For this podcast, expert consultant Bob Korn from DEKRA Process Safety joins us to talk about dust hazard analysis, compliance with NFPA 652, and dealing with combustible dust hazards. As a professional in Process Safety Management, Bob explains the process of conducting an analysis, what to look for, and how to fix gaps in your safety system.
MITCH: Welcome to the Dusty Jobs podcast from Imperial Systems. Industry knowledge to make your job easier and safer.
DONOVAN: Thanks for joining us again here on the Imperial podcast. We’re still at Imperial headquarters here in Mercer, PA. Joining us today is Bob, Bob with DEKRA. Bob, tell us a little bit about yourself and a little about DEKRA.
BOB: Well, thank you, thank you for having me today. My name’s Bob Korn and I’m the Business Development Director for DEKRA Process Safety. We are a process safety consultancy and we help our clients prevent accidents, whether they be with combustible dust, flammable liquids, and/or chemical reactions. We basically do that through providing consulting services, testing services, and training services.
DONOVAN: Yeah, how long have you been… you’ve been in the industry for what…
BOB: I’ve been in the industry a long time, about twenty years in industrial protection and in process safety for approximately the last four years. But industrial protection, over twenty years.
DONOVAN: Yeah, DEKRA’s been around for a while too, right?
BOB: DEKRA has. We were formerly known as Chilworth Technology; a lot of people in the US might recognize that name, but we became part of the DEKRA family about eight years ago, and we’ve been in business for over 30 years providing process safety support for our clients in the US and globally.
DONOVAN: There you go. So, the main reason we had you come in today was because there’s some new standards coming out around DHA.
BOB: There are.
DONOVAN: Yeah, and it’s mostly… what’s that new standard?
BOB: NFPA 652. Actually it’s not quite new, but it was first released in 2015, the first edition, and 652 is the Standard on the Fundamentals of Combustible Dust, and it is now the over-arching standard that NFPA has developed and put out there to really help people have more continuity in understanding the hazards of combustible dust.
DONOVAN: They wrote it in 2015, right, but now it’s actually being implemented in 2020, right?
BOB: Well, there’s a deadline… one of the elements, to be compliant with NFPA 652, you need to complete a dust hazard analysis. It’s really one of the three primary elements with regard to combustible dust, and there is a deadline now that had been established for September of 2020 to be compliant and complete your dust hazard analysis.
DONOVAN: Yeah, but they’re going to bump that back again, don’t you think? Do you think they’re going to bump it back again?
BOB: If they do… as you said, they bumped it once, and the initial due date was September of 2018, and they got some pushback from industry, so they pushed it put to 2020.
BOB: I don’t know if they’ll push it again. They may or may not. The important thing is for people to know that the standard is out there and they need to complete a dust hazard analysis.
DONOVAN: From what we’re hearing it doesn’t really sound like… I was kind of saying that sarcastically. I don’t think it’s going to get pushed back, but if it does it’s important to get it done no matter what to know what your safety is like in your facility, and that’s what you guys do, right?
BOB: Absolutely. You know, it’s important to complete. Combustible dust hazards have been around for a long time. The first combustible dust accident was documented I believe in 1782 in a bakery in Italy. They had a flour dust explosion. A gentleman was in there with a candle-lit lamp and collecting flour. But dust explosions have been with us for a long time.
BOB: NFPA has done a great job with releasing 652 and there’s several other standards I’ll point to that help identify specific industries with the hazards of combustible dust. But NFPA 652 is attempting to combine those into one… well, it’s not combining them now, but they have one overarching standard that basically helps focus people’s activity so they know what to do to be compliant and be safe when they have combustible dust.
DONOVAN: So the first step in figuring out what you need is a dust hazard analysis, right?
BOB: It’s one of the steps. There’s three components, as I mentioned, of being compliant with 652. The first step is really understanding: do you have a combustible dust? And there’s a couple of ways you can go about that. There’s industry data that’s out there if that’s appropriate and descriptive of your process that can be used…
DONOVAN: So there’s some notes out there already on some dust…
BOB: There is some industry, and it might be company literature that they already have, or some research or development or testing they did previously, so they might have some data. Otherwise, there’s many laboratories… DEKRA Process Safety has a certified or ISO-accredited laboratory that provides combustible dust testing, but having good data, solid data to do the assessment, is one of the key elements of…
DONOVAN: So getting your dust tested is…
BOB: Get your dust tested, find the appropriate material properties that fully characterize the hazards of that particular material, that’s the first step really in performing a dust hazard analysis. From there you perform the actual dust hazard analysis, which is similar to a process hazard analysis.
