In this episode of the DustSafetyScience Podcast, we are interviewing Dr. Chris Bloore about conducting a dust hazard analysis remotely.
This is the fourth time Chris has appeared on the podcast. In Episode #40, he explained how to run effective dust explosion training sessions. In Episode #38, he talked about the New Zealand Code of Practice for handling combustible dusts, and, back in Episode #31, the topic was reconciling hygiene with explosion safety in food industries.
Today, Chris goes over the process of carrying out a remote DHA. This topic arose from a discussion on the Dust Safety Academy platform. Due to the global COVID-19 pandemic, borders have been closed everywhere, making it difficult for safety professionals to do their job. Dr. Bloore mentioned in that post that he was doing five-year follow-up dust hazard analyses remotely with some companies, so he’s back on the podcast to answer the following questions:
- How are facilities dealing with the pandemic?
- What considerations are involved when doing a remote dust hazard analysis?
- Are there any steps in a remote DHA that wouldn’t occur in an in-person one?
- What about new facility assessments?
- What are the likely difficulties?
- Is it a bad idea to do a fully remote DHA when the consultant hasn’t been in the facility?
How are facilities dealing with the COVID-19 pandemic?
Most of Chris’ clients are in industries deemed essential, so they are still operating, but with travel being restricted, he’s unable to do a DHA in person, and many of them will soon have reviews due under the NFPA requirement.
“They’ve already been through the process once and they should have learned a lot about how to do it,” he said. “But five years is a long time and you make changes. Staff changes. Management changes. Process equipment breaks down and is repaired or replaced or improved. And I’ve seen many an improvement that was a backward step. So that’s where the remote operation for DHA comes in.”
What considerations are involved when doing a remote Dust Hazard Analysis?
Chris explained that the considerations for remote DHAS depend on a number of things, such as:
- Standard of documentation. If the original DHA was well-documented and the process instrumentation drawings are up to date and in order, it’s easier to do an accurate and effective DHA remotely.
- Whether anything has changed since the last DHA. If the plant is no longer making the same products it did when it was designed, are the new products safer? Or are they more hazardous? “A classic example is when people start using powdered sugar as an ingredient, in place of another product,” Chris said.
- Access to staff. “If you’ve got access to someone with a camera or even better, a GoPro and a cell phone, it’s possible to do a virtual walk around and actually ask them to point the camera at certain things,” he explained.
Chris recommended doing a technical briefing session with key facility personnel like the maintenance manager or plant engineer. They are typically the ones who have regularly been requesting improved safety features and are likely to support the DHA process by being direct and honest about any concerns.
Are there any steps in a remote DHA that wouldn’t occur at an in-person Analysis?
“Not really,” Chris answered. “What you’re trying to do is complete, to the best of your ability, the same suite of things that you would have covered if you were there.”
This includes talking to different levels of personnel throughout the organization, doing a walk-around with a plant manager, and asking questions. “You’re accomplishing the same goal, but you’re doing it through a series of virtual meetings rather than a single comprehensive site visit,” he explained.
What about new facility assessments?
At the moment, Chris has a couple of clients in different countries who will need assessments carried out at new facilities. His approach is to go through the full haz-op approach, during which he reviews everything on paper, such as plant layout and safety systems.
“Then they get through the built physical building of the plant and you get involved again throughout that,” he said. “You start getting photographs of the concrete walls with holes cut in them in the wrong place, and they have to be moved. The equipment must be moved. I can do all of that remotely if I have to, because it’s largely on paper. When you come to the actual plant commissioning, that’s a good time to be there if you can. But again, you can have a remote commissioning engineer who can keep you posted and be your eyes and ears on the ground. So that’s how I’ve coped with those.”
What are the likely difficulties?
In Chris’ opinion, one of the biggest issues is what he called the ‘human factor.’ This includes attitudes toward spillage, hygiene, and equipment maintenance and tolerance for broken or defective safety equipment.
He recalled a factory where the deluge system for the spray dryer went off automatically at a certain temperature. There was a stop auto button that could be pressed if the operator knew during start-up that there would be a transient rise in temperature.
“(They) had a broomstick cut to exactly the right length to go across the room to hold the button, because the guy got his thumb tired, holding it in for two or three minutes,” Chris said. “Management delivered a very verbal warning to the staff, but as soon as he left the room, they ducked round round the back of the cabinet and picked out a spare broom handle. And that’s the sort of thing you have to work around.”
Professionals tasked with doing dust hazard analyses have to make sure that operating procedures are correct and that the company has an appropriate safety culture, which is difficult to do remotely.
He recommended talking directly with plant maintenance managers and plant operators and reassuring them that he wanted to make their jobs easier as well as safer. If they had ideas on how to do things more safely, he would report their feedback to management.
“To do the right thing should be the easiest thing in the world in a well-designed workplace. When staff get the idea that management does, at least once every two or three years, listen to them, you’re looking at a much improved safety culture.”
Is it a bad idea to do a fully-remote DHA when the consultant hasn’t been in the facility?
Chris said that most of the dust hazard analysis could be done remotely if the documentation was in order and personnel were cooperative. He has also created a series of generic checklists for various equipment types, making it easy for someone who is on-site to walk around and tick off all the boxes.
“A spray dryer would have a list of things like: is it vented? If so, are the vents directed to the outside or is there a vent duct? If there’s a vent duct, where are the access controls to it? I recently had to use bolt cutters to cut open padlocks to a vent duct because they were locked for safety and the key got lost.”
Once the checklists are completed, they are scanned and sent back to him. If necessary, he talks to the staff via video to get a feel for how things are operating at the plant.
“What would be the preferred solution in these particular troubled times would be to complete as much of it as you could within the requisite regulatory time frame. But follow up with a personal visit a few months later, once travel restrictions are lifted.”
Conclusion
Chris emphasized the importance of communication and cooperation during remote DHAs.
“Communicate effectively with the plant and its people and emphasize that you’re not there to wave a stick at them, that you’re actually there to try and help them work safely. It ought to be normal, to be safe. Safety should not be a special effort we only make once every five years.”
If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Chris Bloore directly:
Email: [email protected]
LinkedIn: https://www.linkedin.com/in/chrisbloore/
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
DustSafetyScience
Combustible Dust Incident Database
DustSafetyScience Podcast
Questions from the Community
2020 Digital Dust Safety Conference
Previous Podcasts
DSS040: How to Run Effective Dust Explosion Training Sessions With Dr. Chris Bloore
DSS038: New Zealand Code of Practice For Handling Combustible Dusts With Dr. Chris Bloore
DSS031: Reconciling Hygiene with Explosion Safety in Food Industries with Dr. Chris Bloore
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DSS075: Considerations for Performing a Remote Dust Hazard Analysis with Dr. Chris Bloore
