DHA Revalidation. I’ve done my DHA. Am I done?

An increasing number of facilities that handle combustible dusts have conducted a Dust Hazard Analysis (DHA). A DHA, in summary, is an evaluation of the fire, deflagration, and explosion hazards present at a facility due to the handling, generating, and otherwise production of combustible particulates. The National Fire Protection Association (NFPA) requires that all facilities handling and/or generating combustible dusts have a DHA completed by September 7, 2020 (NFPA 652 Chapter 7.1.1.2). The deadline for food and agricultural facilities to conduct a DHA is January 1, 2022 (NFPA 61 Chapter 7.1.2.2).

A comprehensive DHA looks at the process equipment, areas, procedures, PM schedules, and housekeeping techniques. Upon completion of the DHA, it is likely that recommendations will be provided or discussed that reference NFPA standards and industry Best Management Practices (BMPs). These recommendations should be designed to reduce the likelihood, and minimize the damage, from a combustible dust deflagration, explosion, or fire. Once the facility has determined a plan to address and implement these recommendations, operations they should continue in such a way as to protect their facility and their employees from combustible dust hazards. For example, through revised housekeeping methods and frequencies, routine maintenance, and the installation of monitoring sensors, explosion protection equipment, etc. However, this is not the only requirement from the NFPA with regards to the DHA. The NFPA also requires that a DHA be revalidated and updated at least every 5 years.

What is a DHA Revalidation?     

A DHA revalidation is the review and update of a previously conducted DHA. In the maximum 5 year span of time that passes between your DHA and the required revalidation, several changes may have occurred. These include but are not limited to:

  • Changes to the process, including size
  • Replacing and growth of equipment
  • Ingredient changes
  • Updates made to the standards and regulations

Revalidating your DHA reviews all of these changes and ensures that your facility is up to date in maintaining the best possible practices for protecting your facility and employees from disasters caused by a combustible dust deflagration or explosion. It also is a tool to show progress made based on the recommendations stated in the last DHA, and can help assure that capital and resource investments were made adequately.

Nothing at my facility changed. Do I need to revalidate?

Even if your process, equipment, and ingredient and materials have remained the same over the previous 5 years, the NFPA still requires that your DHA be revalidated every 5 years. As mentioned above, regulations are updated every few years and sometimes new standards that are specifically relevant to your facility may be created or updated.

How Can CTI Help?

CTI is an experience environmental and safety consulting firm, helping clients since 1986. Our goal is to provide all clients with strategies that reduce liability and comply with regulatory requirements, at a minimum cost, with real-world solutions. CTI has decades of experience in identifying and reducing hazards for combustible dust. In relation to combustible dusts, CTI offers a wide range of services such as the following:

  • Combustible Dust Hazard Analysis (Initial and Revalidation)
  • Dust Sampling and Analysis
  • Explosion Protection Design and Selection
  • Hazardous (Classified) Location Determination
  • NFPA and OSHA Compliance Review

Please feel free to contact us to discuss the previously mentioned services or if you have any questions regarding the dust hazards that may be present at your facility. We have worked with numerous industries, including food and agriculture, wood products, pulp and paper, chemical, pharmaceutical, energy, automotive, aviation, defense, primary metals and fabrication, and general manufacturing. . If you would like to learn more about the process of conducting a DHA or the hazards associated with a combustible dust, we have many resources available on our website, such as a combustible dust seminars, published articles, and white papers.

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