BOB: Which some people may be familiar with, I believe it was developed by the Chemical Processing Industry many years ago, OSHA has a PSM standard which they’ve applied to many regulated industries, but the difference being with a dust hazard analysis is just a… it focuses on a single hazard, and that is simply combustible dust. And the dust hazard analysis basically is you understand the material properties, and then you walk through a facility looking at each of the unit operations where they either handle or create… they handle combustible powders or they create combustible dust through particle reduction or some other process.
DONOVAN: So by particle reduction you mean like grinding, anything like that. In a facility where they’re generating dust, you want to look at that. So step one is getting that dust tested, step two is actually walking through the facility and seeing where this dust is coming from and how it’s being produced. Am I getting this correct?
BOB: You are.
DONOVAN: All right. So now we’ve got step three, right?
BOB: Not only do we look at the processes when we’re going through the facility, but we’re also looking at the facility itself, because we want to understand what type of housekeeping they have in place, and we look for fugitive dust accumulations, and oftentimes you get dust layers or dust accumulating on horizontal surfaces whether it be at ground level or elevated surfaces. It’s very important to understand at what level or how much dust is accumulating within the facility, and those can present special, unique hazards and can also contribute to a secondary explosion if you have an initial event…
BOB: Yeah, those fugitive accumulations can cause serious consequences if they’re not dealt with and cleaned up.
DONOVAN: So as you’re walking through this facility, you’re looking… you’re not just looking at the process that’s creating the dust, the source of the dust, but you’re also looking at the area around the facility where this dust might be laying, on some ductwork or on a shelf, because heaven forbid that if something would happen, that dust is going to get airborne and create a secondary explosion.
BOB: Absolutely. That’s absolutely correct, and yeah, it’s not just the individual processes, although those are a primary, you know, focus of the dust hazard analysis is looking at the individual unit operations where they’re grinding, as you mentioned, grinding, mixing, milling, sanding, all of those, drying… but you also want to look at the environment in general and the housekeeping program in place, and any fugitive accumulations that could be… whether at a floor level or an elevated level.
DONOVAN: OK. Now, that’s the full walkthrough? Is there something else you do after that?
BOB: Basically… well, initially, you sit down with your client and you review the documents. You get a set of documents, basically a plant layout diagram, PNIDs(?) if that’s relevant to the process, if it’s actually connected, process flows, other flow diagrams, material property data. You review all the documentation ahead of time, maybe sit down with the client and review that when you get onsite, then you walk down the facility and review the operations, document your observations so you can, you know, clearly report those back in the report, do the analysis after you do the walkthrough of the facility and inspect and observe all the different operations and the housekeeping and the fugitive accumulations. And then you compile this into one report. The dust hazard analysis report includes of course your observations, a little bit of description of the process, but it also has the findings and recommendations. So based upon what we’ve seen, the consultant will make recommendations on what particular changes need to be made based upon… what they find or what they look for is gaps.
BOB: And gaps in… there’s certain protection measures that should be in place, and what we do is identify gaps in existing measures and make recommendations to close those gaps so the facility can be operated safely.
DONOVAN: So if I’m a… let’s say I’m a plant manager, I know this is coming up, what are some things I should be doing to prepare for myself, as a plant manager, getting a dust hazard analysis. What are the steps I need to take? Obviously we said to get your dust tested.
BOB: Getting the dust tested will… and we can help guide our client through that… in some cases they have a lot of different types of materials that may be used, and recipes, if you will, for different products, so maybe we’ll help them and advise them to look at, you know, you’ve got 40 ingredients but there’s seven product groups those ingredients go into, so let’s test each one of those seven product groups, the primary ingredients in those seven product groups, get the data we need to do the assessment or the analysis ahead of time, review the documentation from the site, so they’ll be required to pull some of that together. And then we’ll also want to have specific team members, you know, depending on the organization, how they’re structured, but you typically have an EHS person, one of their safety people. You want an operations person, someone that’s familiar with each of the unit operations that you’re going to be looking at. Maintenance people are very useful in the dust hazard analysis. They’re the people who really know the ins and outs of the facility.
