What the Required Dust Hazard Analysis Means for Your Team

If you’ve been waiting to complete a few of the bigger tasks on your agenda, use this season to do some much-needed spring cleaning—especially if your facility faces combustible dust hazards.

Per the NFPA® 652 Standard on the Fundamentals of Combustible Dust (2019), you’re required to complete a Dust Hazard Analysis (DHA) by September 7, 2020; or, you must be able to show strong progress toward completion.

Wondering where to start? NFPA® 652. NFPA® 652 provides fundamental safety principles applicable to all combustible dusts. Other NFPA® standards, related to specific industries or commodities, contain requirements in addition to those in NFPA® 652. In the typical application of these standards, where a Dust Hazard Analysis (DHA) reveals potential fire, flash fire, or explosion hazards, the prescribed requirements for preventative and protective safeguards are put in place. But what exactly does this mean for you and your team? Here, we break it down.

Per NFPA® 652, a qualified, experienced person must identify and provide recommendations on managing the fire and explosion hazards in your facility by using the prescriptive or performance based DHA method. Why? Because implementing preventative and protective safeguards in the form of key risk control methods—including protective engineering risk controls (venting, suppression, containment) and preventative administrative risk controls (housekeeping, hot work permits)—will limit dust (fuel), eliminate ignition sources, and reduce oxidant concentrations to help mitigate risk by reducing both the likelihood of incidence occurrence and the severity of injury.

But it’s also critical that you’re prepared for a situation in which one or more of the above risk controls fails. That’s where Personal Protective Equipment (PPE) comes in. Considered the last line of defense, PPE like FR apparel, can reduce the severity of injury should an incident occur.

An afterthought in past combustible dust hazard mitigation programs, PPE has garnered a considerable amount of well-deserved attention thanks to the latest NFPA® 652 edition—which highlighted PPE for protecting against combustible dust fire and flash fire hazards in Chapter 8—and recent OSHA® enforcement. In fact, after a catastrophic combustible dust explosion with 5 fatalities occurred at their facility in 2017, Didion Milling was issued numerous citations and OSHA fines for a total of $1,837,861, which included a fine of $126,746 for a willful violation of CFR 1910.132 – failure to provide flame resistant clothing as PPE.

While FR clothing/PPE can not protect against concussive forces for those in the immediate explosion vicinity, it can protect them against potentially catastrophic body burn injuries caused by other related (and often subsequent) combustible dust flash fires. While non-FR gear can ignite and continue to burn even after the source of the fire has been eliminated, FR clothing will self-extinguish, limiting the wearer’s thermal exposure and significantly reducing the severity of their burn injuries.

Incorporating FR clothing into your safety program is essential for protecting your team—and with guidance from the latest NFPA® 652 Standard, you can complete the DHA, elevate the status of PPE, and ultimately, reduce the overall risk of combustible dust fatalities and injuries at your facility.

To learn more about the DHA, and additional steps you can take to mitigate dust hazards, click here. To contact one of our FR safety experts, click here. For nearly 20 years, Westex® by Milliken® has been dedicated to helping people like you understand the hazards their company faces and how to protect their employees.

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