Many facilities in the food and agriculture industry have processes that handle combustible dusts and powders. Because of this, the National Fire Protection Association (NFPA) has developed several standards to help facilities have safely manage combustible dust and associated hazards. Many of these standards are commodity-specific standards that are developed to give specific industries combustible dust standards that are based on their types of operation equipment, and the input from those that know the most about those processes and materials. Facilities in the food and agriculture industry should refer to NFPA 61: Standard for Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities which was recently updated in 2020. One primary requirement listed in NFPA 61 is the need for facilities to conduct a Dust Hazard Analysis (DHA) by January 1, 2022.
What is a DHA?
The purpose of a DHA is to evaluate a facility and its processes for potential fires and explosions from handling combustible dusts and powders. A DHA is often confused with laboratory dust explosibility testing that is conducted to determine if a dust is combustible, but dust testing is only one aspect of the DHA process. A DHA is a systematic review of a facility’s processes and areas where each piece of equipment is evaluated for potential hazards associated with a combustible dust flash fire or deflagration. This can be done by identifying rooms, buildings, areas, and pieces of equipment where a hazardous dust atmosphere may be generated and identifying potential ignition sources in those areas. Once hazardous atmospheres and potential ignition sources have been identified, recommendations can be made to reduce the risks of a fire or explosion.
Who is Required to Have a DHA Done?
All food and agriculture facilities handling combustible powders are required to complete a DHA by the deadline of January 1, 2022, regardless of the size of the process or facility. A small facility with a single bag dump where combustible powders are used must complete a DHA just the same as a large multi-site food processing corporation. If you are unsure if powders or ingredients handled at your facility are combustible, dust explosibility testing is recommended.
I Thought the Deadline Was September 7, 2020
The deadline for completing a DHA under the 2019 edition of NFPA 652: Standard on the Fundamentals of Combustible Dust was September 7, 2020. NFPA 652 is the overarching combustible dust standard that was developed to identify requirements that apply to all facilities across all industries. Commodity-specific standards can use NFPA 652 as a starting point when updating their specific standards. When the 2019 edition of NFPA 652 was released, most other commodity-specific standards adopted this deadline. However, the 2020 edition of NFPA 61 set a different deadline of January 1, 2021. This decision was due cost and time constraints. There are more food and agricultural facilities under common ownership than in other standards, which raises the cost and time to have DHAs completed and to begin implementing recommendations from a DHA.
How Often do I Need to do a DHA?
NFPA 61 requires all food and agriculture facilities to have completed DHAs revalidated and updated at least every five years. Revalidations are performed to identify any changes including, but not limited to:
- Process flow or size;
- New or decommissioned equipment;
- Ingredients or powders being handled; and
- Updates made to the current NFPA standards and other applicable regulations.
Revalidating your DHA every five years will ensure that your facility is up to date in maintaining the best practices for protecting your employees and facility from fires or explosions caused by combustible dust.
How Can CTI Help?
CTI is an experienced 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 the food and agriculture industry. 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 food and agriculture facilities to ensure they are operated in the safest manner. 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.