Why Qualifications Matter When Performing a Dust Hazards Analysis
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 the requirement to perform a DHA, they misunderstand the complexities that comprise an effective DHA. These misunderstandings are carried over to the purchasing decision, which causes many facilities to not know or underestimate what they are paying for in terms of safety and quality. In this case, cost deters qualified individuals from performing DHAs. Many facilities assume all DHAs are created equal and believe they are comparing "apples to apples" when it comes to individual qualifications and other aspects of the DHA. This only perpetuates the myth that the cost of a DHA and an individual’s qualifications are unrelated. The adage of "you get what you pay for" could never be truer because the largest influence on the quality and outcome of a DHA is the individual performing the DHA.
To make purchasing decisions based on the cost of the initial analysis without considering the individual's qualifications often produces the opposite cost/benefit outcome than what is expected. Determining QualificationsIt is important to know the qualifications, reputation, and experience of the outside vendor or individual who performs the DHA. Although determining the qualifications of an individual is relatively simple, it is frequently not performed and taken for granted. Frequently, facilities improperly rely on an individual's word or reputation. Relying on this unverified information is dangerous and circumvents the necessity of the qualified person.
Prior to performing a DHA, the facility should establish a system to verify the qualifications of whoever will perform or lead the DHA. Currently, NFPA 652 and all industry- or commodity-specific NFPA standards are silent as to how this determination should be made. However, thorough vetting of individuals or vendors offering to perform DHAs should consist of the following information submittals: Verify employment. Obtain documentation of the individual's job title, responsibilities, length of employment, and other pertinent information. While this may seem arbitrary, many outside entities will contract the DHA to a unvetted third-party consultant and present that their company performed the DHA. Many of these third-party consultants are unqualified to perform DHAs and inconsistently assess and document potential combustible dust hazards.
Check documentation. Obtain the resume and other applicable information (e.g., published articles, copies of certifications, etc.) to gauge the individual's specific activities, accomplishments, and experience that qualifies him to perform a comprehensive and accurate DHA. All of this information should be verified, because individuals frequently misstate their experience and accomplishments.
Establish the plan. Understand what actions the individual will perform while conducting the DHA. The process equipment analysis, fire and explosion hazard scenario identification, ignition source identification, inspection and maintenance deficiencies, housekeeping effectiveness, and operating procedures are some but not all of the items that should be examined within the DHA.
Contact references. Obtain and contact several references, preferably at least one in a similar industry, to shed light on not only how the individual previously assessed and mitigated combustible dust hazards, but also the overall structure and quality of the DHA. At a minimum, at least two references should be contacted.
Obtain a sample DHA report. Obtain and review one or more reports from previous DHAs performed or lead by the selected entity or individual to assess how the information gathered during the DHA will be presented. The thoroughness and quality of the DHA, as well as the effectiveness of the hazard mitigation strategies, also should be compared with competing entities. The above information is required to perform a cost benefit analysis and make the best decision regarding which individual has the qualifications to perform a DHA. Without this information, there is no way to assess an individual's experience, reputation, or qualifications to perform the complex analysis necessary to mitigate combustible dust hazards. Failure to provide any of the above information should be taken as a definitive sign to begin to question the individual’s expertise and experience in assessing and mitigating combustible dust hazards. Conclusion
The individual selected to perform or lead the DHA must be experienced with the process equipment affected by combustible dust hazards. He must have a working understanding of the intent of the numerous combustible dust standards and be able to recognize solutions that fit the facility's needs. This expertise and experience that comprise an individual's qualifications are gained from years of work assessing and mitigating distinct hazards and are not gained by simply reading or studying standards.
What constitutes a qualified person is at best misunderstood and at worst ignored. This lack of understanding and the scarcity of qualified individuals introduces a significant bias into the decision-making process of who will perform the DHA. Thus, many facilities forgo the proper research and instead rely on blind faith when evaluating and choosing a qualified person for the DHA. Unfortunately, many unqualified individuals take advantage of this misplaced trust. It is vital to remember that unqualified individuals often cannot or do not wish to have their qualifications questioned. However, no one who performs any aspects of a DHA should consider himself above being evaluated.
Employee safety should always be the primary focus of any DHA. However, safety often gets lost when cost and other factors are added to the decision-making process. Cost should never be used as the sole factor in selecting an individual to perform a DHA. Rather, one should focus on the totality of expertise and the numerous benefits that an effective DHA can provide. When performed correctly by a qualified individual, the benefits far outweigh the costs of a DHA. However, this is only possible if the facility takes the necessary time and steps to truly verify that the individual possesses the required qualifications to perform the DHA.
References
1. Industry- or commodity-specific standards include, but are not limited to, NFPA 61, NFPA 484, NFPA 654, and NFPA 664.2. Examples of other AHJs are insurance carriers, fire marshals, and building code officials.
Bibliography
1. NFPA 652, Standard on the Fundamentals of Combustible Dust, 2019 Edition, National Fire Protection Association, Quincy, MA2. NFPA 1451, Standard for a Fire and Emergency Service Vehicle Operations Training Program, 2018 Edition, National Fire Protection Association, Quincy, MA
