TLDR: DEKRA’s Kevin Jeffries outlines the essential pathway for combustible dust management: first test dust combustibility (go/no-go test), then conduct a Dust Hazard Analysis examining fuel, ignition sources, dispersion potential, and confinement. Solutions range from simple procedural changes to engineered controls, emphasizing safe, sustainable, and affordable approaches.
Key Points:
• Start with go/no-go combustibility testing
• DHA examines: fuel, ignition sources, dispersion, confinement, oxygen
• Kst and P-max values critical for sizing explosion protection
• Solutions range from procedural changes to capital investments
• Revalidation required every 5 years per NFPA standards
Transcript:
All right. Hello, and welcome. My name is Jordan Newton with SonicAire and today I’m excited to be talking with Kevin Jeffries. So, Kevin is an environmental, health, and safety professional with 26 years of combined industry and consulting experience, he has worked with hazardous materials, including combustible dust for most of his career. And Kevin currently works for DEKRA Services, Inc, as a technical lead process safety for DEKRA North America and he’s a certified fire protection specialist and certified fire and explosion investigator as well. Kevin, welcome. Thanks for joining us today. Thank you, Jordan, good to be with you. So can you tell me a little bit about being a technical lead and what’s involved with that, and what you actually do is that technically,
the primary function is to help the North American Division of DEKRA process safety, develop kind of a centerline approach to our dust hazard analyses, our process hazard analysis, all of our offerings, that, that our clients want to make sure that they are technically sound, that our recommendations are both safe and practical. Also, as technical lead, looking for new offerings and services based on kind of a concept that we use. We want to kind of understand what markets, what potential regulations are coming in the future, and kind of get ahead of the curve and create offerings for clients. And you don’t even know that you have that need yet. So, we’re trying to stay ahead of the safety and risk curve and create solutions for you long term.
I like that. That’s, that’s fantastic. Okay, so I know you’re on the road today. Tell me a little bit about where you are and what’s going on.
This week, I’m at the NFPA Conference and Expo had the honor of speaking. The topic was ignition sources, primarily static energy, and ways to mitigate it. The NFPA conference is one of the better conferences on the market right now in terms of fire and risk prevention. So, the ASSP is a great one for your basic general safety. But there’s NFPA conference, if you’re really looking for kind of cutting-edge technology and solutions and thought leadership on Dust hazard mitigation, fire mitigation, I just wanted to better conferences. Excellent.
Excellent. All right. So um, I’m really exciting. Glad to be talking to you today because I had a friend and kind of a colleague ask me recently his name’s Matt, Matt owns a, you know, family business – has been around for probably 50 years. And they do foam and rubber converting and cutting and they punch holes in foam and things like that. And it makes a little bit of dust, it doesn’t make a ton of dust, like our typical, you know, big dust producers like paper or plastics or wood products that we typically think of in food and grain where we think of the just tons of layers of dust, but he has a little bit of dust. And he’s part of the OSHA Voluntary Protection Program here in the US. And so through one of the inspections that he had recently, the inspector came in and said, hey, what are you doing about the dust, I know you’ve got this kind of an old-style collector thing. But let’s talk more about that and ways to address that and tell me what you’re doing. And so, he called me and I knew I was going to be talking to you and so I figured I would let somebody with some certainly more expertise than I have on the subject kind of elaborate and help me guide him on where to start and how to get going and you know what to even be looking for looking at
the first thing I would recommend is to collect some of the dust and have it tested. There are a couple of pathways that you can take for testing one is a simple go, no go and that will tell you whether or not the dust is actually combustible. The other testing that he’d want is specific testing for specific hazards. You’d want to know the Kst and that’s basically the strength of the explosion. With that test, you also get the p max which is the maximum pressure that during the test, the results show the highest-pressure rating that the deflagration experiences. The Kst and P max values are used in business I need protection for dust collection systems. So ideally, if there was enough dust that an OSHA inspector saw accumulation, a central dust collection system is one option. If you go with that larger central dust collection system, it will need protection, and that Kst-p max value will tell you what type of how to size the protection solution. If it’s a case of point generation, so there are points where particularly setting the drilling and maybe some of the chopping operations, where the dust is generated, there are portable collection options. The portable collection options if they’re less than eight cubic feet don’t require protection. And the primary reason that they don’t require protection is the engineering community has not found solutions that would adequately protect vessels less than eight cubic feet. There are producers on the market there are several that produce portable collection systems. So, you can use a series of smaller systems or look at the larger. But again, the first thing to do is test the dust, understand the properties, there are other test properties you may want, you want may want the minimum ignition energy, which tells you the lowest temperature at which, you know, the dust will react. The lower the MIE, the more reactive the dust. The other test helps you decide if you want to look at other solutions. So, if you need to look at some ignition control if you need to look at maybe some inerting. And for this type of dust, you’re talking about I don t think inerting would be an option. But there are other tests like limiting oxygen concentration, that’s the test that you d performed to determine if you were going to insert the environment. There’s also a minimum ignition temperature layer and cloud. So, there are a variety of tests. But the first thing to do is confirm that the dust is combustible. And then from there, decide on the mitigation pathway.
