Conducting a Dust Hazard Analysis (DHA) is a critical safety step for any facility handling potentially combustible or explosible materials. The process, outlined in NFPA 654, Chapter 7, involves a detailed examination of fire and explosion risks. This includes assessing potential consequences and identifying mitigation measures. A DHA has been required for any facility that may have combustible dust since September 7th, 2020. Many facilities 4 years later still have not conducted a DHA. However, a common question arises: Who is qualified to conduct a DHA?
The Role of a Qualified Individual
NFPA (National Fire Protection Agency) guidelines require that a qualified individual conduct or oversee the DHA. But what does “qualified” mean in this context? While NFPA 654 itself doesn’t explicitly define the qualifications, NFPA 652 provides helpful guidance. A qualified person or team should have expertise in the following areas:
- Familiarity with Processes and Operations – They should understand the facility’s operations, including handled materials, equipment, and the specific risks associated with these processes.
- Knowledge of Process Equipment and Safety Systems – Understanding how the machinery operates and how safety systems function is crucial for identifying and mitigating risks.
- Emergency Procedures – A qualified individual should also be familiar with the facility’s emergency protocols to recommend enhancements, if needed.
- Material Properties – A deep understanding of the physical and chemical properties of the handled materials —including their combustibility and explosibility—is essential for accurate risk assessment.
Who Can Be Considered Qualified?
Based on these criteria, several types of individuals or teams could potentially conduct a DHA:
In-House Experts – Facilities with experienced safety professionals or engineers may conduct the DHA internally. However, these individuals must have a robust understanding of the guidelines and all relevant aspects of the operation.
External Consultants – Many companies choose to hire third-party experts who specialize in dust hazard analysis. Consultants often bring broad experience across various industries. This can be beneficial for identifying risks that in-house teams might overlook.
Interdisciplinary Teams – Combining expertise from different areas, such as process engineering, maintenance, safety management, and emergency planning, can create a comprehensive approach to the DHA.
When Should a Dust Hazard Analysis Be Conducted?
The NFPA mandates that facility owners ensure a DHA is completed in the following situations:
- For Existing Facilities – Even if a facility has never experienced an incident, this is not a valid reason to avoid conducting a DHA. It serves as a proactive measure to prevent potential disasters. If a facility has never had a DHA completed, NFPA mandates that they get one.
- For New Installations or Upgrades – Any new installations, expansions, or upgrades to existing systems require a fresh DHA to assess potential risks introduced by the changes.
- Periodic Reviews – Review and update a DHA at least every five years, even if no significant changes have occurred.
Documentation and Action
Thoroughly documenting the results of the DHA is mandatory, along with actionable recommendations for improving safety. This may include changes to process materials, operational practices, or facility layout.
While NFPA guidelines don’t dictate a specific individual for conducting a DHA, the emphasis is on expertise and thoroughness. Facility owners must prioritize this critical safety measure by involving qualified personnel—whether internal or external—to ensure the long-term safety and compliance of their operations.
