Page 29 - Occupational Health & Safety, January/February 2019

So the real question is, who is qualified to perform or lead a DHA? Unfortunately, the answer to this simple question is ex- tremely convoluted. NFPA 652 suggests that the qualified person who performs or leads the DHA should be “familiar with conducting a DHA and with the hazards of combustible dusts.” However, this state- ment is overly broad and underestimates how much an individual’s expertise can affect the overall quality and outcome of a DHA.
Someone who is truly qualified to per- form or lead a DHA simultaneously has intimate knowledge of a wide range of dust handling processes, as well as specialized knowledge of the complex hazards associ- ated with the various types of combustible dusts. This individual has not only per- formed all of the aspects of several DHAs associated with the affected industry or type of combustible dust, but also has honed his or her expertise by examining and mitigating a variety of fire, deflagra- tion, and explosion scenarios over several months or years.
The rarity of individuals who possess these qualifications cannot be under- stated. To their detriment, many facilities assume that OSHA and other Authorities Having Jurisdiction (AHJs) possess these qualifications.2 AHJs often walk by nu- merous combustible dust hazards, many of which are in plain sight, because they lack the knowledge and due diligence to identify these hazards. This leads to state- ments like “OSHA never cited me” or “our insurance never said anything.” Believing these statements and trusting unqualified AHJs can not only downgrade the exis- tence and significance of the serious haz- ards posed by combustible dusts, but also exacerbate these hazards and potentially cause an incident.
When to Use Outside Resources
Confidence in one’s ability to assess and mitigate safety and health hazards is a ne- cessity for an individual tasked with re- ducing risk. However, confidence alone is neither a justification nor a qualification for evaluating the serious hazards posed by combustible dusts. It is incumbent on the individuals who are employed at the facili- ties where these combustible dust hazards emanate to fully acknowledge when they are not qualified by education or experi-
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