So, am I right that if he doesn’t want to go through all that he doesn’t want to do all the testing, you can treat it as combustible and then just go from there? Right?
Well, if that if he does that, here’s the danger in that is now sizing protection for a larger collector, out without data. And what happens with that is, let’s – say it is – its combustible, but it has a lower Kst value. And lower Kst value means that in terms of isolation, so if you’re protecting a collector, you have to protect the collector either with venting, and ideally, you’d put that vent, the dust collector outside because if you’re dealing with the rubber dust, the byproducts would be toxic. There are flameless vent options, but and those are if you want to store the collector inside, but the flameless vent options are limited, both in terms of melting dust, which the rubber and plastic dust would be, and even toxicity. So, in his case, we’re talking to dust collector outside vented. In order to size that vent properly, you need to know those maximum pressures and the Ksts. The other thing is with the isolation zone, the dirty inlet the air that’s going to the collector, if it comes back, that’s a lower Kst value and you use one of the mechanical isolation devices, that device could potentially be compromised with that lower Kst, we’ve seen where improper placement and sizing of those vessels for lower Kst mixture values. The isolation doesn’t react in time, and you get pressure built up as it goes through system. So, the testing is important for that protection.
Okay, that makes a lot of sense. Now you said two key terms here that I want to maybe go back and unpack this a little bit just in case somebody like my friend Matt is completely new to this space. And doesn’t understand what we’re talking about. He talked about venting and isolation. So, can you talk briefly kind of define those and what’s entailed with that and how that works?
So, with dust collection systems or protecting any vessel, you have a couple of options you can try and suppress the explosion or deflagration or you vent through a designed area, you vent the explosion forces so that would be the pressure and the fire, except with dust collection systems, you have multiple options you can suppress or you can vent, right? The suppression options, the challenge there is if you chemically suppress the system, you have to calculate the operating pressure. So that’s whatever pressures conveying the dust to the collector deflagration pressure and the pressure of discharged canisters that when you talk about pressures and pressure buildup, so we’re talking about in the event, and I say unlikely, but it probably happens more than then we’re all comfortable with.
But we’re talking about when, when a potential spark or something else or some something overheats in the system, and it’s inside the ductwork inside the collector. And now back to the Ksts and the p max you’re talking about, that’s when you’re talking about that pressure builds up, right. And we’re trying to alleviate that pressure so it doesn’t cause catastrophic damage to the building and light loss of life. And that’s,
that’s the goal. And so, if you’re using the chemical suppression option, you’ve got, you’ve got to take all those pressures into account. So that initial deflagration pressure, operating pressure, plus the suppression pressure of the canister, that’s the whole side that has to be properly calculated, because what can happen is that all of that pressure could blow the dust collector apart and then you defeat the purpose. So, the venting option, and you’ve got two options with venting, you’ve got what I call a kind of standard venting, where you’ve got a membrane or a disc, that ruptures, relieves pressure, and allows the flame and smoke and all that to escape. And then you have the flameless vents that I talked about earlier. Flameless vents, there are a couple of manufacturers who have done testing and certification to against melting dust. But there are more failures than there are, you know, success stories like I said, there are only a few manufacturers who have adequately tested against melting dust. But the flameless vent keeps the pressure still released. But the flame is contained in sort of a dust collection system inside the building. That’s an option. But it cannot be a toxic dust. In other words, the rubber in the plastic when they burn, there’s toxic smoke that comes from that. And you don’t want that inside the building. So, the option there with the standard vent, venting pressure, and everything outside the building to a safe area. Sure, sure.
