Combustible Dust Hazards: Navigating OSHA’s Emphasis Program and NFPA 660 Compliance

Combustible dust continues to pose a significant hazard in numerous industrial settings across the United States. From woodshops to food processing plants, the accumulation and dispersion of fine particulate matter can result in devastating fires and explosions if not properly managed. In response, regulatory agencies and standards organizations like the Occupational Safety and Health Administration (OSHA) and the National Fire Protection Association (NFPA) have developed programs and standards aimed at reducing these risks.

This article explores the current regulatory landscape, focusing on OSHA’s Combustible Dust National Emphasis Program (NEP) and compliance with NFPA standards, especially the forthcoming NFPA 660: Standard for Combustible Dusts.

What Is Combustible Dust?

As discussed in our article, What is OSHA’s Standard for Combustible Dust?, combustible dust refers to fine particles that present a fire or explosion hazard when suspended in air under certain conditions. These particles can originate from:

  • Organic materials (sugar, flour, grain, paper, wood)
  • Metals (aluminum, magnesium)
  • Chemicals and plastics
  • Textiles or biosolids

To see a much more comprehensive list of products or materials in powdered form, see OSHA’s Combustible Dust Flyer here.

An explosion can occur when five key elements—known as the Dust Explosion Pentagon—are present:

combustible dust explosion pentagon
Combustible Dust Explosion Pentagon
  1. Fuel (combustible dust)
  2. Oxygen (air)
  3. Dispersion of dust particles in sufficient quantity and concentration
  4. Confinement of the dust cloud
  5. Ignition source (spark, hot surface, friction)

OSHA’s Combustible Dust National Emphasis Program (NEP)

OSHA’s revised Combustible Dust NEP (Directive CPL 03-00-008), effective January 30, 2023, renews the agency’s focus on identifying and mitigating combustible dust hazards. The program does not introduce new regulations but targets enforcement under existing standards such as:

Key Elements of the NEP:

  • Targeted Industries: Includes sectors such as wood manufacturing, food processing, chemical manufacturing, metalworking, and more. New NAICS codes have been added based on incident data and inspection history.
  • Inspection Protocols: Inspections are unannounced and focus on: Dust accumulation on surfaces, ignition control and equipment safety, ventilation and dust collection systems, Employee training, and hazard communication.
  • State Plan Requirements: OSHA-approved state plans must implement an equivalent NEP.

Why It Matters:

From 1980 to 2005, combustible dust incidents caused 119 worker deaths and 718 injuries in the U.S., according to the U.S. Chemical Safety Board (CSB). These numbers underscore the importance of proactive inspections and compliance efforts.

From 1980 to 2005, combustible dust incidents caused 119 worker deaths and 718 injuries in the U.S., according to the U.S. Chemical Safety Board (CSB).

NFPA Standards and the Emergence of NFPA 660

While OSHA provides enforcement, NFPA standards provide the technical backbone for managing combustible dust hazards. Employers turn to NFPA guidance to identify hazards and implement risk mitigation strategies.

Existing NFPA Standards (being consolidated):

  • NFPA 652: Fundamentals of Combustible Dust
  • NFPA 61: Agricultural and Food Processing Facilities
  • NFPA 484: Combustible Metals
  • NFPA 654: Chemical Processing Facilities
  • NFPA 655: Sulfur Handling
  • NFPA 664: Wood Processing Facilities

The New Unified Standard: NFPA 660

NFPA 660, which was officially adopted in 2025, consolidates the existing dust-related standards into a single comprehensive document. It aims to:

  • Simplify compliance across industries
  • Ensure consistency in hazard assessment and control
  • Provide uniform guidance for conducting Dust Hazard Analyses (DHAs)

Key Requirements of NFPA 660:

  1. Dust Hazard Analysis (DHA) – Required for all facilities with potentially combustible dust. Must be completed by a qualified person and updated every 5 years or whenever a process change occurs.
  2. Hazard Mitigation Strategies – Implement control measures. Engineering controls include: dust collectors, spark arrestors, and deflagration vents. Administrative controls include: training, signage, and maintenance schedules. Explosion protection includes: suppression systems, isolation devices
  3. Housekeeping Programs – Clearly defined cleaning frequencies and specific protocols for hard-to-reach areas.
  4. Employee Training – Hazard awareness, safe handling and storage practices, and emergency response protocols.
  5. Documentation – DHA records, operating procedures, and maintenance and inspection logs.

Combustible Dust Support

Combustible dust may be a hidden hazard, but its consequences are anything but. With OSHA intensifying its inspection efforts through the NEP and the upcoming consolidation of NFPA standards into NFPA 660, now is the time for facilities to reassess their risk management strategies.

Cardinal Compliance Consultants partners with organizations to demystify compliance, reduce risk, and build a culture of safety. Whether you’re preparing for an inspection, conducting a DHA, or upgrading your facility’s controls, our team is ready to help you take the next step with confidence.

For any combustible dust guidance or support, contact us to get connected with an EHS consultant.

Our Services Include:

  • Dust Hazard Analysis (DHA) – Performed by qualified professionals, our consultants identify combustible dust risks in processes, equipment, and building design and provide comprehensive documentation to support NFPA 660 compliance.
  • Program Development & Implementation – From creating housekeeping plans to preventative maintenance protocols and written dust safety management programs, we’ve got you covered.
  • Engineering Controls & System Review – We evaluate your dust collection systems, explosion vents, isolation valves, and grounding/bonding and support in implementing effective engineering solutions.
  • Customized Training for Employees & Supervisors – Customized, hands on training classes covering: hazard recognition, safe handling of combustible materials, emergency response, and communication procedures.
  • Regulatory Inspection Readiness – Beginning with mock OSHA inspections and gap assessments (aligned with OSHA and NFPA expectations), we provide guidance on electronic recordkeeping and documentation.
  • Continuous Improvement Support – Offering routine program audits, scheduled DHA reviews (per 5-year requirement), and integration with existing EHS or process safety programs, you can feel secure in meeting your goals.


from Cardinal Compliance Consultants https://cardinalhs.net/blog/combustible-dust-hazards-nfpa-660-compliance/
via Cardinal Compliance Consultants

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