Page 31 - Occupational Health & Safety, January/February 2019
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mitigating distinct hazards and are not gained by simply reading or studying standards.
What constitutes a qualified person is at best misunderstood and at worst ignored. This lack of understanding and the scarcity of qualified individuals introduces a significant bias into the deci- sion-making process of who will perform the DHA. Thus, many facilities forgo the proper research and instead rely on blind faith when evaluating and choosing a qualified person for the DHA. Unfortunately, many unqualified individuals take advantage of this misplaced trust. It is vital to remember that unqualified individuals often cannot or do not wish to have their qualifications questioned. However, no one who performs any aspects of a DHA should con- sider himself above being evaluated.
Employee safety should always be the primary focus of any DHA. However, safety often gets lost when cost and other factors are added to the decision-making process. Cost should never be used as the sole factor in selecting an individual to perform a DHA. Rather, one should focus on the totality of expertise and the numer- ous benefits that an effective DHA can provide. When performed correctly by a qualified individual, the benefits far outweigh the costs of a DHA. However, this is only possible if the facility takes the necessary time and steps to truly verify that the individual pos- sesses the required qualifications to perform the DHA.
Jason Reason, MBA, CIH, CSP, CHMM, senior vice president of
Safety and Health Services and consultant for Lewellyn Technol- ogy, is a widely recognized expert in safety and health, with a special emphasis on combustible dust and industrial hygiene. He serves on a total of six Technical Committees, including serving as the chair of the NFPA 664 Committee, and is coordinating efforts to reshape combustible dust, safety, and health standards. His 13 years of OSHA experience includes hundreds of inspections in most industries, as well as training and advising federal and state OSHA compliance of- ficers across the United States. He is a national speaker at most safety, health, and industry-specific conferences, including ASSE, NFPA, NSC, and Powder and Bulk Solids.
REFERENCES
1. Industry- or commodity-specific standards include, but are not limited to NFPA 61, NFPA 484, NFPA 654, and NFPA 664.
2. Examples of other AHJs are insurance carriers, fire marshals, and building code officials.
BIBLIOGRAPHY
1. NFPA 652, Standard on the Fundamentals of Combustible Dust, 2019 Edition, National Fire Protection Association, Quincy, MA
2. NFPA 1451, Standard for a Fire and Emergency Service Vehicle Operations Training Program, 2018 Edition, National Fire Protection Association, Quincy, MA
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