Page 96 - Occupational Health & Safety, July 2017

COMBUSTIBLE DUST
Analyzing Your Dust Hazards
To be compliant with OSHA’s general duty clause for workplace safety, facilities that produce potentially combustible dust should do everything they can to ensure compliance with NFPA 652.
BY TIM COLLITON
92 Occupational Health & Safety | JULY 2017
www.ohsonline.com
The National Fire Protection Association was founded in 1896, and for the past 120 years the trade association has created and main- tained fire protection and safety standards and codes for adoption and usage by city, county, and state governments across the country. One such code that is critical for manufacturers to be aware of is NFPA 652, which governs combustible dust standards and practices in facilities. Any facility that processes or handles combustible solids or dust such as food- stuffs, wood, plastics, and metals must take careful steps to identify and manage the potential fire and explosion hazards lurking in its everyday operations.
You don’t have to look far to find tragic examples
of the consequences of not identifying and mitigat- ing fire and explosion risks related to suspended fine dust particles in manufacturing operations. Perhaps the most notable example is the February 2008 explo- sion at the Imperial Sugar factory in Port Wentworth, Ga.—a disaster that took the lives of 13 people and injured as many as 40.
The worst part about these types of industrial di- sasters is that they are entirely preventable. To get at this problem, NFPA 652 requires that facilities with combustible dust potential be evaluated for combus- tible dust hazards no later than September 2018.
NFPA 652 is an example of a “consensus stan- dard,” meaning that most jurisdictions don’t have it codified into law but it is the consensus of experts that the standard should be complied with. These types of standards often become law over time as state legis- latures or even county and city governments update their laws and codes. At the federal level, OSHA has proposed a new standard related to combustible or explosible dust, but new federal regulation is likely some time away. However, to be compliant with OS- HA’s general duty clause for workplace safety, facilities that produce potentially combustible dust should do everything they can to ensure compliance with NFPA 652 in the meantime.
And it isn’t just brand-new facilities that need to worry about meeting the standard. There are certain aspects and requirements of NFPA 652 that are ret- roactive to existing facilities that were in existence or substantially complete on the date the standard was published, which was Sept. 7, 2015.
Preparing for a Dust Hazard Evaluation- -Conducting a Walkthrough
So, with the deadline looming, what should these types of facilities expect when it comes to an evalu- ation? How can they prepare? And what should they do once their findings are known?
The first step in getting ready is to conduct a thor- ough walkthrough of your facility and your processes to identify potential dust hazards. Items that facilities need to start paying attention to generally fall into three categories: housekeeping to control dust accu- mulations; ignition source control, which is limiting hot surfaces, static electricity, and other spark pro- ducing devices; and management programs, which involve reviewing and evaluating workplace man-
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