For some facilities, the dust hazard analysis deadline for compliance with the NFPA is fast-approaching. The steps it will take to perform a successful dust hazard analysis (DHA) could make that deadline even more ominously impending. While agriculture and food processing plants have until January 2022 to complete their DHAs, Sept. 7, 2020, is the deadline when all other manufacturers who handle combustible dusts (not in the NFPA 61 category) will need to complete their DHAs successfully.
As an equipment manufacturer that handles bulk raw materials, AZO encourages all parties involved in manufacturing to be aware of dust hazards and to take safety measures into thorough consideration so both people and property are protected. To endure plant safety, AZO has prepared this blog post to identify three potential barriers (or hiccups) a facility might face in completing a DHA. These barriers include:
- The process for completing a dust hazard analysis will likely take longer than you expect
- Experts are needed to facilitate and/or perform the DHA
- Explosivity labs, which are needed for material testing, could be slammed with too many test requests as the deadline draws closer.
More information related to the NFPA standards and DHAs can be found in a new infographic from AZO, but for specific reasons to not procrastinate the execution of your DHA consider the following:
The process for completing a DHA often takes multiple days
Each DHA seeks to accomplish a few key items. It determines potential causes of fires, consequences of those fires, where they might occur and the effectiveness of proposed safeguards. We’ve even outlined these in steps for completing a DHA.
Starting a DHA takes time to collect the data, analyze the potential risks and determine the best safeguards. Completing an effective analysis will likely take more time than expected. In other words, it is simply not something your facility should procrastinate and attempt to complete a few days before Sept. 7.
Experts are needed to perform a dust hazard analysis
An effective dust hazards analysis should absolutely be conducted by someone who is qualified to complete it. In some cases, a member of your team might have the right knowledge and experience to identify and mitigate potential threats, but they need proper time and resources to get the job done.
There is also the risk that something could be overlooked, so to ensure no stone is left unturned in evaluating threats and causes in your facility, you might want to “leave it to the professionals.” If no one in your operation is up to the critical task of performing an accurate DHA, a consultant may also be necessary. Still, it may take some extra time to find one of these if you wait too late to get started (especially as the deadline draws near). Finding that qualified person to complete the DHA could become an additional hiccup to consider when trying to complete your successful analysis.
Explosivity labs could get backed up with test requests
As the deadline draws near, a lot of other manufacturers will need to have materials tested. If you need testing done, it makes sense to get your material inspected as soon as possible. You don’t want to be caught at a time when the demand is overwhelming the labs completing the testing. Failing to complete a DHA by September could potentially lead to an OSHA citation, and no plant or company wants one of those.
Whether an expert is hard to find, labs are busy testing a plethora of materials or (even when you have all your pieces in order) the actual process takes longer than expected, completing a DHA is simply not as simple as some assume. Yes, the requirement for inspecting a facility’s DHA only comes around once every five years, but your records of progress should be kept every year with regards to previous DHAs. A willingness and readiness to meet NFPA standards is one way to keep people and property safe amid the very real risk that combustible dusts pose.
AZO has seven decades of experience in handling raw materials and shaping ingredient automation along the way. Feel free to contact our sales team for any questions on how to help your plant and processes run smoothly.