All right. So, and the whole key here is when it happens, we’re doing a safe and controlled manner,
Safe and controlled manner. And here are a couple of interesting facts, so sometimes, the ignition source is actually just the conveyance of the materials. And it was one of the things I talked about the NFPA conference, you could have a low minimum ignition energy material on bulk solid, that is also insulated, which means the charge as it’s conveying, as the particles make contact and separate, that generates enough energy to actually self-ignite the material as it’s flowing through your ductwork and into your dust collector. Sometimes the pulsing of the dust collector during cleaning could cause the explosion. So, there are you know, there’s, I guess, the traditional pathway of people thinking that maybe a spark or an ember from an opening point and goes to the dust collector, that happens. But there are also instances where I say it again, in insulating dust, low MIE, just pulsing, has created issues. Now you have to have the right concentration at the right time of the energy and all that has to line up. And what happens is, it’s almost like that Russian Roulette, the recipe is there all the time. It’s just that the energy from the spark, the concentration of the cloud, they don’t match at the same time, right? They do or if they do, that’s where protection comes into play.
And it’s like I tell a lot of people when I’m talking to people who are new to the dust industry are new to the dust hazards arena. You know, we’re trained as kids to be aware of fire alarms and fire hazards and that sort of thing. And in school, if somebody you know, there’s a fire alarm, we walk in a straight, orderly line and a neat fashion down the hallway and out the door to the rally point or whatever. But there’s no time for that with a dust explosion. You know, whether it’s in a collector or out in the ambient air in your facility. It’s instantaneous. And once it happens, it’s too late the, you know, the probability and the likelihood that everything happens in that perfect storm that you’re talking about is is fairly low. But the risk of what happens in the results are just absolutely catastrophic when something like that does happen if you don’t have the proper precautions in place like you’re talking about to mitigate that and
and here’s, you know, we offer a deck or we offer two approaches to come to the dust hazard analysis. There’s a risk-based and then what we call a traditional or prescriptive DHA. And what you find is that as you dig into the dust hazard analysis, and that’s the intent, you actually find that the occurrence of each individual event may happen at a frequency that the organization is not aware of and are not comfortable with. So just like the scenario outlined before, where you could have an insulating material, particle separation creates enough energy, just simple loading the material into a sifter could cause a fire or flash fire. And the other thing that I want to say before we move forward is the NFPA standards are designed so that you’re building safeties to prevent fire, flash fire, and deflagration. So, you have to look at all three. So, where you may not have your explosion potential may be low, the fire potential may be high, your flash fire potential may be high. So, you have to look at all areas and as you said, the flash fires and the declaration events, they happen in a matter of milliseconds, right time to react. So that’s why you build in all the safeties. But until you do the deep dive analysis to understand the properties of the material, how the process runs, and how it could potentially create that perfect storm, until you know where all that is, you know, you’re operating at a point where, you know, you’re going to potentially injure people, you’re going to potentially interrupt supply chains, and no organization should be comfortable with either. And so and, you know, we’ve gone into places where, you know, the belief is that the potential for an explosion was so remote that, you know, they originally were not going to move forward with any anything, they were just like, well, it’s a combustible dust but, but once we identified just the layer accumulation and how you could have an initial flash fire, that would create a pressure wave that would, that would disturb all the secondary goals and then the resulting fireball from that flash fire, but it might that and create the secondary deflagration they saw that domino effect and understood, and the solutions that the challenge is, the solutions are not all major capital expenses. Now, you know, there are times where that’s going to be necessary. Sure. Solutions are as simple as going back to the source of generation, maybe even modifying a protocol, whether it’s changing how things are mixed, or adding Point Source dust collection, there are a lot of solutions. So, you don’t, I always tell people don’t go into this thinking that I’m going to have to spend millions and millions on a remedy. Let’s first find what the problem is. And then let’s develop practical solutions. And that’s one of the things that, you know, DEKRA we kind of pride ourselves on is we try to give you as much credit for inherent safeties in the process. We understand where you are in terms of process and business continuity and finances. So, the idea is, let’s find a solution that’s going to be safe first one that you can sustain over the lifetime of your process, and one that is cost-effective.
