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BakerRisk Marketing

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October 2025

It was a Thursday evening on May 2, 1878. An explosion at the Washburn A Mill in Minneapolis, Minnesota, occurred, resulting in 18 deaths and a devastating economic and environmental impact. What was the exact cause of this incident? Flour dust. 

While this substance may seem harmless at face value, if certain elements and conditions align, it can have a catastrophic effect. The most damaging aspect of this event is the subsequent explosions that occurred, causing fires throughout the community, including the destruction of nearby mills. 

Following this tragic event, several steps were taken to reduce the likelihood of similar incidents, including the establishment of the Minneapolis Fire Department in 1879 and advancements in safety standards related to combustible dust. 

According to the Occupational Safety and Health Administration (OSHA), between 1980 and 2005, there were 281 documented combustible dust incidents, resulting in 119 deaths, 718 injuries, and extensive damage to multiple industrial facilities. Consequently, OSHA established a National Emphasis Program (NEP) to inspect facilities that generate combustible dust that can result in hazardous events when suspended in the air, regardless of particle size or shape. 

How Do They Occur?

As defined by OSHA, combustible dust is made up of fine particles that present an explosion hazard when suspended in air under certain conditions. These particles derive from an extensive range of materials, ranging from food, grain, and tobacco to pesticides and pharmaceuticals. These materials are produced in facilities throughout various industries, such as agriculture, chemical manufacturing, textiles, and fossil fuel power generation, among others. The dust produced from materials can accumulate and be found throughout a facility, including on rafters, on ducts, and on equipment.  

But how can a substance that appears innocuous produce such destructive effects? This is best explained by the dust explosion pentagon, as seen below. There must be five elements necessary to produce a dust explosion. The first three elements that are commonly referred to as the fire triangle: oxygen, fuel, and heat; all three must be present for a fire to occur. The other two elements that must be present for a combustible dust explosion to occur include the dispersion of particles in sufficient quantity and concentration and confinement of the dust cloud. 

Upholding safety standards is essential to establish optimal industrial facilities operations and, most importantly, minimize the impact on personnel, communities, and the environment to avoid catastrophes such as the Washburn A Mill explosion and the numerous dust incidents that have occurred throughout history. But how can facility owners make certain that precautions are being taken to reduce the probability of combustible dust incidents? 

How Should Asset Owners and Operators Respond to Dust Hazards?

One of the most effective ways to ensure safety compliance and the assurance necessary to eliminate the probability of a combustible dust incident is through Dust Hazard Analyses (DHA). DHAs are an integral part of securing the safety and integrity of facilities susceptible to combustible dust hazards. DHAs ensure safety compliance with national and international codes and standards, safeguard the integrity and reputation of facility owners and operators, and protect the lives of the personnel who are in direct contact with potential hazards. 

Conducting a DHA

If it has been determined that a combustible dust hazard is present, it is required for facility owners to perform a DHA analysis. According to CCPS’s “Guidelines for Combustible Dust Hazard Analysis,” to which BakerRisk has contributed, it highlights the multiple steps that are required to successfully execute DHAs. They include: 

Step 1 – Identify the location of the combustible dust within the facility (e.g., equipment, building compartment). Decipher the degree of hazard by calculating particle size and understanding the type and size of equipment or building compartment. 

Step 2 – Identify the standards that are applicable. NFPA (National Fire Protection Association) 660 which was released in early 2025, provides the general requirements for the management of combustible dust fire and explosion hazards.  

Step 3 – Obtain the proper documentation. 

Step 4 – Assemble an effective DHA team, incorporating experienced operators, maintenance, and engineering personnel led by a “qualified person.” The qualified person leading the team should be familiar with conducting a DHA and be familiar with the hazards of combustible dust. 

Step 5 – Decide whether the DHA will either be prescriptive or performance-based (risk-based). 

Step 6 – Conduct the DHA. The DHA should be done in a systematic manner and properly documented to identify and evaluate all the potential fire, flash fire, and/or explosion hazards associated with the presence of combustible dust within the facility (e.g., equipment, building compartment). 

Step 7 – Once all hazards have been identified, the team must prioritize action items. Action items include addressing the hazards that pose the highest risk to ensure safe operation. 

Recommendations to Protect Facilities from Combustible Dust Hazards

Facility owners may set up certain safeguards to protect equipment, building compartments, and other areas susceptible to combustible dust, the most common being the establishment of an inspection and cleaning plan that meets NFPA housekeeping requirements. 

A housekeeping checklist that reduces the probability of explosion events, which include the following: 

  • Is there a documented housekeeping program in place? 
  • Does the program establish and require periodic inspections of all elevated surfaces to determine dust accumulation thickness? 
  • Does the program establish a thickness less than the established NFPA standard allowable thickness (i.e., 1/32 inch over 5% of the building footprint) above which cleaning of the surfaces should occur? 
  • Does the program prohibit the use of compressed air cleaning unless special ignition control provisions are in place, per NFPA 6660? 

To maximize safety in areas where combustible dust is produced, our experts recommend the incorporation of various fire and explosion protection systems. These include: 

  • Deflagration Venting 
  • Flameless Deflagration Venting 
  • Chemical Suppression Systems 
  • Spark Mitigation Systems 
  • Deflagration Isolation Systems

Conclusion

At BakerRisk, we aim to deliver assurance to our clients by upholding our commitment to safety and integrity. Our experts possess outstanding qualifications to safeguard your facility from the impact of combustible dust hazards—over 100 years of combined experience, 300+ DHAs performed, and 50+ combustible dust incidents investigated. 

Lastly, our experts sit on relevant NFPA committees responsible for developing the standards to identify and mitigate combustible hazards. Our team also incorporates experts who have co-authored CCPS’s Guidelines for Combustible Dust Hazard Analysis, making our team uniquely qualified to interpret and implement the requirements of these standards. 

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