In today’s episode, we’re giving you a glimpse inside the Dust Safety Academy with a replay from one of our recent Ask Me Anything sessions. Jason Reason from Seam Group, who has been interviewed on the podcast before came on to answer questions about remote dust hazard analyses. They include:
- What are the main differences between remote and traditional DHAs?
- How do you address things like fugitive dust control remotely?
- How do you address things like training with remote DHAs?
- Are the costs for remote and traditional DHAs similar?
- Is there any difference between a DHA and a review?
- Are AHJs accepting remote DHAs?
- Is there such a thing as a mini-DHA?
- Do you see people using pre-DHA checklists?
What are the main differences between remote and traditional DHAs?
Jason explained that when a facility has a no-visitor policy due to coronavirus or a stay-at-home order is in place, Seam Group will do the DHA remotely through a series of phone calls.
“Some people have even taken videos,” he said. “I had one client that took a drone. I won’t get into how they did it, but they took drone photos of everything. It was entertaining because one time they crashed it. They sent that too.”
The whole purpose of the remote DHA is to gather enough information to compile a report. “Call it a draft report if you want,” Jason said, adding that this document is used to address identified hazards. “Then, hopefully within a month or two after the virus calms down a little bit, we would then go on site and would finalize that report with anything we weren’t sure about. That’s how we do a remote DHA.”
How do you address things like fugitive dust control remotely?
Jason admitted that housekeeping issues are one of the most challenging matters to address with a remote DHA. When he speaks to health and safety personnel or operators, they often show him photos or videos of an immaculate facility.
“I think I told one person, “I’ve never seen a woodworker look that immaculate. You cleaned it, didn’t you?” They’re like, “Yeah, how’d you know?” I’d go, “Because it’s never that clean.” I just could tell. You’ve got to be careful with that, to not assume that the housekeeping is correct, because you’ve got to dig down into that, especially with operators and employees, to figure out what it is truly like.”
Whenever Jason does an onsite DHA, he urges management to let him see the facility as it normally is, so he can make a more accurate assessment of any obvious or potential hazards. It’s not easy to achieve similar results remotely.
“You’ve got to dig deep. For one housekeeping issue on the phone, it took me over an hour until I was comfortable figuring out how it truly was, where if I was onsite, I would have answered it in five minutes.”
How do you address things like training with remote DHAs?
Jason admitted that it can be difficult sometimes to get a feeling for the programs in place from companies being assessed.
“I think the number one thing is, they don’t want to admit they’re wrong. We try to tell them, “It’s okay. We’re here to find efficiencies. If you don’t have a hot work program, tell us you don’t have one.” They go, “Well, we’re looking for one.” I already know they don’t have it.”
He said that in most of the DHAs that he has done, the combustible dust training was inadequate. “That’s the number one cited thing by OSHA, here in the states: not doing the combustible dust training. Not training your employees on the physical hazards of combustible dust.”
Are the costs for remote and traditional DHAs similar?
Speaking for his company, Jason said that the cost difference between the two methods is negligible.
“It all equals out in the end. What I mean by that is, if you do a (traditional) DHA, you do the report, you backload all the time because you’re working on the report and you’ve got to go onsite. Well, all you’re doing is front-loading the time now (with remote DHAs), because you’re working on the report first.
“Actually, it makes the onsite go a little faster because if we’ve already dealt with this dust collection system, we don’t need to look at it that hard. Whereas, if we were on site, we may have to spend more time. That’s why our cost, pretty much is about the same for whether it’s remote or whether we do it the standard way.”
He said that he has observed a troubling trend with DHAs in general.
“I’ve seen people offering $2,000-$3,000-DHAs now. I’ve got to warn everybody that if you’re thinking about getting one of those, you better check (it) because, to do a DHA for that amount of money and make sure all the hazards are properly assessed, I’ve never seen it.
“In fact, I know of at least two incidents so far in the last two months that this type of DHA caused an incident. They’re missing the hazards or implementing an incorrect method that the DHA told (them) to do. Because it wasn’t properly researched, it caused an actual explosion.”
The message was clear: avoid hunting for a rock bottom price, because there’s always the possibility that the quality of the DHA will be equally low.
