DHA reports: The top five mistakes

At the 2024 Global Dust Safety Conference, Diane Cave, eastern lead for Element6 Solutions, presented “Top five mistakes identified during external audits and reviews of incomplete Dust Hazards Analysis (DHA) reports.”

Based in Halifax, N.S., Cave has spent more than 20 years working with dust collection systems, covering all aspects from existing system retrofits, new system designs and installations, and hood/ducting designs, for a variety of applications including sawmilling and wood processing, grains and feeds mills, carbon black, paints, pigments, rubber manufacturing and more.

Here are Cave’s top five DHA report mistakes based on her experience:

#5) Too much filler

The first mistake Cave identified was too much filler in the DHA reports. One example she touched on was unnecessary multi-page resumes.

“You should verify or qualify as to why you are a qualified person. That can be done in five, six sentences, maybe half a page if you want to stretch it out. It doesn’t need to be a nine-page resume and list every article you’ve ever published or every email you’ve ever sent on the topic,” Cave said.

Other examples of filler included the same information being repeated over and over; and details on the sizing of equipment. She added that DHA reports should also not be used as sales pitches or be a regurgitation of the code.

“It’s a methodical examination,” Cave said. “It is ways of suggesting mitigating danger… and its objective is to review and communicate the results.”

#4) Poor identification of hazards

Cave said issues she’s encountered related to poor identification of hazards include lengthy discussions on theoretical items (such as pages and pages of a theoretical debate over whether or not inlet isolation is required); and identifying hazards that are not actually DHA-related hazards.

“The hazards of liquid storage in a liquid storage area, we don’t need to know about. Plumbing issues, I mean, we care about fire and sprinkler because that is part of the area that we’re covering, but only pertaining to dust. So, make sure the items within the report adhere to the audit items,” Cave said.

#3) Poorly organized or hard to read DHA reports

Issues related to poorly written or organized DHA reports include problems like equipment being named incorrectly.

“Call it what the facility calls it, not what is randomly listed on a drawing, because it can cause a lot of confusion,” Cave said.

Another issue is when it is unclear what process is being evaluated.

“In the DHA report, there should be quick synopsis as to what the process is that we’re looking at. You don’t know who gets this report. So, you don’t know how far up the line it goes,” Cave said.

Reports not having pictures, or being stuck in an appendix forcing the reader to be constantly surfing through different parts of the report, is another common issue.

“If you have named stuff incorrectly in the report, but then you include a picture, then they know what you’re talking about,” Cave said. “Whether that is specifically on each piece of equipment, or whether that is because an explosion vent is discharging into a walkway, or whether because there’s a hole in a piece of equipment, pictures go a long way at explaining as to what problems and issues are.”

#2) Language

Soft or weak language such as “might consider,” “should think about,” or “should consider,” should not be used in DHA reports.

“If you look at explosion protection, the only option on a vessel is to put suppression on. Suppression is not cheap. And so, if you say, ‘You should consider installing suppression.’ They go, ‘OK, we’ll consider it.’ And then they look at it, they get some price quotes, and then they go, ‘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 this soft, weak, wimpy language, because it just convolutes what actually needs to get done,” Cave said.

Another type of language that should not be used is overly technical language.

“You can get people lost in the weeds, because remember, these people, whoever is reading the report, isn’t an expert. So, they don’t necessarily want to know the formulas and calculations and whatnot all behind it. And putting all that in a report, you can lose people and they don’t understand what the point is, and what they need to do,” Cave said.

Similar to soft or weak language, non-concise language is another issue.

“If something is required, say that it’s required. If it’s a recommended thing or a good practice, then say that,” Cave said.

#1) Lacking clear recommendations and a path forward

One example is having the DHA report simply list codes and standards that have not been met without clearly explaining a path forward.

“So, instead of saying, ‘You need explosion protection,’ it says, ‘Section NFPA 69 section has not been met.’ But then whoever gets the report then has to go back and read it, and find out what that means,” Cave said. “It doesn’t actually say you need to do this or you need to do that. There’s basically no recommendations, and there’s no risk ranking or hazard assessment. So, it’s just kind of a whole lot of ‘blah’ on the page that doesn’t tell you what to do or where to start.”

She reminded attendees that when creating DHA reports, that they’re not about teaching all the intricacies of fire and deflagration hazards, a regurgitation of the code, or a summary of the codes that were not met. DHA reports need to review and communicate results that include defined areas of risk.

“You want to make sure that you give it a risk ranking or a hazard analysis, and put a number beside it. Give the people, ‘This is your problem. This is how bad it is.’ Some form of where to start,” Cave said. “These people that get the report have a million other things to do, and they’re making product XYZ, and they want to know what the problem is, and then where to start, and then a rough idea of how to get there.”

To learn more about the Global Dust Safety Conference 2024, visit: www.dustsafetyacademy.com.