by Michael L. Walker, PE
Vice President, Principal Engineer

and Larry Rockefeller, CIH, CSP
Director, Industrial Hygiene Services

Why have some companies not yet conducted dust hazard analysis? Especially since it’s been 7 years since the original NFPA Standard was issued?

Dateline: January 27, 2023 – “The U.S. Department of Labor’s Occupational Safety and Health Administration today issued a revised Combustible Dust National Emphasis Program. Any combustible material can burn rapidly when in a finely divided form. If such a dust is suspended in air in the right concentration, under certain conditions, it can become explosible. The purpose of the revised emphasis program is to continue OSHA inspections of facilities that generate or handle combustible dusts likely to cause fire, flash fire, deflagration and explosion hazards.”

So, why have some companies not yet conducted dust hazard analysis? 

There can be several reasons why some companies have not conducted a dust hazards analysis (DHA) yet:

  • Lack of Awareness: Some companies may not be aware of the potential hazards associated with combustible dust or the regulatory requirements for conducting a Dust Hazard Analysis (DHA.
  • Cost: Conducting a DHA can be expensive, particularly for smaller companies with limited resources. This cost can include hiring an outside consultant, conducting testing and analysis, and implementing recommended control measures.
  • Time: Conducting a DHA can be a time-consuming process, particularly for larger facilities or complex processes. Some companies may be hesitant to commit the necessary time and resources to complete the analysis.
  • Complacency: In some cases, companies may have operated without any major incidents for many years and may become complacent about the risks associated with combustible dust.
  • Lack of Expertise: Conducting a DHA requires specialized knowledge and expertise, particularly in areas such as dust collection and explosion prevention. Some companies may not have the necessary expertise in-house and may not know where to turn for help.

If these are your reasons, it may be wise to reconsider and act.  Most people in the safety arena know about the West Pharmaceutical explosion in 2003 and the Imperial Sugar plant explosion in 2008.   But incidents continue to occur (as do OSHA citations).  For example, in 2021, combustible dust was responsible for 163 fires, 53 explosions, 215 injuries and sixty-nine deaths, according to Dust Safety Science’s Combustible Dust Incident Report.

Overall, conducting a DHA is essential for companies to ensure the safety of their employees and their facilities. However, there can be barriers to completing a DHA, including cost, time, and expertise, which can make it challenging for some companies to undertake.

  • A dust hazard analysis (DHA) is conducted to identify potential hazards and assess the risks associated with combustible dust in a facility or process. A DHA is important for several reasons:
  • Safety: Combustible dust can be a serious safety hazard in many industries, and a DHA can help identify and mitigate potential hazards before an accident occurs.
  • Compliance: Regulatory bodies such as OSHA (Occupational Safety and Health Administration) require employers to assess and control hazards associated with combustible dust.
  • Cost Savings: Identifying and addressing potential hazards before an incident occurs can save a company money by avoiding property damage, loss of productivity, and potential legal costs.
  • Reputation: A company’s reputation can be damaged by incidents caused by combustible dust, which can lead to negative publicity and loss of business.

Overall, a DHA is an important tool for managing the risks associated with combustible dust and ensuring the safety of employees and the facility.

Final Notes: 

  1. NFPA has published numerous standards containing prescriptive requirements for specific industries and commodities.  These standards must be used to address site-specific dust hazards.
  2. NFPA 652, Standard on the Fundamentals of Combustible Dust, which was initially developed to fill in baseline gaps in other NFPA standards and will be consolidated into NFPA 660.

How We Can Help
At The EI Group, our professionals have experience in process safety and risk assessments designed to prevent catastrophic incidents from occurring.  Please contact Mike Walker at (919) 459-5245 or [email protected] or Larry Rockefeller at (919) 459-5257 or [email protected] with any questions or specific needs around these issues.