The Complete Guide to Dust Hazard Analysis (DHA) for Manufacturing Facilities

Combustible dust poses potential hazards and regulatory compliance issues in manufacturing facilities across various industries. A facility manager or business owner must ensure a safe working environment. Every facility is different, though, and there are significant dust risks that you need to know about your facility to protect yourself, your employees, and your facility as a whole. Conducting a Dust Hazard Analysis (DHA) is essential in identifying and mitigating combustible dust hazards.

Of course, like several technical reports, it may not be the most easy to translate into layperson’s terms. (And being a dust expert as well as a facility expert is unrealistic to ask of anyone.) That’s why we’re breaking it down to ensure you know what to expect and how to translate the analysis so you can turn words into actionable steps to protect your company.

Understanding Combustible Dust Hazards

Before we get into the details of what you can expect in your DHA, you may need a small reminder about the dangers of combustible dust. Some types of dust are combustible, meaning that when it accumulates, it’s a significant danger to your facility and employees. Even when it is not combustible, though, when built up, it can still be flammable. Other types of dust, however, are neither flammable nor combustible. That’s why it’s so important to conduct your facility’s DHA. You must first determine your risk in day-to-day production and plan for mitigation methods.

What Is Included in a Dust Hazard Analysis (DHA)?

A Dust Hazard Analysis (DHA) is a fundamental step in safeguarding manufacturing facilities from potential dust-related hazards. It identifies specific combustible dust hazards within a factory and develops strategies to mitigate them. 

One disclaimer before we continue, though. While all DHAs have the same goal, to provide a thorough analysis of your facility’s dust and have mostly the same methods, some of the analyses will vary based on who implements the DHA. After all, the 2019 version of NFPA 652 offers in Annex B an example but not a template. There is no standardized form on how DHAs must be completed. They are to document each individual dust hazard and how it is currently being managed, as well as potential solutions. Each dust-related hazard is to be classified within the documentation as one of three general categories:

• Not a hazard
• Might be a hazard
• Deflagration hazard

As long as the DHA details dust hazards thoroughly, your local governing agency’s template may vary drastically from another’s. As you will see, we have used the DEKRA Combustible Dust Hazard Analysis (DHA) for The Golden Aluminum, Fort Lupton, CO Facility as an example throughout this guide.

(As a reminder, the NFPA is merging several combustible dust standards to form a “single source of truth” on combustible dust in its pending NFPA 660. You can read more about that on our blog, The New NFPA Standard 660: What is it and How Will it Affect YOUR Facility?)

Below, we dig into the sections of the DHA we see most often across facilities, industries, and municipalities. Hopefully, there will be enough to help you understand common sections, what your DHA will be interested in, and how it may look.

Project Details

The project details include important information such as the revision history, contact details of key personnel, and the scope of the analysis. This information is crucial to understanding the DHA’s context and establishing credibility.

Executive Summary

Before diving into the details of the analysis, it will often start with an executive summary that highlights the main findings and recommendations. This provides readers with a high-level overview of what to expect from the rest of the article and lets them grasp the significance of the analysis immediately.

Often, it will also include an introduction before or after this section that details what you may already know: how dust is combustible, what it will require to combust, and what kind of risk it presents to your facility. You may also see some information about OSHA regulations and NFPA standards here. 

Flammability Data

The DHA should detail the flammability data obtained for the dust generated at the facility. This data includes properties such as maximum explosion pressure, minimum ignition energy, minimum explosible concentration, and more. By presenting this information, readers can better understand the nature and severity of the potential hazards associated with these dusts.

Overview of the Facility

Here, the DHA details the specific facility more closely. It provides a general overview of the facility, including its processes, layout, and materials handled. This section should familiarize readers with the specific operations being analyzed and lay the foundation for the subsequent sections.

Dust Hazard Analysis (DHA)

This is the heart of the article—a detailed analysis of the dust hazards present in your facility’s various processes. We’ll examine each process individually, discussing the specific areas of concern and providing recommendations to mitigate risks. In this section of the DHA, you’ll see photographs that act as evidence of the DHA findings. (See picture below.)

General Recommendations for Hot Work, Fire Protection, and Control of Ignition Sources

In this section, the DHA outlines general recommendations applicable to hot work, fire protection, and control of ignition sources. These recommendations are crucial to prevent and minimize the risk of fires and explosions throughout the facility. Topics may include safe hot work practices, adequate fire protection systems, and control measures for potential ignition sources.

General Housekeeping and Hazardous Area (Electrical) Classification

Proper housekeeping and hazardous area classification are critical components of ensuring a facility’s safety. Here, the DHA may make general statements about practical housekeeping, emphasizing the importance of regular inspections and adherence to relevant codes and standards. It may continue to explore the guidelines for proper hazardous area classification to prevent the occurrence of ignition events in potentially explosive atmospheres.

