by Mark Yukich, Fauske & Associates, LLC
Do you have a combustible dust or think you may have a combustible dust? Have you wondered if you need to label the material with a warning for a dust explosion hazard? Recently, the Global Harmonized System (GHS) in the area of the Standard Data Sheets (SDS), particularly focusing on the labeling of dust hazards, has caused companies to consider the explosibility of their dust and if they should be labeling their product with a warning.
According to the new Hazard Communication Standard (HCS 29 CFR 1910.1200 (f)), “Manufacturers, importers and distributors are required to assess available evidence regarding a product’s hazards and must consider exposures under normal conditions or use or in foreseeable emergencies when evaluating what hazards must appear on the label.” HCS continues to say, “Where manufacturers are aware that the downstream use of their product routinely generates combustible (hazardous) dusts, a warning addressing a potential explosion hazard should be included on the label as an immediate visual reminder.”
As for the labeling, HCS has instructed that labeling provided should include the word “warning” and the hazard statement: “May form combustible dust concentration in the air.” The easy solution would be to say that all dusts are combustible, but there is a danger to taking this approach. Many companies see SDS’s as a way to communicate to their clients about the hazards of a given material. Saying that a dust, “May form combustible/hazardous dust concentrations,” does not provide operators or technicians with any guidance for how to handle their dust. It also does not give any security to an EHS department who wants to be sure that their people and processes are safe.
The first step towards issuing a warning label would be to figure out if you are dealing with a combustible dust or not. Fortunately, there is a quick and easy test to determine whether a dust is combustible or not. This test is called the Explosibility Screening Test or a “Go/No Go” test. If your sample is determined to be a “No Go” then your dust is not combustible. However, a sample that is a “Go” would mean that your dust is combustible and other testing will need to be done to determine the risks associated with the material. These additional tests will determine what type of mitigation is necessary to ensure safe handling of the product.
It is preferable to take the conservative approach when dealing with the safety of your employees and your facilities. This means that you would test your materials per the ASTM methods. Remember to first test each item in a “Go/No Go” test or Explosibility Screening test to determine if it is a hazard. Once you determine the product is a “Go,” conduct the proper testing to ensure the safety of your process and that of your customers. Finally, add a proper safety label on your product to meet the standards set by the GHS standards. We all want to be sure that our process is safe, so take the necessary steps in protecting your employees, customers and facilities.
For more information regarding combustible dust, flammable gases and vapors and other hazardous materials, please contact Mark Yukich, Fauske & Associates, LLC, 630-321-4788, firstname.lastname@example.org, www.fauske.com