Effective September 7, 2020

Each year, combustible dust explosions result in fatalities, injuries, millions of dollars in capital costs, hefty litigation fees, and stringent regulatory action. To safeguard companies and their employees, the National Fire Protection Association (NFPA) issued Standard 652 to address combustible dust. All facilities that produce combustible dust must complete a Dust Hazard Analysis (DHA) by September 7, 2020 to comply with the NFPA Standard 652.

Does your facility need to comply?

  

What exactly is combustible dust?

A combustible dust is any fine material that can catch fire and explode when mixed with air. Surprisingly, many organic materials such as flour, sugar, wood dust, grains, starch, potatoes, and even rice are combustible under the right conditions. Additionally, metals, plastics, chemicals, rubber, pharmaceuticals, and textile dusts are also commonly combustible. These products or materials may be stored in silos or containers, may gather in buildings at the eves, rafters, on the roofs, and various other places.

  

How does a dust explosion occur?

Diagram: Fuel (Dust) + Oxygen + Ignition Source + Ideal Dispersion + Confinement of the Dust Cloud = Explosion

  

What types of facilities must comply?

  • Food production and agricultural processing facilities
  • Chemical, pharmaceutical and general manufacturing facilities
  • Lumber processing or woodworking facilities
  • Metal processing and fabrication facilities
  • Recycling facilities
  • Power plants fired by coal
  • Mining and process industries

  

What is the risk?

According to the Chemical Safety Board (CSB), from 2003‑2017, nine combustible incidents killed 55 people and injured hundreds more.

Beyond the potentially fatal consequences, combustible dust hazards can result in OSHA enforcement actions and monetary penalties.

  

How stringent is this compliance requirement?

After the National Emphasis Program on combustible dust was rolled out, OSHA began its inspection and enforcement program. In just two years, they inspected over 1,000 facilities and issued over 4,900 violations. Of these citations, 75% were levied from federal inspectors and 34% from state inspectors.

With the enforcement of NFPA 652, those inspections will increase. Moreover, once employers are on notice of combustible issues because of an incident or OSHA citation at any of their facilities, OSHA may treat future violations as willful, and civil liability increases.1

  

What do you need to do?

Put safety first. While NFPA itself doesn’t have regulatory authority, OSHA currently follows NFPA standards to ensure that facilities stay safe while handling potentially explosive/combustible materials. If your facility falls within one of these at-risk industry sectors, you may need to conduct a DHA, if you haven’t already. You will also need to complete a DHA if you have experienced or adapted any process change since your last DHA. As guidance evolves, variables such as storage and confinement conditions change, and combustible dust accumulates over time, DHAs should be reviewed and updated every five years.

This is where Apex can help. We will review your facility, processes, documents, and your existing engineering and administrative controls. This will identify where a hazard may exist and any associated risks, as well as ensure that the appropriate safeguards are in place based on NFPA 652 requirements.

  

What OSHA standards apply to NFPA 652?

  • General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act (Employers must keep workplaces free from recognized hazards likely to cause death or serious physical harm).
  • §1910.22 General requirements
  • §1910.38 Emergency action plans
  • §1910.39 Fire prevention plans
  • §1910.94 Ventilation
  • §1910.146 Permit-required confined spaces
  • §1910.157 Portable fire extinguishers
  • §1910.165 Employee alarm systems
  • §1910.176 Handling materials—general
  • §1910.178 Powered industrial trucks
  • §1910.261 Pulp, paper, and paperboard mills
  • §1910.263 Bakery equipment
  • §1910.265 Sawmills
  • §1910.269 Electric power generation, transmission and distribution
  • §1910.272 Grain handling facilities
  • §1910.307 Hazardous (classified) locations
  • §1910.1200 Hazard communication
  • §1910.119 Process safety management

1 Source; Howard Mavity, Partner, Fisher Phillips law firm: Workplace Health & Safety Law Blog, July 13, 2018.

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