Conducting PHAs on Combustible Dust Processes

Process hazard analyses (PHAs) have been conducted on chemical processes for decades. Now PHAs are being conducted on combustible dust handling processes to meet several industry standards, such as NFPA 654 and 664. Although many of the same analysis techniques can be applied, conducting effective PHAs for combustible dust processes requires some differences in approach. Due to the prescriptive nature of most of the safeguards for combustible dust handling, a Checklist methodology is far more suitable for these processes than a traditional Hazard and Operability (HAZOP) methodology. Additionally, the hazards and concerns associated with handling combustible dusts may not be as well understood. Time may need to be allotted to discuss the potential hazards.

This presentation will present suggestions for leading combustible dust PHAs based on our experience with a variety of industries. It will also discuss the type of information that should be gathered before the PHA team is assembled.

PHAs have been required for processes covered by OSHA’s Process Safety Management (PSM) and EPA’s Risk Management Plan (RMP) regulations for many years. These regulations don’t cover combustible dusts and OSHA doesn’t currently have a standard for combustible dust handling. Instead, combustible dust safety is currently addressed by a variety of standards and publications. Some of the key references for combustible dust safety are included in the list below:

  • NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities
  • NFPA 484, Standard for Combustible Metals
  • NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities
  • NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids
  • OSHA Combustible Dust National Emphasis Program (Reissued)
  • OSHA Safety and Health Information Bulletin, Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions
  • CCPS’s Guidelines for Safe Handling of Powders and Bulk Solids
  • Various FM Global Data Sheets

The main reference standards that OSHA defers to when conducting inspections are the NFPA standards listed above.

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