Page 28 - Occupational Health & Safety, January/February 2019

COMBUSTIBLE DUST
Why Qualifications Matter When Performing a Dust Hazards Analysis
It is important to know the qualifications, reputation, and experience of the outside vendor or individual who performs the DHA.
BY JASON REASON
The Dust Hazards Analysis (DHA) was re- cently created to identify and combat the po- tential hazards associated with combustible dusts and combustible particulate solids. For a DHA to be effective, it must analyze all of the po- tential fire, deflagration, and explosion hazards asso- ciated with the affected process equipment and build- ing compartments. While this approach may seem simple, many of the factors that can contribute or be affected by these hazards are not always adequately analyzed during many DHAs.
Although all of the NFPA combustible dust stan- dards now retroactively require a DHA to be per- formed, the importance of a DHA goes far beyond just a requirement. When performed correctly, a DHA not only thoroughly identifies and assesses complex combustible dust hazards, but also provides specific techniques to mitigate these hazards. Unfortunately, these serious hazards are frequently misidentified or ignored because many DHAs are performed by un- qualified individuals.
The individual performing the DHA not only has the greatest effect on the quality of the DHA, but also the safety of any employees affected by these hazards. However, what constitutes a qualified individual is one of the most confusing and underestimated as- pects of a DHA.
A Flawed Definition
NFPA 652 and all of the industry- or commodity- specific NFPA standards require any DHA to be per- formed or led by a qualified person.1 NFPA 652-2019 defines a qualified person as a “person who, by posses- sion of a recognized degree, certificate, professional standing, or skill, and who, by knowledge, training, and experience, has demonstrated the ability to deal with problems related to the subject matter, the work, or the project.” Besides this definition, NFPA 652 sheds little light onto what qualifications are truly re- quired to perform or lead a DHA.
The confusion caused by the simplicity of this definition is overshadowed by its inaccuracies. There are no specific degrees or certifications one can ob- tain to demonstrate their knowledge in assessing and mitigating various combustible dust hazards. An ad- vanced degree, license, and/or certification (e.g., PE, CIH, CSP, CFPS, etc.) alone does not automatically qualify an individual to perform or lead a DHA. De- spite assertions to the contrary, there is also no single training course or class that an individual can take to instantly become qualified to perform or lead a DHA.
Ultimately, the inaccuracies in this definition are caused by its origin. Everyone assumes that the defini- tion for a qualified person was created when NFPA 652 was developed. In fact, NFPA 652 references this definition from NFPA 1451, which is a standard that is designed to outline the development of a fire and emergency service organization (FESO) vehicle oper- ations training program. No one would conclude that the qualifications for performing driver training are synonymous with the qualifications for performing a DHA. However, using the same definition across mul- tiple standards reduces the importance of the term itself and more importantly implies that the required qualifications are trivial and meaningless.
While NFPA 652 tries to define the essence of be- ing qualified in simplistic terms, what makes an in- dividual qualified to perform or lead a DHA is much more difficult than the definition implies. All too of- ten, individuals examine this flawed definition and incorrectly assess their own abilities and expertise to perform or lead a DHA. These inexperienced and unqualified individuals perform DHAs that do not adequately identify and address all potential combus- tible dust hazards associated with process equipment and building compartments. The conclusions reached during these “DHAs” may create additional hazards and provide a false sense of security that the fire, def- lagration, or explosion hazards are effectively identi- fied and mitigated, when in fact they are not.
Who is Qualified?
While some prescriptive requirements exist, most of the requirements that comprise the DHA methodol- ogy and documentation are arbitrary and left to in- terpretation. The combination of these performance- based requirements and the flawed definition of a qualified person lead many individuals to incorrectly believe they are qualified to perform DHAs.
While the fire, deflagration, and explosion hazards posed by combustible dusts primarily fall under the umbrella of EHS and engineering, these hazards are much more complex than they appear. Simply being an EHS professional or engineer does not necessarily mean one has the necessary skills and unique knowl- edge to perform a DHA. The complexities associated with analyzing the potential combustible dust hazards in processes, equipment, and building compartments demand specialized expertise. The skills, knowledge, and other factors that comprise this expertise cannot be easily learned in a short duration or by merely ob- serving a DHA.
22 Occupational Health & Safety | JANUARY/FEBRUARY 2019
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