The Importance of Language in a Dust Hazard Assessment

It all really comes down to the two words shall and should.

Diane Cave, Regional manager of Eastern Canada, Element6 Solutions

June 24, 2024

3 Min Read
Diane Cave
Diane Cave, regional manager of Eastern Canada, Element6 SolutionsElement6 Solutions

In every aspect of life--business or personal--language defines us. It is how we get information from our heads out into the world for others to understand. If we don’t do a good job in defining our thoughts, the receiver of our information will not fully understand what we are trying to tell them. This is what happens all too often with Combustible Dust Hazards Assessment (DHA) reports.

Frequently the recipient of a DHA looks at the report and all they see is a pile of paper, meaningless words, a lot of technical jargon, and references to codes and standards. They want to know what to do next but can’t decipher it from the report.

We, the DHA report writers, often forget that the people reading these reports aren’t experts in combustible dust; often they do have a good base knowledge, but not always. The people reading the reports are experts in milling/moving grain, making cookies, tires, paint, or a million other things, but they aren’t experts in combustible dust hazards, because if they were, they’d be completing the DHA themselves. When we the writers are putting pen to paper, we must keep this in mind.

I want to be clear that the objective of the DHA is not to fix the identified problems, but to inform the reader of the current hazards and risk, ultimately where the really bad things are lurking. Our goal to the reader is to identify the hazards, communicate where the highest risks are, and provide rough idea on what actions are required to mitigate the risk. The report doesn't solve all the combustible dust hazard issues. It guides the diligent reader on how to address these problems, where to start, and ultimately making the facility progressively safer. To do this the reader needs to know what actions are required and what is suggested (recommended).

Requirements versus recommendation are outlined in the National Fire Protection Association (NFPA) standards. Really it comes down to the two words: shall and should. The beginning of each NFPA volume lists the definition of shall and should. Shall indicates a mandatory requirement and should indicates a recommendation or that which is advised but not required. This seems clear as to what is required and what is recommended, so why are the readers of DHA reports having such a tough time understanding next steps, locations of hazards, and/or amount of risk from the DHA report? It is the duty of the author to be concise for their reader.

DHA reports are historically littered with soft, non-direct language: might consider, would be a good idea if, should look into--you get the point. To drive this point home, let’s look at an example of a dust collector lacking a method of explosion inlet isolation. The report needs to have specific language. Something like “inlet isolation is not currently installed, it is required; a method of explosion inlet isolation must be installed.” We do a disservice to the reader when we use soft, non-concise language like “the installation of inlet isolation should be considered.” The reader looks at the report, checks the cost, the pain it’s going to be to install a method of inlet isolation, and all necessary things associated with the inlet isolation. They’ve considered it. They consider it to be too much money or will create too many headaches and ultimately, it’s not done. But they considered it as written in the DHA report; item closed! You can’t really fault the reader of the DHA report; they have done what the author wrote: considered it.

When it comes to language in reports, remember the reader isn’t the expert, the author is. Authors must inform the reader what they need to do according to codes and standards. Be concise. If something must be done, use the words must, don’t recommend it, or consider it. Use wording like must, required, obligated, and required. No single word has relegated more projects to the intellectual scrap heap than “should.” It’s time we send the “considers, think abouts, and might be a good ideas” to the scrap heap.

Diane Cave is regional manager of Eastern Canada, Element6 Solutions.

About the Author(s)

Diane Cave

Regional manager of Eastern Canada, Element6 Solutions

Diane is a registered professional engineer in Nova Scotia and Ontario, Canada. She is currently the engineering manager at EPM Consulting in Halifax, Canada.  She has worked extensively in the fields of dust collection, combustible dust protection, NFPA compliance and material handling systems.  She has experience in the fields of pulp and paper, salt and minerals, metals, animal food processing, fume collection, waste water treatment, woodworking, wood processing, rubber manufacturing and tire building. Diane has spent the majority of her career as a design engineer exclusively in the area of dust collection systems, which involved extensive site troubleshooting and system analysis.  Diane specializes in retrofitting existing dust collection systems to bring them up to current standards and codes as well as improving system performance. She has been independently and jointly involved in the preparation and delivery of various training modules and programs, some of which were part of Dalhousie University Continuing Education.

Click here to Ask This Expert a Question and view more Q&As.

Sign up for the Powder & Bulk Solids Weekly newsletter.

You May Also Like