During a recent ‘Ask Me Anything’ session at the Dust Safety Academy, Tim Heneks, Director of Engineering Services at Dustcon Solutions in West Palm Beach, Florida, discussed NFPA 652, Chapter 8. Tim’s presentation was a two-part session, the first half of which is covered in this episode.
Chapter 8 contains a lot of information. Most of NFPA 652 is dedicated to hazard identification, combustible dust testing, hazard analysis. These later chapters cover management systems – things like management of change, training, contractor requirements and training, inspection systems, maintenance systems and more.
Management Systems Are Often Overlooked
Tim explained that when he does a dust hazard analysis, he often sees the management system side being overlooked.
“Management systems typically focus more on those administrative controls,” he said. “They’re the ways in which we ensure that the safety for combustible dust is maintained over time. What we don’t want to happen is a dust hazard analysis (being) performed, or a design included and installed for combustible dust safety and then, three or five or ten years down the road, those safeguards have been eroded away because they just weren’t kept up.”
Chapter 8 clarifies the requirements for things like housekeeping, hot work permitting, inspection, testing and preventative maintenance. It also provides a framework for how facility owners and managers can, on an ongoing basis, ensure that they’re working correctly.
He explained that the level of attention given to management systems during DHAs largely depends on who’s doing the inspection and how familiar they are with these systems.
“Large dust accumulations… are quickly identified by somebody who’s got a keen eye for it. But going that step further and asking questions like “Is this done as part of a written procedure?” or “What kind of auditing or inspection do you have in place?” is a really important part when we’re going through the management systems at these facilities.”
Management of Change Is Not Always Tracked
Tim said that the thing he often sees missing is management of change (MOC).
“When we dive in a little bit deeper with them, they may have some type of change management process within their organization, but it’s rarely focused on combustible dust. And the reason is usually that the process is driven by quality and not as much by safety. So, for example, if we’re going to change the type of grinder that we’re using from a hammer mill to maybe a gap mill or something like that, the question immediately comes up: “Well, how is this going to change the product that we’re producing?” A question like “How does this impact the safety of the facility?” is not asked as often.”
On a similar note, Tim finds that training systems related to combustible dust are often lacking. In many cases, engineering and safety personnel are the only ones who understand combustible dust hazards in a facility. The frontline operators or maintenance people don’t have an equally solid understanding.
“It’s vitally important that those operators who are dealing with material understand what combustible dust is and what hazards it might present so that they can be the first ones to identify when something’s wrong or take preventative action when they see what might be an ignition source that’s present.”
He added that contractors also need to be made aware of potential hazards.
“When you bring contractors on site, it’s important for them to understand what the hazards of combustible dust are. It’s incumbent on the owner-operator of the facility to ensure that they have that knowledge and what the specific hazards are for the area that contractor is going to be working in.”
Tim recommended that management of change be documented after receiving input from various parties involved with the change, such as engineering, health and safety, maintenance, plant management, and operations. This way, all procedures are written down in case a key person leaves or new employees are brought aboard.
When one listener asked what should be included in a management of change document, Tim recommended the following:
- A definition of what constitutes a change, therefore triggering the MOC process
- Who needs to be involved
- A procedure for getting the details of the change and its potential impact to everyone
“There are a couple of ways I’ve seen this done. One large chemical company had a very sophisticated access database that this whole MOC process was done through. It automatically generated these questions and sent them out to different stakeholders in the project.It was their responsibility to complete the tasks associated with that MOC prior to implementation of whatever that change would be.
“But I’ve also seen it done on a much smaller scale. Maybe there’s a single organization with 50 to 100 people working there. It can be done through a paper route. The MOC documentation can be routed through engineering, plant management, safety, maintenance. Everybody signs off that they’ve understood and that they’re comfortable with it. Then you move forward from there.”
Conclusion
In the end, Tim feels that knowledge is key.
“You can put all the engineering controls in place that you want,” he said. “But if they’re not maintained correctly, or if the operators who are using them are not trained on what they are and why they’re there, eventually they’re going to probably not be as effective. And they may not provide the safety level that we thought.”
If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Tim Heneks directly:
Email: [email protected]
LinkedIn: https://www.linkedin.com/in/timothyheneks/
If you have questions about the contents of this or any other podcast episode, you can go to our ‘Questions from the Community’ page and submit a text message or video recording. We will then bring someone on to answer these questions in a future episode.
Resources mentioned
The resources mentioned in this episode are listed below.
Dust Safety Science
Combustible Dust Incident Database
Dust Safety Science Podcast
Questions from the Community
Dust Safety Academy
Dust Safety Professionals
Organizations
NFPA
Standards
NFPA 652
Companies
Dustcon Solutions
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DSS117: Ask Me Anything – About NFPA 652 Chapter 8 with Tim Heneks (Part 1)
