Fertilizer manufacturers ultimately want to produce the best possible product – fertilizer with high production yields, high material integrity and quality, and strong marketability. But the manufacturing process leads to other concerns and challenges. Manufacturers must also reduce explosion potential in their facilities and reduce their workers’ exposure to toxins, which means pristine facility hygiene. All of these goals can be achieved through fertilizer dust control.

Dusting of fertilizer at various points in manufacturing, transporting, and storage can cause many issues from equipment wear to higher probability of explosions.

Why fertilizer dust control matters

Without dust control, the fertilizer manufacturer faces a lot of potential liability, danger for workers, and loss of product and equipment. Not to mention, fertilizer dust-related problems could cause damage to the manufacturer’s reputation within the industry.

On one end, a lack of fertilizer dust control can have minimal effects.  A processing facility might need to invest in more frequent maintenance and upkeep of machinery or purchase new machinery more frequently. This means unnecessary expenditures when these funds could be used elsewhere in the business.

But a lack of dust control can have more detrimental effects.  Prolonged, unmitigated exposure to toxins could result in illness or disease for workers.  A study published in the American Journal of Industrial Medicine (Daniels, Dunn, Kubale, Stayner, & Yiin, 2016)[1]found that workers continuously exposed to various chemical elements at a phosphate fertilizer plant had higher rates of lung cancer and emphysema.  Poor dust control can even lead to disaster.  The 1947 Texas City, Texas blast was the deadliest industrial accident in American history (Lallanilla, 2013)[2], and it was caused by improper handling of ammonium nitrate, which is a key ingredient used to improve fertilizer’s nitrogen content.  More recently, a 2013 fire at an ammonium nitrate storage and distribution facility in West, Texas killed 15 people (EPA, 2015)[3]and even damaged nearby businesses, homes, and schools.

1947 Texas City, Texas explosion at an ammonium nitrate plant had blasts so strong they shattered windows 40 miles away in Houston.

Fertilizer dust control isn’t just a way for processing facilities to save money; it can also save lives.

The benefits of dust control

Dust that’s produced during material processing operations becomes a major source of harm and environmental pollution.  This isn’t just in the processing facilities; it’s also a concern at the mining stage and even during shipping and storage.

Fertilizer dust control can mitigate risk at every stage of the production process:

• It protects granule integrity during storage.
• It ensures fertilizer doesn’t become too fragile, which prevents deterioration.
• It reduces risk of fire and dust explosion.
• It boosts safety for all workers and improves on-site visibility.
• It prevents unpleasant odors.
• It reduces the need for, and cost of, maintenance and cleaning.
• It slows wear and tear on equipment.
• It cuts down on wasted product.
• And, it creates a healthier workplace, which in turn improves worker morale and boosts both production and the quality of work.

Some facilities aren’t taking the proper actions, mistakenly thinking they can continue on business as usual or refine select parts of their production processes.  But other companies have turned to regular dust control coatings because they’re long-lasting, they minimally impact the treated fertilizer’s flowability, and they make day-to-day operations safer and more economical.  Even better, fertilizer dust control helps facilities and farmers alike ensure compliance with federal regulations.

Essential regulations for every fertilizer processor

In addition to worker safety and protecting the environment, dust control coatings help with compliance with a slew of regulations from the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and Mine Safety and Health Administration (MSHA).  There are several regulations, and it’s recommended that all fertilizer manufacturers and farmers read them in full, but some of the most important ones to note are as follows.

EPA

• For facilities that handle more than a threshold quantity of certain toxic and/or flammable substances, they’re required to have a Risk Management Program and Plan (RMP) in place. The RMP must be submitted to the EPA for approval.  This plan covers everything from a prevention program and risk management plan to an emergency response program and plans for communication with the public in the event of an accident or emergency (EPA, 2019)[4].
• Each fertilizer facility and all farms must adhere to the General Duty Clause, which essentially states that any business handling hazardous chemicals has a duty to identify potential hazards and take steps to ensure safety for workers and surrounding communities (EPA, 2009).[5]
• Fertilizer facilities must follow the Emergency Planning and Community Right-to-Know Act (EPCRA), which was created in 1986 and requires facilities to report the storage and handling of hazardous materials to federal, state, and local governments (EPA, 2019)[6].
• Some farms are subject to the Clean Air Act, which monitors the release of certain pollutants into the environment and regulates air quality (EPA, 2019)[7].
• EPA also offers guidance and research specific to different types of fertilizer (EPA, 2019)[8]. For example, for fertilizers made from recycled wastes, there are limits for the amount of heavy metals or toxic compounds that can be included in these products.

