Page 30 - Occupational Health & Safety, January/February 2019

COMBUSTIBLE DUST
ence to undertake a DHA. Failure to do so could cause serious fire and explosion haz- ards to be misidentified, unmitigated, or, worse, both.
Any individual who questions or de- bates his own qualifications is not qualified to perform or lead a DHA. Recognizing the limitations of one’s ability is a mark of professionalism, underscored in the Code of Ethics of many professional certifying organizations. This must not be dismissed when factors such as a need to demon- strate individual value to the organization, reservations about outside entities (third parties), and overconfidence begin to influ- ence the decision-making process.
Evaluating combustible dust hazards and conducting a DHA is a resource- intensive process. When attempted in house, a DHA redirects facility personnel away from running the business for sev- eral weeks, resulting in frustration and acknowledgement that outside resources are required to adequately address the combustible dust hazards.
Once facilities make this fateful deci- sion, they are forced to turn to consultants, engineers, and other outside entities to perform the DHA. While it seems like this may alleviate the problem, the combustible dust expertise advertised by many of these outside entities is frequently comprised of mistruths and inaccuracies. The worst mis- take a facility can make is trusting this un- verified “expertise” and assuming all DHAs are created equal.
Cost vs. Qualifications
What is the value of a comprehensive and effective DHA? Does the value rely on its cost or its content, and what affects the cost and content? The answers to these ques- tions are dependent on the qualifications of the individual who performs the DHA.
Cost is the most misused and least un- derstood deciding factor for undertaking a DHA and indirectly evaluating an indi- vidual’s qualifications. While most facilities understand the requirement to perform a DHA, they misunderstand the complexi- ties that comprise an effective DHA. These misunderstandings are carried over to the purchasing decision, which causes many facilities to not know or underestimate what they are paying for in terms of safety and quality. In this case, cost deters quali- fied individuals from performing DHAs.
Many facilities assume all DHAs are created equal and believe they are compar- ing “apples to apples” when it comes to in- dividual qualifications and other aspects of the DHA. This only perpetuates the myth that the cost of a DHA and an individual’s qualifications are unrelated. The adage of “you get what you pay for” could never be truer because the largest influence on the quality and outcome of a DHA is the indi- vidual performing the DHA.
To make purchasing decisions based on the cost of the initial analysis without considering the individual’s qualifications often produces the opposite cost/benefit outcome than what is expected.
Determining Qualifications
It is important to know the qualifications, reputation, and experience of the outside vendor or individual who performs the DHA. Although determining the qualifica- tions of an individual is relatively simple, it is frequently not performed and taken for granted. Frequently, facilities improperly rely on an individual’s word or reputation. Relying on this unverified information is dangerous and circumvents the necessity of the qualified person.
Prior to performing a DHA, the facil- ity should establish a system to verify the qualifications of whoever will perform or lead the DHA. Currently, NFPA 652 and all industry- or commodity-specific NFPA standards are silent as to how this determi- nation should be made. However, thorough vetting of individuals or vendors offering to perform DHAs should consist of the fol- lowing information submittals:
■ Verify employment. Obtain docu- mentation of the individual’s job title, re- sponsibilities, length of employment, and other pertinent information. While this may seem arbitrary, many outside entities will contract the DHA to a unvetted third- party consultant and present that their company performed the DHA. Many of these third-party consultants are unquali- fied to perform DHAs and inconsistently assess and document potential combustible dust hazards.
■ Check documentation. Obtain the resume and other applicable information (e.g., published articles, copies of certifica- tions, etc.) to gauge the individual’s specific activities, accomplishments, and experi- ence that qualifies him to perform a com-
prehensive and accurate DHA. All of this information should be verified, because individuals frequently misstate their expe- rience and accomplishments.
■ Establish the plan. Understand what actions the individual will perform while conducting the DHA. The process equip- ment analysis, fire and explosion hazard scenario identification, ignition source identification, inspection and maintenance deficiencies, housekeeping effectiveness, and operating procedures are some but not all of the items that should be examined within the DHA.
■ Contact references. Obtain and con- tact several references, preferably at least one in a similar industry, to shed light on not only how the individual previously assessed and mitigated combustible dust hazards, but also the overall structure and quality of the DHA. At a minimum, at least two references should be contacted.
■ Obtain a sample DHA report. Obtain and review one or more reports from previ- ous DHAs performed or lead by the select- ed entity or individual to assess how the in- formation gathered during the DHA will be presented. The thoroughness and quality of the DHA, as well as the effectiveness of the hazard mitigation strategies, also should be compared with competing entities.
The above information is required to perform a cost benefit analysis and make the best decision regarding which indi- vidual has the qualifications to perform a DHA. Without this information, there is no way to assess an individual’s experi- ence, reputation, or qualifications to per- form the complex analysis necessary to mitigate combustible dust hazards. Failure to provide any of the above information should be taken as a definitive sign to be- gin to question the individual’s expertise and experience in assessing and mitigat- ing combustible dust hazards.
Conclusion
The individual selected to perform or lead the DHA must be experienced with the process equipment affected by combustible dust hazards. He must have a working un- derstanding of the intent of the numerous combustible dust standards and be able to recognize solutions that fit the facility’s needs. This expertise and experience that comprise an individual’s qualifications are gained from years of work assessing and
24 Occupational Health & Safety | JANUARY/FEBRUARY 2019
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