I like that safe, sustainable and affordable. Yeah. I think that’s a big deal. And I think those are certainly some key elements that need to be in place for any organization to adopt something or change that that’s coming their way. And they’ve got to own it and make it their own. Okay, so you touched, and you kind of went down the road of the DHA the dust hazard analysis a little bit. So is that where I should tell my friend, Matt, to start, and take a look at something like
That? Yeah, first confirm that the dust is combustible and the form that it’s generated. Once that happens in the next phase is the DHA and the DHA. We ve done complex systems where you’ve got multiple collectors, multiple areas where dust is generated to some simple systems where there’s just some wood grinding or chopping or something like that. So that DHA is designed to look at the process and look at the potential for the fuel of course because now we ve tested and confirmed it is combustible. We’ve got the fuel. We’re looking for credible ignition sources. Now the testing depending on how much testing so if we do the testing, we get the MIEs and we get the layer ignition temperatures. That also tells us where we need to focus our efforts in terms of looking at credible ignition sources. So, if the MIE is 500 or greater, Milla Joules, 500 Milli Joules or greater. That means that the material is difficult to ignite not impossible, but difficult. At that point, we’re looking at mechanical sparks from failures, we’re looking at hotspots from friction, we’re looking at surface temperatures. That’s what those are the things that we’re focused on open flames, process conditions. So one of the other things that we look at is, is there a potential for a runaway reaction that could generate heat, that could then be the source of ignition, so we look at that. Anything less than, generally, we say, if you’re in that 100 milli joules or less range, we’re going to be concerned not only with those higher ignition energies but also static. So now the bonding, the grounding, all of those things matter. So that MIE test will tell us where we need to focus. So now we’re not looking at a wide range of ignition sources, we may be able to narrow that. And then we’re looking at potential for dispersion. So, if there’s a potential for dispersion, that means that dust could stir up and get in the air, then we’re going to, you know, look at surfaces, we’re going to look at a lot of variety of ignition sources. If dispersion is not possible, or there are no credible means of dispersion, then we’re focused on fire potential. Right. Okay. And then we’ll look at confinement. So, if confinement is there, then we have the potential for the explosion, the deflagration, if confinement is not there, then we’re looking at flash fire potential, right. So
talk, talk a little bit more about confinement and what that means we’re not talking about you know, in an industrial setting, sometimes you hear the word confinement, you think confined space. So, we’re not talking about that that well pick, pick it apart a little bit
what we’re talking about in terms of confinement is at the point like, let’s say they’re drilling the components, and they were to enclose that area where they’re drilling, then that’s a confined area that if the dust is dispersed, it means credible source of ignition. The pressure can’t relieve fast enough. You have that compromise of that structure. So, confinement, just think about it anything that anywhere you’ve got a point source generation for dust if there’s anything that is covering it, so even with, like sifters, and things like that, any kind of clam shells or coverings, that’s creating a confined environment. And if you have that confined environment, and you don’t have a relief of the dust concentration – you’re now – all you need now is that credible source of ignition, and you’ve got the combustible dust Pentagon .
Sure. And this can even be as big as your four walls and the roof, right?
Yes, exactly. Yeah, exactly. And that’s what happens with the secondary explosions, which can which usually lead to more of a catastrophic loss of life. The buildings not designed to relieve that pressure. Of course, the pressure is going to escape, but it escapes through members that now cause structural failure and collapse.
Yeah. That goes back to the cant … can t run like he came with a fire alarm. The walls go out and the roof comes down. And it’s bad news very quickly. Yeah. Okay. So, under the DHA, we’re looking for fuel. We’re looking at ignition. We’re looking for dispersion. What else
Confinement.
Yep. confinement, right.
