Powder and Bulk Engineering

PBE0320

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8 / March 2020 powderbulk.com INDUSTRY PERSPECTIVE PBE Jack Osborn, PE, senior project engineer Airdusco Engineering and Design Services josborn@airdusco.com DHAs: 6 months and counting T ime is running out for many companies that are handling or process- ing combustible dusts. As of September 7, 2015, NFPA 652: Standard on the Fundamentals of Combustible Dust was approved as an ANSI standard. This is important because that date started the deadline clock running for completion of the dust hazards analysis (DHA) and its associ- ated combustible dust compliance issues. Initially, the time allowed for DHA completion was 3 years (2016 edition of 652), but that was extended to 5 years (2019 edition) when the situation became apparent that more compliance time was required, especially for larger companies with multiple facilities. Thus, the DHA completion date was extended to September 7, 2020, which is about 6 months away. The only exception to this is NFPA 61: Standard for the Prevention of Fires and Dust Explo- sions in Agricultural and Food Processing Facilities — 2020 Edition, which has a compliance date of January 1, 2022. For those companies where combustible dust is handled or processed that haven't completed the required DHA, the need to get this done cannot be overstated. Why? First, since compliance with NFPA 652 is now manda- tory as part of the International Fire Code (IFC) and International Building Code (IBC), fire marshals and other enforcers of these codes can compel companies to complete a DHA and enact penalties for non-compliance. Secondly, per conversations with industry representatives, OSHA is now asking for proof of completed DHAs. Perhaps even more important, should a deflagration event occur with injury to others or property dam- age, your liability could result if evidence shows non-compliance with publicly accepted standards. Not completing the required DHA is direct evidence of non-compliance. Additionally, don't assume that you can wait until the last minute to complete the DHA. Part of a DHA requires testing your material(s) for explosivity characteristics (K St , P max , MIE, MEC). Currently, the explosivity testing labs have extensive waiting periods for testing due to the need to complete DHAs before the end of the year. Secondly, the time to properly complete a successful DHA for a single facility can require multiple days. Finally, many facilities lack the expertise to conduct a successful DHA, which results in the need to hire competent, qualified experts to assist. This also means delays because these experts are in short supply. Don't wait! Take the necessary steps to complete the required DHA as soon as possible.

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