Your Dust Hazard Analysis (DHA) Questions Answered
Question 1: I‘ve missed the deadline in NFPA 652 for completing a Dust Hazard Analysis on my facility. What do I do now?
Answer: National Fire Protection Association (NFPA) 652 ‘Standard on the Fundamentals of Combustible Dust’ contains a deadline – September 7, 2020*. Do you have combustible or explosible dusts? If so, this is the date by which you should have completed a Dust Hazard Analysis (DHA) for your facility or processes.
As process safety specialists, Stonehouse consultants have undertaken many DHAs with or on behalf of our many North American company clients. We’ve noticed that the phone is still ringing, though, with clients asking for assistance with this work.
There is no doubt that the Covid-19 pandemic has disrupted many companies process safety plans and this is partly the reason for the delays. It’s taken a while for companies to become comfortable with having outside consultants visit and inspect their plants, even if they are operating as normal. So, if you have not yet completed your DHA, our experience tells us that you are not yet alone! There are quite a few companies out there that still need to undertake their DHAs.
Because of the Covid-19 pandemic and to keep things moving in the right direction for our clients, at Stonehouse we have devised ways to conduct at least parts of the DHAs remotely (see our Process Safety Dispatch article here Performing a Dust Hazard Analysis (DHA) During the Coronavirus Pandemic Lockdown). For some of those clients we are now entering the project phase where we are vising them for final inspections, follow-ups, and final checks to ensure that the remote DHAs have not missed anything. We are also conducting DHAs in person where companies have Covid-secure plans in place, and we expect the pace of requests for on-site-DHAs to pick up as the pandemic is brought under control.
Our advice: Contact us now and discuss the options available to your company. The requirement to conduct a DHA has not gone away. If you do not do a DHA you have not addressed a known (dust explosion) risk to your people and business. We are taking lots of DHA bookings right now for the weeks and months ahead.
Question 2: I completed a Dust Hazard Analysis on my facility a few years ago. Is there more I need to do to comply with NFPA 652?
Answer: Absolutely YES! Obtaining a good DHA and then ensuring the action points in the DHA are fully implemented is really just the starting point.
There are ongoing requirements associated with the DHA and of course the DHA should also be updated as processes, equipment or other changes to plant and process operations are made. There is additionally a formal requirement to review/renew the DHA every 5 years.
A sample of some of the ongoing tasks you should be considering are listed here for your reference:
- A periodic walk-through review of operating areas – a schedule established to verify that operating procedures and safe work practices are being followed.
- Up to date written procedures for operating the facility and equipment.
- An Inspection, testing, and maintenance program should be established and implemented to include:
- Fire and explosion protection and prevention equipment in accordance with the applicable NFPA standards,
- Dust control equipment,
- Potential ignition sources,
- Electrical, process, and mechanical equipment, including process interlocks,
- Process changes,
- Lubrication of bearings,
- This activity should be documented, and records kept,
- Training programs according to the potential exposure to combustible dust hazards and the potential risks should be established and implemented. Training programs should include contractors as appropriate.
- There should be an emergency plan established (and reviewed annually).
- Any incidents should be investigated and documented – with lessons learned and changes implemented as appropriate.
- Procedures should be established to guard against dangers introduced by change (management of change procedure).
- There should be a system in place to manage and retain documentation relating to the dust fire/ explosion risk.
This list is not comprehensive. Further information is available in NFPA 652 and by contacting us directly.
Our advice: We are here to help. If you have already performed a DHA that is coming up for review or if there are questions of implementation that still need addressing, please contact us for a complementary discussion. We’ve assisted many companies, large and small, from multiple different industrial sectors, with our practical DHA advice based on years of experience undertaking dust explosion work in North America, Europe, and Asia. Let us draw on that experience to help your organization. Contact us on 609-455-0001 or email us at email@example.com.
* Deadline for completing a DHA for agricultural and food processing facilities is June 2nd, 2021.