In today’s episode of the Dust Safety Science podcast, we discuss four common challenges in the application of NFPA 652. This is the final episode in a three-part series based on a presentation that Dr. Chris Cloney gave at the 125th Annual Conference of the NFPA.
In the last two episodes, we answered five common questions associated with NFPA 652. Today, we talk about four common challenges being encountered in its application. They are as follows:
- What is the first step overall?
- What is the scope of a DHA?
- How do you hire a DHA consultant?
- How do you complete a DHA yourself?
What is the First Step of NFPA 652?
The first step is hazard identification, which is addressed in Chapter 5 of NFPA 652. Do you have a potential combustible dust? If so, do you know the combustibility and explosibility of that material? Unless you have historical data (usually in the form of fires and explosions), the next step is normally to run a go-no-go test.
Section 5.4.3.1 of NFPA 652 states that where the explosibility is not known, it shall be determined according to one of the following tests:
- The go-no-go screening testing methodology described in ASTM E1226
- The standard test method for minimum explosible concentration of combustible dust (as indicated in ASTM E1515)
- An equivalent test methodology
For the go-no-go screening test, you want to use a material that’s representative of the worst-case conditions at your facility. This may be taken from your dust collection system, where you have the smallest particle size and the driest material, or fugitive dust at the facility. You really want to avoid a false negative. If you use material from another part of your facility where the dust isn’t as dry or small in terms of particle size, it can come back as a no-go.
What is the Scope of a DHA?
Section 4.2.4 of NFPA 652 addresses compliance, but the steps involved remain open to interpretation. In general, facility managers may use a prescriptive approach in accordance with Chapters 5, 7, 9 & 8 in conjunction with any prescriptive provisions of commodity-specific NFPA standards. The aforementioned chapters cover hazard identification, dust hazard analyses, hazard management, and management systems.
Owners and operators are responsible for all of these activities, so they should determine the scope of their DHA before they start getting quotes from professionals and understand what their responsibilities are once the DHA is complete.
How Do You Hire a DHA Consultant?
The approach we use at Dust Safety Professionals is to cover the three core components of a qualified person. They are:
- Broad knowledge and understanding of combustible dust hazards
- Specific understanding of the industry processes and systems under review
- Demonstrable experience in performing DHAs and/or leading DHA teams
If you’re missing one of these three elements, you’re not likely to get a very effective dust hazard analysis completed, so we came up with a three-step process for recognizing a qualified person.
- Verify the background, knowledge and qualifications of the individual. Request a copy of their CV or their resume and ask about their certifications, qualifications, and any technical committees that they’re involved in.
- Verify their industry-specific understanding and competency by asking them about projects they’ve worked on before. For example, if they’ve only focused on metals, they may not be the right provider for the wood pellet industry.
- Verify their experience in performing DHA and leading DHA teams. To do this, ask for a dust hazard analysis sample. It’s also a good idea to ask for references on previous projects.
Once you engage someone, verify what will be in the dust hazard analysis. Will they include risk-ranking and/or an implementation plan? Will they include a support period for that implementation plan? Will they include management system review and recommendations? Will they include hazard area classification? These are all things you want to understand about your provider.
How Do You Do a DHA Yourself?
The final challenge is how to complete a DHA yourself. Maybe you have multiple facilities and you want to train one of your staff to be able to complete dust hazard analyses at them. You may have a lot of change operations or keep adding new sections or equipment in your facility. You want to be able to revisit and reassess those dust hazard analysis on a more frequent period.
Below is a recommended three-step process for those who prefer to do DHAs in-house:
- Identify gaps in knowledge and competencies. For example, if one of your employees has a lot of combustible dust knowledge and also knows your industry very well, all they may need is training on how to do a DHA.
- Gain experience in performing DHAs and/or leading DHA teams. Some ways you can do this is to be part of a DHA team led by someone else or shadow the consultant who does an initial DHA at your facility and learn the ropes. You can also get a third-party review of your DHA.
- Be aware of the risks of performing a DHA internally. They include time constraints, money considerations and difficulty with being impartial.
Conclusion
These four common challenges have solutions that may differ from one facility to another. Finding the right ones for your location can make it easier to comply with NFPA 652 and, by extension, improve safety for everyone there.
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
Organizations
NFPA
Standards
NFPA 652
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