The National Fire Prevention Association (NFPA) updated industry consensus standard ( NFPA 652, entitled Fundamentals of Combustible Dust, 2019), calls for manufacturing industries with combustible dust to complete dust hazard analyses (DHAs). Two major requirements of NFPA652 are that owners/operators must:
- Obtain and evaluate dust combustion properties
- Conduct a DHA by September 7, 2020
The first step to achieving compliance with the new NFPA652 standard is to identify all potential dusts generated/handled at the facility, conduct a review of the SDS, obtain available dust data from vendors, review online dust data, and/or collect site dust samples to send out for dust explosivity analysis. Once dusts are characterized, the data is utilized in a DHA. During a DHA, a list of equipment is developed, fire and explosion hazards are identified, credible ignition sources are identified, consequences are identified, risks are evaluated, and recommendations to reduce risks are documented.
While Occupational Safety and Health Act (OSHA) had proposed a combustible dust standard in 2009, the rule was never finalized. However, the lack of a specific rule has not prevented OSHA from citing employers that fail to correct “recognized hazards.” If a hazard is not addressed by the employer per OSHA Section 5(a)(1), often referred to as the General Duty Clause (GDC), citations may occur. This section requires employers to "furnish to each of his employees' employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees".
Some common OSHA dust violations that incurred citations under the GDC have included:
- Dust collectors located inside an occupied building with no or improper explosion protection
- Lack of bonding and grounding
- Lack of housekeeping
- Lack of employee training
- No classification of electrical equipment
Previously mentioned common hazards have all been causal factors in actual combustible dust fire or explosion incidents that resulted in the loss of life or serious injury, in addition to the loss of capital assets and business interruption. Understanding the characteristics of your dusts and performing a robust DHA should identify such hazards, using NFPA standards as guidance. A DHA also identifies prevention and mitigation strategies that can be implemented to manage the risk associated with combustible dust fire and explosion hazards, as well as avoid costly OSHA citations.
Trinity Consultants has qualified, trained consultants that can assist you with the evaluation of your dust properties and conduct a DHA of your facility. Contact your local Trinity Office at 800.229.6655 for a consultation or proposal for Trinity to help you achieve compliance with NFPA652 and avoid costly OSHA citations.