DONOVAN: The guys who gotta vac it up, right? They know where it’s coming from.
BOB: The guys that have gotta fix the broken stuff, yeah. And when you’re looking at, say, a bucket elevator, we need to know… you know, they’ve got belt line gauges or sensors that tell them when that belt is out of alignment. You know, critical things that they need to keep on top of to ensure you don’t introduce mechanical friction and sparks or ignition sources.
DONOVAN: An ignition source.
BOB: One of the key elements when you’re talking about dust hazard analysis… and there’s four primary things that you’re looking at when you’re doing a dust hazard assessment, and that is can… is the dust combustible, is the dust small enough to be…
DONOVAN: Particle size?
BOB: Yeah. Is the particle size small enough to propagate or promote a deflagration event? Can the material be lofted in the air, is there some mechanism that it could be lofted into the air, dispersed in the air? Is it… can that dispersed cloud reach the minimum explosive concentration? Is there enough of it? And the final element, is there a credible ignition source? So that’s why we look at equipment, you know. Equipment can be one source, mechanical, friction or sparks, there’s also thermal conditions with hot bearings and so forth, electrostatic conditions, hot work… there’s a myriad of ignition sources out there, and as someone, I’m not sure who, said, ignition sources are free.
DONOVAN: They’re free….
BOB: No extra charge!
DONOVAN: Someone’s always looking to light this stuff on fire!
BOB: Well, that’s what you have to plan for, you know, is that it can potentially happen at any time. The upset conditions are a reality, and when we’re doing dust hazard analysis, not only do we look at the standard operating conditions, but we also consider what could happen in upset conditions. What happens if this belt comes off or this pulley gets stuck, or this sensor doesn’t work, and you know, what are the potential risks associated with that?
DONOVAN: So, trying to think of some other things that we could cover here… utilize most of your knowledge… so we got what’s involved, we have… kinda looking at our notes here… so once a customer comes to you, you do the walkthrough, you do all of your analysis.
BOB: Do the dust hazard analysis.
DONOVAN: So then the idea is to come back to them with the risk and solutions, correct? Is that what you do, or…
BOB: Well, after we perform the onsite survey, if you will, or the onsite portion of the analysis, they’ll… the consultant will take that information and do the assessment or the analysis of all the information collected while onsite. They’ll prepare a report that certainly documents their observations and their findings and identifies the gaps in the safety measures that are existing, or just missing completely. And then make recommendations to close those gaps. And those recommendations will be risk-ranked from high, medium, to low. In some cases we’ll see situations at a facility, it’s a very high-risk situation, and we’ll make that recommendation immediately while on site that you need to stop doing that. Unplug this…
DONOVAN: So you might be somewhere, you see something going on, you’re like “just turn it off right now”.
BOB: It’s very dangerous, deal with it right now. And then the other risk ranking is there for, as you return the report to the client and they’re reviewing what they need to do, obviously we all have a limited amount of resources and capital to do things, so the risk ranking helps them identify which ones are most important, ones they need to address in the short term and apply their funds and their resources to, to correct.
DONOVAN: Everybody’s got a budget these days.
BOB: Yes, they do.
DONOVAN: And then you’ve gotta figure out how much you can tackle at once.
BOB: Absolutely. It’s one bite at a time, as far as some of these projects can be very large and very extensive in some of these large facilities, and there’s a lot of findings, and they really need that risk rating to determine what do they attack first?
DONOVAN: Yeah, it kind of helps you as a… helps your customers get a strategy to move forward. Maybe it seems overwhelming at first, but you guys can help whittle it down to just what needs tackled, primary issues, and then secondary issues that are coming up down the line, they can budget for those as time comes on, and the money comes on, to be able to do that.
BOB: Correct. And that’s… the dust hazard analysis is the second portion of 652, the second element that you need to perform to be compliant. The third element is to ensure that after the dust hazard analysis, or as part of the dust hazard analysis, we’ll often look at their process safety management program while we’re onsite and ensure that they have the appropriate elements within their safety management program that address combustible dust issues. And the client needs to ensure that they have that in there, and sometimes we’ll provide a service where we’ll audit their program. In some cases they don’t have a program and we’ll develop a program for them. SO that’s basically the third component, and part of that, I think the important part of the safety management program, is another service we provide on a regular basis to ensure that the personnel within the facility that are in close proximity or work with combustible dust have some training and some knowledge, some basic knowledge of the hazards around dust, so training is very important.
