Combustible Dust Regulation Updates

Over the past several decades, the Occupational Safety and Health Administration (OSHA) as well as the National Fire Protection Association (NFPA) have been expanding and enforcing regulations and standards designed to lessen the potential for disasters in facilities that handle combustible dusts. Any facility that processes or handles combustible solids or dusts, such as food products, wood, plastics, and metals should take preventative measures in identifying and managing the potential fire and explosion hazards present during normal operations at an industrial facility. A catastrophic incident of a facility failing to properly identify and mitigate the hazards associated with handling combustible dust is the explosion at the Imperial Sugar factory in east Georgia back in 2008. This combustible dust explosion killed 13 people and injured 40 more. This accident was entirely avoidable.

In an effort to address the issues mentioned above with the handling of combustible solids and dusts and to join the standards already in place, the NFPA is in the process of updating it standard NFPA 652: Standard on the Fundamentals of Combustible Dust, especially the sections covering the mandates requiring facilities to evaluate combustible dust hazards.

NFPA 652 was established to outline the requirements for hazard analysis, promote employee and employer awareness, and to separate the analysis of combustible dusts from the process hazard analyses found throughout other areas of industry. This standard specifies that a Dust Hazard Analysis (DHA) is to be conducted by all facilities to determine if there are any potential combustible dust hazards if that facility has processes that generate dust or use powders. It’s not just new facilities that are required to meet this updated standard. NFPA 652 requires all facilities that process, generate, or handle combustible dust, and use less complex dust collection systems to perform a DHA and risk assessment for each process line that handles or creates combustible dust, including the dust collection system. The DHA is required for both new facilities as well as for upgrades made to existing facilities by September 7, 2020.

Before NFPA 652 was established, companies were not required to conduct a hazard analysis on an existing process line that handles combustible dust unless more than that process was modified by more than 25% of its original installation cost. Now, along with the requirement to conduct a DHA and the September 7, 2020 deadline set to conducting the DHA, facility owners/operators must demonstrate reasonable progress towards the goals of reducing and mitigating combustible dust hazards every year until the DHA is performed. Also, once the initial DHA is performed, it must be reviewed and updated at least every 5 years. What this means is that although the deadline for conducting the DHA is not until 2020, all facilities need to maintain records of progress being made each year with regards to previously conduct DHAs or in preparation for potential findings before the September 7th, 2020 deadline.

To help in moving forward with the above-mentioned requirements, some documentation that should be prepared is as follows:

  • All results of material testing
  • Operation, maintenance, and housekeeping procedures and audits
  • Employee and contractor training

NFPA 652 has been constructed to be used as a starting point for facilities that handle combustible solids and dusts to determine how to safely handle these materials and how to determine the hazards present in dust handling equipment and process lines. With the recent updates, the NFPA has put the responsibility of compliance on the facility owner/operator. It does this by requiring a review of the overall process, including a comprehensive audit of the equipment that handles particulate solids, as compared to a simple consideration of equipment and hardware alternatives. Facility owners/operators, please be aware that OSHA is training more and more inspectors to recognize combustible dust hazards and better understand both OSHA and NFPA regulations that govern combustible dusts. It is imperative that you be proactive with assessing your dust handling processes and equipment, and, more importantly, with protecting your workers.

CTI is one of the top industry leaders on NFPA 652 and combustible dust. Please contact us if you have any questions about the updated NFPA standards or would like to discuss having us visit your facility to conduct a DHA.

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