Combustible Dust: Who Can Require a Dust Hazard Analysis and What It Has to Contain
Who can require a combustible dust hazard analysis: OSHA, the fire code, NFPA 660 and your insurer. What each one demands, and what the analysis must contain.
A property carrier asks for a dust hazard analysis. A fire marshal’s report cites one. Corporate EHS issues a directive naming one. The first thing to settle is which of those documents you are answering, because the obligations behind them come from four separate authorities with four different consequences for combustible dust, and the four do not carry the same weight. Federal OSHA has no combustible dust standard for general industry at all. The fire code, where your jurisdiction adopted a recent edition, does have a requirement with legal force. NFPA 660 holds the actual technical requirements and binds nobody by itself. Your insurer does not need a standard.
Facilities that skip this step buy the wrong scope. A dust hazard analysis written to satisfy an inspector looks different from one written to close out a loss control recommendation, and a plant that commissions the wrong one pays twice.
Four parties can demand a dust hazard analysis, and only one of them has to prove anything
OSHA has to document every element of a General Duty Clause case before it can cite you. Its own enforcement directive tells compliance officers that “OSHA may only cite for violations of OSHA standards, section 5(a)(1), and OSHA regulations (such as recordkeeping)” (CPL 03-00-008, effective 01/30/2023).
A fire marshal enforcing International Fire Code Chapter 22 proves nothing, because the code text already says the requirement applies. Section 2203.2 reads: “The requirements of NFPA 652 apply to all new and existing facilities and operations with combustible dust hazard.”
NFPA 660 carries the requirement itself in Chapter 7, and it is a consensus standard. It becomes binding through fire code adoption, through a contract, or through a policy condition.
An insurer proves nothing either. It can reprice the risk or decline it.
What is a dust hazard analysis?
NFPA 660 Chapter 7 defines the deliverable: a documented evaluation that determines whether each process part, building and building compartment presents a dust flash fire or explosion hazard, identifies ignition scenarios, and records action items requiring changes to materials, operations, equipment, safety systems or facilities. Section 7.2.3.2 requires the results be kept for the life of the process.
The contents are specific enough to write into a scope of work. Determine whether each dust you handle is combustible or explosible, by test data or defensible published data. Evaluate every part of the process, and document each part that meets the criteria as a dust flash fire or explosion hazard under Section 7.3.3.3. Do the same for buildings and for building compartments under Sections 7.3.4.3 and 7.3.4.4, where confinement makes a compartment an explosion hazard rather than only a flash fire hazard. Identify ignition scenarios, including the self-heating evaluation that Section 5.3.1.1(3) triggers when the analysis finds a self-heating scenario. Include electrostatic hazards involving flexible intermediate bulk containers, which Section 9.6.6.4.1 routes back into the Chapter 7 analysis. Then record action items under Section 7.2.3. An analysis that lists hazards and recommends nothing will not close out with an insurer and will not satisfy an authority having jurisdiction.
Does OSHA require a dust hazard analysis?
No. CPL 03-00-008 states OSHA “may only cite for violations of OSHA standards, section 5(a)(1), and OSHA regulations,” and no standard names a DHA. The rulemaking that would have created one, RIN 1218-AC41, was withdrawn in the Spring 2017 Unified Agenda “due to resource constraints and other priorities.” Inspectors still request your DHA and perform their own.
The closest thing to a federal mandate is grain specific and it is a written program, not an analysis. 29 CFR 1910.272(j)(1) requires that “The employer shall develop and implement a written housekeeping program that establishes the frequency and method(s) determined best to reduce accumulations of fugitive grain dust,” and 1910.272(b)(1) applies that to grain elevators, feed mills, flour mills, rice mills, dust pelletizing plants, dry corn mills, soybean flaking operations and the dry grinding operations of soycake.
Not having an analysis is not itself a violation. The conditions an analysis would have found almost always are.
Authority one: federal OSHA, which has to build the case from borrowed parts
Enforcement runs through the General Duty Clause and through standards that were written for something else. The NEP directive states that “A citation under section 5(a)(1) of the OSH Act (the General Duty Clause) may be issued for fire, flash fire, deflagration, and explosion hazards,” and that “General Duty Clause citations can only be issued where all elements of a 5(a)(1) violation are documented.” Hazard, industry recognition, feasible abatement and serious harm, each proven. The directive also tells inspectors that NFPA standards, NFPA 654 among them, can supply the evidence of industry recognition. That is how a consensus document becomes an enforcement exhibit without becoming law. NFPA 654 content now lives in NFPA 660.
