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July 2020 / 29 BREAKING DOWN DHAs FOR PROCRASTINATORS No matter what industry you're in, the deadline for your facility to complete a dust hazards analysis (DHA) is drawing near. Whether you've never done a DHA or done the analysis only once, it's a fairly simple process that, once completed, will last you 5 years. This article describes what a DHA is, why it's necessary, and how to accomplish a successful DHA. Jack Osborn, Airdusco various enforcement methods and the agency has done so on multiple occasions. The requirement for hazards analysis in NFPA stan- dards dates back to 2002 for the wood industry, 2006 for the chemical and chemical-related industries, and 2015 for the metals industry. The food industry didn't specifically require a DHA until NFPA 61's 2017 edi- tion. However, the requirement became universal for all industries working with combustible dusts starting September 7, 2015, with the publishing of NFPA 652. A DHA is described best in NFPA 652: Standard on the Fundamentals of Combustible Dust, Chapter 7, "Dust Hazards Analysis," and the associated annex. Basically, any new system or facility requires a full DHA, which is a guide used to improve facility safety by identifying the specific combustible dust hazards associated with a facility's processes. After reviewing your facility and processes and identifying potential combustible dust hazards, the DHA helps you to create a plan to mini- mize or mitigate those risks. Completing a DHA is an ongoing requirement. Also, except for the agricultural and food businesses, this DHA requirement is retro- active and applies to all existing facilities and process systems. The agricultural and food standard, NFPA 61, limits the retroactive portion to certain types of sys- tems and equipment, but ignoring any possible hazard source makes no sense because of the hazard's poten- tial for harmful personnel and property consequences. Your DHA's purpose What's the actual purpose of a DHA? First, a DHA evaluates the hazards that exist in your processes. Sec- ond, a DHA determines the best method or methods to manage those hazards. Third, this analysis creates a plan to complete the tasks or methods necessary to mitigating or eliminating those hazards. The overall DHA purpose is to determine the hazards, eliminate P rocrastination seems to be a favorite American pastime, but when it comes to completing your facility's dust hazards analysis (DHA), time is truly running out. If your facility handles combustible dust, such as those subject to potential fire, flash fire, or explosions or a combination of these conflagration dan- gers, then you have until September 7, 2020, to complete a DHA for each of your facilities. The only exception to this requirement is that the agricultural and food processing industries have until January 1, 2022, to complete their DHAs. DHA and the NFPA Considering all the problems associated with the coronavirus pandemic, there was the possibility that the DHA deadline would be delayed, but that's very unlikely to happen. This is mainly due to the fact that all industries handling combustible dusts have been required to complete a DHA since September 7, 2015. Although NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities added more time to complete the required DHA during the latest cycle (2020 edition), all other NFPA commodity-based standards — NFPA 484 for metals, NFPA 654 for chemicals, NFPA 664 for wood — have kept the deadline at 5 years from 2015 for com- pleting the required DHA. The NFPA is a nonprofit, nongovernmental organization, and therefore, it has no enforcement authority. However, NFPA 652 and subsequent com- modity-based combustible dust standards are now mandated by the International Fire Code (IFC) and International Building Code (IBC), which do enforce the DHA requirement. Also, OSHA may not have any regulations about DHAs, but OSHA is able to make combustible dust compliance compulsory by other