OSHA

In conjunction with the EPA, OSHA has pulled together an exhaustive list of resources about handling fertilizer.

• There are several regulations about the safe storage, handling, and management of solid ammonium nitrate prills (EPA, OSHA, 2015)[9]. For example, AN prills can’t be heated in a confined space, they can’t be exposed to strong shock waves from explosives, and they can’t be contaminated with combustible materials or organic substances.

Concerning the storage of ammonium nitrate, OSHA goes deep into the innerworkings of processing facilities (OSHA, 2019)[10]:

• Floors must be constructed to eliminate floor drains and piping, to keep out molten materials that could flow or be confined during a fire.
• Facilities must regularly clean floors and equipment as well as the entire plant.
• The land surrounding a mixing plant must be kept clear of brush, dried grass, leaves, and other flammable shrubs for 25 feet.
• Facilities must dispose of AN bags in a safe manner.
• Explosives can’t be used inside of or within 50 feet of a facility that’s used for mixing blasting agents.

MSHA

MSHA focuses many regulations on the proper handling of hazardous chemicals and protection of workers doing the handling.

• Facilities must inform miners about chemical hazards. This involves inventorying chemicals at the mine, determining the hazardous ones, keeping an updated list, writing out a hazard program, and properly labeling hazardous chemicals with accurate Material Safety Data Sheets (MSHA, 2002).[11]
• The MINER Act requires Mine Emergency Response Development (MERD) exercises at least twice per year, to ensure that emergency plans are adequate and officials can act swiftly in the case of a real emergency (MSHA, 2009).[12]
• Mining companies are also obligated by law to maintain the lowest possible personal dust exposure limit for miners (MSHA, 2009).[13]

In short, fertilizer dust control is a necessary part of any fertilizer processing facility’s operations, as it helps company efficiency, ensures worker safety, and fosters the creation of a stronger product for farmers.  The EPA, OSHA, and MSHA regulations further illustrate why dust control and proper handling of hazardous chemicals is so important.

If you’re not sure where to start with fertilizer dust control for your facility, look to DustAid from MinTech’s MinTerra product line.  DustAid coatings were designed to control dust during manufacturing, transportation, and application stages, and they reduce dust on a wide variety of fertilizer blends.  To find out more about DustAid, visit https://mintech.com/minterra/dustaid/.

[1]Daniels, R. D., Dunn, K. L., Kubale, T. L., Stayner, L. T., & Yiin, James H. (2016). A Study Update of Mortality in Workers at a Phosphate Fertilizer Production Facility. Retrieved from: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4913354/

[2]Lallanilla, Marc. (2013). What Causes Fertilizer Explosions?Retrieved from: https://www.scientificamerican.com/article/what-causes-fertilizer-explosions/

[3]Environmental Protection Agency. (2015). Chemical Advisory: Safe Storage, Handling, and Management of Solid Ammonium Nitrate Prills. Retrieved from: https://www.epa.gov/sites/production/files/2015-06/documents/an_advisory_6-5-15.pdf

[4]EPA. (2019) Risk Management Plan (RMP) Rule. Retrieved from: https://www.epa.gov/rmp

[5]EPA. (2009). The General Duty Clause. Retrieved from: https://www.epa.gov/sites/production/files/2013-10/documents/gdc-fact.pdf

[6]EPA .(2019). Emergency Planning and Community Right-to-Know Act (EPCRA). Retrieved from: https://www.epa.gov/epcra

[7]EPA. (2019). Summary of the Clean Air Act. Retrieved from: https://www.epa.gov/laws-regulations/summary-clean-air-act

[8]EPA. (2019). Agriculture Nutrient Management and Fertilizer. Retrieved from: https://www.epa.gov/agriculture/agriculture-nutrient-management-and-fertilizer

