DSS012: Qualified Persons and Combustible Dust Hazard Training with Jason Reason

In this episode of the Dust Safety Science podcast, we are speaking with Jason Reason, Director of Combustible Dust Services at SEAM Group (formerly Lewellyn). He has an extensive background in combustible dust hazards and combustible dust safety, having been a compliance officer with Indiana OSHA from 2000 until 2013 before becoming a consultant. He also participates in more than eight technical committees, several of them NFPA, and is currently chairman of NFPA 664.

In addition to talking about the challenges he sees in the combustible dust safety community today, Jason talks about:

Some of the challenges that OSHA compliance officers face today.
The training difficulties faced by industry participants such as workers, OSHA personnel, and people involved in the handling of combustible dust.
The definition of a qualified person in terms of performing dust hazard analyses.
Issues surrounding the consolidation of standards moving forward.

Early Compliance Challenges

Jason recalled that during his days as a compliance officer for IOSHA, knowledge about combustible dust was basically nonexistent at facilities and even on the OSHA side. Compliance officers would walk by combustible dust during inspections because they didn’t understand combustible dust hazards. Although most of them know flour was combustible, people were shocked to learn that sugar and many other powers could also explode.

A couple of Jason’s colleagues inspected Hayes Lemmerz in Indiana where, on October 29, 2003, a series of explosions injured one worker, severely burned two others (one of whom subsequently passed away) and caused property damage. Looking back, things were missed during the inspection but at the time, as Jason put it, “the knowledge wasn’t there.” The OSHA Training Institute didn’t even have a class on combustible dust.

When the OSHA National Emphasis Program started, Jason would show up unannounced at various facilities with a certain North American Industrial Classification System (NAICS) code and do a thorough inspection for combustible dust. In many cases, managers would insist that there was no problem but the facility was having incidents that weren’t reported simply because no one had died.

When he inspected one plastics recycling facility, the floor was thick with dust. They were having one flash fire a week, none of which had been reported. If the National Emphasis Program had not been in effect, a compliance officer would never have visited the facility.

On another occasion, Jason visited a paper facility with a broken dust collector system. Instead of sucking up dust, it would blow it back out of a hopper and create a cloud so thick that no light could be seen through it. Forklifts were driving through this cloud too!

It is a situation like the one discussed in Podcast Episode 11 with Dr. Ivan Pupulidy where these low-severity incidents provide a chance to learn about the combustible dust hazards and improve the processes, but these opportunities to learn were not being taken advantage of.

Challenges With Combustible Dust Hazards Today

Using his perspective as a former compliance officer and a combustible dust safety consultant, Jason identified lack of training as a primary challenge. He has personally seen cases where compliance officers enforce the wrong standard, such as NFPA 64 to address a metal dust hazard.

There has also been little effort on site-specific training on combustible dust hazards in facilities. Federal law requires managers to train all of their employees on the physical and health hazards of any chemical they work with, and under OSHA’s definition, combustible dust is a hazardous chemical – but this is often overlooked.

Why Qualifications Matter

The term ‘qualified person’ was created when NFPA 652 introduced the Dust Hazard Analysis (DHA). Although many parties, such as facility managers, fire marshals, and building code officials may believe themselves to be qualified, they aren’t according to Jason. As he puts it “You can’t take a class and be qualified all of a sudden to do it a DHA”. Many clients have paid for a DHA only to have the applicable NFPA standard regurgitated to them, which is not the intention of this process.

Jason emphasized the importance of proper qualifications in a recent article for Occupational Health & Safety Magazine titled Why Qualifications Matter When Performing a Dust Hazards Analysis.

How Can We Alleviate the Problems as an Industry?

Jason recommended taking the following steps to move forward:

The qualified person issue definitely needs to be taken care of because it’s a bigger issue than people realize. There is a misnomer out there regarding who is qualified to do a DHA.
More combustible dust safety training needs to be done in facilities and among OSHA compliance officers.
Managers need to stop letting fear prevent them from understanding and acting on hazards. Many of them don’t want to know if a hazard exists in their facility because they believe that it could put them out of business when there are actually cost-effective and safe ways of mitigating combustible dust hazards.
The standards that apply to combustible dust need to be consolidated. There are currently over 50 standards in that area. There are 20 to 25 with the NFPA in addition to standards in state and local fire codes and building codes. A single OSHA combustible dust standard can arguably make a facility safer at the end of the day.

Conclusion

This interview with Jason yielded valuable insights on:

How to best define qualified people for the purpose of carrying out DHAs;
How the different NFPA guidelines work;
How consolidation of existing standards might work; and
The perspective of an OSHA compliance officer.

These are all major topics in the effort to improve combustible dust safety and, by extension, avoid the facility damage and fatalities that take such a toll on our resources and our people.