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DUST HAZARD ANALYSIS AUDIT

NFPA 652

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All facilities that generate dust, and were required to meet the September 7, 2020 deadline must now comply with the requirements of NFPA 652. SEA can help you get ready for these audits!

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  • What is NFPA 652?

    This National Fire Protection Association standard outlines the requirements for the management of fire and explosion hazards related to combustible dusts.

    Updated from its previous version, the 2019 NFPA 652 requires facilities to complete a dust hazard analysis (DHA), demonstrate progress in completing a DHA in years leading up to the deadline, and continue to review and update the DHA every five years.

    This standard is the go-to source for facility managers, inspectors, safety personnel, contractors and engineers for handling combustible dust safety in any industry.

  • What is combustible dust?

    NFPA 652 defines combustible dust as “a finely divided combustible particulate solid that presents a flash fire hazard or explosion hazard when suspended in air or the process-specific oxidizing medium over a range of concentrations.”


    <Click Here for a free OSHA Combustible Dust Poster and List of potential materials>

  • What is a DHA?

    A Dust Hazard Analysis is a facility review that examines all areas where combustible dust is present. This analysis identifies hazards as related to explosions and fires. A DHA categorizes each area of the facility as Not a Hazard, Might Be a Hazard, or Deflagration Hazard. If any hazard areas are identified, the facility must define safe operating ranges, list any existing hazard management methods, and identify additional options to consider for future hazard management.

  • Who must meet this standard?

    NFPA 652 pertains to all industries that include processes that can generate combustible dust, although it specifically addresses the metal, agricultural, chemical and wood processing industries. According to OSHA, the risk of combustible dust explosions is present in a wide range of industries, including those that process food, grain, tobacco, paper, rubber, dyes, plastics, pesticides, metals, pharmaceuticals and pulp.

  • Who is qualified to perform a DHA?

    NFPA 652 states that the DHA shall be performed by a “qualified person”. The leader of the DHA should be highly knowledgeable in the hazards related to combustible dust as well as the process which is being observed.

    With over 25 years of knowledge and experience in hazard analysis and Industrial Hygiene, SEA can help you with your DHA needs.

