The DHA dilemma: Addressing industry’s shortage of qualified Dust Hazard Analysis providers
It has been nearly 10 years since the National Fire Protection Association (NFPA) released NFPA 652, Standard on the Fundamentals of Combustible Dust (2016), which introduced the requirement that all facilities handling combustible dust must complete a Dust Hazard Analysis (DHA). While NFPA 652 has since been consolidated along with all the other previous NFPA combustible dust standards into NFPA 660 Standard for Combustible Dusts and Particulate Solids (2025),1 the requirement for all dust-generating facilities to complete a DHA and review and update that DHA at least every five years remains.
The deadline for existing facilities to complete their initial DHAs was September 7, 2020 (January 1, 2022, for agricultural and food facilities), and while no method for tracking compliance exists, combustible dust experts believe that many companies, particularly smaller ones, have not yet done a DHA. According to Alexandre Cordoso, Canada operations supervisor at BakerRisk and alternate NFPA 660 committee member, “I'm sure a lot of facilities aren’t even aware that the DHA requirement exists until something happens and OSHA gets involved and there's a citation.”
Some experts are also concerned that many DHAs that have been completed fail to adequately identify hazards and recommend mitigation solutions. At the recent 2025 Powder & Bulk Solids Conference & Exhibition, Jason Reason, lead combustible dust consultant at Airdusco EDS and chair of the NFPA 660 Combustible Dusts committee, presented a session titled “The Pitfalls and Traps of Dust Hazards Analyses” in which he discussed the poor quality of many DHAs being performed, which he warned can lead to missed hazards and combustible dust incidents. In an interview previewing his presentation, Reason stated, “We have a big problem in the industry, at least in my opinion, of unqualified individuals doing dust hazard analysis, which is actually now causing incidents to occur.”2
DHAs are absolutely necessary for facilities handling combustible dusts. How can companies understand the hazards and risks without truly understanding how combustible dust compliance relates to them?
- Jack Osborn, Airdusco EDS
No data exists on the percentage of DHAs being performed by unqualified individuals, but estimates range from “hopefully not many” to 90%. “I see a lot of DHAs come across my desk from all sorts of sources including third-party consultants, engineering firms, and end users themselves,” says Jason Krbec, director of business development at CV Technology and NFPA 660 committee member. “Only about one in four of those DHAs properly accomplishes the task of evaluating the hazards and providing recommendations to manage the hazards associated with combustible dust.”
Missed hazards are not the only risk associated with poorly executed DHAs. Chris Giusto, national director of combustible dust safety at Hallam-ICS, adds that poorly done DHAs can also create undue financial burdens on companies by improperly identifying hazards. “One client contacted us for a second opinion because their parent company would close the facility before they would spend the money to implement the recommendations in their DHA report,” Giusto explains. “Upon review, it was apparent to us very quickly that the other consultant had a superficial understanding of certain requirements and made overzealous recommendations without adequate due diligence into the details of the situation.”
Who is qualified to conduct a DHA?
With such concern among experts about inadequate DHAs being performed by unqualified individuals, it seems important to define what qualifies a person to conduct a DHA. Laura Moreno, Standards Lead, Industrial and Chemical Engineering at NFPA and staff liaison to the NFPA 660 technical committees, points out that the definition of “qualified person” in Chapter 3 of NFPA 660 (2025) is not specific to combustible dust hazards, but just describes “a person who, by possession of a recognized degree, certificate, professional standing, or skill, and who, by knowledge, training, and experience, has demonstrated the ability to deal with problems related to the subject matter, the work, or the project.”
How big is the shortage of DHA providers?
Adam Haroz, Conversion Technology: There are many individuals and companies that are available and capable of leading or conducting DHAs. The issue is whether they are knowledgeable about the multiple NFPA standards, relevant regulations, and consensus standards and if they have experience working with the materials and process equipment related to the facility. At the end of the day, the responsibility for determining qualifications falls on the facility and/or person who decides to hire the DHA personnel.
Chris Cloney and Michelle Murphy, Combustible Dust Training Institute (CDTI): It’s hard to give an exact number because there’s no central database or formal definition of what “qualified” actually means in this space — and that’s part of the problem. If you use a broad definition, you might find multiple hundreds of people in the U.S. who have relevant experience. But if you narrow that to folks who’ve led dozens of DHAs, it’s probably fewer than 100. This lack of clarity and capacity is a big reason why we’re introducing certification programs — to help standardize some of the approaches around combustible dust safety and start building a more robust, reliable pool of professionals for the future.
