Kevin N.

Jeffries, CEAS
Corporate Safety Systems
Manager

A Comprehensive Approach
to Combustible Dust
Management

October 21, 2010 1

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Continuous Improvement!

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 Agenda

• Safety Objectives
• Partners and Process
• Equipment Design
– Understanding Sugar Risks
– Design Principles
– Implications and Examples
• Policies and Procedures
– Safety Above All Else
– Housekeeping
– Maintenance
– Personal Protective Equipment
• Training & Education
• Future Initiatives
• Outreach 4
 Safety Objectives

• To Operate the Safest Sugar Refineries in the World

• Demonstrate What’s Possible - Compliance as a Minimum
• Utilize “Core Combustible Dust Consensus Standards”
– NFPA 61 & 654
– Other consensus standards referenced in NFPA 61 & 654
• Comprehensive Approach
– Design improvements
– Policies/Procedures
– Training
• To “Give Back”
– Respect
– In thanks

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 Partners & Process

Partners Process
• Chilworth Global • Redefine Process
• Dennis Group • Conduct PHA – New Design
• Fluor • Design Reviews
• Fike • Teamwork & Communication
• Fenwal Among Partners & Imperial
• MAC Sugar
• CV Technology
• Zurich
• Legal Support
– Alston & Bird
– Jones Walker

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 Design Principles

• Understand the Risk • Layers of Protection –

– Investigations (history) Continued
– More than 120 sugar – Separation
samples – Suppression
• Additional knowledge – Isolation
• New MSDS (employees & – Pressure relief
end users) – Life safety
• Layers of Protection --
Prevention
– Control ignition sources
– Minimize fuel
– Avoid suspension

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 Understanding the Risk:
General Properties of Sugar

 Sugar is remarkably soluble in water [1 g. of water dissolves 2 g. sugar]

 Sugar is one of the least-toxic materials known [LD 50 = 4.5 lbs./150-lb. person]

 Heat of combustion is relatively low, for an organic material [4 kcal/g.]

 There are few waste materials in a sugar refinery: Sugar-dust collection, spills,
etc. are re-processed
 The moisture content resulting from prolonged exposure to atmospheric
humidity does not increase above a fraction of a percent before a solution is
formed

INFORMATION DEVELOPED BY CHILWORTH TECHNOLOGY, INC

 Understanding the Risk - What Was Learned:
Explosion and Fire Hazards of Sugar

Sugar/Sucrose Explosion Hazards:

 Minimum Ignition Energy of fine dust can be very low [4 millijoules]

 Non-conductive [can generate and accumulate static electricity]

 Explosion of fine dust can result in rapid pressure increase [Kst=139]

Sugar/Sucrose Decomposition Hazards:

 Sugar melts at about 185°C [365°F] and then decomposes

 The decomposition of sugar is exothermic [gives off heat]
 Decomposition also yields gases: a flammable aldehyde, CO2, and H2O
 Confinement of the gases can lead to very high pressures
 Large containers of sugar need protection against slow overpressure

INFORMATION DEVELOPED BY CHILWORTH TECHNOLOGY, INC

 Engineering Controls -- Prevention

Ignition Control: Fuel Control: Avoid Suspension:

• Electrical • Building materials • Local exhaust ventilation
Classification • Physical separation • Dense phase conveyance
• Grounding, bonding, • Sealed equipment
and static control • Design for housekeeping
• T3B (Max. Temp) • Wet dust collectors
• Monitoring: • Central vacuum systems
- Bearing temp’s • Monitoring choked chutes
- Belt tracking
- Pulley/shaft speed
• Belt speed (<350
fpm)
• Plastic buckets
• Screens and magnets
• Access Restrictions

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Dense Phase Conveying: Comparison

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 Dense Phase Conveying

Main Storage Silos

Bulk Loading

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 Electrical Classification

NEMA 9 Enclosures in Classified Areas

EE Forklifts

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 Interlocked Monitors

Elevator Belt Alignment

Elevator Speed Switch & Bearing Temperature

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 Screens with
Rotary Valve Feed System

Rotary Valves for

Isolation

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 Explosion Relief Panels

Bulk Station Bucket

Elevator

Bulk Tanks

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 Suppression and Isolation

Rotary Valves

Chemical
Suppression

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Powdered Sugar

• Class II, Division 1, Group G

• Highly monitored and interlocked
process and equipment design
• Explosion Relief Panels
• Segregated with pre-cast walls (3
hour fire rating)
• Intumescent paint on columns
• Explosion venting for vessels
• Chemical isolation & suppression
• Access control

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 Silos

– Segregated from high occupancy areas

– Pressure relief and grounding
– Dense phase material handling systems
– Wet dust collection system

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Packaging Wet Dust Collectors

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Local Exhaust Ventilation

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Transportation Protection

Truck Loading Dust Collection

Railcar Grounding System

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Central Vacuum System

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 Packaging Area Innovations

Silos
Tapered
Sills

Sealed
Static Dissipative Ceiling
Floor Test Connection

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Walk On Ceiling

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Deluge Systems

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Life Safety

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 Agenda

• Safety Objectives
• Partners and Process
• Equipment Design
• Policies and Procedures
– Safety Above All Else
– Reinforcement of Core Procedures
• Management of Change (MOC)
• Confined Space Entry
• Hot Work
• Lockout/Tagout
– Housekeeping
– Maintenance
– Personal Protective Equipment

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 Policies and Procedures

• Our Principles. Safety is part of Imperial Sugar’s core

set of values because it impacts the lives and livelihood
of our people, our customers and our communities.
• Safety is Always More Important than Production. If
necessary to avoid an unsafe condition, stop work, shut
down, or lock out.
• Safety Policies and Procedures Are Critical. All
associates need to follow safety procedures, and a
failure to do so can result in discipline up to and
including discharge.
• Reporting Safety Concerns or Violations is Required.
Mechanisms provided for reporting directly to any level
of management.

