Tim Heneks, Director of Engineering Services at Dustcon Solutions in West Palm Beach, Florida, recently participated in a two-part ‘Ask Me Anything’ session at the Dust Safety Academy. The second half of this episode, which was a detailed overview of NFPA 652, Chapter 8, reviews the following:
- How to convince your executive management that management of change (MOC) and other systems are needed
- How to implement management systems when finances are a concern
How Do You Get Management Buy-In for an MOC Program?
Tim said that he has seen many cases where getting management buy-in was difficult, but the effort is worth it. He added that having a dust hazard analysis (DHA) that thoroughly illustrates the problem can help. So can identifying the wins that may be made without spending a lot of money.
“I know that many, many businesses are strapped for cash, especially in these times where a business might be slow because of the COVID-19 pandemic,” Tim says. “If you’re able to show that you’re going to make valuable improvements to the combustible dust safety of the facility, and you can do it without using a ton of capital, but rather the resources and personnel that are already on site… that might also be a way to do it.”
Is There a Great Reference to Help Classify Events or Near Misses Proportionately?
Tim explained that this is a difficult question to answer because a flash fire in a metal producing plant is going to have a different consequence than a similar event in a pharmaceutical plant, sawmill, or bakery.
“Industry-specific knowledge really comes from those who’ve been involved in the industry,” he says. “So I don’t know that there’s an easy answer to that one. A lot of that comes from just having experience within that industry, and being able to draw on that.”
In his opinion, housekeeping is one of the most important things that can be done to maintain combustible dust safety.
“Name a high-profile explosion that has occurred as a result of combustible dust that did not somehow include a deficiency of housekeeping,” he says.
Tim says that addressing fugitive dust alone may not prevent issues like flash fires or explosions in process equipment. A more holistic approach is necessary.
“Whether you’re worried about business interruption or life safety, the primary event is very much a risk to both of those hazards, right? What we want to avoid through the use of housekeeping is that secondary event that can be a 5X, a 10X, a 20X multiplier for the damage in terms of dollars or the damage in terms of life safety.”
What Management Systems Strategies (as per NFPA 652) Should be Looked at for Housekeeping and Fugitive dust?
Tim emphasized the importance of limiting the amount of fugitive dust available. Enclosed systems with good seals, dust collection points with adequate pickup velocity and sloped surfaces above structural elements are all ways that can prevent it from accumulating.
“As anybody who’s worked in powder handling manufacturing knows, it’s impossible to avoid the occasional spill or material getting out and accumulating on surfaces,” he concedes. “So there are several methods that are acceptable as housekeeping methods, as described in Chapter Eight. And there are some that I see often used incorrectly.”
They include:
- Water washdown: This method works well because it removes dust from surfaces without creating a cloud. If materials are water-reactive, water washdown is not an option, but otherwise, it’s an effective way of performing housekeeping.
- Vacuuming: This method is great for capturing fugitive dust that has built up on horizontal surfaces, tops of equipment, cables, and pipes. However, it is critical to use a combustible dust-rated vacuum.
- Sweeping, and shoveling, and scooping: These methods are used in mineral and wood manufacturing operations.
- Compressed air blowdown: This method is becoming less common in industry, but is sometimes used to clear out equipment crevices or access areas that a hose can’t reach. To prevent a dust cloud from appearing, most material should be removed using other methods first, and ignition sources must be cleared away.
Should There Be an MOC for Replacement in Kind?
“If we’re changing out a rotary valve that is model XYZ with model XYZ, there’s no real reason that a management change process needs to occur there,” Tim says. “But if all of a sudden you go from a wet grinding or grinding of material with 25% moisture content, to now grinding something that’s got 5% moisture content, there’s a huge difference in the potential for an emission source to cause a deflagration somewhere downstream of that mill.”
Are There Good Hazard Guide Words for Dust Processes?
Tim explained that a lot of terms used with chemical process safety can be adapted for combustible dust environments.
“Using a what-if scenario generation session is a great way that I found to use that framework to identify things that might occur within the facility and identify what needs to occur either in advance or at the time of, to prevent or mitigate it. A lot of the same guidelines could be used, but you have to do it in a way that focuses towards combustible dust. We’re really not as interested in toxicity hazards or environmental damage. Not that we don’t care about those things, it’s just not within the scope of the DHA.”
Conclusion
When Tim works with clients, he tells them where they are at now and where they need to be. He advises them to not try doing everything overnight.
“The only way to eat an elephant is one bite at a time. So get there by making incremental improvements. Housekeeping alone cannot address all of your combustible dust habits. And even more so, it may only be a Band-Aid to some of the larger problems that you have. You may need to fix leaky seals, or improve your dust collection design, or add dust collection where you don’t have it. All of those things go into how the dust is getting there in the first place.”
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/
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
Companies
Dustcon Solutions
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DSS118: Ask Me Anything – About NFPA 652 Chapter 8 with Tim Heneks – Part 2
