processes. You have to
budget strategically for the capital investment required for any
engineered solution. Far too often, we stay comfortable with the
status quo until something cataclysmic happens. The tragedy of a
combustible dust explosion then forces a change.
Another issue is that you have to be careful about how the
technology is used. Firstly, the equipment has to be appropriated
and installed correctly, and the technology needs to be used
continuously so process areas are clean. Secondly, for clean fans,
you dont want to robotically clean more than a 90-100 diameter
per fan because there are too many obstacles in the way.

The effective solution

permanent clean. Professionals can show the ROI of their

expenditures, amortizing the costs against the ongoing costs
of manual cleaning. The duration of the payoff will depend
on the technology chosen. An engineered approach allows
for automated, controlled cleaning that doesnt interfere with
production.
Most significant is the benefit that an engineered approach
means that plants can now be in continuous compliance.
Depending on the sophistication of the specific technology, it

Initial cost
Operating cost
On-going labor cost
Employee morale
Energy usage
Disruption to normal production
To conclude, we know we have to control combustible dust,
regardless of the complications. If we fail to do so, we will have
to deal with the consequences of combustible dust controlling us.
So regardless of where the regulations are, we should do the right
thing to prevent an explosion. We have nothing to lose except
for combustible dust.

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