And then, of course, in most processes, the oxygen is always going to be present. But as I mentioned before, that limiting oxygen concentration test, that’s an environment where you would inert so a lot of the folks are in the 3d printing, where they’re using metal additives. That’s all done under an inert environment. Because using the laser, you’ve got the combustible metals, you’ve got all of that stuff there. But you’ve removed the oxygen. That’s the only reason why in that environment, you don’t have the explosion. But what we’re seeing now is that the subsequent dust collection, and some of the off-gassing, if that’s not properly passivated, we’ve seen that turn into fire, flash fire, and explosions as well. So the actual process is covered. But some of the dust collection creates an issue
for 3d printing a fascinating new technology that’s pretty revolutionary, but now there’s new hazards associated with that. And so we’ve got to come up with new solutions and new ways to do that safely. Yeah. I love it. That’s great. All right. So how does Matt start on a DHA journey?
So, on the journey, what you know, contact resources, preferably DEKRA to find out what their protocols are for collecting samples and sending the dust out for testing. So, you want a credible lab and accredited credible lab to do the testing. DEKRA you know, before I joined DEKRA, I was in an industry working for a variety of companies and I used DEKRA for the bulk of testing for a particular solid. So you send the material off, you get it tested, you get your report, then based on those results, now you can do, you can do two things, you can have the test pathway going, and you can kind of talk to someone and get a DHA scheduled, the way that happens is, you know, our sales team would work with him on understanding the process, the types of equipment, types of materials, put together a proposal based on the proposal, the proposal would include preparation. So that would include looking at state and local regulations as it relates to dust because one thing you have to remember with this is there’s a compliance element. And there’s a risk element, right. And the two are generally linked, but sometimes not. Sometimes, from a from a regulatory standpoint, there could be more stringent requirements in a particular area. And sometimes those requirements are based on experiences other people in the area that may have had an event. And based on that the local authority said I’m not going to allow anyone else to have more than three dust collection systems inside of a building. And again, they’re perfectly within their right to do that. And that’s usually justified based on some experience. So, what we would do is we’d examine the regulatory impact. So that’s looking at state federal local, then we dig into the process itself, looking at actual risk. And there are instances where, from a prescriptive standpoint, there are some requirements that you’d have to satisfy. But one of the things that we tried to do is look at performance-based options. So, you’ve got two pathways to correction, there’s prescriptive, where you just look at the codes and standards, and you follow them to the letter. And then there’s performance based where you, you look at calculations, you look at probabilities, you look at some of the science behind what the scenario, the credible scenarios you’ve identified. And if you can prove that there are risk mitigation methods that are safety equivalent, but not meeting not necessarily the exact things that are mentioned in the standard, you then go to your local authorities, your local firefighters, your fire marshals, maybe even your insurance company, because they are in authority having jurisdiction because they insure your automation. And if you show them your analysis, and everybody’s on board with it, then you go down that performance base path. Performance Based is usually more in terms of pricing, the upfront engineering and analysis is where the cost is. But sometimes that solution long-term is less over time. So again, those are the options. So, if we’re talking about his journey to a DHA, and ultimately a list of recommendations, you know, it’s the testing, it’s talking with the salesperson to get the proposal developed. It’s then having the consultant come out to the site, perform the dust hazard analysis, generate the report with findings and observations and recommendations. And then from there, the recommendations are ranked in terms of severity. So, there’s our high priority medium, and low, then all he d do is take those and start knocking out some of those high priorities. Sometimes the lower priorities or general recommendations are administrative controls that can, you know, soften or reduce the potential for an event to occur until then larger capital could be developed. So, there that’s the general approach. And again, the DHA what we’re finding is that some local authorities have asked some fire marshals have actually asked for the DHA and what those what’s recommendations, the regulatory communities, different things, different states, so you can’t the requirement to have a DHA completed was September 7 of 2020. Right. So, there are people who met the deadline. And again, there are some fire officials who are asking, let me see it. But we’re not seeing that in every state, in every jurisdiction.
