The United Nations issued its 8th Revision to the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) late last year and in this 8th revision we have some very good guidance on Combustible Dust (COM DUST). For the record, OSHA is considering adopting the 7th Revision; we currently are using the 3rd revision in our 1910.1200 compliance. So this is not so much about OSHA compliance, but more about another resource to educate and manage combustible dust hazards for those who feel NFPA 654 is too intrusive and demanding. ANNEX 11 GUIDANCE ON OTHER HAZARDS NOT RESULTING IN CLASSIFICATION is where we turn to find our COM DUST program. ANNEX 11 provides guidance on the factors that contribute to a dust explosion hazard and on hazard identification and the need for risk assessment, prevention, mitigation, and communication. The standard/ANNEX applies to…
any solid substance or mixture, which is combustible, may pose a dust explosion risk when in the form of fine particles in an oxidizing atmosphere such as air.
A risk assessment may be needed for many substances, mixtures, or solid materials, not just those classified as flammable solids in accordance with Chapter 2.7. In addition, dust may be formed (intentionally or unintentionally) during transfer or movement, or in a facility during handling or mechanical processing (e.g., milling, grinding) of substances/mixtures/solid materials (e.g., agricultural commodities, wood products, pharmaceuticals, dyes, coal, metals, plastics). Thus, the possibility of the formation of small particles and their potential accumulation should also be assessed. Where a dust explosion risk is identified, effective preventive and protective measures should be implemented as required by national legislation, regulations, or standards.