The agency tried to close the gap with a standard and quit. The CSB rulemaking watch records an advance notice published October 21, 2009, a small business review panel postponed from April 2011 to December 2011 to October 2013 to November 2013 to April 2014, a downgrade to long-term action in the Fall 2014 agenda, a brief upgrade in May 2015, and then the March 30, 2017 withdrawal. Nine years later nothing has replaced it. Anyone selling you readiness for a coming OSHA dust standard is selling preparation for something that was abandoned in 2017.
The federal government’s own investigative body disagrees with that outcome. CSB Recommendation 2006-1-H-1, asking OSHA to “Issue a standard designed to prevent combustible dust fires and explosions in general industry,” is still open, as is Hoeganaes recommendation 2011-4-I-TN-2. The CSB’s 2006 study counted 281 combustible dust incidents between 1980 and 2005 that killed 119 workers and injured 718, and five further investigations after that study accounted for another 27 killed and 61 injured.
Inspection pressure through the program is measurable and it is falling. OSHA has run “about 600 inspections annually” under the dust program since 2007, a figure the agency published in January 2023. Read it against the inspection totals: federal OSHA ran 34,625 inspections in FY2024 including 17,170 programmed, and 30,273 in FY2025 including 13,962 programmed. Programmed inspections are the channel an emphasis program runs through, and that channel lost roughly 3,200 inspections year over year, a drop of about 19 percent. OSHA publishes no per-program breakdown, so the 600 figure should be read with that decline attached.
Which industries are on OSHA’s combustible dust inspection list?
Appendix B of CPL 03-00-008 lists the targeted NAICS codes, including 321113 Sawmills and 332322 Sheet Metal Work Manufacturing. The 2023 revision added six: 311812 commercial bakeries, 325910 printing ink, 321912 cut stock and resawing, 316110 leather tanning, 321214 truss manufacturing, 424510 grain and field bean wholesalers.
Targeting runs off that list in random order, and complaints, fatalities and catastrophes produce inspections regardless of list position. By material, OSHA’s own incident data points at wood and food first: in 2018, wood and food products made up an average of 70 percent of the materials involved in combustible dust fires and explosions. The practical trigger list for a plant manager is wood and cellulosic dust from sawing, sanding, routing or truss fabrication; metal dust and fines from grinding, polishing, deburring, machining or additive manufacturing; grain, flour, sugar, starch and feed dust; plastic and rubber dust from grinding and regrind; and powder coating overspray and recovered powder. Recovered powder in a booth, cyclone or hopper is a combustible particulate solid for analysis purposes, which is a separate question from the booth cleaning duties covered in paint booth cleaning and what OSHA 1910.107 requires.
The directive states that it “does not replace the grain handling facility directive, OSHA Instruction CPL 02-01-004, Inspection of Grain Handling Facilities, 29 CFR 1910.272,” but that “operations involving grain processing that are outside the scope of CPL 02-01-004 may be covered under this directive,” so a grain facility can face both. The scope of the program itself is covered in our walkthrough of OSHA’s revised combustible dust National Emphasis Program, and the 2026 emphasis program landscape in which industries OSHA’s emphasis programs target in 2026.
What does a combustible dust citation actually cost?
29 CFR 1903.15(d) caps serious and other-than-serious violations at $16,550 each and willful or repeated at $165,514, with a willful floor of $11,823. These amounts are in effect for 2026, unchanged from 2025. Real cases: $536,965 at a Nebraska grain elevator in 2024, $147,542 after a fatal Nebraska wood dust explosion in 2026.
The $16,550 figure also sets the per-day maximum for failure to abate, and the posting penalty. There is no 2026 escalation to plan around. OSHA’s May 21, 2026 memorandum states that “There are no inflation-based increases to OSHA civil penalties for 2026, so 2025 penalty amounts remain in effect for 2026,” because the Bureau of Labor Statistics “was unable to produce the required October 2025 CPI-U data” and the statute provides no alternative calculation. OMB M-26-11 is the governing instrument. Content telling you penalty maximums rose this year is wrong.
Because no single dust standard exists, citations stack. A dust inspection commonly produces findings across housekeeping at 1910.22(a)(1) and 1910.176(c), hazard communication at 1910.1200, electrical hazardous classified locations at 1910.307, flame-resistant clothing under 1910.132(a), powered industrial trucks at 1910.178, ventilation at 1910.94, welding at 1910.252 and signage at 1910.145, plus the General Duty Clause for dust collector, ductwork and deflagration venting deficiencies. Specialty standards come in by industry: 1910.263 for bakery equipment, 1910.265 for sawmills, 1910.261 for pulp and paper mills, 1910.107 for spray finishing, and Subpart E for egress.
