Dust hazards analysis requirements under NFPA 652

Q: Our plant has what the NFPA calls a combustible dust. According to what I've heard, this
means we need to complete a DHA within the next few years. What's a DHA, and what does
it mean for our facility?

You're correct. If your plant handles a combustible dust, NFPA 652: Standard on the Fundamentals of
Combustible Dust requires a dust hazards analysis (DHA) within the next few years. This standard is
part of a series of documents released by the NFPA to regulate industrial handling of combustible dust
and improve safety. However, there are some additional factors that should be considered and
understood.
NFPA 652 went into effect on September 7, 2015. Contained within that document are multiple
fundamental requirements for those facilities handling combustible dusts. The NFPA identified a need
for this "fundamentals" standard in direct response to the enforcement issues raised by the OSHA
National Emphasis Program (NEP) issued in March 2008. To further complicate matters, the four
commodity standards NFPA 61: Standard for the Prevention of Fires and Dust Explosions in
Agricultural and Food Processing Facilities (2017); NFPA 484: Standard for Combustible Metals
(2015); NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing,
Processing, and Handling of Combustible Particulate Solids (2017); and NFPA 664: Standard for the
Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities (2017) have
recently been revised or are in the revision process to coordinate with the new NFPA 652 standard. All
these standards will require that a DHA is performed at each facility handling combustible dusts.
The requirement for a DHA (NFPA 652, Chapter 7) is one of the more critical activities for a facility
where combustible dusts are present, processed, or both. Evaluating the hazards and risks associated
with handling and processing combustible dusts to properly manage hazards and risks in your facility
is important.
According to the previously mentioned standards, the facility owners and operators are responsible to
assure a DHA is completed in a timely manner. However, the actual time allotted to complete the task
will vary based on the type of combustible dust. NFPA 652 allows 3 years for DHA completion while the
new NFPA 61 and NFPA 654 standards allow 5 years. The varying intervals allowed for completing
these assessments further complicates the issue so knowing which standard applies to your
combustible dust is essential.
Compliance with these NFPA standards means that, at a minimum, a DHA:

Shall be led by or performed by a qualified person (as defined in the standard).

Shall evaluate the fire, deflagration, and explosion hazards and provide recommendations to
manage those hazards.

Shall determine the explosibility by conducting a Pmax, KSt, MIE, MEC, or other test of the
material(s) involved.

Shall identify and evaluate the processes or facility areas where fire, flash fire, and explosion
hazards exist.

Where such hazards exist in a process or facility area the DHA must determine the safe
operating ranges for any involved equipment, what safeguards currently exist to manage the

previously identified hazards, and recommendations for any additional safeguards necessary
to manage those hazards.

Thoroughly document the DHA and have it available for review by the authority having
jurisdiction such as OSHA, area fire marshalls, an insurance provider, or other relevant
entities.

In this brief article we can't thoroughly cover the full impact of the DHA, which represents only a
fraction of the upcoming changes. As a result, Powder and Bulk Engineering is offering a full review at
a 1-day course at Powder 16: the Midwest Powder Show & Conference, which runs from October 1820, 2016, in Columbus, OH. During the course, I'll thoroughly explain the effects of the new NFPA 652
and the associated revisions in the other commodity standards. To learn more and register, click here.