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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