So, you said something, I think is very important. You said there’s a difference between compliance and safe. And I think you know; we see that every day when we get in our car and drive down the road putting our seatbelt on is compliance with the law. That’s what you know, law enforcement is looking for as you pass them, but having airbags most of the cars we dropped today have airbags and that’s an extra layer of safety to protect us and when we think about putting our families in a car that’s something you know, we may be looking for when we go purchase a new car. It’s that extra level of safety and I think when we’re we are in charge of workplace safety if we’re in that position where a plant manager, production manager of safety, health and safety manager or advisor, that’s what we’re looking for. And it, it shouldn’t be just about the minimum we can get by with compliance. That’s, that’s okay. That’s a place to start. Right. But that’s not always the best practice. And so, yeah, you talked about the cost. And I think some people also get concerned about the cost when they think, DHA and oh, I’ve got to change what I’m doing, oh, I’ve got to get a collector or get new suppression or new venting, put in a collector or, or whatever the case may be. I think there’s a pathway and a progression, it’s not something they should freak out and say, oh, I’ve already spent all my capital budget for this year, I can’t do it. I’ll have to wait till next year. There’s ways to get started on that process. Now, yes. And then you can budget for that over time, you can present to the authorities, you know, Matt, with the VPP process, he can show them what he’s working on and where he’s going. Right, right that
it shows progress over time. And again, there are again, I’ll say our approach to conducting a DHA. Let me give you the example of mixers, right mixtures are an inherent hazard and a process. But depending on the formulation, how you add the solids, or any liquids, or anything, and the speed of the mixers, you have various degrees, you may actually not have a hazard that needs to be protected, versus wanted if you just go into it. And this is where screening your consulting resources important if you have someone who goes in and just understands the regulations, or the code, but they don’t understand the background of the regulation of code. So, the NFPA standards and one thing too, I want to you know, the NFPA standards are clear. But what happens is they’re not written in a format that everybody is used to seeing in terms of OSHA is concerned. NFPA actually provides more technical guidance and direction, if you go through and you take the time to read the standard. So, there’s some good guidelines there. But in every one of the standards, it gives you the basis of where that recommendation came from. And if you hire a resource to do a DHA, and that resource doesn’t understand the science behind the recommendation, and they come in and they see your mixers and say they all need to be protected. And they don’t ask you those critical questions like, talk to me about your production rates here, talk to me about how full the mixer is talking about the tip speeds, then they’re not going to do the necessary analysis to determine Well, you got mixers, you got dust collectors, you got sifters, where do I start, if you’re not peeling back the layers to look at the total operation, then somebody’s going to get this report, but all of these recommendations, and it’s going to be frustrating. But our approach is to try and dig down to that level to say, well, you may need to address the mixers. But here’s where you’ve got some mitigating circumstances because we’ve done the analysis. So, the experts can be a phase two in the 2023 budget, as long as you’re doing these things now. But your priority are those dust collectors. And internal dust collectors is dust collector, one, three and seven, you know, so we do that deep dive analysis so that when you walk away, you know, if there are some mitigating circumstances, and it’s like, Yep, I can wait until the next budget cycle. Or if there’s some things that you know, shut this down, here’s some immediate things you need to do. And we’ve done that I’ve been on site where we had to shut down an operation, we had to do some calculations, we had to make some calls. One of the things about the DEKRA network, we built, you know, a good, good rapport with a lot of different folks. And we made calls and kind of taking advantage of those partnerships that we have with people to get clients back up and running. With a mitigating circumstance. One case in particular client had a standard explosion vent on a dust collector inside the building. Which means in we did the calculation about a 20 or 30-foot fireball aimed right at packaging employees. Again, not aware that the hazard was there, shut the process down. It worked with you know, in terms of the scheduling all this, but made a call to one of our partners who’s in the space of providing flameless vents. They had one on the shelf that met the requirements for the client. Then at that point, we stepped back those, two developers made your mutual agreements and purchase orders. There was one on the truck coming to the client within a week. Love it. And so, it’s that kind of approach and we’re not just going to come in and just say hey, you know you got a problem, and walk away. We try to partner with you, our goal is to become that trusted adviser for life. So, you know, I don’t want people to listen to this and say, you know, I’m going to have to process modifications may be necessary capital investments may be necessary, but until you peel back the layers and do the analysis, you won’t know where to go. And our goal is to give you more of a playbook so you know where to budget and put your funds.