NFPA Requirements for Equipment

This section builds on the last by addressing the specific requirements outlined by the NFPA regarding equipment used in combustible dust environments. It will focus on topics such as explosion protection, explosion isolation, and other safeguards recommended by the NFPA to ensure safe operation.

Conclusions

This section will summarize the analysis concisely, highlighting the most critical points discovered during the assessment and emphasizing the implementation of the recommended actions and controls.

Summary of Recommendations

Finally, the DHA will provide facility managers with a comprehensive list of all the recommendations made throughout the article. This allows them to quickly reference the suggested actions while planning and implementing changes within their facilities.

By following the recommendations within the DHA, the facility can significantly reduce the risk of fires and explosions, fostering a safer working environment for employees and visitors alike.

Do you know Who’s in Charge of the DHA at Your Facility?

Conducting a Dust Hazard Analysis

Understanding the Process

Conducting a thorough DHA requires expertise and meticulous attention to detail. While some organizations attempt to perform this analysis internally, partnering with a reputable company specializing in dust hazard analysis, like DEKRA, ensures the utmost accuracy and compliance. Local governing agencies may have specialists who would be best suited, especially if using such an agency will contribute to your community’s overall view of your facility.

During the analysis, experts will evaluate your entire facility, examining each area for potential hazards related to combustible dust. They will scrutinize your manufacturing processes, review equipment design, assess ventilation systems, and inspect other critical factors contributing to dust accumulation and dispersion.

It is worth noting that even if you conduct your DHA internally, you’ll very likely still need to send your dust type off for testing to receive a complete review of its combustibility.

Regular Revalidation and Management of Change

Obtaining a comprehensive DHA report is just the beginning. Adhering to regular revalidation schedules is crucial to maintain ongoing safety and regulatory compliance. While mandatory revalidation must occur every five years, remember that significant changes within your facility might necessitate additional assessments.

Managing change is a key aspect to focus on when reviewing your dust hazard analysis results. Any modifications or additions to your processes or equipment must be carefully evaluated to ensure that new risks are appropriately addressed and mitigated. A full DHA may not be needed every time you purchase new equipment, but an amendment is undoubtedly a good idea.

Evaluating Facility Hazards

A dust hazard analysis begins with evaluating your entire facility for potential sources of combustible dust and identifying equipment or processes prone to dust generation. Thorough inspections, documentation reviews, and interviews with key personnel provide the insights necessary for a comprehensive analysis. 

Because there is so much at work in properly analyzing the dust in your facility, there is all the more reason to outsource this inspection. Internal employees may simply be too close to see the big picture and how impacts may link.

Partnering with DEKRA for Compliance

Performing a thorough dust hazard analysis requires expertise and knowledge of local regulations. DEKRA, a leading organization in safety solutions, offers specialized services to assess, analyze, and create customized plans to mitigate the identified hazards. Partnering with DEKRA ensures both compliance and peace of mind.

Implementing Changes after DHA

Once the dust hazard analysis is complete, it’s essential to act upon the findings and recommendations promptly. Failure to address identified risks could result in catastrophic consequences. While the universal answer to “How long do I have to implement recommendations is “as soon as possible,” OSHA generally expects all recommendations to be implemented within a year.

Here are some crucial steps you’ll need to consider regarding the implementation of recommendations.

Mandatory Revalidation and Continuous Monitoring

Although a DHA revalidation is mandatory every five years, continuous monitoring is equally critical to maintaining a safe working environment. Don’t wait until the next revalidation to implement necessary changes; instead, establish protocols to evaluate and update your control measures regularly.

Managing Change Effectively

Changes within your facility, whether related to operations, equipment, or materials used, should prompt a thorough reassessment of your DHA. Utilize Management of Change (MOC) procedures to ensure all modifications align with safety standards and do not introduce new risks inadvertently.

Ensuring Facility Safety with DHA (and SonicAire Fans)

Prioritizing the safety of your manufacturing facility involves understanding and mitigating combustible dust hazards. Dust Hazard Analysis (DHA) plays a pivotal role in identifying potential risks, classifying hazards, and establishing appropriate control measures. By conducting regular DHAs and implementing recommended changes, you create a safer work environment for everyone involved.

Once you have your DHA, you’ll know exactly how serious the hazards in your facility are and just how important it is to be proactive in your response. SonicAire dust control fans are specifically designed to tackle this issue, ensuring a safer and cleaner workspace. By reducing dust accumulation, our fans help facilities comply with safety regulations and standards related to combustible dust. This protects employees and reduces the risk of costly fines and operational interruptions.

Ready to protect your facility from the dangers of combustible dust? Discover how SonicAire dust control fans can transform your workplace into a safer and cleaner environment. Contact us today for a free consultation and see the difference effective dust control can make. Don’t wait—ensure the safety and efficiency of your operations now!