All industrial facilities have a vested interest in operating in the most environmentally responsible and safe manner possible. This is because operating in this manner carries with it the lowest risk of interruption to production. Whether that interruption is in the form of a hazardous material release, regulatory violation, injury, lawsuit, or negative publicity, this is a situation that no facility wants to find themselves in. Reducing the potential for environmental pollution and improving worker safety might seem secondary to production, but serious injuries and regulatory violations can have significant implications which can range from heavy fines to shutting down operations entirely. All industrial facilities should, at the very least, take the time to consider whether they are currently running the risk of being impacted by these types of issues.
Most facilities that are handling/producing combustible dusts are now familiar with the term “Dust Hazard Analysis” or “DHA” and understand that it comes from a standard issued by the National Fire Protection Association (NFPA), nfpa.org. Furthermore, by now, many facilities subject to the requirements for conducting a DHA on their existing processes have had that completed. The most referred to standard is NFPA 652 – Standard on the Fundamentals of Combustible Dust. This set the requirement to have the DHA completed for existing processes by September 7, 2020. Now the commodity specific standard for agricultural and food: NFPA 61 – Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities did set a different date of January 1, 2022. This is the only commodity specific standard that did this; all other standards refer to the date in NFPA 652. There are a few other differences around the DHA requirements between NFPA 61 and 652. For the purposes of this article, we will just focus on the requirements in NFPA 652. Continue reading “Dust Hazard Analyses (DHAs) for New and Modified Processes”
If your industrial processes generate wastewater, then you need to know how to properly dispose of that wastewater. Process wastewater of any kind cannot simply be discharged into the sewer or outside where it can leave your property without first obtaining the proper permits. The most common options of disposing process wastewater include: Continue reading “Staying in Compliance with Industrial Wastewater Streams”
After a difficult year amidst a global pandemic in 2020, we can finally look ahead to a hopefully brighter 2021. A new year always brings changes to health and safety regulations and requirements. On January 19, 2021, James Frederick was appointed as the Deputy Assistant Secretary of Labor for Occupational Safety and Health, and will be the acting administrator for the Occupational Safety and Health Administration (OSHA) until a new Director is determined.
One of OSHA’s primary concerns at the start of 2021 has been employee safety relating to COVID-19. Since the start of the pandemic, OSHA has issued citations with penalties totaling $3,930,381. Common violations found from these inspections include failures to perform the following: Continue reading “What to Expect From OSHA in 2021”
When we are discussing whether a facility needs to conduct a Combustible Dust Hazard Analysis (DHA) or if dust explosibility testing is needed, it is common for material like aluminum dust, phenolic resin, iron, powder coat, etc. to be included in the discussion as it is relatively known that these materials are combustible dusts. However, it regularly occurs that the dusts and fumes from welding activities are not brought up by the facility. A widely held view in general industry is that dust from welding operations contains only oxidized metal and is therefore not combustible. Recent studies and CTI’s own investigations have found this to be incorrect.
One of the easiest ways for an EPA or state inspector to find violations is to compare your current operating equipment and emissions with the permitted equipment and emissions. If you do not keep your Air Quality Permit up to date, you run the risk of an inspector finding serious violations – which come with serious monetary fines. This applies to your facility whether your permit is a Title V, Synthetic Minor, or even True Minor operating permit.
If you operate under a Title V Air Quality Permit, you are required to renew your permit every 5 years, and likely have an annual inspection conducted by the EPA or state. With these measures in place, chances are your Air Quality Permit is staying up to date. However, anytime your facility installs new operating equipment or removes/decommissions old operating equipment you should reassess your air emissions. Continue reading “Is My Facility Fully Covered by My Air Quality Permit?”
Join CTI for our upcoming webinar presentations and events:
- March 1-3, 2021: 2021
Sponsor/Event: Dust Safety Science
Speaker: Jeff Davis, PE
In-house DHAs vs Third Party DHAs for Multiple Sites, 3/1/21 @ 11:00 AM; Dust Hazard Analysis for New and Modified Processes, On-Demand
More Info: Information and Registration
- March 16-17, 2021: 2021 14th Annual International Biomass Conference and Expo (Virtual Event)
Sponsor/Event: BBI International and Biomass Magazine
Speaker: Jeff Davis, PE
Presentations: Combustible Dust Hazard Identification and the DHA (3/17/21 8:30 AM)
More Info: Information and Registration
Most facilities that are handling/producing combustible dusts are now familiar with the term “Dust Hazard Analysis” or “DHA” and understand that it comes from a standard issued by the National Fire Protection Association (NFPA), nfpa.org. The most referred to standard is NFPA 652 – Standard on the Fundamentals of Combustible Dust. This is the overarching standard that applies to all facilities and serves as a starting point for the commodity-specific dust standards (e.g., 61 for agricultural and food, 664 for wood products, 484 for metals, 654 for general processing). The requirement for all facilities handling and/or generating combustible dusts to conduct a DHA originated from the 2016 edition of NFPA 652. The 2019 edition of this standard did change the deadline for existing operations to have the DHA completed was updated to September 7, 2020 and several of the commodity specific standards made the same updates. However, the 2020 edition of NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities set a different deadline. The deadline for existing food and agricultural facilities to have their DHAs completed is January 1, 2022.
Why would NFPA 61 use a different deadline? This is the only commodity standard that changed the deadline. All other industries kept the September 7, 2020 date. The reason for this deadline comes down to cost and time constraints:
- There are more affected food and agricultural facilities under common ownership than in the other standards;
- The cost and time to have the DHAs completed for all applicable facilities under one company is greater; and,
- The cost for implementing the recommendations for all applicable facilities under one company is greater.
On July 26, 2019, the Environmental Protection Agency (EPA) proposed revisions that would allow an operating facility to be reclassified from a major source of hazardous air pollutants under Section 112 of the Clean Air Act to an area source, thus removing the policy commonly known as “once in, always in”. This revision could take a lot of pressure for capital investments and permitting off of facilities that are eligible.
Completing Multi-Site DHAs Across Many Locations in Food and Grain Industries
Thursday, November 19, 12:30 ET (UTC -4) | Jeff Davis | Conversion Technologies, Inc.