Friday, July 21, 2017

NFPA 652: Standard on Fundamentals of Combustible Dust

NFPA serves as the foundational NFPA document to guide the control of the hazards associated with combustible dust. One of the key items introduced by this standard is that it is the responsibility of the owner/operator of a facility to determine if the dust in their facility is combustible/explosible or not. This determination is made by collecting a sample of dust from the facility and sending it to a lab for combustibility tests. If the dust is not combustible, then the owner/operator has complied with the standard (and probably the OSHA General Duty Clause) and the formal documentation process concern combustible dust is over. (Please note that the everyday aspects of safety still apply: housekeeping as an example. You can’t leave piles of dust around even if it can’t explode.) If the dust IS combustible, then further tests are required. In addition, the owner/operator must carry out a formal Dust Hazard Analysis (DHA).

What is a DHA? In the simplest sense the DHA is a formal process whose output is a document which describes/assesses the hazards present in a facility, describes how the hazards will be controlled, eliminated, or mitigated, and describes what management systems will be implemented to ensure that the hazards continue to be controlled in the future. The hazard assessment must be backed up by results from combustible dusts tests. The management portion must include Standard Operating Procedures for items such as housekeeping, preventative maintenance, and training.

The overall goal of the DHA is that the owner/operator of a facility performs a legitimate and thorough evaluation and not just a cursory look at a system. A thorough evaluation will find and control a lot of simple, easily fixed risks (the “low hanging fruit”) which typically increases the safety of employees operating a process or working in a facility. 

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