Eric Maynard and Josh Marion, Jenike & Johanson: In the absence of quality data and statistics, it is tempting to speculate on the shortage of qualified DHA providers. There is no DHA regulatory or licensing body in the U.S., thus, it is currently impractical to quantify (A) how many “qualified” DHA providers there actually are, and (B) how many qualified DHA providers are actually needed to satisfy demand. There isn’t even a standard protocol for defining what makes one a “qualified” person to perform a DHA to begin with. It is far easier for licensed professions such as doctors, lawyers or law enforcement officers, as these are areas where the licensure protocol is well-defined and there are available statistics from the U.S. Bureau of Labor Statistics and from industry groups that can provide guidance. However, the number of facilities and applications involving combustible particulate solids or dusts is massive, as 70% of anything manufactured in the U.S. involves a powder or bulk solid in raw, intermediate, or final form, and of those materials, fire, flash fire, or dust explosion hazards can be present nearly 70% of the time!
Vahid Ebadat, Stonehouse Process Safety: Our experience and the experience of others with whom we talk is that the main peak of DHAs has now passed (NFPA 652 (2019) is 6 years old) and NFPA 660 adds nothing new. Clients might need to wait a few weeks for a consultant, but not months. If there were a shortage, I would have expected people who come to us to tell us they have struggled to find a DHA person. I don’t think we have ever heard that.
Jack Osborn, Airdusco EDS: The requirement has lessened as industry has recognized the need for qualified personnel for DHAs (facilitators, subject matter experts, process experts, dust collection, etc.). The “shortage” STRONGLY depends on the industry. For example, there is only one true expert for DHAs involving additive manufacturing systems, while a plethora of people claim to have the knowledge and capabilities to perform DHAs (in foods, wood, etc.).
Adam Haroz, director of engineering at Conversion Technology and NFPA 660 committee member, says that the definition was a major discussion point when preparing the standard. “Concerns arose when it was identified that many potentially unqualified companies (e.g. companies that install residential pools) were advertising services for DHAs,” Haroz says. “Of course, the problem with that is they can be more likely to do those DHAs by providing lower bids. However, if they are unqualified, potential fire and explosion hazards could go unidentified, or corrective actions could be inadequate to ensure the safety of facility personnel and property.”
The definition as it stands intentionally avoids specific certifications, degrees and experience levels to avoid excluding competent individuals and because certifications, degrees and experience do not necessarily indicate that a person is qualified to conduct or lead a DHA and recommend suitable corrective actions. “NFPA 660 does not go into detail about what experience and education a person might need to perform or lead a DHA,” explains Moreno, “because it can vary greatly and would be hard to select a specific number of years of experience or number of DHAs involved in, etc.”
Chapter 7 (the DHA chapter of NFPA 660) is more specific to combustible dusts than Chapter 3, requiring that a DHA be performed or led by a qualified person who “possesses documented experience and education regarding methods for performing a DHA and the assessment and identification of mitigation or elimination options for the fire, flash fire, explosion, and related hazards of the specific type or types of combustible dusts involved in the facility.” Delving deeper into NFPA 660, Annex A (which contains material that is explanatory rather than required) states, “Someone who is qualified to perform or lead a DHA has performed all the aspects of several DHAs associated with the affected industry or type of combustible dust(s).”
“It is a bit of a chicken or egg question,” says Tim Myers, principal engineer and office director at Exponent and NFPA 660 committee member. “You want qualified people to perform or lead DHAs, but do they have to first perform DHAs before they become qualified?”
While some, including Jack Osborn, senior project engineer at Airdusco EDS and member of all six NFPA 660 committees, believe that the current definition is inadequate and needs to limit more clearly who is truly qualified, others feel that the definition is reasonable and point out that further revisions are likely in later editions of the standard.
How does one become qualified to conduct DHAs?
While the debate over the definition of a “qualified person” is likely to continue, nearly all experts seem to agree that the number of people qualified to conduct or lead DHAs is insufficient to meet industry demand. This is another area where hard data is lacking, but Diane Cave, eastern lead at Element6 Solutions describes the situation as follows, “There are an estimated 100,000 facilities in the U.S. and Canada that handle combustible dust. This includes all industries, of all sizes. By all rights, all these facilities require a DHA. And there are, at best, a couple hundred folks that are qualified to do such work. The demand far surpasses the ability of the folks in the industry.”
The “couple hundred folks” Cave mentions typically became qualified through mentorship and many years, if not decades, of working with combustible dust hazards and NFPA standards. That sort of mentorship and training continues at many combustible dust consulting firms to usher in the next generation of leaders in the field. But such training takes years and will partially serve to simply maintain the status quo as experienced experts retire.
In your opinion, what would be the best way to increase the number of qualified people to conduct or lead DHAs, and what would their training look like?