And I think that that plays into your strength, what you’re talking about that prescriptive analysis. So, you know, it may not require a capital expenditure, it may be like you were talking about slow the mixer down or, you know, change your ingredients in your mix a little bit if that can work for you. That’s a way to do it and mitigate a lot of the risk rather than having too big capital expenditures and that sort of thing.
And it gets back to you. And then that’s where we ask the question, can you sustain it. So, when we conduct a dust hazard analysis, we want more players in the room, the more players in the room, the better. So that’s even down to your HR representative, we want to understand the total footprint of the operation. Because if we leave the site with an agreement that this is the path forward. And we haven’t looked at the R&D pipeline, we haven’t looked at the innovation schedule for the next couple of years, what we come to in terms of a basis of safety may change based on what you’re planning to do over the next two or three years. So that’s another thing that you know, from the standpoint of our approach, we want to understand the total business, this is not, again, let’s come in tunnel vision, let’s only look at these factors, we want to understand, again, it’s that partnership, right, we want to be apart, we understand the total business total operation. Because if we build in or we don’t take into account that you’re going to go with a smaller particle size in two years, and what that means to the operation, we could be a disservice.
Sure. And I’ve seen that I’ve seen a facility that was running a batch of plastic compounding material, and they switched from to a smaller particle size from their supplier. And it gave them the end product they were looking for. But suddenly, they’ve got tons of leaks, and all their ducting and equipment. And their fire marshal came in and said, you’ve got a huge combustible dust issue. And they were able to simply go back to their supplier and say, hey, we need to go back to the larger particle size in it. And it solved this. So, it was an easy fix. In a scenario like that. It was
going things one of the things with that. And again, it’s part of our assessment is looking at management systems. And one of the critical components of a good management system is management of change. So, the idea is that before you make that change, you do the technical review. And you go back to look. And so, in our report, we talked about all the different requirements. And this is you know, if this, then that right, so if you go back and you say, well, I’m making a modification, I’m adding a grinder, I’m trying because in the report, we’ve outlined that particle size was a basis of safety. If you go through the management of change, what you do is you go through and you say, well, this is here’s the potential impact. And then you would already build in those safeties before you make the change. Because we recognize innovation keeps people in business. So you’re not confined to it and say that’s it. But you have to assess what that potential innovation is going to do to any safeties that we’ve already agreed to after a dust hazard analysis.
Sure. So, in that same vein in that line of sustainability, so my friend Matt does is DHA. He’s worked with you guys. He’s talked about his future plans, and he’s kind of gone through that change management process. And he’s aware of that, but how can he be sure my biggest concern is that you’ve limited the amount of dust building up out in the plant, but now he’s put the DHA up on the shelf, and that’s where all the dust is collecting on that DHA because he’s not pulling it off regularly and taking a look at it. And going through that. So, what is your recommendation on how often should they be reviewing it? And
when do they take a look at it? So, from a consensus standard standpoint, and again, NFPA being progressive and establishing this, there’s a revalidation that is required every five years. Right. Okay. And we’re in the process and part of my road warrior journey has been doing a couple of revalidation is where you go back and you look at the recommendations. You look at everything that was done five years ago. You look at any change management documents that were developed between the time of the initial DHA and now this five-year review period, and then you look for any new hazards, so you have to revalidate it every five years in terms of putting it up on the shelf. If the DHA is done correctly. There are checks and balances built into the controls, that should be audited and maintained over the life of the process. So, this is that management systems element, there is a requirement to have management review. So, there should be action items that are reported on just like you would have report scheduled attainment, just like you would report a quality defect, just like you’d report any other safety incident, any of the critical items identified in the DHA should be part of your, your reporting metrics and your monitoring. So, what we try to do is we try to integrate certain requirements or continuous checks into maybe some PMs, right, so you have a pm for dust collector, we may add one or two steps that are required for your maintenance folks to check out, someone needs to just like they would audit the regular PMS, make sure those things are done. So usually, with companies that are, you know, in that continuous improvement space, they’re measuring and monitoring OEE overall equipment effectiveness, right, you’re looking at your schedule attainment, you’ve got all those different metrics. So, as you report those, what we try to do is integrate our solutions into what you’re already monitoring and reporting with some specificity in terms of here’s, here’s why you’re doing this because it’s related to does. So, if you’re doing the checks and balances on those, the report itself, you could sit somewhere, you don’t want it to just collect dust, but you’ve got enough integrated management system components that if there’s a failure occurring, someone should know. So that leader at the plant that plant director, but someone comes into her or his office and says, hey, we’re going to change line one, we’re going to have this like this, the first thing should be let me see the MOC the management of change. That plant leader, that plant director should sign off on all changes that occur in the plant. And what they should ask for is the technical basis for the change that they’ve done the analysis and the impact of the change. At that point, again, a metric of how many MOCs submitted and approved their sustainable systems that you built into the process that will tell you if you are succeeding, or failing in terms of your journey. So, it becomes a living document in that it creates checkpoints, gateways and other systems. So, you shouldn’t have to always go back, you could go back to it as a technical reference for the MOC. Because when we right around three, put a lot of different technical information and we site code, you could go back to it for that. But in terms of your daily journey, if we’ve done our job correctly, it’s integrated in what you do as a business.
