2008-05-I-GA-1

Apply the following standards to the design and operation of the new Port Wentworth facility:

• NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities
• NFPA 499: Recommended Practice for the Classification of Combustible Dusts and Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas.
• NFPA 654:Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids. 
• NFPA Handbook, Electrical Installations in Hazardous Locations. 
• NFPA 70 Article 500:Hazardous (Classified) Locations.

Status: O-ARE/AR

2008-05-I-GA-2

Conduct a comprehensive review of all existing Imperial Sugar Company sugar manufacturing facilities against the standards listed in recommendation R1 and implement identified corrective actions.

Status: O-ARE/AR

2008-05-I-GA-3

Implement a corporate-wide comprehensive housekeeping program to control combustible dust accumulation that will ensure sugar dust, cornstarch dust, or other combustible dust does not accumulate to hazardous quantities on overhead horizontal surfaces, packing equipment, and floors.

Status: O-ARAR

2008-05-I-GA-4

Develop training materials that address combustible dust hazards and train all employees and contractors at all Imperial Sugar Company facilities. Require periodic (e.g., annual) refresher training for all employees and contractors.

Status: O-ARAR

2008-05-I-GA-5

Improve the emergency evacuation policies and procedures at the Port Wentworth facility; specifically,

• Install an emergency alert (alarm) system in the facility, and
• Require routine emergency evacuation drills and critiques.

Status: O-ARAR

2008-05-I-GA-6

Incorporate combustible dust hazard awareness into employee and member companies’ training programs, such as the Safety and Health Management Systems training course. Include combustible dust characteristics, especially ignition energy and minimum explosible concentration; best practices for minimizing dust accumulation, especially on elevated surfaces; and safe housekeeping practices.

Status: O-ARE/AR

2008-05-I-GA-7

Add specific combustible dust inspection requirements and metrics to the Food Contact Packaging Facility audit procedures.

Status: O-ARE/AR

2008-05-I-GA-8

Actively promote improvements in combustible dust hazard awareness and control throughout the wholesale baking industry by publishing bulletins or safety guidance that address combustible dust characteristics including ignition energy, minimum explosible concentration, best practices for minimizing dust accumulation, and safe housekeeping practices.

Status: O-ARE/AR

2008-05-I-GA-9

Require member companies to:

• Develop and implement combustible dust hazard awareness training for all facility audit personnel, and
• Incorporate combustible dust hazard identification in the audit protocols.

Status: O-ARE/AR

2008-05-I-GA-10

Ensure that all risk engineers are trained in the hazards of combustible dust, and that refresher training occurs at regular intervals. Provide a copy of your combustible dust hazard awareness training materials to your clients who deal with combustible dust.

Status: O-ARE/AR

2009-05-I-GA-11

Proceed expeditiously, consistent with the Chemical Safety Board’s November 2006 recommendation and OSHA’s announced intention to conduct rulemaking, to promulgate a comprehensive standard to reduce or eliminate hazards from fire and explosion from combustible powders and dust.

Status: O-ARE/AR