[9]EPA, OSHA. (2015). Chemical Advisory: Safe Storage, Handling, and Management of Solid Ammonium Nitrate Prills. Retrieved from: https://www.epa.gov/sites/production/files/2015-06/documents/an_advisory_6-5-15.pdf

[10]OSHA. (2019). 1910.109 – Explosives and blasting agents. Retrieved from: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.109

[11]MSHA. (2002). Telling Miners About Chemical Hazards. Retrieved from: https://arlweb.msha.gov/REGS/COMPLIAN/GUIDES/Hazcom/HazComToolKit.pdf

[12]MSHA (2009). Mine Emergency Response Development (MERD) Contest Guidelines. Retrieved from: https://arlweb.msha.gov/REGS/COMPLIAN/GUIDES/MERDGuidelines062009.pdf

[13]MSHA (2009). Questions and Answers, MSHA’s Final Rule on Conveyer Belt, Fire Prevention and Detection, and Use of Air From the Belt Entry. Retrieved from: https://arlweb.msha.gov/REGS/COMPLIAN/GUIDES/BeltAir.pdf

On January 20, 2017 Donald Trump was sworn in as the 45th President of the United States. During his campaign, he assured the citizens of this country he would Make America Great Again, and one of the many ways he promised to reach that goal was through reviving the coal industry. One avenue President Trump has vowed to take is the dismantling of the Obama administration’s coal regulations, including the Clean Power Plan. The Clean Power Plan (CPP) is a rule proposed in 2015 under the Clean Air Act to force power plants to decrease their carbon emissions, helping to address climate change.

Critics of the CPP say it is an assault on the coal industry that will kill jobs while greatly increasing energy costs for the American consumer. Supporters say it’s an historical step in the right direction of fighting pollution and climate change that will have little effect on the already-declining coal industry.

The CPP was stayed by the Supreme Court a year ago, in February 2016, and with Trump’s election and subsequent nominations of Scott Pruitt (a self-proclaimed “leading activist against the EPA’s activist agenda”) to the head of the US Environmental Protection Agency (EPA) and Neil Gorsuch to fill the vacant seat on the Supreme Court, it’s not clear how the plan will go forward. However, the issues the CPP has raised on both sides have shined a spotlight on the state of the American coal industry and what has shaped its steep decline over the last decade.

Let’s take a look at two key drivers:

The Clean Air Act (CAA):

To truly understand how coal has gone from providing almost 60% of our nation’s electricity to providing only 32%, we have to take a trip back to when environmental protection regulations first came into play.  Through the strict regulation of what the EPA calls “major stationary sources of air pollution,” the CAA has had significant impacts on the coal industry.

Air pollution regulation started its journey toward federal oversight in 1955 with the Air Pollution Control Act, and every step along the way has led to tighter regulations, stricter enforcement, and harsher consequences for coal-fired power plants.

Here’s some history on the CAA:

The first federal legislation to pertain to controlling air pollution was the CAA of 1963.  The law authorized research into techniques for monitoring and controlling air pollution.  Then, in 1967, the Air Quality Act enabled the federal government to increase its activities to investigate enforcing interstate air pollution transport and perform the first stationary source inspections and far-reaching ambient monitoring studies.

President Nixon signed further amendments into law in 1970, which substantially increased the federal government’s role in the control of air pollution.  The legislation:

• Allowed the development of federal and state limits on emissions from stationary and mobile sources (industrial facilities and motor vehicles)
• Established the National Ambient Air Quality Standards (NAAQS)
• Initiated State Implementation Plans (SIPs)
• Authorized New Source Performance Standards (NSPS)
• Instituted National Emission Standards for Hazardous Air Pollutants (NESHAPS)

In December of that same year, the US EPA was established to consolidate the research, monitoring, standard-setting, and enforcement of the requirements included above.

