Multi-Site DHAs in the Food and Grain Industries

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), 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.

Due to the cost and time involved with completing DHAs across multiple sites, many companies are opting to complete the DHAs completely in-house, utilizing existing resources. The NFPA standards only require that the DHAs be led by a Qualified Person. Provided there is a Qualified Person within the company, this is perfectly acceptable; however, there are drawbacks to this. The first, and most obvious, is the time constraint. This will pull people away from their other duties to focus on DHAs. Second is the familiarity with the process. This is a double-edged sword. There is a benefit to have a deep familiarity with the process, but there can be a disadvantage in that one could overlook things with a “well, that’s how that area always looks, and it’s never been an issue in the past.” The final drawback is the potential for pushback from upper management. This could come in the form of downplaying what an internal report says all the way to pressuring employees not to identify safety concerns.

The alternative to doing the DHA in-house is to utilize a 3rd party. This has the obvious drawback of overall expense. If a company has 10, 20, or even 50+ locations, bringing in a 3rd party to complete the DHA at each one of those locations is an expensive proposition.

There is a third option for completing these multi-site DHAs: utilize aspects of both the in-house and the 3rd party DHA. At CTI we work with each of our clients individually to determine a DHA option that works best for their specific needs. Some of these options include:

  • Completing the DHAs for several facilities and giving the client the necessary tools to complete the remaining DHAs in-house;
  • Serving as a 3rd party to review/audit/certify DHAs completed in-house; or,
  • Offering multi-site discounts on DHAs (especially as many of the sites may be similar in appearance and operation).

Regardless of who conducts the DHA, the result of a completed DHA is recommendations designed to reduce the likelihood and/or severity of fires and explosions where there is unacceptable risk (as determined by the DHA). These recommendations should be based on the NFPA standards and offer a priority based on a balance of which items present the greatest risk and which recommendations are most feasible. Many facilities may be putting off conducting the DHAs because of a concern over what the potential recommendations could be. A common statement we hear is: “My facility is over ___ years old and there is just no way for this place to be in compliance with current NFPA standards, so we won’t even do the DHA.” In using the results of the DHA, it is important to understand:

  • What is required vs. what is recommended?
  • Are there other control options in lieu of protection recommendations?

This is where a 3rd party can be crucial as they would have the knowledge of the NFPA codes as well as the firsthand experience of seeing what others have done.

CTI has decades of experience in identifying and reducing hazards from combustible dust. CTI is a principal member of both the NFPA 61 Technical Committee for Agricultural Dust and the NFPA 664 Technical Committee for Wood and Cellulosic Materials Processing and has worked with several of the other committees. We offer the following, and many more, consulting services for dust:

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

Please feel free and contact us to discuss the above-mentioned services or if you have any questions regarding the dust hazard present at your facility.

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