(70k) Ensure Compliance to NFPA Standards through Corporate Level Combustible Dust Audits

The Occupational Safety and Health Administration (OSHA) CPL 03-00-008 Combustible Dust National Emphasis Program (reissued) has been in effect since March 11, 2008. The traditional strategy of regulating only major industry sectors has long passed. Currently industries handling hazardous combustible solid particulates/fibers, including small manufacturing businesses, are subject to Instruction compliance. Industries covered by this Instruction must also comply with applicable OSHA and related National Fire Protection Association (NFPA) Standards. Managing compliance is a necessity but can sometimes be perceived as an overwhelming task. After conducting a number of corporate audits for compliance to the combustible Dust NEP, some common technical and administrative themes will be shared that could help an EH&S audit group and initiate a revision of their current protocols especially for legacy facilities and new design/construction.

Using NFPA 654 as the reference standard, audit protocol items related to facility dust hazard assessments will be presented. These include but are not limited to: dust control, ignition control, damage control, and administrative issues such as training for new and veteran affected employees and contractors, Management of Change, Process Hazard Analysis (PHA), Inspections and Preventive Maintenance, and Safety Data Sheets. Reports from individual facility findings and recommendations should follow a standard format, and allow for local management to obtain a clear understanding of the issues related to their specific site and compare findings with plants of similar technology. In legacy facilities, which were built or acquired prior to current combustible dust regulations, there are additional unique findings that are specific to industry type, age of the facility, and vendor installed equipment.

Corporate audits can be planned to identify common strengths and opportunities across the organization to allow senior management to understand the prioritized recommendations in a systematic action plan based on safety needs. A “report card” has been developed to provide an overview of a corporation’s combustible dust current program, which compares actual compliance to Instruction guidance and NFPA standards. Common field trends will be presented as well as guidance for establishing and properly maintaining engineering and administrative systems for a safer combustible dust program.