Jeramy Slaunwhite, chief technical officer, Rembe, Inc., joins Feed & Grain Chat to lend his expertise on dust hazards analyses (DHA), which are critical for preventing the risk of explosions in facilities that handle combustible particulate matter. Slaunwhite highlights key practices for conducting a DHA and recommendations for fire and explosion prevention and protection in feed and grain facilities.
Transcription of Feed & Grain Chat with Jeramy Slaunwhite, chief technical officer, Rembe, Inc.:
Elise Schafer, editor, Feed & Grain: Hi everyone, and welcome to Feed & Grain Chat. I'm your host. Elise Schafer, editor of Feed & Grain. This edition of Feed & Grain Chat is brought to you by WATT Global Media and FeedandGrain.com. FeedandGrain.com is your source for the latest news, product and equipment information for the grain handling and feed manufacturing industries.
Today, I'm joined on Zoom by Jeramy Slaunwhite, chief technical officer for Rembe, Inc. He's here to overview the requirements of a combustible dust hazards assessment and recommend some practical hazard mitigation solutions. Hi, Jeramy, thanks for joining me today.
Jeramy Slaunwhite, chief technical officer, Rembe, Inc.: Hi, thanks so much for the opportunity to be here and looking forward to having this chat for you guys.
Schafer: Absolutely, thank you for joining me. Now, what is it dust hazards analysis and why is it crucial for facilities handling combustible particulate materials?
Slaunwhite: So a dust hazards analysis, or acronymized as DHA in the industry, is a systematic review throughout a processing facility that contains combustible dust of any kind of dust related-hazards that might exist due to the actual processing or residual effects of handling combustible dust. And that came into play really relevantly in the NFPA National Fire Protection Association Standard 652, a few years back, a couple publications ago, to really bring light to these hazards so they really can't be ignored. And the element of the DHA is again, to identify not just that they exist, but where they exist, and prioritize the severity, but most importantly, make recommendations on how to manage those hazards.
Owner/operators, managers can't necessarily say, ‘Well, we've been operating for 60, 70 years and haven't had an explosion; Why should we be concerned now?’ Well, those hazards still exist, and sometimes by also knowing what you're doing right to identify the hazards and what the management structures of managing those hazards are in place, help to understand so that they don't get taken out of place and reintroduce those hazards that might otherwise be already controlled.
Schafer: Can you elaborate on the key requirements of NFPA 652, and the implications for facilities that fail to comply?
Slaunwhite: Yeah, indeed. That's always one of the questions we get is, how do I stay compliant? There's a lot of different standards and regulations floating around for different things, but yes, NFPA 652 is the current publication that guides us on combustible dust fundamentals. And the requirement is that a dust hazards analysis be performed on basically any facility that has combustible dust hazards, with also a requirement to renew or revisit it, update it every five years. As for implications, the governing body of this kind of stuff typically would be OSHA, sometimes state, local authorities, fire marshals, jurisdictions — their reach can be varied. There's not necessarily a determination by OSHA that you have to do a DHA because not doing a DHA doesn't say that there is a hazard. It just identifies that hazards exist. So, there has been one, maybe two, citations from OSHA in manufacturing facilities, not necessarily feed and grain, but just in general, for failing to do a DHA. But they had other underlying issues, as well, so the element might be, if there is an issue and OSHA becomes involved, they might ask if a DHA has been done, but they will typically draw to their own conclusions, then default to the general duty clause of protecting the employees from hazards anyway.
Where some of the other implications get into place is, if there's an event, there's always a due diligence that the owner/operator responsible ought to know or ought to protect. So, having a document that says you've been made aware of the hazards, it's kind of a double-edged sword that once you're aware of the hazards, you can't escape them. You have a duty to correct the issues because if something happens now you're on the hook for knowing that the hazards exist. If you fail to address it, then there's a negligence aspect there.
There are some specific differences for the feed, grain and agriculture industry in NFPA 61. Typically, the DHA requirement applies to new facilities or major modifications. That's one of the big differences in accordance with grain, food and agriculture. They don't necessarily directly apply to every small grain elevator that's been around for so many decades. They're trying to grasp and look at the major operations where the major risk is because the industry is so big and so broad, it would be very daunting to blanket apply it to everything, and the feed and ag industry have done a pretty good job at advocating this at the table in these NFPA technical committees to ensure their members are duly represented, but also staying safe.
