Implementing a Combustible Dust Program at a Large Facility

This author reviews the latest NFPA 652 requirement on Dust Hazards Analyses (DHA) and compares it to OSHA PSM’s Process Hazards Analyses (PHA) requirement and other process analyses required by industry specific NFPA dust regulations. Though process analyses have been a part of NFPA regulations for several years and in the OSHA PSM regulation for 25 years, the 2016 version of NFPA 652 has clearly defined that a process analysis called Dust Hazards Analysis must be done where there is a combustible dust risk. The subject of this paper is the Dust Hazards Analysis.

The aim of the paper is to find commonality in dust hazards analysis, process hazards analysis and process analysis for tips that may limit the number of analyses a company may have to perform. These tips provided will assist a PHA leader in doing their DHA’s. This will not be an exhaustive review of standards or regulations, but an overview and guide for those starting DHA’s. It has become obvious that NFPA regulations are modeling a PSM framework and some discussion will be made on the subject in the area of risk assessment and management systems. Some comments will be made concerning the software that can be used, but no software will be sold or marketed. The author is not sharing examples of DHA’s from his company due to confidentiality and timing of his DHA’s.

Some of the Dust Hazards Analysis differences detailed are the emphasis on dust inside and outside of equipment, the use of NFPA dust thickness calculations, building reviews, and frequency of re-validating the analyses. How does a Dust Hazards Analyses affect the process safety information required, team make-up or report after the review? What are the real requirements for a DHA leader? The paper will focus on the industry specific NFPA regulation 654, 664 and 484. Prescriptive vs performance design routes will be discussed in general.