In today’s episode of the Dust Safety Science podcast, Tim Heneks, Director of Engineering Services at Dustcon Solutions based in West Palm Beach, Florida, talks about the details that need to be included in a dust hazard analysis (DHA).
Tim has been on the podcast several times, starting with Episode #28 and, more recently in Episodes #117 and 118, which were ‘Ask Me Anything’ sessions. In his current role at Dustcon Solutions, he works with clients to set up their DHAs and offers peer review services for DHAs.
According to Tim, the idea for this podcast has been on his mind for awhile. Before coming to Dustcon Solutions, he sold explosion detection equipment. When he transitioned, he was highly familiar with what the back end of the dust hazard analysis process looked like (e.g., where explosion detection may need to be installed) but now he was on the front end, which required him to understand the methodologies used and what to include in a report.
Tim Quickly Realized That Clear DHA Standards Were Lacking.
More recently, Tim spoke with an insurance broker who stated that the level of detail in DHA reports seemed to vary from one company to the next. These conversations made him realize that there was sometimes a disconnect between the scope of the responsibilities seen by the DHA provider and the person who is receiving it as well as authorities having jurisdiction (AHJs) who look at the report after.
“It really sparked this [realization] in my mind that there’s not necessarily a clear guidance,” Tim says. “I think about the accounting industry, which has a very specific layout and formats and questions they need to ask for audits. But as I look across our industry landscape right now, you look at 20 DHAs, you might have 18 different formats that are not at all similar.”
Material Properties Often Get Too Little (or Too Much) Attention.
Tim said that he often wonders how many DHAs cover material properties with the right degree of depth. Some appear to go too light on the details while others go overboard.
“There are a couple of different ways that we can go about obtaining the necessary explosibility parameters or combustibility parameters for a material,” he explains. “We can obviously grab a sample and test the dust and create a sampling plan and learn a lot about the material. Then there are some instances where it’s appropriate to use published data or high-level assumptions that are conservative enough that you’re good to go. There are some materials out there that we have a ton of published data on, so we know that this particular material has a ceiling on its KSt value or a floor on its MIE value.”
Management Systems Have Their Challenges.
Although management systems play a critical role in combustible dust safety, Tim says that he has seen some DHAs omit them entirely and others fail to give them the consideration they deserve.
He recalled one client that had a robust housekeeping program on paper and still received an OSHA citation because high levels of combustible dust accumulated in a boiler room. Although they had the housekeeping program in place, it wasn’t effective and it wasn’t being continuously monitored by management of the facility.
“It makes me wonder how we can effectively understand whether or not these management systems are in place and effective in a way that works well for our clients,” Tim says. “How much time should we be taking to review the details of somebody’s housekeeping program versus a high-level overview of it? It’s something that has to be communicated and understood between the consultant and the client.”
Lack of Methodology Results in Varied Approaches.
Without a standard DHA methodology in place, there are going to be variations in approach. For example, a provider from an industrial hygiene background will approach things from that perspective and use those methodologies and procedures for capturing samples and labelling them. Somebody who comes from a PHA background might be much stronger on the risk-based side of the dust hazard analysis methodology as opposed to somebody who approaches it in a more prescriptive way.
“Part of [the problem] is that there’s not a set methodology. There’s not a set report format. There’s not even a clearly defined limitation of the responsibility,” Tim says. “You need to have the connection between the client and the consultant so that you can agree on what is going to be provided. For example, will there be risk-ranking and prioritization of recommendations as part of the dust hazard analysis, or is merely a summary or a list of those recommendations going to suffice? You really need to establish that upfront, and make sure that everybody’s on the same page.”
Conclusion
Tim concluded the episode by soliciting feedback from listeners.
“I really look forward to any and all feedback that we can get from the community, whether you’re an end-user or somebody who’s in the market for DHA services, an insurance provider or insurance broker or a regulator. I would love to know what your expectation is for the scope, the responsibility and the boundaries of a dust hazard analysis. Talking openly about these things is going to be the best way for us to improve the entire industry and create safer working environments across the board.”
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/
Website: https://dustconsolutions.com/
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
Dust Safety Science
Combustible Dust Incident Database
Dust Safety Science Podcast
Questions from the Community
Dust Safety Academy
Dust Safety Professionals
Companies
Dustcon Solutions
Previous Podcast Episodes
DSS028: Recent changes to NFPA 69 – Standard on Explosion Prevention Systems with Timothy Heneks
DSS117: Ask me anything on NFPA 652 Chapter 8: Management Systems with Tim Heneks | Part 1
DSS118: Ask me anything on NFPA 652 Chapter 8: Management Systems with Tim Heneks | Part 2
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