Robert Zuiderveld impressed us with the above rhyme during a recent combustible dust discussion on Linked In, but don’t be fooled by the poetic inspiration. Linked In’s Combustible Dust Policy Institute group is one of the most valuable combustible dust forums on the web. Aside from private consultants and combustible dust equipment suppliers (like us!), active members of the group include the people who’s voice really needs to be heard…manufacturers affected by combustible dust. Posts range from questions on best practices, to combustible dust statistics, to some healthy venting on government agencies and personal experiences. But in all cases, the conversation is honest, personal, and unfiltered.  So, if you haven’t already, join the discussion (Not a member of the professional networking site? Shame on you! Sign up…it’s worth it.)

Some things recently overheard in the combustible dust group:

• According to media accounts there were 100 combustible dust related fires and explosions in 2009. 17% of these  incidents were dust explosions with the majority of all incidents occurring in national industries (NAICS) not recognized in Appendix D-1 & D-2 of the OSHA Combustible Dust NEP.
• OSHA fines are like monopoly money. The large companies aren’t affected by them, because they can afford it.  The small companies aren’t affected by them because they will never be able to pay it.
• Looking for a suggestion on a violation pending with OSHA. We were cited on two dust collectors in our shop…this is not a good financial time.

• The Longopac® collection system: this “endless” bag can be dispensed as needed to your desired length. Once filled, it can be cut, sealed, disposed and restored for a new use.
• LED indicators that automatically monitor filter performance and increase productivity.
• Liquid and Solid Level LED sensors (100 L machines only) that automatically shut-off the machine when maximum capacity is achieved.
• Ergonomic design for ease-of-use; includes an accessory storage tray.
• Multiple configurations, including stainless steel construction, automatic filter cleaning systems, and HEPA filtration.
• Dozens of hose, filters and accessories to meet any industrial cleaning challenge. 

The two-motor S2 comes with a 50 liter (13 gallon) collection container, while the S3, three-motor machine, is available with 50 or 100 liter (26 gallon) collection capacities. Both models feature a modular design for easy modifications, upgrades and servicing and are NRTL-approved for electrical safety.

These vacuums are the next generation of our most popular single-phase vacuums; Perfect for everything from general maintenance in a food facility, to spill control in a pharmaceutical processing plant, to overhead cleaning, and preventative combustible dust maintenance.

So, are you ready to enlist the new Nilfisk CFM S2 and S3 for the front lines of your maintenance plan? www.NewNilfiskVacuums.com

1.  NASA space missions

2. Libraries, including the Syracuse University Library (and remember, Ben Franklin launched libraries!)

3. Hurricane Katrina clean-up

4. Iconic American brands like Kraft and Hershey use Nilfisk vacuums in their day-to-day processes

5. The Smithsonian and various museums across the country,  including the New Orleans Collection

6. Ground Zero

7. United States Post Office (Again, Ben Franklin!)

8. Our pharmaceutical vacuums and cleanroom vacuums have played an important part  in the R&D and processing of major life saving drugs.

More than 80 million homes in the United States contain traces of lead, a deadly element that if exposed to, even in small amounts, can cause serious effects on the brain, nervous, reproduction, cardiovascular, muscular, skeletal, renal, and blood systems. 

Lead is often absorbed through contaminated dust in older buildings and through paint chips easily ingested by small children, putting them at high risk for lead poisoning. In 2008, in order to curb the occurrence of lead-related diseases, the EPA issued 40 CR, Part 754, Subpart E, also known as the Lead RRP.

In effect since April 22, 2010, the new rule requires contractors who perform renovations, repair or painting projects on homes or schools built before 1978- the year lead paint was banned- to be licensed and become “EPA Lead–Safe Certified” in order to prevent lead contamination. 

As a result, the RRP has sparked a fury amongst contractors to hurry up and fulfill the new requirements, or pay a hefty fine; and while there are approximately 240 EPA-accredited training providers across the country offering the certification, which includes 6 hours of class time and a 2-hour hands-on skills assessment, the number of firms seeking certification is well over 200,000.

To help alleviate the long lines of contractors waiting to be certified, the State of Kansas approached ComplyAbility (Work Comp Associates, LLC), a non-profit web-based human resources, regulatory compliance, training, testing and performance tracking software company to develop a program that addressed the Lead RRP requirements.  

