Audit of Flammable and Combustible Dust Safety Practices

The Challenge

A global provider of specialty materials and ingredients for personal care, healthcare, agricultural, and other applications required an audit of their plant's flammable and combustible dust handling equipment, which typically handles organic solvents and dusts. The scope of work required verification against a range of standards, including OSHA and its National Emphasis Program, NFPA codes, CGA standards, and CCPS guidelines.

Our Approach

The ioKinetic protocol addresses regulatory, RAGAGEP, as well as quality issues associated with implementing an effective flammable / dust handling system that complies with United States regulatory standards. Our assessment methodology was comprehensive, interviewing facility staff and contractors; reviewing policies, procedures, records, and documents; and observing safe work practices and equipment over two days. The audit was conducted in the following sequence:

• On-site inspections of the facility
• Detailed examination of safety administrative and operating records
• Interviews and discussions with facility staff to understand daily practices and challenges
• Lab testing of material to define the critical populations (safety bounds) and sub-population (operational variables and material states) of data
• Verification of the facility's systems to ensure adherence to regulations and internal procedures

Lab testing included the Explosion Severity Test (KSt) to determine the magnitude of a potential explosion and the Minimum Ignition Energy Test (MIE) to identify the types of electrostatic ignition sources to be avoided. Minimum Auto-Ignition Temperature (MAIT) testing assesses a dust's sensitivity to hot surfaces, such as dryers, bearings, and other mechanical parts. Minimum Explosible Concentration Testing provides insight into the minimum amount of combustible dust that will explode when dispersed in air. Additional tests were conducted to meet the requirements of certain individual client materials.

ioKinetic assessed the following activities:

• Tanker operations, including loading and offloading
• Bulk storage (including overfill protection)
• Equipment level measurement (e.g., when the reactor is filling)
• Container storage and handling, including drums, totes, etc.
• Pipeline transfers
• Distillation and recycling operations
• Combustible dust handling
• Other flammables handling, including decanting, transfer, separations
• Area classification (zoning)
• Verification that all stationery and mobile equipment is appropriately rated for use (zoned)
• Earthing, grounding, and bonding

Our auditors conducted a daily debriefing meeting to present preliminary findings and coordinate remaining work with the facility's in-house audit team. The documentation was prepared using Process Safety Office^® PSMPro™ software.

The Benefits

ioKinetic delivered substantial value to the client through a comprehensive report summarizing all findings in easily digestible tables. Worksheets created within PSMPro™ detailed the hazards and their associated causes, consequences, and safeguards. The final report included the following:

• A description of the purpose, objectives, scope, and methodologies
• A list of the flammable and dust handling programs, procedures, and practices that were audited
• Any documented findings identified during the audit

This format directly empowered the client by providing clear recommendations and actionable requirements for the plant to achieve full adherence to RAGAGEP, OSHA regulations, and local attention matters. The client was very pleased with the attention to detail and completeness.

Learn More

ioKinetic has reduced process safety risk, maintained compliance and substantially increased peace of mind for our clients worldwide. To learn more about how we can help you manage risk, contact us today or call us at 1-844-ioKinetic.