Understanding the Importance of a DHA Revalidation

The revalidation process is not just a best practice—it’s a requirement embedded in NFPA 652, which is referenced by various fire, building, and OSHA codes. The intent is to keep your facility’s safety measures up-to-date with the latest standards and any changes that have occurred in your operations.

At Dustcon, we will start with a documentation review of your facility’s available drawings, dust test reports, and management systems.  We will also include a review of the initial DHA you completed. We will work to understand any changes made and what recommendations have been acted on. We will then visit the facility and complete a walkthrough. After the walkthrough is completed, we will sit down and cover the management systems review and then return to the office to write the report. 

The report you will receive when we are done may look a little different than your current DHA. Whether your first DHA was with us or someone else, DHA reports have evolved over the years based on client feedback and other ways to improve the format while incorporating any changes to standards or relevant annex material released in the interim years. However, this doesn’t mean you will be starting from scratch. Our primary goal at Dustcon is to ensure the reports we give you are clear and actionable with guidance that is easily understood. 

Facility and Process Changes Since the Last DHA

Over time, your facility may undergo minor or significant changes. Whether it’s new equipment, altered production processes, or changes in facility layout, these modifications can alter the risks associated with combustible dust. Revalidating your DHA ensures that these changes are accounted for and that your safety measures are effective.

Implementation of DHA Recommendations

When your initial DHA was conducted, it likely included recommendations to reduce or mitigate fire, deflagration, and explosion risks. As these recommendations are implemented, they can introduce new variables into your facility’s operations. A DHA revalidation reviews these changes to ensure they have been effective and to identify any new risks that may have arisen.

Changes Through Management of Change (MOC)

The Management of Change (MOC) process is designed to control safety risks associated with operational changes. However, even with MOC in place, not all changes may have been fully integrated into your original DHA. Revalidation captures these updates, ensuring a comprehensive and current hazard analysis.

Unaddressed Recommendations Due to Staff Turnover or Other Reasons

Sometimes, recommended changes from the initial DHA may not have been fully implemented due to staff turnover, budget limitations, or other operational challenges. Dustcon is not an Authority Having Jurisdiction (AHJ). Our role is to partner with you, not penalize you for unaddressed issues or minimal changes. 
Revalidation provides an opportunity to revisit these recommendations. We will work collaboratively with you to understand why recommendations weren’t acted upon and create a practical plan to manage these hazards going forward.

By proactively scheduling your DHA revalidation, you not only ensure compliance with NFPA 652 but also protect your facility, employees, and bottom line. The peace of mind that comes with knowing your safety measures are up-to-date and effective is invaluable.

Unmatched Expertise
Our consulting team consists of engineers with extensive plant-level experience, including expertise in designing and implementing explosion protection systems. This wealth of technical knowledge not only guides our recommendations but also influences the NFPA codes and standards governing your facility. With multiple consultants actively participating in NFPA technical committees, we ensure that the feedback from our clients converges with the latest developments in the industry’s standards. Leveraging our broad experience across a wide range of industries and commodities, we bring valuable insights and innovative approaches to managing combustible dust risks.

Our foundation of knowledge ensures that every DHA we conduct benefits from a thorough understanding of the challenges involved in translating recommendations into actionable safety measures. Additionally, our extensive experience working with Building and Fire Code Officials, OSHA, and insurance companies gives us insight into what these entities prioritize. This enables us to guide you through these processes or prepare you for them, shaping our guidance to help you effectively identify and manage hazards with precision and confidence.

Going Beyond the DHA

When it comes to managing combustible dust hazards, revalidating your DHA is just one piece of the puzzle. At Dustcon, we offer a suite of additional services that, when combined with your DHA revalidation, provide a more robust and effective safety strategy. Our approach is designed to meet regulatory requirements while adding additional value that enhances your overall safety program.

Hazardous Area Classification
For instance, many DHAs recommend confirming if electricals and motors are in classified area and are properly rated for the classification. Hazardous Area Classification (HAC), is a service we offer that will provide you with a report detailing  the findings and rationale and drawings specifying classified areas. By doing this concurrently, you can seamlessly integrate the HAC with your DHA revalidation, ensuring a more cohesive and comprehensive safety assessment.

Documented Risk Assessment
We also specialize in Documented Risk Assessments, particularly for clients who may be hesitant to invest in vessel or equipment protection due to cost concerns or a belief that there’s no significant hazard. Our team brings a nuanced understanding of these scenarios, helping you make informed decisions that align with both safety and other considerations.

Explosion Protection Design and Specification
Moreover, our expertise in Explosion Protection Design and Specification means we can take your DHA recommendations and translate them into practical solutions. As an advocate for your needs, we simplify the process of determining the necessary protection by working closely with equipment suppliers to ensure the solutions we recommend are tailored to your specific requirements.

By combining these services with your DHA revalidation, you gain a comprehensive, tailored approach to managing your facility's hazards. Choosing Dustcon Solutions means partnering with a team that’s committed to your safety and providing value that goes beyond just compliance.

Is this really required?

Yes, a 5-year DHA revalidation is required under NFPA 652, which is referenced by various fire, building, and OSHA codes. The revalidation ensures that your Dust Hazard Analysis remains accurate and reflective of any changes in your facility, helping to maintain compliance and, more importantly, safeguard against combustible dust hazards.

What will happen if I don't revalidate?

Failing to revalidate your DHA could lead to several serious consequences. First, you may fall out of compliance with regulatory standards, which could result in fines or other penalties. Your insurer may also have an issue if the facility is not taking the required steps to minimize your risks. More critically, without revalidation, your facility may become vulnerable to undetected hazards, increasing the risk of incidents such as fires or explosions, which can have devastating effects on your operations and workforce.

I'm already past due, what does this mean for me?

If your DHA revalidation is overdue, it's essential to act quickly. Being past due doesn't just mean you’re out of compliance—it also increases the risk of unmanaged hazards. Fortunately, Dustcon Solutions can help you get back on track. We'll work with you to prioritize the revalidation process and address any potential issues as swiftly as possible, minimizing the risk to your facility and operations.

Can I do it before 5 years?

Yes, you can absolutely conduct a DHA revalidation before the 5-year mark. In fact, NFPA 652 says, “A DHA shall be completed for all new processes and facility compartments” (7.1.1.1) If your facility has undergone significant changes, doing it at a specific time would align with your budget better, or any number of other reasons, you can absolutely revalidate earlier. Regular updates can help ensure that your safety measures are always current and effective.

My first DHA was a Desktop DHA for a new facility, what does that mean for me?

A Desktop DHA is often used for new facilities where on-site evaluations were not possible. While it provides an initial assessment, it includes recommendations based on available documentation rather than a thorough, on-site inspection. As your facility becomes operational and evolves, it’s crucial to conduct a full, on-site DHA to ensure that the initial assumptions hold true and that all potential hazards are accurately identified and managed.

Partnering with Dustcon Solutions for your revalidation process means working with a team that understands your facility’s unique challenges and is committed to helping you achieve the highest standards of safety. Don’t wait until it’s too late—schedule your 5-year DHA revalidation with Dustcon Solutions today and take the next step in protecting your facility and your people.

For more information on how Dustcon Solutions can assist with your DHA revalidation and other safety needs, contact us today. Let’s work together to create a safer, more compliant operation.