In today’s episode of the Dust Safety Science podcast, Diane Cave, Eastern Lead from Element6 Solutions, returns to the podcast to talk about the top five mistakes identified during external audits and review of dust hazard analysis reports. During the discussion, she answers the following questions:
- Why might a company bring someone in to audit an existing DHA or risk assessment?
- What does this review process look like?
We’re going to cover the five key themes that Diane has identified after doing these types of reviews and then review any questions that companies should be asking their data provider before starting to work with them.
Why Might a Company Bring Someone in to Audit an Existing DHA or Risk Assessment?
Diane explained that there are a few reasons why a company might hire someone to review an existing dust hazard analysis (DHA) or risk assessment.
First, the report might not include an actual risk assessment, just a list of problems without any advice on where to start or which issues are the most serious. If the people at the facility don’t understand the dangers of combustible dust, they won’t know how to prioritize their actions. For example, they might not realize the importance of choosing the right type of equipment to prevent fires, like using a specific broom to avoid static sparks versus having a dust collector without explosion protection.
Another reason is that the reports can be overly complex and technical, making them difficult to understand. In this case, the company might need someone who can explain the report in simple terms and provide clear directions on what to do next.
Lastly, some reports are just poorly written, and companies need help to make sense of them and decide on the best steps to take.
“I’m sure that there are some other outlying things out there sometimes, like insurers or a third party or something external to the facility will just have a request, especially if the DHA has been done internally,” Diane said. “So you have company X and they have the skill set to do it internally or they think they have the skill set to do it internally. So they do it internally. But then a third party, whether it’s an insurer or whatnot, will come in and then be like, well, no, we want it reviewed by somebody outside. That’s another one that’s happened a couple of times too.”
She added, “Sometimes, the request is straightforward. For instance, a company might receive a recommendation in their dust hazard analysis (DHA) to install a new dust collection system or explosion protection but doesn’t know how to proceed. They ask us to review the DHA to confirm if that’s the right next step or to provide guidance on how to implement it.
“Other times, the request is more complex. A company might find the report so confusing that it’s like it’s written in a different language. In these cases, our role is more in-depth. For the first type of request, our job is to validate the recommendation and suggest practical steps. For the more complex situations, it feels like we’re reviewing or even auditing the original report, which requires a more thorough examination.”
What Does the Process Look Like?
The process varies depending on the complexity of the report. If a report is filled with technical jargon, the job involves thoroughly reviewing it and then distilling its recommendations into an accessible, itemized list for the client. This can include deciphering technical content and images within the report, along with additional information provided by the facility, to prioritize actions based on severity and risk.
This review often happens in the office and is more about interpreting than conducting an on-site audit. However, when reports are poorly written or difficult to understand, resembling a regurgitation of codes and standards without clear guidance, the task becomes more challenging. In such cases, a complete reevaluation may be necessary.
One example that Diane provided involved a client with multiple facilities across the U.S. and Canada struggling to implement recommendations from their DHAs due to unclear reports. Upon review, it was evident that the report was too convoluted to follow, prompting advice for a redo. This led to a new, understandable report, enabling the client to initiate significant risk mitigation projects.
Mistake #1: Too Much Filler
The only place where excessive filler might be acceptable is in a pie, not in reports. A Dust Hazard Analysis (DHA) must be conducted by someone with the appropriate qualifications, a topic often debated. Yet, there’s a tendency for some to include extensive qualifications in their reports, sometimes extending to an 8 or 10-page resume within the DHA document. This addition seems unnecessary, merely adding pages that are likely to be overlooked. Instead, a brief summary of qualifications would suffice.
Additionally, there’s a common practice of copying entire codes and standards into the report, rather than succinctly citing the relevant sections. This approach unnecessarily extends the report’s length. For instance, in discussions about hazardous area classifications, some reports have included every diagram from NFPA 499, scanned and inserted, which could be seen as superfluous. Readers primarily need to know whether a hazardous or electrical area classification is required, not to sift through extensive copied material. The main purpose of a DHA is to identify hazards and outline necessary actions, not to provide an exhaustive explanation of every detail.
Diane noted that often, especially in facilities constructed simultaneously, there may be multiple dust collectors of the same model and vintage, all likely to encounter similar issues. Rather than detailing each of the 37 dust collectors individually, it’s more efficient to group them together in the report. Including a photo of each can be helpful, providing clarity on what is being discussed, but consolidating them into a single section can reduce redundancy, turning what could have been 37 pages into just one or two.