Authority two: the fire code, where the requirement actually has legal force
International Fire Code Chapter 22, Combustible Dust-Producing Operations, is the provision that turns an analysis into an obligation. In the 2018 and later editions, Section 2201.1 brings equipment, processes and operations involving dust explosion hazards under the code and under NFPA 652. Section 2201.2 requires permits for combustible dust-producing operations. Section 2203.1 puts compliance on the owner or operator. Section 2203.2 is the hook: “The requirements of NFPA 652 apply to all new and existing facilities and operations with combustible dust hazard.” The same section adds that existing facilities shall have an analysis completed in accordance with NFPA 652 Section 7.1.2, and that “The fire code official shall be authorized to order a dust hazard analysis to occur sooner if a combustible dust hazard has been identified in a facility that has not previously performed an analysis.” Get the schedule from the AHJ, because the referenced section belongs to a standard NFPA no longer updates. Section 2203.3 prohibits smoking, open flame devices and spark-producing equipment. Section 2203.4 requires that “Accumulation of combustible dust shall be kept to a minimum in the interior of buildings” and states that “Forced air or similar methods shall not be used to remove dust from surfaces.” Table 2204.1 pulls in the commodity standards by reference.
Two things follow. First, if your jurisdiction adopted a 2018 or later edition, you have an enforceable analysis requirement and the official who enforces it is the fire marshal. Second, the code text still points at NFPA 652, which NFPA has folded into NFPA 660. Your authority having jurisdiction may be enforcing a document NFPA no longer updates. Get the edition and the referenced standard from the AHJ in writing, by email, before anyone scopes work.
Does my state require a dust hazard analysis through the fire code?
IFC Chapter 22 Section 2203.2 states “The requirements of NFPA 652 apply to all new and existing facilities and operations with combustible dust hazard,” so the answer turns on which International Fire Code edition your jurisdiction adopted. Oklahoma moved to IFC 2018 and then to IFC 2024, effective September 14, 2026, and Colorado adopts IFC 2021. Kansas’s state code adopts the 2006 edition. Missouri has no statewide fire code at all.
This is the variation that matters, and it is fire code variation rather than OSHA variation. None of Kansas, Missouri, Oklahoma, Nebraska, Texas or Colorado has an OSHA-approved State Plan covering private employers (OSHA State Plans). Federal OSHA has jurisdiction over most private sector workers in all six, so CPL 03-00-008 and the 2015 accumulation depth memorandum apply identically across the region with no state amendments layered on top.
The fire code side diverges sharply:
| State | Adopted fire code | Carries the Chapter 22 analysis requirement? |
|---|---|---|
| Kansas | K.A.R. 22-1-3 adopts the International Fire Code, 2006 edition, excluding chapters 22, 30, 33, 34, 35, 36 and 38 | No. The 2006 edition predates the NFPA 652 reference. Its dust chapter is Chapter 13, which is adopted but contains no analysis requirement. A local jurisdiction on a newer edition is a different answer and has to be checked individually |
| Oklahoma | OAC 748:20-4-1(a) now adopts the International Fire Code, 2024 Edition, first printing October 2023, effective September 14, 2026. It replaced the 2018 Edition, second printing, adopted at the same rule number | Yes. Chapter 22 is not separately amended and is not on OUBCC’s non-adopted list, so it applies as published. Ask the AHJ which consensus standard the 2024 Chapter 22 references, because the referenced standard is what your scope follows |
| Colorado | 8 CCR 1507-101 Section 3.2.2 adopts the International Fire Code, 2021 Edition, first printing October 2020. Rule 3.2 is currently effective 8/14/2025 | Yes within Division of Fire Prevention and Control jurisdiction. DFPC’s direct reach is limited, so local adoption governs most private manufacturing |
| Missouri | None. The Division of Fire Safety states “Missouri does not have a statewide fire code” and directs facilities to the local jurisdiction | No statewide hook. A Kansas City or St. Louis plant can carry a hard requirement while a plant in an unincorporated county carries none |
| Nebraska | Title 153 Chapter 1 adopts NFPA codes by reference rather than the IFC. The published chapter is too old to establish current adopted editions | Not confirmed. Verify directly with the Nebraska State Fire Marshal before relying on any Nebraska fire code claim. Both enforcement cases below are Nebraska facilities, so this gap is not academic |
| Texas | No statewide fire code applicable to private manufacturing was located. The State Fire Marshal’s Office states that state-adopted NFPA editions “do not automatically override local building or fire codes” and routes conflicts to the local AHJ | Local only. Ask the municipal fire marshal. A large Texas city can be on an older edition than the state’s NFPA adoptions, so the municipal fire marshal is the only reliable answer |
Authority three: NFPA 660, which holds the requirement and binds nobody on its own
What is the current NFPA combustible dust standard?
