I suggest you review the requirements for a Dust Hazard Analysis (DHA) in NFPA 652 Standard on the Fundamentals of Combustible Dust which addresses this question. You can use the DHA to establish a program that ensures the dust is not "manufactured, generated or used in such a manner that the concentration and conditions create a fire or explosion hazard based on information prepared in accordance with Section 414.1.3" (the 2018 IBC code language). The section quoted requires "A report shall be submitted
to the building official identifying the maximum expected quantities of hazardous materials to be stored, used in a closed system and used in an open system, and subdivided to separately address hazardous material classification categories". The DHA would address that need.
Also note the 2018 IBC and IFC use the old definition of combustible dust with a size limitation (420 micron or smaller). NFPA 652 and most modern dust codes, recognizing that all dusts attrit, generally require any size dust be considered for combustibility. I suspect the IBC and IFC will catch up with that shortly.
The University of Wisconsin gives a 2 day course on this area (which is probably more than you need) and can arrange for an abbreviated in-house one to discuss just NFPA 652. You can get more info on the course at https://epd.wisc.edu/course/combustible-dusts-general-hazards-and-code-compliance/. (Unfortunately the next public offering will be next fall although you can arrange for in house or local training.)
Richard Palluzi
PE, CSP
Pilot plant and laboratory consulting, safety, design,reviews, and training
Richard P Palluzi LLC
72 Summit Drive
Basking Ridge, NJ 07920
rpalluzi**At_Symbol_Here**verizon.net
908-285-3782
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Markopoulos, Marjorie Marie
Sent: Monday, October 29, 2018 10:10 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Lab Design
I have one interesting situation that we have recently experienced with laboratory chemicals (powdered aluminum, sulfur, and magnesium) being identified as combustible dusts. The building code designated for the space categorized as a non-H building. The building code states that in non-H spaces combustible dusts cannot be stored or used beyond quantities where an explosion risk exists if exposed to an ignition source. Interesting, the plans examiners are reviewing detailed chemical inventories by building code definitions and quantities.
We are currently working through the combustible dust situation and would also appreciate any insight to how others have documented a Hazardous Materials Management Plan for these situations or if others had to completely remove any type of combustible dust chemicals storage and use from these non-H spaces.
Marjorie
Marjorie Markopoulos, Ph.D., CBM, CCHO, RBP, CSP
Director
Department of Environmental Health and Safety
3640 Colonel Glenn Hwy | 047 Biological Sciences II
Dayton, OH 45435-0001
Phone: 937.775.2797 | Cell: 937.239.7936
marjorie.markopoulos**At_Symbol_Here**wright.edu
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Mary Beth Mulcahy <mulcahy.marybeth**At_Symbol_Here**GMAIL.COM>
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Date: Monday, October 29, 2018 at 9:37 AM
To: "DCHAS-L**At_Symbol_Here**PRINCETON.EDU" <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Subject: Re: [DCHAS-L] Lab Design
Thanks everyone, and Ralph I had never seen that publication so thanks for posting the link.
Support staff is definitely included in the stakeholders, I just happened to only mention the audience that I would be talking to. Actually, the link Ralph posted does a nice job listing different stakeholders.
I thought there might be some more stories or there like the flooring example. If anyone thinks of others, I'll be listening.
Kimi, do you keep the researchers involved in the design process after you have them fill it the form, or do you feel that one you are aware of the hazards that EH&S can shepherd the rest of the process through?
Mary Beth
On Fri, Oct 26, 2018, 9:09 AM Luis A Samaniego <l-samaniego**At_Symbol_Here**northwestern.edu> wrote:
I would also add:
=B7 Rubber mats to prevent floor tile cracking when dispensing liquid nitrogen into dewars. Some researchers have a tendency to leave a dripping liquid nitrogen transfer hose nozzle touching the floor which creates floor cracks.
=B7 A snorkel exhaust system for researchers working with anesthetics during animal surgical procedures.
=B7 Ensure drench hoses do not get confused with eyewash stations as the water pressure and temperature differs .
All the best,
Luis.
Luis Samaniego, CSP
Sr Laboratory Safety Specialist
Northwestern University
Research - Safety
303 East Chicago Avenue
Ward B-106, W223
Chicago, IL 60611
l-samaniego**At_Symbol_Here**northwestern.edu
(312)503-8300
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Brown, Kimberly Jean
Sent: Friday, October 26, 2018 5:33 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Lab Design
Mary Beth:
Your initial list covers many of the major issues I've seen. Another thing to account for is the placement of and safety implications of free-standing and benchtop equipment that is expected to be in the space. This is a factor when you have a definitive equipment list and are planning a space for a particular researcher, but also when you are designing a generic lab space for a specific research type with equipment that can be reasonably anticipated.
Examples include:
- Need for local exhaust for benchtop equipment such as furnaces, ovens, balances, vacuum pumps, flash chromatography, soldering stations, etc.
- Placement of chemical-storage cabinets and refrigerators (if they're near a door to the corridor, expect more odor complaints from neighbors)
- Deciding whether chemical cabinets should be vented
- Placement of liquid nitrogen tanks (these, as well as gas cylinders, are not always anticipated by designers or included in researcher equipment lists)
- Need for Hazardous-gas or low-oxygen alarms
- Amount and types of built-in chemical storage provided vs. designated locations for free-standing cabinets
- Clearance around electrical panels (don't place the electrical panel in prime real estate for equipment and storage)
When we know who's going in the space we have them fill-out a survey of their lab's hazards early in the design process. We can then communicate to the rest of the design team what impact these hazards may have on how the lab is built. This helps to uncover some of the needs that may have otherwise slipped under the radar until it becomes too late or unnecessarily expensive to re-design.
Best of luck to you!
Kimi Brown
(Kimi Bush)
Sr. Lab Safety Specialist
Environmental Health and Radiation Safety
University of Pennsylvania
3160 Chestnut St., Suite 400
Philadelphia, PA 19104-6287
Office: 215-746-6549
Voice/cell/text: 215-651-0557
fax: 215-898-0140
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Mary Beth Mulcahy <mulcahy.marybeth**At_Symbol_Here**GMAIL.COM>
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Date: Thursday, October 25, 2018 at 6:04 PM
To: "DCHAS-L**At_Symbol_Here**PRINCETON.EDU" <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Subject: [DCHAS-L] Lab Design
All,
I am trying to put together an activity related to laboratory design that involves looking at the flow of personnel, waste, samples, and reagents in laboratories in a science building. In the activity, participants (scientists, engineers, and other users of the facility) are provided a laboratory layout and are then asked to discuss its strengths and weaknesses from security, safety, and practical work flow perspectives. It helps illustrate that the building/laboratory design can simplify work flow protocols and that architects actually need our input.
I'm looking for specific design issues you all have seen related to chemistry laboratories (I have a good bio lab layout already). For those of you who recently have done remodels or new builds, are there issues you were able to design out? Or, for those of you who haven't had that opportunity, do you have a dream list of what you would design out (e.g. the recent floor drain conversation on the listserve)? Are there shared equipment spaces that are perfectly or imperfectly located, or are there labs using particular materials that could be better isolated?
A few topics I have skimmed from the listserve and elsewhere include:
1. Moving hazardous wastes from a top floor via an elevator
2. Materialreceiving and distribution
3. Conference room/admin offices/science office locations/break areas
4. Placement of safety showers/eye washes
5. Chemical storage
Any other ideas from the collective DCHAS brain would be greatly appreciated.
Sincerely,
Mary Beth
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