This approach not only simplifies the document but also ensures that any unique cases stand out. For instance, if Dust Collector 7 underwent modifications making it different from the others, its details might be lost among repetitive pages. By highlighting this collector separately or marking the modifications distinctly, it draws attention to the changes, ensuring they are not overlooked amidst the uniformity of the other collectors.
Mistake #2: Poor Identification of Hazards
In scenarios observed within the industry, there’s a tendency to either over-identify hazards, including those unrelated to the primary focus, or to narrowly concentrate on specific areas based on the author’s expertise. For instance, in a dust hazard analysis (DHA), the inclusion of details on an electrical panel within a liquid storage area might occur. While not irrelevant to safety, this detail belongs to a different context, as DHAs are dedicated to identifying fire, flash fire, and explosion risks associated with dust, not liquid-related hazards.
Such reports should adhere strictly to their intended scope, omitting irrelevant hazards like slip risks from water or plumbing issues unrelated to fire suppression systems. The author’s specialization often colors the report’s focus. For example, someone deeply versed in dust hazards might prioritize discussions on dust collection and potential explosion risks, given their familiarity and concern with these issues. Conversely, an author with a strong background in static electricity might overemphasize low-risk static hazards, such as those from synthetic brooms, which might distract from more critical issues.
This was illustrated in a case where a report extensively discussed the minimal risks of static electricity in synthetic brooms, overshadowing more significant hazards. Notably, the facility had dust collectors with explosion vents improperly discharging inside, near operator stations, a critical safety concern that went unaddressed. Meanwhile, the facility focused on replacing brooms due to overstated static electricity risks, neglecting far more severe explosion risks posed by the poorly situated explosion vents.
Adding to the discussion, the significance of selecting an external auditor with a specific expertise for a Dust Hazard Analysis (DHA) was highlighted. It’s advisable for a facility, especially one dealing with particular hazards such as low Minimum Ignition Energy (MIE) where static electricity poses a significant risk, to choose an auditor proficient in that area. Similarly, facilities involved in powder-liquid mixing or those at high risk of flash fires or dust explosions would benefit from auditors with relevant experience. This tailored approach ensures a comprehensive understanding of the facility’s unique hazards.
Mistake #3: The Report is Poorly Organized and Hard to Read
The practice of including photographs directly within the relevant sections, rather than relegating them to appendices, is strongly recommended. This method facilitates immediate reference, enhancing comprehension and the identification of equipment. This approach proved particularly useful in instances where equipment might be known by multiple names within a facility, thereby clarifying potential ambiguities.
Mistake #4: Ambiguous or Unclear Language
Recommendations should be distinctly labeled as such, while mandatory actions must be conveyed with assertiveness to guide facilities effectively. This is crucial in areas concerning safety, such as the improper placement of explosion vents, where ambiguous language could lead to inaction. Acknowledging that facility operators may not possess specialized knowledge in hazard management, explicit directives are essential for ensuring safety measures are understood and implemented.
Mistake #5: Lacking Clear Recommendations and a Path Forward
Auditors should also include a clear list of recommendation requirements. This approach has been highly appreciated by readers, who find it incredibly useful for understanding exactly what actions need to be taken. By reviewing this list and the appendices, which include risk rankings, readers can quickly grasp the necessary steps and priorities without needing to delve into the entirety of the report. However, a common issue identified is when reports only list non-compliant codes or provide recommendations without any prioritization, leaving facilities without guidance on addressing the most critical hazards first.
Conclusion
Diane’s expertise shines a light on the importance of expertise in conducting DHAs, the need for clarity and precision in safety reports, and the benefits of tailoring audits to address the unique hazards of each facility. Her insights serve as a valuable guide for companies seeking to improve their safety protocols and for auditors aiming to provide meaningful, actionable, and comprehensible assessments. This episode not only educates on common mistakes but also offers practical advice for enhancing safety through better reporting and auditing practices in dust hazard analysis.
If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Diane Cave directly:
Website: https://e6dustsolutions.com/
LinkedIn: https://www.linkedin.com/in/diane-cave-p-eng-616b405/
Email: [email protected]
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
Companies
Element6 Solutions
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