Wherever combustible dust accumulates, catastrophe is possible. That possibility became a tragic reality in February 2008, when an explosion in a Georgia sugar refinery killed 14 people and injured another 36. Since then, food producers have become increasingly aware of the safety issues related to dust accumulation, but without a proactive and compliant strategy for managing day-to-day dangers, workers could still be at risk.
For example, many dairy facilities rely on decades-old equipment, built when clouds of combustible dust were an accepted norm. That equipment might have electrical components that aren’t properly sealed or grounded according to modern standards — or it might generate high heat, creating a potential source of ignition.
When that source comes into contact with powders small enough to hang in the air, those powders can explode. This is likely what happened in Georgia, where investigators believe an overheated bearing ignited the dust suspended inside an enclosed conveyor belt.
The volume and variety of these dust-related risks recently prompted regulators to update their requirements. Owners must now undertake a thorough review of potential hazards in all dust environments inside their plant, culminating in a report that meets the standards established by the National Fire Protection Association (NFPA).
OSHA ties compliance to NFPA standards
Just a few months before the incident in Georgia, the Occupational Safety and Health Administration (OSHA) launched a National Emphasis Program (NEP) focused on combustible dust hazards. That program gained momentum after the sugar refinery explosions, and while OSHA has yet to issue its own standard on combustible dust, it empowered inspectors to cite plant operators for dust-related hazards under its General Duty Clause.
The General Duty Clause compels employers to provide a workplace free from the risk of death or serious physical harm. This clause encompasses everything from how an employer communicates hazards to how it maintains its facility’s electrical systems.
To ground this broad requirement in some specificity, OSHA encourages inspectors to rely on the standards issued by other authorities such as the NFPA, which offers several standards relating specifically to managing dust hazards. The best place to start is NFPA 652, “Standard on the Fundamentals of Combustible Dust.”
The recent changes I mentioned above are laid out in NFPA 652. Beginning in September 2020, that standard requires plant owners to complete and maintain a dust hazard analysis (DHA) for every new and existing facility, and to update that DHA every five years. Owners must also review any new equipment installed between DHA updates.
Because OSHA inspectors routinely turn to NFPA 652 when assessing compliance under the General Duty Clause, all dairy plant owners should complete a DHA to avoid an OSHA citation. The DHA can also help owners satisfy their local building codes, which often require a similar risk assessment exercise.
Seek expert advice to complete your Dust Hazard Analysis
It takes particular knowledge and experience to lead an in-depth assessment of combustible dust risks and translate that assessment into a thorough and compliant report.
Some plant owners will find this specialized knowledge in-house. Others should consider outside consultation to ensure not only compliance with regulatory requirements, but also safety for all those who come to work every day in the dairy manufacturing industry. By closely following the regulatory guidelines, our industry can ensure that a catastrophe like the one in Georgia never happens again.
