Combustible Dust Regulatory & Consensus Standards

June 26, 2015

5 Min Read
Combustible Dust Regulatory & Consensus Standards

By Kevin Jeffries, Lewellyn Technology

When making a commitment to mitigate combustible dust fire and explosion hazards in your operation, it is extremely important to identify all applicable regulatory and consensus standards applicable to your operation. This can be a daunting if you are not sure where to start. This article will highlight several regulatory and consensus standards EHS and engineering professionals should consults when developing a comprehensive combustible dust risk mitigation plan.
    
Most EHS and engineering professionals consult safety standards established by the Occupational Safety & Health Administration (OSHA, 29 CFR 1910 or 29 CFR 1926) when attempting to create a safe work environment. OSHA does not have a single, comprehensive combustible dust standard at this time. In light of a standard, OSHA issued the Combustible Dust National Emphasis Program (NEP) first in October 2007, then reissued in March of 2008. The NEP provides guidance to employers and OSHA inspectors on the wide range of requirements and solutions needed to mitigate combustible dust hazards. Under the NEP, OSHA has conducted well over 3000 inspections, citing employers for violations of existing OSHA standards applicable to combustible fire and explosion risk mitigation such as HazCom (29 CFR 1910.1200), Fire Prevention Plans (29 CFR 1910.39), Housekeeping (29 CFR 1910.22), and Hazardous Locations (29 CFR 1910.307). You will find a full list of applicable, existing OSHA standards that address combustible dust safety in the NEP for Combustible Dusts. A federal dust standard is most likely not on the horizon for the near future. A vital step in establishing a comprehensive standard has been delayed until 2016. This is the sixth delay in the rule making process since April 2011.
    
Your state and local fire authorities also have standards and regulations your operations should consult and comply with to mitigate dust hazards. It is important to identify which fire code your state adopts: NFPA 1 (Uniform Fire Code) or the International Fire Code. Chapters 40 and 60 of NFPA 1 outline specific requirements for dust handlers and processors. Chapter 13 of the 2009 version of the International Fire Code and Chapter 22 of the 2012 Code address combustible dust. Your state and local fire authorities may also exercise the provisions in both fire codes that require dust handlers and producers to permit operations prior to start up. If you process or handle combustible dusts in the state of Georgia, you are required to comply with 120-3-24-05 “Rules & Regulations for Loss Prevention Due to Combustible Dust Explosions & Fires.” This standard developed by the state fire marshal is one of the most comprehensive standards in the U.S. Dust handlers and producers are required to sign an annual affidavit of compliance and register with the state fire marshal’s office each year.
    
Consensus standards written by the National Fire Protection Association (NFPA) are another important resource EHS and engineering professional should consult when addressing dust hazards. The step is identifying the NFPA standard(s) applicable to your industry. NFPA 61 for agricultural and food processing, NFPA 484 for metals processes, NFPA 664 for wood processing and woodworking, and NFPA 654 a comprehensive standard that address hazards associated with other dust processes such as paper, plastic, rubber, etc. After consulting industry or process specific standards, EHS and engineering professionals should consult standards such as NFPA 68 for explosion venting solutions, NFPA 69 for deflagration prevention systems, NFPA 499 for electrical classification requirements, and NFPA 101 for life safety considerations. The NFPA will issue NFPA 652 this year. This standard will act as a comprehensive “gateway” standard in that it provides guidance and recommendations for dust hazard mitigation for all industries, all applications in practical terms. NFPA 652 will outline requirements for dust testing, hazard analysis, and sustaining performance. A copy of the proposed standard is available at www.nfpa.org.
    
There are several international regulations that address dust hazard mitigation. In Canada, Part II of the Canada Labour Code, Part X of the Canadian Occupational Health & Safety Regulations, and the Workplace Hazardous Materials Information System (WHMIS – 2015) are your “go to” resources. Several NFPA consensus standards are also incorporated and referenced in Canadian standards.
    
If you have operations in the European Union, you will want to consult ATEX Directive 99/92/EC (ATEX 137 – The Workplace Directive) and ATEX Directive 94/9/EC (ATEX 95 – The Equipment Directive). ATEX standards are more restrictive in some instances than any establish U.S. consensus standards. Some organizations mistakenly believe that meeting U.S. standards will adequately address hazard mitigation requirements associated with their global operations.
    
The International Electrotechnical Commission (IEC) established two standards widely integrated in global standards in other countries. IECEx 60079 – Protection Requirements for Equipment & Systems and IECEx 61241 – Electrical Apparatus Requirements provide guidance on dust mitigation techniques in areas such as building construction, equipment protection, and electrical protection. It is not unheard of for the Ministry of Labour in a given country to develop a hybrid standard based on NFPA, IEC, and ATEX standards.
    
The journey of a thousand miles begins with the first step. For EHS and engineering professionals, one of the first steps is identifying codes, standards, and regulations that establish requirements for their process.  
   
Kevin Jeffries is VP - combustible dust consultant, Lewellyn Technology. Jeffries brings more than 17 years of industry experience in EHS systems development & implementation, specializing in combustible dust fire and explosion prevention, hazard evaluation, contingency planning, EHS culture development, and the development and implementation of written corporate compliance programs. Prior to his time as a combustible dust consultant with Lewellyn Technology, Jeffries was a senior EHS manager for the Kellogg Co., and corporate safety systems manager for Imperial Sugar after the company’s 2008 combustible dust explosion.

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