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 220.127.116.11). The deadline for food and agricultural facilities to conduct a DHA is January 1, 2022 (NFPA 61 Chapter 18.104.22.168). Continue reading “DHA Revalidation. I’ve done my DHA. Am I done?”
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.
Today, during the Technical Meeting at NFPA’s 2015 Annual Conference, there were two certified motions up for a vote related to the new NFPA Standard on Fundamentals of Combustible Dust – NFPA 652. One motion was to remove the requirement for a Dust Hazard Analysis, and the other was to delay the issuance of the Standard completely. Both motions were defeated by an overwhelming majority of the NFPA voting members, including myself. These votes were the last hurdle in the issuance of the Standard later this year.
NFPA 652 is the first step in developing a single, overarching standard to deal with fire and explosion hazards associated with combustible dust of all types and in all industries. Currently, there are several industry and commodity specific standards, such as NFPA 61 for agricultural dust and 664 for wood dust, that often lack consistency, leading to confusion among users, authorities having jurisdiction (e.g. OSHA), and safety professionals. The development of NFPA 652 intends to alleviate some of the confusion … eventually. Over the coming months, CTI will be writing articles, providing presentations at conferences and online, and consulting our clients with the specifics of the standard. If you are interested in staying in touch with these developments and other news, please email email@example.com and ask to be included on our Newsletter list.