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.