Ethanol plants have complex explosion and fire hazards not found in other manufacturing national industries (NAICS) where the attributes of a grain handling facility is combined with a chemical plant in the production of ethyl alcohol. Subsequently, these process facilities must follow stringent regulatory guidelines according to the OSHA Process Management Standard (PSM) and EPA Risk Management Program (RPM). Additionally, combustible dust hazards are addressed in the OSHA Grain Facility Standard.
With the multitude of regulatory control measures protecting workers, the environment, and the public; accidents still happen. The question arises can the current high incident rate be minimized? In less than a year six ethanol plant explosions have occurred in Michigan, Arizona Minnesota, Kansas, Wisconsin, and Nebraska with ensuing injuries in 50% of these incidents.
So what is an unacceptable accident and injury rate before stakeholders reassess current administrative and best engineering control measures? All the proper administrative and best engineering control measures seem to be in place in the prevention and mitigation of fires and explosions. Yet the incidents are exponentially higher than any other national industry(NAICS)
For instance, ethanol trade associations such as the Renewable Fuel Association (RFA) has an proactive safety program addressing many of the hazards in ethanol production. Additionally, the RFA works collectively with the University of Illinois Fire Service in providing industry with educational programs that prevent future incidents.
Recently, Kirkwood Community College in Cedar Rapids, Iowa was awarded a $174,978 OSHA Susan Harwood Training Grant in hosting a 2 ½-hour awareness-level combustible dust safety course addressing grain dust and other organic dusts such as sugar, flour and paper. The training will provide 150 courses in 14 Midwestern states for 3,000 employers and employees primarily in the agriculture, food processing and fiber sectors with a focus on grain elevators and ethanol bio-refineries. Training is a great administrative approach in providing hazard awareness. But what about the current best engineering control measures and are they adequate?
With the current progression of incidents, this unique national industry with a primary NAICS 325193 Ethyl Alcohol Manufacturing and secondary NAICS 311211 Wet Corn Milling is quite similiar to tectonic plates shifting, one upon the other, and its only a matter of time before another event occurs in the seismic proportion of the 2007 Steamboat, Iowa explosion, causing millions of dollars in damage in addition to potential fatalities and injuries.
Overall, in the majority of these recent ethanol plant incidents, life safety, structural integrity and mission continuity objectives of the NFPA combustible dust standards have been maintained. This is an excellent example illustrating that combustible dust related explosions cannot be totally prevented only the severity reduced. The task now is to somehow reduce the probability.
This overview is not meant to place blame on the ethanol industry which is actively striving to reduce incident rates. Hopefully the information from tracking and researching these incidents will provide stakeholders an enhanced awareness concerning trends that have been developing. With this information possible preventative and mitigative strategies can be devised in minimizing the occurrence of another tremor.
