Lockton Companies contributing writers: Michael Mansfield, senior VP, team lead, lost control consultant; Mary Keiser, senior VP, food and beverage practice leader; and Matt Dubiel, account executive.
CHICAGO — Dust Hazard Analysis (DHA) is becoming increasingly important because of the growing awareness of the significant risks posed by combustible dust in various industries, leading to stricter regulations and a greater emphasis on proactive safety measures to prevent potential dust explosions and fires that can cause severe injuries, property damage and business disruptions.
Essentially, a DHA is now considered a critical tool for identifying and mitigating combustible dust hazards in workplaces, making it a vital part of facility safety practices. Lockton Companies, the world’s largest independent insurance brokerage, has seen more stringent insurance carrier requirements related to DHA in the last 12 months. Carriers are now requiring insureds with dust exposure to provide evidence of DHA by location to underwrite property insurance.
Many insureds are also seeing loss control recommendations to follow certain standards imposed by the DHA to prevent losses related to workers’ compensation, including respiratory issues, baker’s lung and work-related asthma.
Key components of DHA
A comprehensive DHA is composed of five steps:
– Dust source evaluation
– Physical dust characteristics
– Assessing site conditions
– Recommended mitigations
– Development of control plan
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History of NFPA guideline changes
Dust Hazard Analysis, in one form or another, has been around for more than 30 years. However, the depth of analysis and impact to commercial property underwriting has never been more significant.
Many point to National Fire Protection Association (NFPA)’s “652 Standard on the Fundamentals of Combustible Dust” as the primary standard on combustible dusts. In 2019, NFPA revised its standard to require that any facility handling combustible dust must perform a DHA. Additionally, this version was more prescriptive in outlining what was required to accomplish a DHA.
The timeline below highlights other significant events that led to this revision:
– 1977: Imperial Sugar explosion in Georgia; 29 dead and more than 100 injured
– 1981: U.S. Chemical Safety Board (CSB) was established, and subsequent explosions and incidents were further evaluated
– 1990s: Continued review of incidents across industry by CSB and others
– 2009: CSB issued guidance on combustible dust that urged OSHA and others to develop standards to identify and protect people from explosion risks
– 2010: NFPA introduced the first version of NFPA 652
– 2016: OSHA issues a final rule on necessity of evaluating combustible dust hazard risks
Commercial bakers interested in learning more about DHA requirements and mitigation as it relates to insurability can contact the authors via email:
– Michael Mansfield | michael.mansfield@lockton.com
– Mary Keiser | mary.keiser@lockton.com
– Matt Dubiel | matt.dubiel@lockton.com
