Common Challenges in Applying the NFPA 652 Standard
Whether you are the Health & Safety Manager or Site Supervisor, when your boss or the local Fire Marshall asks you if you’re site is compliant with NFPA 652, do you know what your answer is? Below we will go through four of the common challenges that organizations face in the application of NFPA 652.
Table of Contents
What is NFPA 652?
NFPA 652 comes from the National Fire Protection Association and is the standard on the Fundamentals of Combustible Dust. To know if NFPA 652 is applicable to your organization, you need to first be able to identify if it is a hazard. To do this, you need to refer to chapter five in the standard. Here, it asks if you have potential combustible dust, and if you know what the combustibility of that material is?
How to Identify the Combustibility of a Material
There are a number of ways that you can test the materials for combustibility. These include:
– The go-no-go screening test methodology (ASTM E1226 provides more information)
– The standard test method for minimum explosible concentration of combustible dust (refer to ASTM E1515)
– Any other equivalent test methodology.
If you are going to use a go-no-go screening test methodology, it’s important to make sure that you use a material that represents the ‘worst-case scenario’. What this will do is ensure that you don’t get a false negative result. A false-negative result is where you test negative from the go-no-go screening test, but only because the material tested was not the worst material on site (isn’t as dry or small in particle size). To ensure that you are getting an accurate response, always ensure that you are selecting a material from areas like your dust collection system or a fugitive dust at the facility.
What is involved in a Dust Hazard Analysis? (DHA)
A DHA or Dust Hazard Analysis is a requirement from the National Fire Protection Association to review a facility to identify and evaluate the risk of explosion hazards associated with combustible dust. The score of a DHA is covered in Section 4.2.4 of NFPA 652, but the steps involved remain open to interpretation. Generally speaking, the facility managers are to act in accordance with Chapters 5,7,9 & 8 and any material-specific standards.
Therefore, it’s important to make sure you familiarise yourself with the standards and the relevant responsibilities prior to getting quotes for works.
How to complete a DHA?
Firstly, if you or a staff member will be completing a DHA internally it’s important to make sure that they are sufficiently trained and knowledgeable on the relevant standards, techniques and competencies. Not only this, but they should have hands-on experience completing a DHA or leading a DHA team. You can always get an external consultant to come and review any site audits to ensure competency, however it’s also important to note possible impartiality issues, time restraints and costs. An alternative solution to doing all of this yourself is to hire a DHA Consultant.
Hiring a DHA Consultant
An effective DHA Consultant should have a broad knowledge and understanding of combustible dust hazards, as well as specific industry processes and systems. They should also be able to demonstrate their experience in performing DHAs.
The last thing before deciding on your DHA Consultant, is to ensure that you know what is included in their analysis. Will they be providing a risk-ranking? Or will they be supporting during implementation period or provide an implementation plan? These types of questions are always answered best up front to avoid any confusion or misaligned expectations.
It’s important to be proactive in your compliance with NFPA 652 and clearly understand the responsibilities and requirements involved. If undertaking the reviews of standards, analyses and implementation is beyond the scope of your expertise or you simply want the assistance of an expert, hiring a DHA Consultant or having an external provider review your analysis is a great way to assist you in meeting the standards.