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 Policies and Procedures
• Incident Investigation
– Tier I & Tier II
– Team based
– 5 Why Analysis
• Management of Change
– Includes emergency MoC
– Weekly meetings
– Encourages utilization of outside
consultation when needed
• Combustible Dust Training
– Defines tiers of annual training
requirements for employees,
contractors, and visitors
• Lockout/Tagout
– First lock by equipment owner
– Considers chemical explosion
suppression and isolation equipment
• Hazardous Area Electrical
Classification
– Defines how hazardous areas are
classified, labeled, and controlled
• Hot Work
– Includes requirements from NFPA 61
– No hot work on operating equipment
– ISC issues hot work permit for
contractors
• Impairment of Safety Critical
Equipment
– Fire & explosion protection equipment
(e.g., fixed fire protection + explosion
suppression)
– Emergency process control systems
(e.g., safety critical interlocks, alarms,
paths of egress, environmental
controls, over-pressure protection,
staffing reductions, and food safety
critical controls
– Defines mitigations
• Confined Space Entry
– Developing detailed “confined space
entry specification sheets”
• Preventive Maintenance
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Revised Hot Work Permit

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 Policies and Procedures:
Housekeeping

• Shutdown Expectations
• Master Housekeeping
Schedule
• Routine, Quantifiable Audits
• Housekeeping Culture Change
- “Housekeeping is a part of my
job”
• Static Dissipative Tools
• Incident Investigations for
>1/32”

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 Policies and Procedures:
Housekeeping – Underneath Silo

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Policies and Procedures:
Housekeeping – Bins

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 Personal Protective Equipment

• Fire Resistant Clothing

• Static Dissipative Shoes
• Considering SD Shoe Testers
• Anti-static Gloves for Selected
Tasks (not fully deployed)

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 Agenda

• Safety Objectives
• Partners and Process
• Equipment Design
• Policies and Procedures
• People: Training & Education

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 People: Training and Education

Combustible Dust Training

• Classroom or one-on-one instruction by internal and external
resources for managers, supervisors and engineers
• Annual computer-based training for employees and contractors –
passing scores required
– Depth of training varies dependent upon audience risk
• “Working Safely Around Sugar Dust”: General awareness and control
mechanisms for office employees, contractors, unaccompanied visitors
• “Safe Production Around Sugar Dust”: More in-depth instruction for plant
employees and selected contractors (nested and higher exposure)
• “Maintaining Sugar and Dust Handling Equipment”: In early stages of
development. Will provide detailed instruction about maintenance and
preventative maintenance for dust collectors, screw conveyors, bucket
elevators, etc.

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People: Training and Education

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 Policies and Procedures

• Other training
– Traditional regulatory requirements (e.g., lockout,
confined space, hot work, hearing conservation,
hazard communication, emergency response)
– Electrical classification for focused audiences
– How and when to submit a safety complaint for all
employees
– Aggressive slate of training for managers,
supervisors, superintendents, and engineers on a
breadth of safety topics (e.g., Life Safety Code, NFPA
61, 68, 69, 499, 654; OSHA 30 Hour Course;
Ergonomics; Industrial Ventilation)
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 Agenda

• Safety Objectives
• Partners and Process
• Equipment Design
– Design Principles
– Understanding risk - Sugar
– Implications and examples
• Policies and Procedures
• People: Training & Education
• Future Initiatives
• Outreach

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 The Future

• User Functional Specification Process

• Safety Management System
– OHSAS 18001
– Electronic Tool (DakotaSoft)
• Management of Change
• Action Tracking
• Incident Reporting & Investigation
• Continuous Improvement – All Processes,
Programs, etc.
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 Agenda

• Safety Objectives
• Partners and Process
• Equipment Design
– Design Principles
– Understanding risk - Sugar
– Implications and examples
• Policies and Procedures
• People: Training & Education
• Outreach

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 Outreach

Government
• Strong Supporter of OSHA Combustible Dust Standard
• Participated in Stakeholder Meetings and Commented on ANPR
• Hosted Chemical Safety Board
Food Industry
• Sugar Industry Technologists
• Sugar Association Safety Exchange
• Hosted Three Individual Sugar Companies
• Customer Safety Day
• Sugar Users Association (10/13/10)
Professional Groups
• Georgia Fire Safety Symposium
• River Parishes Emergency Response Exchange
• NFPA Journal
• American Industrial Hygiene Association Carolinas Spring PDC
• Carolinas Environmental Information Association
• NFPA Fire Protection Research Foundation Symposium (10/21/10)
• National Safety Council Working Group on Combustible Dust
Other
• Modern Marvels

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We’re Not Finished Yet!

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