In today’s episode of the Dust Safety Science podcast, Dr. Chris Cloney sits down with Kyle Levanen, mechanical engineer at JBW Consulting Engineers, to discuss the pros and cons of the Dust Hazard Analysis (DHA) checklist included in NFPA 61. NFPA 61 is the standard for preventing fires and dust explosions in the agricultural and food processing industries. While the DHA checklist provides a structured approach to evaluating facility hazards, it also comes with challenges related to its prescriptive nature and applicability to different sites.
Kyle, with over five years of experience in dust hazard analysis and process design, shares insights on how the checklist is used in the industry, where it falls short, and how facilities can leverage it as part of a broader safety strategy.
What Is the DHA Checklist in NFPA 61?
NFPA 61, often referred to as the grain handling standard, includes a DHA checklist in its annex (Appendix F). The checklist consists of 12 pages of yes/no questions covering various aspects of facility design, ignition source control, explosion protection, and dust hazard mitigation.
The checklist serves as a guide for plant engineers and safety professionals conducting hazard evaluations, ensuring they address key risk factors in their facilities. However, it remains underutilized, largely because it is buried in the annex section of the NFPA 61 document.
Pros of Using the DHA Checklist
- Easy to Use & Understand – The checklist provides a structured framework for hazard identification, making it accessible to facility managers and engineers unfamiliar with the complexities of NFPA 61.
- Good Teaching Tool – Walking through a facility with a checklist can help train new employees on hazard identification and safety measure.
- First-Cut Assessment – It offers a baseline evaluation of combustible dust hazards, highlighting areas where further assessment is needed.
- Encourages Compliance – Since each question links back to NFPA 61, facilities can use it to align their operations with industry standards.
Cons of Using the DHA Checklist
- Overly Prescriptive – The checklist is rigid, which can lead to unnecessary overprotection in some cases. A more flexible, risk-based approach may be preferable for certain facilities.
- Lacks Depth – While the checklist provides a high-level overview, it does not offer detailed guidance on mitigation measures or next steps for facilities that fail certain criteria.
- Limited Actionability – Checking “no” on an item doesn’t inherently provide the next course of action. Facilities may struggle to determine whether the issue requires minor adjustments, procedural changes, or major capital investments.
- Operator-Dependent – The effectiveness of the checklist relies on the knowledge and expertise of the person conducting the assessment. A lack of experience can result in misinterpretations or overlooked hazards.
How the Checklist Aligns with Site Assessments
Kyle noted that while the checklist does a great job of covering major risk factors in NFPA 61, it does not provide a comprehensive hazard analysis on its own. When conducting a site assessment, experienced consultants often go beyond the checklist, incorporating risk ranking matrices, cost-benefit analyses, and implementation roadmaps.
For example, one question in the checklist asks whether bearings are kept free from dust buildup and excess lubrication. While answering “no” identifies a risk, the next steps are not outlined. Does the facility need a housekeeping plan? A process change? New equipment? Answering these questions requires industry expertise.
Checklist Limitations in Explosion Protection
One of the major gaps in the checklist is its treatment of explosion protection. NFPA 61, Section 9.7, outlines extensive requirements for explosion mitigation, but the checklist simplifies this to a single yes/no question. Properly assessing explosion hazards requires knowledge of multiple NFPA standards, including NFPA 68 and NFPA 69, which are not explicitly referenced in the checklist.
Chris and Kyle highlighted that explosion protection measures such as venting, isolation, and suppression must be evaluated comprehensively. Simply following a prescriptive checklist approach can result in facilities either under-protecting or over-protecting key equipment.
Implementation and Prioritization of Findings
Another key discussion point was how facilities should act on findings from the checklist. Some companies prefer a “hands-off” approach, where consultants provide recommendations but do not assist with implementation. Others require detailed guidance on prioritizing actions and selecting cost-effective mitigation strategies.
Kyle emphasized that not all action items carry the same urgency. High-risk items that pose immediate safety threats should be addressed first, while lower-risk items may be planned over time. He also noted that facilities often struggle with finding reliable vendors for combustible dust safety equipment, as many suppliers do not have strong visibility online.
Key Differences Between Wood and Grain Facilities
While NFPA 61 applies to agricultural and food dusts, Chris and Kyle also touched on differences between wood and grain processing facilities:
- Grain facilities commonly use bucket elevators, which are less frequent in wood processing sites.
- Wood facilities may rely more on pneumatic conveying systems and conveyors to move dust.
- Different NFPA standards apply, with wood facilities following NFPA 664, which does not have a direct checklist like NFPA 61.
- Explosion mitigation strategies vary based on the type and properties of the dust being handled.
Final Thoughts & Recommendations
- Use the Checklist as a Starting Point – Facilities should not rely solely on the checklist but use it as an initial hazard assessment tool.
- Seek Expert Input – If uncertainties arise, consulting a dust hazard analysis professional can help clarify risk factors and develop practical solutions.
- Trust But Verify – When using a checklist, always validate findings and assess whether additional hazards exist that the document does not cover.
- Prioritize Safety Investments – Implement corrective actions in a way that balances safety improvement with cost-effective risk mitigation.
Conclusion
The DHA checklist in NFPA 61 is a useful tool for identifying combustible dust hazards in agricultural and food processing industries. However, it has limitations, particularly in areas like explosion protection and action prioritization. By supplementing the checklist with expert analysis and a structured implementation plan, facilities can ensure they effectively address their combustible dust risks.
If you have experience using the NFPA 61 checklist, we’d love to hear from you. Feel free to email Chris at [email protected] with your thoughts.
If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Kyle Levanen directly:
Website: https://jbwconsult.com/
LinkedIn: https://www.linkedin.com/in/kyle-levanen-3b650482/
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
Dust Safety Science Podcast
Questions from the Community
Companies
JBW Consulting Engineers
Organizations
NFPA
Dust Safety Science
NFPA 61
NFPA 68
NFPA 69
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DSS293: Pros and Cons of the DHA Checklist in NFPA 61 with Kyle Levanen
