At the 2024 World Dust Safety Conference, Diane Cave, Eastern Director of Element6 Solutions, presented “Top Five Mistakes Identified During External Audits and Reviews of Incomplete Dust Hazard Analysis (DHA) Reports.”
Based in Halifax, Nova Scotia, Cave has spent over 20 years working with dust collection systems, covering all aspects from retrofits of existing systems, new system designs and installations, and hood and duct designs, for a variety of applications including sawmills and wood processing, grain and feed mills, carbon black, paints, pigments, rubber manufacturing and more.
Below are the five most common mistakes Cave makes in DHA reports based on his experience:
#5) Too much filling
The first mistake Cave identified was the excessive padding of DHA reports. One example he mentioned was unnecessary multi-page CVs.
“You need to verify or justify why you are a qualified person. That can be done in five or six sentences, maybe half a page if you want to stretch it out. It doesn’t need to be a nine-page resume and include every article you’ve ever published or every email you’ve ever sent on the topic,” Cave said.
Other examples of padding include repeating the same information over and over and details about team size. He added that DHA reports should also not be used as sales pitches or a regurgitation of the code.
“It’s a methodical analysis,” Cave said. “It’s about ways to suggest measures to mitigate the danger… and the goal is to review and communicate the results.”
#4) Poor identification of hazards
Cave said the problems he has encountered related to poor hazard identification include lengthy discussions of theoretical elements (such as pages and pages of theoretical debate about whether or not inlet isolation is necessary) and the identification of hazards that are not actually related to DHA.
“We don’t need to know anything about the hazards of liquid storage in a liquid storage area. I mean plumbing issues, we worry about fires and sprinklers because they’re part of the area we cover, but only as it relates to dust. So make sure the elements of the report fit the elements of the audit,” Cave said.
#3) DHA reports poorly organized or difficult to read
Problems related to poorly written or organized DHA reports include issues such as incorrectly named equipment.
“Call it what the facility calls it, not what randomly appears in a drawing, because it can cause a lot of confusion,” Cave said.
Another problem is when it is not clear what process is being evaluated.
“There should be a brief synopsis in the DHA report of what the process is that we are looking at. It is not known who receives this report, so it is not known how far it goes,” Cave said.
Another common problem is that reports either lack images or are stuck in an appendix, forcing the reader to constantly navigate through different parts of the report.
“If you’ve named things correctly in the report, but then you include a picture, then they know what you’re talking about,” Cave said. “Whether it’s specifically each piece of equipment, or because an explosion vent is venting onto a walkway, or because there’s a hole in a piece of equipment, pictures go a long way in explaining what the problems and issues are.”
#2) Language
DHA reports should not use soft or weak language such as “may consider,” “should consider,” or “should consider.”
“If you look at explosion protection, the only option on a ship is to put in a suppression system. Suppression systems are not cheap. So if you say to them, ‘You should consider putting in a suppression system,’ they say, ‘OK, we’ll consider it. ’ And then they look at it, get some quotes and say, ‘OK, we’ve considered it. It’s too much money. We don’t have the money to do it. ’ If something is required, then use that language. Get rid of that soft, weak, cowardly language, because it only complicates what really needs to be done,” Cave said.
Another type of language that should not be used is overly technical language.
“People can get lost in the details, because remember, these people, whoever is reading the report, they are not experts. So they don’t necessarily want to know the formulas and the calculations and everything that’s behind the report. And by putting all that in a report, you can lose people and make them not understand what the goal is and what they need to do,” Cave said.
Similar to soft or weak language, non-concise language is another problem.
“If something is required, say so. If it’s recommended or a good practice, say so,” Cave said.
#1) Lack of clear recommendations and a way forward
One example is where the DHA report simply lists the codes and standards that have not been met without clearly explaining the way forward.
“Instead of saying ‘you need explosion protection,’ it says ‘NFPA Section 69 has not been met.’ But whoever gets the report has to go back and read it and figure out what that means,” Cave said. “It doesn’t actually say you need to do this or that. There are basically no recommendations and there’s no risk rating or hazard assessment. So it’s just a bunch of ‘blah’ on the page that doesn’t tell you what to do or where to start.”
He reminded attendees that when creating DHA reports, the goal is not to teach every detail of fire and explosion hazards, nor to repeat the code or summarize codes that were not met. DHA reports should analyze and communicate results that include defined risk areas.
“You have to make sure you give it a risk rating or a hazard analysis and put a number next to it. You have to tell people, ‘This is your problem. This is how bad it is.’ Some way to get started,” Cave said. “These people who get the report have a million other things to do, and they’re making product XYZ, and they want to know where to start, they want to know what the problem is, and then where to start, and then a rough idea of how to get there.”
For more information on the 2024 World Dust Safety Conference, please visit: www.dustsafetyacademy.com.
