Canadian Biomass • Summer 2024 • Editorial

Irecently had the pleasure of attending the 2024 Global Dust Safety Conference. One of the sessions that caught my interest was presented by Diane Cave, eastern lead for Element6 Solutions. Cave presented “Top five mistakes identified during external audits and reviews of incomplete Dust Hazard Analysis (DHA) reports.”

During this informative presentation, Cave offered her top five DHA report mistakes based on her 20-plus years of experience, which I wanted to share with the readership in countdown order:

5) Too much filler

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

4) Poor identification of hazards

Issues Cave has encountered related to poor identification of hazards include lengthy discussions on theoretical items; and identifying hazards that are not actually DHA-related hazards.

3) Poorly organized or hard to read

This included problems like equipment being named incorrectly, and it being unclear what process is being evaluated. 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.

2) Language

Soft or weak language such as “might consider,” “should think about,” or “should consider,” should not be used in DHA reports, Cave said. Another type of language that should not be used is overly technical language. Similar to soft or weak language, non-concise language is another issue.

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. Cave 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.”