For years, ComplyAbility has assisted companies with training on a variety of topics related to state and federal regulations, but they were unaware of the Lead RRP rule when the state’s Building Industry Association contacted them about a year ago.

“Fortunately we have strong web capabilities to support the requirements of the Lead RRP class that are very specific,” said Tom Knight, CEO of Work Comp Associates, LLC. “With only 1 other accredited online Lead RRP in the country, ComplyAbility’s program, www.leadsafeonline.com, offers not just convenience, but the ability for contractors all over the country to take the class on their own schedule.  We can also accommodate an infinite amount of students, as opposed to live classes that easily hit their 20-person capacity.”

As required by the EPA, ComplyAbility’s online training includes 17 different modules, featuring descriptive text, photos and videos along with complete audio. Students have the ability to ask questions of a certified trainer at any time while proceeding through the class and can save their work at any step of the program to return later to complete. 

Each module is followed by a quiz, with a 30-question final exam at the conclusion of the course; however, the certification process doesn’t end there.

Following the online portion of the class, students move on to the mandatory hands-on skills assessment, taught by 10 of ComplyAbility’s certified trainers, available to firms all over the country.

“We’ll often partner with an entity like a lumberyard or paint store that sponsor RRP certification for their customers and staff in order to alleviate some of the costs.  Once they pass the online portion, we’ll make arrangements to travel to their facility or meeting location, anywhere in the U.S,” said Knight.

The main purpose of the 2 hour skills assessment is for students to demonstrate the work practices they learned about during the online course. They will be required to, establish interior and exterior containment, perform interior and exterior final cleaning, properly dispose of waste, and keep dust levels low using a HEPA filter vacuum cleaner.  

“HEPA vacuum cleaners are a critical part of the Lead RRP,” said Knight. “The EPA requires they be used to clean walls, furniture, and even workers before they leave the work area. They can also be used to collect dust at the source of sanding and grinding with vacuum-assisted power tools. We even teach our students about safe disposal of waste by using the vacuum cleaner to remove excess air from plastic bags filled with lead debris.”

ComplyAbility relies on Nilfisk GD930 HEPA Vacuums, which were donated by the industrial vacuum manufacturer to be used during hands-on training. While the EPA does not recommend any HEPA vacuums, they do discourage against the use of lower cost shop-style vacuums retrofitted with a HEPA filter in place of the original basic filter.

The GD930 HEPA Vacuum meets the EPA’s definition of a HEPA vacuum cleaner, capturing 99.97% of particulate, down to and including 0.3 microns. The vacuum is also available with a carpet beater bar floor nozzle, another EPA requirement that agitates carpet fibers to collect embedded lead dust.

Upon conclusion of both the online and hands-on training, ComplyAbility processes all paperwork and issues the firm or individual their EPA Lead-Safe Certification, allowing them to legally renovate older homes and schools. The entire ComplyAbility program is offered for just under $200, which is in line with the national average cost of Lead RRP certification classes, but contractors must also apply for a separate Lead RRP license through the EPA, which carries an additional $300 fee.

So, while the Lead RRP requires contractors to invest in both equipment and training, the cost not to comply can result in fines upwards of $37,500 per violation, per day; not to mention potential private lawsuits brought on by homeowners.  Indeed, initial costs will be a heavy burden for some, but considering the deadly effects of lead poisoning, it’s a small price to pay.

For more information on the EPA’s Lead RRP, visit
www.epa.gov/lead/pubs/renovation.htm.

For information on ComplyAbility’s online training program, visit www.leadsafeonline.com 

 HEPA Vacuums Play Critical Role in Lead RRP

On April 22, 2010, the Environmental Protection Agency’s Lead RRP (40 CFR, Part 745, Subpart E) went into effect. The new rule requires contractors performing renovation, repair, and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978 to be certified and follow specific work practices to prevent lead contamination.

Among these required work practices are the use of a HEPA-filtered vacuum cleaner, to minimize dust and thoroughly clean the work area.

According to the rule:

• Walls must be cleaned starting at the ceiling and working down to the floor by either vacuuming with a HEPA vacuum or wiping with a damp cloth.

• Remaining surfaces are to be cleaned by thoroughly vacuuming all remaining surfaces and objects in the work area, including furniture and fixtures, with a HEPA vacuum. The HEPA vacuum must be equipped with a beater bar when vacuuming carpets and rugs.