Schafer: How does the standard address qualifications for who should lead and conduct the DHA?
Slaunwhite: Sometimes in qualifying a DHA provider, it does take a little bit of effort to understand what their capabilities are. As for the regulations, NFPA, what they say is that a DHA must be led by qualified persons. Unfortunately, it's not really well-defined specifically what that is. It doesn't say it has to be an engineer or a PE (Professional Engineer) or of anyone of specific credentials, but what it does recommend is that the person that's leading it should be at least number one, familiar with combustible dust, the hazards and the mitigation methods, as well as the process itself. Someone that's experienced in the chemical industry might not understand the operations of a grain processing/drying operation and what the hazards might actually be and maybe miss something or misinterpret something. So having familiarity with both the type of hazards and the type of industry are huge qualifications that are valuable in conducting that analysis.
And as a whole, another thing that's generally recommended and a general good practice in DHAs is for a DHA to be not necessarily just a one-person operation, but involve a team that includes maintenance, operations, the process team, safety team, to understand the implications, as well as history of the facility to include that data, to both understand the likelihood and the approaches for managing these hazards. If a hazard mitigation method that might be recommended is not necessarily manageable, it might not be able to do its job. So, involving everyone to get their buy-in participation is hugely critical for both the learning/understanding of the hazards and the implementation of the solutions.
Schafer: Now, one of the most important pieces of the DHA is specific recommendations to manage the identified hazards. What are some examples of effective recommendations, and how are they implemented in feed and grain facilities?
Slaunwhite: Also, very good question, and I think, as mentioned earlier, this is absolutely the critical point or purpose of the DHA is to make recommendations on how to manage these hazards. I've seen and heard of many, let's say, lackluster DHAs that basically just point to code and reference standards saying, ‘You have to be compliant with the standard or this chapter.’ It doesn't really tell the owner/operator anything on how to fix and how to change and improve. So, by number one, prioritizing — adding some sort of weight or assigning a priority or risk matrix — to qualify the hazards based on probability and severity, are a great asset to help steer and drive the urgency and especially the funding, the budget on implementing recommendations on where to start.
Now, as for some of these deficiencies and what would be recommended — if you have a hazard, you have to protect, and those hazards can come in form of fire, flash fire or explosion. So, we're looking at prevention and protection methods.
We can prevent by using a lot of different methods, like spark detection in conveyance pipes, heat sensors, temperature sensors, vibration sensors on bearings to prevent overheating, preventing some of those ignition sources. Now, that's not necessarily going to solve the problem guaranteed, so you have to look at some of the protection strategies, like explosion protection, suppression, isolation, valves, things like that, that are going to prevent that explosion, if it happens, from causing catastrophic damage, injury or getting outside of the process and leading to secondary events propagating through the facility.
So when those hazards are identified those methods of explosion protection, for example, shouldn't be as broad as, ‘You have to apply explosion protection for a dust collector filter house.’ Understanding what options make sense for that facility should be recommended in the DHA to give the owner/operator at least an option, idea of what needs to be there. So, by referencing the type of device that's called out in the standard: isolation flap valve, rotary valve, these type of devices that are generically referred to in the industry, that will work in that application.
Now, personally, I always like to understand from the maintenance team what their comfortability and capabilities are because not all systems are created equal, as well. Passive systems versus active systems have their own undertakings by way of reliability and maintenance requirements. So, understanding the appetite for the operation of the site and the expectations of the type of protection equipment is a great thing to take into consideration when those recommendations are being put in place.
Schafer: Well, Jeremy, thank you so much for sharing this information with us today.
Slaunwhite: Absolutely. I know it's a lot of information really quick and condensed, but at least it gets people floating in the right direction, and between the standards, there's a lot to understand and learn to try and keep everything safe.
Schafer: That's all for today's Feed & Grain Chat. If you'd like to see more videos like this, sign up for our YouTube channel, subscribe to the Industry Watch Daily eNewsletter, or go to FeedandGrain.com and search for videos. Thank you again for joining and we hope to see you next time.