Why Qualifications Matter When Performing a Dust Hazards Analysis

April 1, 2019

It is important to know the qualifications, reputation, and experience of the outside vendor or individual who performs the DHA.

 

The Dust Hazards Analysis (DHA) was recently created to identify and combat the potential hazards associated with combustible dusts and combustible particulate solids. For a DHA to be effective, it must analyze all of the potential fire, deflagration, and explosion hazards associated with the affected process equipment and building compartments. While this approach may seem simple, many of the factors that can contribute or be affected by these hazards are not always adequately analyzed during many DHAs.

Although all of the NFPA combustible dust standards now retroactively require a DHA to be performed, the importance of a DHA goes far beyond just a requirement. When performed correctly, a DHA not only thoroughly identifies and assesses complex combustible dust hazards, but also provides specific techniques to mitigate these hazards. Unfortunately, these serious hazards are frequently misidentified or ignored because many DHAs are performed by unqualified individuals.


The individual performing the DHA not only has the greatest effect on the quality of the DHA, but also the safety of any employees affected by these hazards. However, what constitutes a qualified individual is one of the most confusing and underestimated aspects of a DHA.
A Flawed DefinitionNFPA 652 and all of the industry- or commodity-specific NFPA standards require any DHA to be performed or led by a qualified person.1 NFPA 652-2019 defines a qualified person as a "person who, by possession of a recognized degree, certificate, professional standing, or skill, and who, by knowledge, training, and experience, has demonstrated the ability to deal with problems related to the subject matter, the work, or the project." Besides this definition, NFPA 652 sheds little light onto what qualifications are truly required to perform or lead a DHA.


The confusion caused by the simplicity of this definition is overshadowed by its inaccuracies. There are no specific degrees or certifications one can obtain to demonstrate their knowledge in assessing and mitigating various combustible dust hazards. An advanced degree, license, and/or certification (e.g., PE, CIH, CSP, CFPS, etc.) alone does not automatically qualify an individual to perform or lead a DHA. Despite assertions to the contrary, there is also no single training course or class that an individual can take to instantly become qualified to perform or lead a DHA.


Ultimately, the inaccuracies in this definition are caused by its origin. Everyone assumes that the definition for a qualified person was created when NFPA 652 was developed. In fact, NFPA 652 references this definition from NFPA 1451, which is a standard that is designed to outline the development of a fire and emergency service organization (FESO) vehicle operations training program. No one would conclude that the qualifications for performing driver training are synonymous with the qualifications for performing a DHA. However, using the same definition across multiple standards reduces the importance of the term itself and more importantly implies that the required qualifications are trivial and meaningless.

While NFPA 652 tries to define the essence of being qualified in simplistic terms, what makes an individual qualified to perform or lead a DHA is much more difficult than the definition implies. All too often, individuals examine this flawed definition and incorrectly assess their own abilities and expertise to perform or lead a DHA. These inexperienced and unqualified individuals perform DHAs that do not adequately identify and address all potential combustible dust hazards associated with process equipment and building compartments. The conclusions reached during these "DHAs" may create additional hazards and provide a false sense of security that the fire, deflagration, or explosion hazards are effectively identified and mitigated, when in fact they are not.


Who is Qualified?While some prescriptive requirements exist, most of the requirements that comprise the DHA methodology and documentation are arbitrary and left to interpretation. The combination of these performance-based requirements and the flawed definition of a qualified person lead many individuals to incorrectly believe they are qualified to perform DHAs.


While the fire, deflagration, and explosion hazards posed by combustible dusts primarily fall under the umbrella of EHS and engineering, these hazards are much more complex than they appear. Simply being an EHS professional or engineer does not necessarily mean one has the necessary skills and unique knowledge to perform a DHA. The complexities associated with analyzing the potential combustible dust hazards in processes, equipment, and building compartments demand specialized expertise. The skills, knowledge, and other factors that comprise this expertise cannot be easily learned in a short duration or by merely observing a DHA.


So the real question is, who is qualified to perform or lead a DHA? Unfortunately, the answer to this simple question is extremely convoluted. NFPA 652 suggests that the qualified person who performs or leads the DHA should be "familiar with conducting a DHA and with the hazards of combustible dusts." However, this statement is overly broad and underestimates how much an individual's expertise can affect the overall quality and outcome of a DHA.


Someone who is truly qualified to perform or lead a DHA simultaneously has intimate knowledge of a wide range of dust handling processes, as well as specialized knowledge of the complex hazards associated with the various types of combustible dusts. This individual has not only performed all of the aspects of several DHAs associated with the affected industry or type of combustible dust, but also has honed his or her expertise by examining and mitigating a variety of fire, deflagration, and explosion scenarios over several months or years.

The rarity of individuals who possess these qualifications cannot be understated. To their detriment, many facilities assume that OSHA and other Authorities Having Jurisdiction (AHJs) possess these qualifications.2 AHJs often walk by numerous combustible dust hazards, many of which are in plain sight, because they lack the knowledge and due diligence to identify these hazards. This leads to statements like "OSHA never cited me" or "our insurance never said anything." Believing these statements and trusting unqualified AHJs can not only downgrade the existence and significance of the serious hazards posed by combustible dusts, but also exacerbate these hazards and potentially cause an incident.


When to Use Outside ResourcesConfidence in one's ability to assess and mitigate safety and health hazards is a necessity for an individual tasked with reducing risk. However, confidence alone is neither a justification nor a qualification for evaluating the serious hazards posed by combustible dusts. It is incumbent on the individuals who are employed at the facilities where these combustible dust hazards emanate to fully acknowledge when they are not qualified by education or experience to undertake a DHA. Failure to do so could cause serious fire and explosion hazards to be misidentified, unmitigated, or, worse, both.

Any individual who questions or debates his own qualifications is not qualified to perform or lead a DHA. Recognizing the limitations of one's ability is a mark of professionalism, underscored in the Code of Ethics of many professional certifying organizations. This must not be dismissed when factors such as a need to demonstrate individual value to the organization, reservations about outside entities (third parties), and overconfidence begin to influence the decision-making process.


Evaluating combustible dust hazards and conducting a DHA is a resource-intensive process. When attempted in house, a DHA redirects facility personnel away from running the business for several weeks, resulting in frustration and acknowledgement that outside resources are required to adequately address the combustible dust hazards.


Once facilities make this fateful decision, they are forced to turn to consultants, engineers, and other outside entities to perform the DHA. While it seems like this may alleviate the problem, the combustible dust expertise advertised by many of these outside entities is frequently comprised of mistruths and inaccuracies. The worst mistake a facility can make is trusting this unverified "expertise" and assuming all DHAs are created equal.


Cost vs. QualificationsWhat is the value of a comprehensive and effective DHA? Does the value rely on its cost or its content, and what affects the cost and content? The answers to these questions are dependent on the qualifications of the individual who performs the DHA.
Cost is the most misused and least understood deciding factor for undertaking a DHA and indirectly evaluating an individual’s qualifications. While most facilities understand t