DONOVAN: So do you guys offer that training too?
BOB: We do.
DONOVAN: So that would be something that… if there was classes or something that a customer was under-educated in a certain field, you could help bring them up to where they needed to be?
BOB: Depending upon the client need we offer either onsite training from simple one-hour overviews to webinar training. If they’ve got multiple sites in multiple time zones we can do webinar training, or we can do more intensive boot camp type training where we do one, two, or three day training onsite with ten, twenty individuals and we can do… we also include workshops in those trainings that we can tailor to similar operations that that client might have on their site.
DONOVAN: So once you complete all three of those steps, that would bring you into what is considered compliant, then.
BOB: With 652. And one element that I forgot to mention is 652 is kind of the overarching standard, but there are also commodity-specific standards for… there’s NFPA 61, which is the agricultural food standard. There’s 484, the metal standard, there’s 664, the wood standard, and so forth. Well, those are commodity-specific standards and they give guidance for these very specific industries, if you will, and if you don’t fall into those commodity-specific standards there’s a guideline in 654 which is kind of your standard guideline for protection and so forth.
DONOVAN: This is a lot of numbers and a lot of information, and I am glad there are people out there that are thinking about this full-time.
BOB: And there is, but the good news is these standards used to have significant inconsistencies from standard to standard. NFPA has done a good job recently of really pushing the committees to remove some of these inconsistencies, because at the end of the day the plant owner, it’s a little bit… it’s a large task to read these documents and understand them. That’s why there’s experts like us that can help and assist there, but it’s even easier for us as there’s less contradictions from standard to standard.
DONOVAN: Oh, yeah… I can imagine. And then it could get overwhelming.
BOB: It is. Very quickly.
DONOVAN: So… well, I think we covered a lot about what a DHA is and what you need for it. I’m trying to think if there’s any other common questions that people come to you with that we might be able to cover, help out… anything you guys get on a regular basis? Because with this coming up we want to be sure we’re able to help people get what they need.
BOB: Yeah, you know, one of the most common questions is “how long is this going to take?” and from… it really depends on the size of the facility and the number of operations that we have to look at, but for most facilities we can do the walkthrough of the site in one to three days. A three-day onsite visit is a pretty large facility, typically. And then the report is generated usually within 30 days after the onsite visit, and we issue a draft report to the client. The client can review that, and they may have questions or comments about the draft report, and then the draft report is then finalized. It’s just kind of how the process goes.
DONOVAN: So you’re looking at, for a standard-sized facility, about a month, month and a half process?
BOB: By the time you gather information and get onsite and do the assessment and do the analysis, and then get the report done, two months would be a pretty quick…
DONOVAN: It takes about two months and the deadline is in September. It’s going to be…
BOB: There’ll be a lot of people scrambling…
DONOVAN: There’ll be a lot of people scrambling.
BOB: … to get things done. But there’s no… you know, even though there’s a deadline, you know, there’s the authorities having jurisdiction will come in and say, “get this done”. There’s different ones out there, so there’s… the important thing is that you’ve got to… if you think you have a combustible dust hazard, be doing something about it now. If you don’t get it done, have a plan in place. Certainly, if an AHJ comes into your facility and asks the question and if you don’t have a plan, you’re going to be in a less favorable position than if you did have a plan.
DONOVAN: Well, thanks for taking some time to share with us. Thanks for giving us some knowledge, some information that’s going to hopefully help everybody out there who’s trying to figure out a little bit more of what they have to get done with this DHA and with the new standards that are going on, that they can find a little information in this. If they need more information they can look you guys up. What’s the best way to get a hold of you?
BOB: Just look at dekraprocesssafety.com and you’ll find us out there. If you Google us, Google combustible dust or process safety or DEKRA process safety you’ll find us and we’ll be glad to help.
DONOVAN: There you go. Once again, if you guys can’t find them, feel free to contact us, we’ll be glad to point you their way, and thanks for listening to the podcast!
BOB: Thanks for having me.
MITCH: Thanks for listening to the Dusty Jobs podcast. Breathe better, work safer.