• The use of machines that remove lead-based paint through high speed operation such as sanding, grinding, power planing, needle gun, abrasive blasting, or sandblasting is prohibited unless such machines are used with HEPA exhaust control.

So, what does the EPA mean by a HEPA vacuum cleaner? In 40 CFR 745.83, the EPA states:

“HEPA vacuum means a vacuum cleaner which has been designed with a high efficiency particulate air (HEPA) filter as the last filtration stage. A HEPA filter is a filter that is capable of capturing particles of 0.3 microns with 99.97% efficiency. The vacuum cleaner must be designed so that all the air drawn into the machine is expelled through the HEPA filter with none of the air leaking past it”

For more information on HEPA Vacuum Cleaners for the Lead RRP, visit www.nilfiskcfm.com/vacuum-applications/EPALeadRRP-hepa-vacuum.aspx or call 1-800-645-3475.

Details: 

What:  “Clearing the Air: Preventing Combustible Dust Hazards with the Proper Cleaning Equipment”

When:  TODAY! Monday, May 24^th @ 2:30pm

Doors open at 2:20pm

Where: Hyatt Regency Denver (across the street from the convention center)

                Centennial C, Level 3

Details: Combustible dust-related fires and explosions are a constant threat for manufacturers. In fact, OSHA estimates that in the U.S. alone, over 30,000 facilities are at risk for major combustible dust explosions. While these incidents are not 100% preventable, they are certainly not inevitable. You can significantly reduce the risk of a combustible dust accident by instilling best engineering practices — practices that include a solid maintenance plan in order to reduce or eliminate dangerous dust that settles on floors, walls, machinery, and overhead areas.

This event will provide attendees with a basic understanding of combustible dust issues and discuss critical housekeeping tips and recommendations. We’ll answer your questions:

• How OSHA define combustible dust?
• How does the OSHA Combustible Dust NEP pertain to maintenance?
• Why is proper maintenance so critical?
• What are “properly-equipped” industrial vacuums to combat combustible dust?
• Are “explosion-proof” vacuums always necessary? 

P.S. Refreshments will be served!

What: Clearing the Air: Preventing Combustible Dust Hazards with Proper Cleaning Equipment

When: Monday, May 24, 2010; 2:30 – 4:00pm CDT

Where: American Industrial Hygiene Conference and Exposition (AIHce)Hyatt Regency Denver Convention Center (Centennial C) across the street from AIHCE.

Sign-up: http://ohsonline.com/nilfisk

Combustible dust-related fires and explosions are a constant threat for manufacturers. In fact OSHA estimates that in the U.S. alone, over 30,000 facilities are at risk for major combustible dust explosions. While these incidents are not 100% preventable, they are certainly not inevitable. You can significantly reduce the risk of a combustible dust accident by instilling best engineering practices — practices that include a solid maintenance plan in order to reduce or eliminate dangerous dust that settles on floors, walls, machinery, and overhead areas.

This event will provide attendees with a basic understanding of combustible dust issues and discuss critical housekeeping tips and recommendations. We’ll answer your questions:

• How OSHA define combustible dust?
• How does the OSHA Combustible Dust NEP pertain to maintenance?
• Why is proper maintenance so critical?
• What are “properly-equipped” industrial vacuums to combat combustible dust?
• Are “explosion-proof” vacuums always necessary?

SPEAKERS 

Aside from combustible dust, high enforcement priories for SVEP will also include amputation hazards, unsafe excavation practices, and silica dust exposure.

So while I am a huge advocate of educating before citing, repeat offenders can’t use the excuse of “we didn’t know.”  And when it’s a matter of protecting your workers who work hard for you day after day, you better straighten up, or pay the price.

1. Don’t create dust clouds while sweeping (or using compressed air, which doesn’t  remove the dust anyways)

2. If your dust is “classed” be sure to use non-sparking, anti-static accessories

3. Make sure your vacuums are approved for use in your classed environment (consult with your AHJ to determine if your environment requires explosion-proof equipment). In many cases, a standard vacuum with anti-static accessories will do the trick, but check with your AHJ first.

4. Don’t forget those hard-to-reach areas, especially tops of machinery, ceiling pipes, lights, etc.

5. If you opt for a contract cleaner, make sure they’re trained and certified to deal with combustible dust; and make sure they have the right equipment! Beware of companies who use shop-style vacuums to collect hazardous materials.  Improper equipment can actually cause the deadly spark.

Want more info, check out www.explosionproof-vacuum.com