Brand New NFPA Combustible Dust Standard Is Already Being Used by OSHA

The National Fire Prevention Association has recently issued an updated industry standard for combustible dust: NFPA 652 Standard on the Fundamentals of Combustible Dust. Under the standard, manufacturers in industries with combustible dust are urged to complete an analysis of the dust hazards at their facilities by September 7, 2020, and begin taking actions to reduce them.

But even though the deadline is a year away, OSHA is already issuing citations to employers who don’t currently comply with NFPA 652.

Combustible Dust Basics

OSHA defines combustible dust as “a combustible particulate solid that presents a fire or deflagration hazard when suspended in air or some other oxidizing medium over a range of concentrations, regardless of particle size or shape.”

A combustible particulate solid is “any combustible solid material composed of distinct particles or pieces, regardless of size, shape, or chemical composition.”

Some of the major industries that generate and need to manage combustible dusts include:

• Agriculture
• Food Products
• Chemicals
• Textiles
• Forest and furniture products
• Metal processing
• Tire and rubber manufacturing
• Paper products
• Pharmaceuticals
• Wastewater treatment
• Recycling operations (metal, paper, and plastic)
• Coal handling and processing facilities

OSHA’s has produced a helpful summary of the health and safety issues around combustible dust and the agency’s most common recommendations for controlling dust, its ignition potential, and the injury and property damage it can cause.

OSHA’s Other Rules Applied to Combustible Dust

OSHA attempted to formulate its own combustible standard back in 2009, but the rule was never finalized. Since then, OSHA has used several of its existing rules supplemented by a 2015 National Emphasis Program to cite employers failing to correct combustible dust issues that rise to the level of a “recognized hazard.”

Those existing rules being applied to dust hazards include:

• Housekeeping standards: 29 CFR 1910.22 and 29 CFR 1910.176(c)
• General Duty Clause for deflagration, fire or explosion hazards: Section 5(a)(1) of the Occupational Safety and Health Act
• Process Safety Management (PSM) standard for eligible facilities: 29 CFR 1910.119
• Grain-handling facility standards: 29 CFR 1910.272

OSHA’s Other Combustible Dust Guidance

Although OSHA has thus far failed to promulgate a comprehensive rule for combustible dust hazards, it has managed to produce a series of guidance documents on dust in the workplace, including:

• Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosion. OSHA Safety and Health Information Bulletin (SHIB) (July 2005 and updated November 2014).
• Hazard Alert: Combustible Dust Explosions. OSHA Fact Sheet (March 2008).
• Hazard Communication Guidance for Combustible Dusts. OSHA Publication 3371-08, (2009).
• Policy Memo on Accumulation Depth for Combustible Dusts (April 2015).

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