Eric Maynard and Josh Marion, Jenike & Johanson: We believe there is an improvement avenue through education about combustible dusts and deflagrations in academia to ensure awareness at the college level in a variety of degree/credentialing paths. For instance, combustible dust training could be covered in basic chemistry or physics classes in all mechanical, chemical, or civil engineering programs. For those pursuing degrees in fire protection, a mandatory semester class should be required. For those becoming certified fire professionals and/or first responders with a fire focus, training should also be mandatory. Then, as fire professionals advance in their careers and capabilities, licensing and assessments should incorporate awareness level and competencies in combustible dusts and particulate solids. This way, when fire inspectors are involved with facility inspections at building, commissioning, or periodic operational assessments, they will know not only to look for standard hazards and risks, but also those involving fires, flash fires, and explosions related to combustible particulate solids and their dusts.
Tim Myers, Exponent: It would be useful for more organizations to expand their training on combustible dust hazards to include a follow-up course focused on DHA techniques, as well as offer examples of completed DHAs. There are other resources on performing DHAs, including published articles and the CCPS book Guidelines for Combustible Dust Hazard Analysis.
Chris Giusto, Hallam ICS: I believe the best way to create qualified DHA leaders is through an apprenticeship type of arrangement. It is the ability to apply the technical knowledge that makes someone qualified, not just having that knowledge. And the only ethical way to learn how to do that is to do it working under someone with more experience who can help fill in any gaps until the person reaches a level of experience where they are self-sufficient. I think what [CDTI] is doing is a step in the right direction, but I’m curious to learn more about the project submission and review process.
Adam Haroz, Conversion Technology: I hope in the future that there are more certification programs like [CDTI’s] and especially that NFPA itself puts either a program together or lists programs that they have vetted to provide guidance on this. The training itself, similar to some that we have provided, should take the time to review the NFPA standards. This would include not just NFPA 660 but also the multiple standards that cover the rating of hazardous (classified) locations (NFPA 497 and 499), practices on static electricity (NFPA 77), the electric code (NFPA 70), deflagration venting and prevention (NFPA 68 and 69), etc. It should review material properties, specifically how dust, and potentially vapors and gases, can become suspended in the air or accumulate on surfaces and consequently how an explosion, deflagration, and flash fire can occur. Then it should go through the fundamental methodology of conducting a DHA, including how to review processes, equipment, and surrounding areas to identify the potential for ignition sources or malfunctions to occur. This should entail determining how a potentially hazardous dust or vapor cloud can form and how it could be ignited, then a review of how to assess and determine levels of risk and how to provide corrective action recommendations that correlate with the identified risk levels. With all of that completed, the training should then have workshops or real-world scenarios and/or facility operations reviewed and assessed by a DHA.
To improve combustible dust awareness and help address the shortage of qualified DHA leaders, Chris Cloney, founder of Dust Safety Science, and Michelle Murphy, president of the consulting firm, Mica, recently started the Combustible Dust Training Institute (CDTI). CDTI offers two certifications: Certified Dust Safety Professional (CDSP) and Certified DHA Leader (CDHA). Both certifications share a core curriculum around dust testing, explosion protection, and ignition source evaluation. The CDSP program also includes modules on management systems, housekeeping, and interpreting test data, while the CDHA program focuses on DHA-specific training, including a dedicated 8- to 10-hour course on facilitation techniques.
The CDTI has a rotating advisory panel made up of five or six subject matter experts that review the curriculum and suggest improvements. “They give feedback on course content, experiential requirements, and even limitations — for example, clearly defining what a certificant shouldn’t do,” explain Cloney and Murphy. “This allows us to refine the program iteratively, and any upgrades we make are rolled out at no cost to existing certificate holders. We also require annual revalidation, so everyone stays current as the field evolves.”
While the CDTI program is not currently recognized by any independent organizations, Cloney and Murphy say they are actively exploring accreditation. “The challenge is that very few organizations have the technical expertise to properly evaluate a certification program focused on combustible dust,” they say. “That’s something we hope to address, perhaps even in collaboration with our advisory panel. University accreditation is another route we’ve looked at, but again, most schools lack the hands-on experience to meaningfully assess this kind of program.”
While enrollment indicates a positive early response to CDTI’s programs, some industry experts caution that, while such education is valuable, programs such as this cannot replace years of experience working with combustible dust hazards, and the “certification” label might falsely overstate a person’s expertise. “Certification could be a dangerous concept,” says Vahid Ebadat, CEO of Stonehouse Process Safety and NFPA 660 committee member. “In any case, who certifies the trainer? In professional circles, it is generally through professional institutions.” Still, Ebadat hopes the program can generate enough interest to be successful.