“I had someone who paid $5,000 for an onsite DHA. They showed up onsite for one day. Did a report that was 15 pages long. Issued the report. By the time it was all over, there was no incident, but by the time the insurance got involved, OSHA got involved, everybody else got involved, they had to pay $300,000.”
Is there any difference between a DHA and a review?
NFPA 652 requires a DHA to be done, followed by five-year reviews. Jason said that the five-year review is not the same as a DHA. He recommended that facilities have a Management of Change (MOC) program that analyzes any potential change regarding combustible dust.
“For example, I’ve had people say, “Well, we want to go from one dust collector to two.” Well, you need to do a Management of Change on that, analyze it, and ask, “How does this affect the DHA we just did?” I have people, especially in 3D printing, all the time telling me, “Well, we want to switch from titanium to aluminum.” Okay. You may have to redo significant portions of this DHA now, because you’ve switched materials. I know it seems [redundant] to analyze every change, but if you do that, it’s less likely you’re going to need much of a review, if at all, in five years because you would have been doing it all along.”
Are AHJs accepting remote DHAs?
Jason confirmed that insurance companies are accepting remote DHAs, but he has noticed that regulators like OSHA and fire marshals are not always taking them at face value. These AHJs are more concerned about qualified individuals.
This is a challenging situation because there is no specific definition of a qualified person, but for Jason, it means someone who has the necessary expertise and experience.
“There is no magic course,” he said. “There is no certificate. There is nothing out there unfortunately, that’s going to tell you you’re qualified. It’s just, what was your expertise in doing this? Generally, you learn from a qualified person and then you get qualified as the years go on. Even when we hire someone as a consultant, they rarely come in being qualified, in my opinion. It takes one to two years to get them qualified, doing multiple DHAs under supervision.”
He said that people frequently ask him if they are qualified. “I go, “The fact you had to ask, says you’re not.” You know (when) you are.”
Is there such a thing as a mini-DHA?
Jason confirmed that a DHA can be done on a single piece of equipment, although it may not be the most efficient approach.
“Honestly, it’s easier just to do everything at once, especially if you’re going to hire somebody from the outside. If you just want to do one piece of equipment, yeah, you could do that as long as you follow the DHA process, whatever that is.”
Do you see people using pre-DHA checklists?
Although clients have asked him if they should support an upcoming DHA by doing a checklist, Jason admitted that he is not a fan of the idea.
“It’s just too easy. Checking yes and no doesn’t give you enough information in most cases. You’ve got to dig deep on these things. For example, all too often I see people look at a dust collector and say, “Oh, it has a vent. We’re good.” They never look at where the vent points, which is generally near an emergency exit. They never look at whether the vent is sized or maintained correctly… and that’s where the checklist falls apart.”
He conceded that when the information is complete and gathered correctly, checklists can work, but there has to be a lot of communication on the contents. “I’m only going to sign off on something that I know has either been properly assessed, or properly mitigated, or both.”
Do you think remote DHAs will continue?
Jason said that remote DHAs can become a staple for many processes, if done correctly and by qualified people, but loss of interaction can be an issue.
“We’ve showed up on site and they’re like, “You know, we’re glad you showed up because you pointed out stuff that we didn’t see.” You can see stuff while you’re there, that maybe the camera didn’t catch, or they didn’t get a picture of it, or the video missed it. I don’t think (remote DHAs) are going to substitute for that interaction that you could have.”
Conclusion
In next week’s podcast, we’re going to cover the second half of the Ask Me Anything session with Jason. This time, he answers a variety of different questions about NFPA 664, mixing of different types of metal dust, 3D manufacturing, or additive manufacturing, 3D printing and more. If you’re interested in having access to this type of training, we encourage you to become a member of the Dust Safety Academy.
If you would like to discuss remote DHAs further, leave your thoughts in the comments section below. You can also reach Jason Reason directly:
Email: [email protected]
LinkedIn: https://www.linkedin.com/in/jason-reason-cih-csp-chmm-b561a148/
Website: https://www.seamgroup.com/combustible-dust
If you would like to suggest topics for future live training, you can email [email protected]. If you have questions about the contents of this or any other podcast episode, 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
Companies
Seam Group
Standards
NFPA 61
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DSS091: Ask Me Anything on Remote Dust Hazard Analysis with Jason Reason | Part 1