And somebody’s really got to own it, right? Somebody’s got to be the point person, it can’t just be the team. Because it’s in my experience if the team owns it and the teams in charge, right? If everybody’s in charge, nobody’s in charge kind of thing. So, who typically do you see is the owner of the DHA and is responsible for that
here? Here’s the crazy thing about that we see a wide range. So sometimes we’re called in by engineers, sometimes we’re called in by EHS folks. And ironically enough, if we’re calling them by engineers, you know, we, our approach, you know, in terms of the information we get, and we’re already with a resource that knows the capital budget knows all of the right things, when we’re called in by EHS folks that we know the incident histories, we know all. So ultimately, we want to get them all together. But what we found is that it is, again, back to a concept of developing a RACI, right, responsible, accountable, consulted, and informed that point person on site. That’s a question we generally ask, and it depends on, you know, culture, right. And some instances because a lot of this is going to be capital, it’s going to be equipment over some time. The engineering resource is the point person and will be the captain for lack of a better Sure, sure, some organizations see it as regulatory and risk so it falls under the EHS person. But one of the things that we do before we leave is we try to understand clearly who that point person is going to be. That point person is the one that you know, we generally have the contact with that over the life of the process, again, trying to be the trusted adviser. We want to make sure that that point person knows that they can call us you know, if it’s something that requires new proposals and new estimates, then we make that clear, but if it’s just some general clarifications, then we do that but it’s usually in most instances, it is kind of an engineering resources serves that point, point person, but we’ve seen engineering and EHS partner or take elements, management systems and some risk areas for EHS and then all the equipment, reviews and things like that with engineering.
Got it, yeah, that makes sense to make. All right. So, I’m going to get with Matt. And I’m going to tell him to test his dust. Number one, to get a starting point, get a baseline, understand what he’s really working with, and go from there. And then start down the DHA path, right? And giving you guys a call and getting started with the DHA to look at, you know, and really, it’s the five elements of the field are the combustible dust pentagon, looking at fuel ignition, dispersion, and confinement and oxygen, and trying to eliminate those pieces through that DHA process of understanding what’s going on in this facility where the risks are, and creating a roadmap, not that has to be executed today. But that can be done over time, and start planning for that and taking care of the big risks first. So again, I love what you talked about creating a path that is safe, sustainable, and affordable. Right. So how do they get in touch with you and DEKRA? And how do they get started on that journey?
So, you there are a couple of resources available to you for DEKRA, you can go on our website, DEKRA.com DEKRA, North America, you can reach me directly at 609-285-9244 or kevin.jeffries@dekra.com via email. And we’ll direct you to the right resources. We are the process safety division. So, we are the group that handles your process hazard analyses and your dust hazard analyses. But again, the DEKRA.com DEKRA North America websites and you can get to us from there.
Excellent. All right. Thank you so much for your time today and sharing your expertise. I’ve enjoyed this. Probably a little too much dust and combustible dust. So, thank you so much. It’s been an honor and a pleasure to have you on today. If you out there watching us today have enjoyed the content and appreciate what we’re doing. Go follow us on LinkedIn. Give us a thumbs up and follow us on YouTube and subscribe to our channel. Thanks so much for watching. I’m Jordan with SonicAire. Have a great day