The establishment of the EPA and the 1970 amendments paved the way for the federal government’s 1977 Clean Air Act Amendments (CAAA), which had a major impact on coal end users, such as coal-fired power facilities and industrial boilers.  With the 1977 CAAA, the federal government set forth the provisions for Prevention of Significant Deterioration (PSD) and the permitting process known as New Source Review (NSR).  NSR requires power plants to submit construction plans to EPA for review prior to making modifications to new facilities or building new facilities if they will create a “significant increase” of a regulated pollutant; however, the rule does not require “routine scheduled maintenance” projects to be reviewed.  It is this permitting process that has caused much tension among the EPA, environmental groups, and utilities companies, costing utilities billions.  (More on that in a bit.)  It also required states to submit plans for nonattainment areas (areas that have not met the NAAQS) to reach attainment status within five years.

Next let’s turn to the 1990 CAAA which, proposed by President George H.W. Bush, addresses acid rain, urban air pollution, and toxic air emissions.  The amendment also authorizes a national permitting program (Title V) that requires large businesses to address, control, and minimize air pollutants through planning and reporting processes.  Because coal-fired power production generates 71% of the electric power sector’s carbon emissions, these amendments, like the ones before them, have had significant impacts on the industry.

Now, back to the NSR process.  Because of a lack of clear definitions of “significant increase” and “routine scheduled maintenance,” NSR permitting became a very gray area for some utility companies.  In 1999, the EPA began a concerted effort to enforce NSR compliance and began filing civil complaints against plants they said had illegally released pollutants through violation of the NSR rule.  From 2000 to 2015, there were over 30 coal-fired power plant settlements resulting in closure of plants and generating company commitments to spend millions on environmental mitigation projects, billions on environmental cleanup at their facilities, and civil penalties of $96 million dollars.

The cost of the settlements alone is enough to create significant financial consequences for utilities companies, let alone the cost of monitoring, controlling and developing plans to minimize emissions.  It’s no wonder the industry is seeing steep declines and a long list of bankruptcies.

Market Shifts:

While the CAA might have been the lynchpin of the coal industry decline, opening the door for, and even shifting favor to, other fuel sources, it’s not the only issue.  Just like most things in life, it’s a combination of factors that ultimately lead to the end result.  For coal, one of those factors is the availability of lower cost power generation options, such as natural gas.  Due to fracking technology, natural gas has become a more desirable fuel because it burns cleaner and is cheaper than coal.  To compare costs of natural gas vs. costs of coal is very complex, and ultimately needs to take into consideration delivered prices, emission costs, contract terms, etc., but if we look at it in spot price of $/MWh, we get a more consistent view based on equivalent energy content and efficiency.

If you’re interested in the $/mmBtu, take a look at the chart below.  Keep in mind that gas-fired combined cycle units tend to be more efficient than coal-fired steam units.

Due to the competitive pricing, natural gas consumption has been on the upswing since 1990 and now makes up 33% of the nation’s electricity generation (that’s one point higher than coal).

While renewable resources such as solar and wind are not yet major contributors of electricity generation, they have also seen consistent growth over the past several years, mainly due to reduced costs, making them more viable investments for states.  According to Lazard, the unsubsidized levelized cost of solar PV has fallen 85% since 2009, and the cost of wind has fallen 66% for the same time period, bringing them line with and sometimes cheaper than coal.  The chart below shows the levelized cost of all plant types for 2015; levelized cost is an economic assessment of the average total cost to build and operate a power-generating asset over its lifetime divided by the total energy output of the asset over that lifetime and is used to compare different methods of electricity generation on a consistent basis.

Levelized Cost of Energy by Fuel Source, 2015 (Lazard 2015)

Finally, in addition to lower demand at home, we are seeing lower need for coal exports.  Typically, when demand has been low here, we could depend on other countries, such as China and India to help prop it up.  However, due to environmental commitments of their own, from 2014-2015, China’s coal consumption declined an average 3.2% per year.  And exports to India are not looking much better, as they have begun putting policies into place to reduce coal imports.

While shifts away from coal appear to be the key factor driving down the coal industry in today’s market, one can reasonably attribute those shifts to the increasing burdens the passage of stricter and stricter environmental laws have put on the industry, the awareness of pollution those laws have brought to the public’s attention, and the opportunity those laws have given other fuel sources to further develop and become competitive.

President Trump has committed himself to quite an undertaking when he says he is going to revive the coal industry.  The downward trend has been a long time in the making, and it’s not likely he can affect the quick and drastic turnabout he’s vowed to put in motion with just the loosening of a few regulations.