By Derek Jennings 10 May, 2024
In a recent announcement from the U.S. Department of Labor, significant changes to the structure of the Occupational Safety and Health Administration (OSHA) regional operations were unveiled. These strategic adjustments aim to better protect workers by directing resources effectively and enhancing the agency's resilience. Let's delve into how each state will be affected by these changes and the broader implications. Alabama, Arkansas, Kentucky, Louisiana, Mississippi, Tennessee, and the Florida Panhandle: Introducing the Birmingham Region One of the key changes is the establishment of a new OSHA regional office in Birmingham, Alabama. This office will oversee agency operations not only in Alabama but also in Arkansas, Kentucky, Louisiana, Mississippi, Tennessee, and the Florida Panhandle. The creation of the Birmingham Region is in response to the area's growing worker population and the hazardous nature of industries such as food processing, construction, heavy manufacturing, and chemical processing. This move signifies a focused effort to address specific regional needs and ensure comprehensive workplace safety measures. West Coast Consolidation: The San Francisco Region Regions 9 and 10 will be merged to form the new San Francisco Region, streamlining operations and reducing costs. This consolidation reflects a strategic decision to improve efficiency and effectiveness in overseeing workplace safety in the western United States. The West Coast, known for its diverse industries and regulatory landscape, will benefit from a more cohesive approach to OSHA oversight, facilitating smoother enforcement and compliance efforts. Regional Renaming: Reflecting Geography In addition to structural changes, OSHA will rename its regions to better reflect geographical locations rather than numerical designations. For example, Region 4 will now be known as the Atlanta Region, with jurisdiction over Florida (excluding the Panhandle), Georgia, North Carolina, and South Carolina. Similarly, Region 6 will be renamed the Dallas Region, focusing on workplace safety issues in New Mexico, Oklahoma, and Texas. These new designations aim to enhance clarity and alignment with the geographical areas they serve. Implications and Outlook Assistant Secretary for Occupational Safety and Health Doug Parker emphasized that these changes align with the nation's demographic and industrial shifts since the passage of the OSH Act. By reallocating resources to regions with evolving needs, OSHA aims to better serve all workers, including historically underserved populations. With a stronger enforcement presence in the South and consolidated oversight in the West, the agency is poised to address emerging challenges and promote safer workplaces nationwide. Looking Ahead OSHA plans to fully transition to its new regional structure later in fiscal year 2024, with updated regional maps and contact information to be made publicly available. These changes mark a significant step toward enhancing workplace safety and protecting workers' rights across the United States. As the agency adapts to changing dynamics, its commitment to ensuring the well-being of workers remains steadfast. In conclusion, the restructuring of OSHA's regional operations reflects a proactive approach to safeguarding workers and addressing evolving workplace hazards. By tailoring strategies to specific regions and fostering collaboration, the agency aims to create safer and healthier workplaces for all. Need More Information? Contact me at https://www.seainc.net/contact or leave a comment below. Forward this to your colleagues to opt into our blog articles and newsletters. https://www.seainc.net/contact Media Contacts for USDOL: Patrick Malone, 202-997-3512, malone.patrick.m@dol.gov Paloma Renteria, 202-579-1643, renteria.paloma.b@dol.gov By Derek Jennings, President SEA
By Derek Jenninga 01 May, 2024
It's a question that might raise a few eyebrows during a job interview, but one of the best Environmental, Health, and Safety (EHS) Managers I know—and a dear friend—makes it a point to ask every candidate this very question. The responses? Always enlightening. The Occupational Safety and Health Administration (OSHA) was created with a noble goal: to ensure safe and healthful working conditions by setting and enforcing standards, and by providing training, outreach, education, and assistance. There’s no denying the vital role these standards have played in reducing workplace injuries and fatalities. However, as with any regulatory framework, the implementation in the real world can sometimes be a little less than ideal. Good Intentions vs. Reality OSHA standards are crafted with the best intentions, aimed at providing universal solutions in diverse industries. Yet, the practical application often reveals significant discrepancies between the theoretical safety standards and the on-ground realities faced by industries. This mismatch can lead to frustration among safety professionals who strive to maintain compliance while ensuring real workplace safety. The Quirks of Interpretation One of the main challenges with OSHA standards is their interpretation. The OSHA Letters of Interpretation are meant to clarify the standards, but they can sometimes complicate compliance efforts. These interpretations can vary significantly, leading to confusion among EHS professionals about the best course of action. Inconsistency in Enforcement Another pain point is the inconsistency in audit findings. Depending on the inspector and the region, the enforcement of the same standard can vary, making it difficult for businesses to predict how they should prepare for inspections. This inconsistency can be particularly challenging for companies that operate in multiple states or regions. The Low-Hanging Fruit Often, OSHA inspections focus on the most obvious breaches of safety standards—the "lowhanging fruit"—rather than delving into more complex issues that could have a profound impact on worker safety. This approach can sometimes result in superficial improvements that don't address the root causes of safety issues. A Necessary Pillar of Workplace Safety Despite these challenges, it is crucial to recognize that OSHA standards do make us better. They push companies to place worker safety at the forefront of their operations, fostering environments where health and safety are integral to organizational culture. Yes, OSHA inspectors are human too—they can be good, bad, or indifferent, depending on the day. Like any of us, they face pressures and challenges that can affect their performance and judgment. Join the Conversation! Now, I turn the question to you: Which OSHA standard do you dislike the most, and why? Email me your thoughts, and I will share the findings in our June blog. The best three submissions will receive prizes. While I'm still negotiating with our CFO on what those will be, I promise they will be worth your effort. This conversation is not just about venting frustrations—it's about sharing experiences and insights that can lead to real improvements in how we approach workplace safety. Your input is invaluable, and together, we can continue to make our workplaces safer for everyone. Looking forward to your responses!
By Derek Jennings 19 Apr, 2024
The hazards posed by combustible dust are often underestimated until it's too late. These fine particles, when suspended in the air under certain conditions, can lead to catastrophic explosions, resulting in severe injuries, fatalities, and the destruction of buildings. For example, a tragic incident occurred in a metal processing plant where a combustible dust explosion resulted in the loss of several lives and substantial property damage. This serves as a stark reminder of the potential dangers lurking in what might seem like harmless dust accumulations. While the Occupational Safety and Health Administration (OSHA) has yet to establish a specific standard for combustible dust, it recognizes the severity of these hazards through its National Emphasis Program (NEP) (CPL 03-00-008). This program aims to guide inspections targeting industries known for frequent or severe dust-related incidents, including agriculture, chemical manufacturing, and recycling operations. OSHA also provides valuable guidance materials to help businesses understand and mitigate these risks. What Qualifies as Combustible Dust? Combustible dust can come from a variety of sources, including both organic and metallic materials. These are finely divided particles such as: Metal dusts, including aluminum, magnesium, and some iron forms. Wood dust. Carbon-based dusts like coal and carbon black. Organic dusts from sugar, flour, paper, rubber, soap, and dried blood. Dusts generated from human and animal food processing. Textile fibers and dust. These materials may seem innocuous in larger chunks, but as dust, they can burn rapidly and explosively under the right conditions. The Dynamics of Dust Explosions A combustible dust explosion is more complex than a typical fire. It requires five elements— known as the "dust explosion pentagon": Oxygen (from air) Heat (from an ignition source) Fuel (the combustible dust itself) Dispersion (a cloud of dust particles in a sufficient quantity and concentration) Confinement (an enclosed or semi-enclosed space) If any element of this pentagon is missing, an explosion cannot occur. However, once ignited, the dust cloud can lead to rapid and violent combustion, often manifesting first as a primary explosion within process equipment or enclosed spaces, followed by secondary explosions as additional dust is disturbed and ignited. Preventative Measures and Safety Programs To effectively manage these risks, OSHA recommends conducting thorough hazard assessments that cover: Materials handled. Operations conducted, including by-products. All spaces, even those less obvious. Potential sources of ignition. Implementing a written combustible dust safety program is a best practice for any facility handling potentially explosive dusts. This program should: Define specific safety procedures tailored to the organization. Communicate and ensure understanding of these procedures among all employees. Outline steps to control dust, ignition sources, and potential damage, minimizing injury and property damage risks. How SEA Can Assist You At Safety & Environmental Associates, Inc. (SEA), we understand the complexities of managing combustible dust risks. We offer comprehensive services tailored to your needs, including material testing, dust hazard analysis, hazard classification, and effective grounding techniques. Don't wait for an incident to remind you of the importance of dust safety. Contact SEA today to ensure your operations are safe and compliant. Together, we can create a safer working environment that protects both your workforce and your facilities. By Derek Jennings, President SEA
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