a notion of understanding about particular dusts, while reducinig costs for employers. “For every employer to take representational samples of ev -ery dust they have, and to send it to a lab for testing, paying the money for that, and all the associated costs with it, was just overly burdensome, especially for small and medium sized employers,” Tasker said. “We also recognize that some dusts are easily recog -nizable as combustible. We don’t need to conduct those tests in order to understand and manage those dusts.” To simplify things for employers, the assumption clause states if a workplace handles or generates a dust, employers must as -sume it’s ignitable and deflagrable, unless they do one of two things: test the dust or show evidence that it is not combustible. “If you believe that the dust that you have at your workplace is not a combustible dust, you can send a sample to a lab, follow [WorkSafe BC’s] methodology and confirm that it is, in fact, not a combustible dust,” Tasker said. “Because we understand that there’s access to published data on various dusts, if you believe that your dust at your workplace is not combustible, you can rely on that objective published data, provided that it’s been derived from the prescribed testing method that’s indicated in the regulation.” RISK ASSESSMENT THE FIVE FACTORS The risk assessment and specific requirements that flow from within the proposed regulation are aimed at tackling these factors: What is the type and amount of fuel (dust) that’s present at the workplace? How much of it and what type is it? What sources of ignition are around in that workplace that could ignite the dust? What degree is there potential is for confinement of the dusts? What is the possibility of the dust being dispersed or suspend-ed in the air? And to a lesser extent, what amount of oxygen is present? “That’s really what a lot of the provisions and requirements in the draft are flowing from, and what they’re aiming towards is having the employer control those five factors at their work -place,” Scollard explained. TIMELINE Once a company has dealt with the assumption clause, they can proceed to the next step in the process, which is to begin a risk assessment. Every employer in B.C. that has a combustible dust at the workplace is required to conduct a risk assessment in con -sultation with a qualified person. “Within the regulation, it outlines the risk assessment pro -cess that needs to be followed the types of things that need to be considered in order for it to be a valid risk assessment. And we also provide language as to when that risk assessment has to be reviewed and updated,” Tasker said. “For example, if there’s a change in materials or machinery or processes, then there’s a re-quirement to go back and review and update your risk assessment to reflect those changes.” For the definition of a qualified person used by WorkSafe BC for the proposed regulation, the organization adopted the univer-sal definition of qualified that WorkSafeBC relies on in Occupa -tional Health and Safety Section 1.1. “We didn’t come up with a specialized definition of qualified for the purposes of combustible dust,” Tasker explained. After a risk assessment is completed and combustible dust has been identified in a workplace, the next step is to develop a combustible dust management program. The combustible dust management program should outline how to manage that risk, and what controls need to be put in place. “Those controls can be many, can be few, depending on the on the nature of the workplace and the nature of the risk,” Tasker said. “This program is a written program that has to be developed by the employer, and once again, under consultation with a quali-fied person. And within the regulation, we also stipulate the basic elements of a combustible dust management program in order for it to be considered adequate to manage the risk.” At the time of this article’s publication, the proposed regulation was still undergoing consultation in its draft format and is sub-ject to change. Feedback was being accepted until May 17, 2024. “Part 6, Substance Specific Requirements — Combustible Dusts” is available to download at the WorkSafe BC website at: www.worksafebc.com/en/resources/law-policy/discus-sion-papers/part-6-substance-specific-requirements-combusti-ble-dusts-2024-may?lang=en. • AUTOMATE MOISTURE CONTROL DRYER CONTROL, PRODUCT QUALITY & MORE MoistTech’s near-infrared moisture sensor allows manufacturers the ability to adjust moisture levels based on real-time information lowering raw material and fuel costs, prolonging equipment lifecycle and increasing product quality & production efficiency. www.moisttech.com 941-727-1800 Canadian BIOMASS CB_MoistTech_Summer24_CSA.indd 1 13 2024-07-18 2:45 PM
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