Eric Maynard, vice president at Jenike & Johanson and NFPA 660 committee member, and Josh Marion, senior project engineer at Jenike & Johanson, applaud the efforts of groups such as CDTI, but note that companies should look beyond such a certification when hiring DHA professionals. “We do not believe that the intention of the program sponsors is to launch hundreds of “certified” personnel that are actually unprepared!” Maynard and Marion emphasize. “However, it will require careful evaluation as some may view certification as a business opportunity for generating revenue, yet poor execution could lead to significant detriments to facilities and personnel.”
Such sentiments are echoed by many in the field, praising CDTI’s work at raising combustible dust awareness and education but cautioning that such programs are no substitute for years of experience and mentorship.
What should companies look for when hiring a DHA consultant?
While consultants could potentially face some liability for poor-quality DHAs, NFPA 660 clearly states that the companies handling the combustible dusts are responsible for identifying and mitigating the hazards in their processes. Costs to hire outside DHA consultants vary widely depending on plant size and complexity but typically range from around $10,000 to over $100,000; however, experts caution against simply going with the lowest bid or attempting to conduct the DHA internally to save money unless the company has experts with demonstrated experience on staff.
What liability issues does a DHA provider face if an incident occurs as a result of a hazard that was not identified in their DHA or as a result of a recommended action in their DHA?
Tim Myers, Exponent: This is an open question. The level of thoroughness of DHAs I see at facilities varies significantly. There are examples of facilities having multiple third parties perform DHAs on the same facility and seeing different hazards identified. Part of my work involves incident investigations. Increasingly, when I am investigating a combustible dust incident, the facility will have had one or more DHAs performed. Sometimes the DHAs do not explicitly identify the scenario that occurred or the appropriate mitigation methods. In other cases, the facility had not yet mitigated an identified hazard.
Vahid Ebadat, Stonehouse Process Safety: Anything from no consequence, to being sued! Like all such questions, it depends on consequence and cause (negligence, unforeseeable hazards). And, of course, it is not just a liability issue, life safety should be the primary focus.
Jack Osborn, Airdusco EDS: This is tricky. A qualified DHA provider MUST provide true and correct solutions to the problems encountered. If not (and I have seen many so-called DHAs without this), then what good is it? This should result in high liability. If the customer does not follow the recommendations and solutions — especially with a viable and definite plan — then the customer should assume liability.
Chris Giusto, Hallam ICS: NFPA is very clear that the owner/operator is responsible for identifying the hazards and ensuring that they are mitigated. As DHA consultants, we are only leaders or facilitators. That said, if an incident were to occur at a facility where a consultant provided a DHA, I would be shocked if that consultant was not pulled into some legal proceedings.
Reputable DHA consultants should be able to provide references and examples of previous DHAs. These examples should not simply be a checklist, but a comprehensive report that includes items such as a description of the team involved and the methodology used; a listing of the dusts and their relevant characteristics; an evaluation of each step of the process(es) involved, including documenting hazards, existing mitigation strategies and areas of hazard classification; risk analyses and mitigation methods; and additional supporting material such as calculations, worksheets, references, records, etc. While this list is not comprehensive, and DHA reports will vary from firm to firm, experts agree that DHA mitigation recommendations should not simply repeat the lines from the standard but rather interpret the standard in a way that is relevant to the specific process and hazards, effectively mitigating risk without introducing an unnecessary burden to the company.
Experts also agree that a DHA should be a team effort rather than a solitary endeavor and, in addition to the DHA lead, should generally involve a range of onsite personnel with knowledge of the plant, process and operation, such as plant management, process/mechanical engineers, EHS personnel, operations, maintenance, etc.
Is increasing combustible dust awareness leading to improved safety?
While industry still has much work to do regarding both combustible dust awareness and education, combustible dust safety has improved in recent years through the combined efforts of OSHA investigators, NFPA committees, insurance providers, OEMs, local AHJs, consultants, and individual companies handling combustible dusts. “We have seen the dust explosion incident rate decrease by about 30% over the last 10 years in certain industries like agricultural dust, but we are still a long way from properly managing combustible dust hazards,” says Krbec. “As new and more advanced manufacturing practices are developed, like additive manufacturing, we introduce new hazards and risks associated with particulate solids.”
Despite these challenges, many in the industry are optimistic. “As awareness and understanding in industry improves, buyers of DHA services will be better able to evaluate consultants and make better decisions,” says Giusto. “Simultaneously there will be growth and improvement in the available resources for facilities, including consultants, training courses, educational materials, etc. This is a big issue that has been around for a very long time, and the risk will never be zero. But we are getting closer to a day when the average worker sees a combustible dust hazard and recognizes it as easily as [they recognize the danger of] someone working at height without fall protection.”
References
1. https://www.nfpa.org/codes-and-standards/nfpa-660-standard-development/660
2. https://www.processingmagazine.com/podcasts/podcast/55277629/special-episode-powder-show-conference-preview