NFPA 660, 2025 edition, Standard for Combustible Dusts and Particulate Solids, published December 2024 per CSB. NFPA’s own page states it “is a combination of Standards NFPA 61, NFPA 484, NFPA 652, NFPA 654, NFPA 655, and NFPA 664.” Status is Active, and the next revision cycle moved up to Fall 2027.
CSB records the document as published in December 2024 in its Horizon Biofuels investigation update. First revisions for the next edition were submitted through the first half of 2026.
Are NFPA 652 and NFPA 654 still valid?
Both pages still read “Status: Active” on nfpa.org, but each states the standard “has been combined into new consolidated Standard NFPA 660” and that the listed current edition is “the last published edition of the standard’s content as a stand-alone standard.” NFPA 652 stops at 2019, NFPA 654 at 2020. Neither page uses the word withdrawn.
Practitioners say withdrawn. NFPA’s own site does not. The consequence runs the other way from a wording quibble: because the fire code text still references NFPA 652, a jurisdiction can be enforcing a standard that NFPA has stopped revising, while your consultant works from NFPA 660. That is a real scoping conflict and the AHJ resolves it, in writing.
How often does a dust hazard analysis have to be redone?
Every 5 years. NFPA 660 Section 7.1.4: “The DHA shall be reviewed and updated at least every 5 years.” Section 1.4.3 adds a trigger outside that clock: when renovating, modifying or adding to an existing facility, equipment or process, the standard applies to the affected portion, which forces a re-look before the 5 years run.
The Chapter 8 retroactivity clause is the one that catches existing plants: “This chapter shall be applied retroactively to new and existing facilities and processes where the DHA has determined that a combustible dust or particulate solid fire, flash fire, or explosion hazard exists.” That one is conditioned on the analysis having found a hazard, which makes the analysis the gate that opens it. Chapter 10, emergency planning and response, is not conditioned that way. Section 10.1 applies the chapter retroactively “to new and existing facilities and processes” outright, so emergency planning duties do not wait on a DHA.
One caution on dates. We could not confirm a calendar deadline for existing facilities to complete a first analysis under the 2025 edition from NFPA’s own site, because the full text sits behind an NFPA sign-in. The 5-year review interval at 7.1.4, the qualified-person rule at 7.2.2, the documentation duties at 7.2.3 and 7.2.3.2, the Chapter 8 retroactivity clause and the Section 1.4.3 modification trigger are all confirmed from NFPA-hosted documents. A specific compliance-by date is not. If a vendor quotes you one, ask which section of the 2025 edition it comes from, and do not accept the three-year schedule from the superseded NFPA 652.
Who is qualified to perform a dust hazard analysis?
NFPA 660 Section 7.2.2 requires the DHA and subsequent 5-year reviews to be “performed or led by a qualified person” with documented experience and education in DHA methods. The standard sets no license or certification. Require documented qualifications in the proposal, because an insurer or AHJ rejecting the author voids the deliverable.
Authority four: the insurer and the corporate parent, where the obligation is contractual
Why is my insurer asking for a dust hazard analysis when OSHA has no dust standard?
Because a carrier does not need a standard. OSHA must prove industry recognition and feasible abatement for every 5(a)(1) citation, per CPL 03-00-008. An insurer only has to price or decline the risk. That asymmetry is why DHA requests arrive on carrier letterhead years before an inspector appears. Scope the DHA to the loss control recommendation.
Corporate EHS programs work the same way and frequently impose an analysis across every site regardless of local code, because the parent signs the budget. Neither obligation is regulatory, and either can demand more than NFPA 660 does. A loss control recommendation letter is the governing document for the work it asks for, so read it line by line and price against it. We could not quantify how much of total analysis demand comes from carriers against regulators from any primary source, so treat the pattern as practitioner observation rather than a statistic.
Where the dust depth numbers come from
Is the 1/32 inch dust layer an OSHA limit?
No. It appears in an OSHA memorandum dated April 21, 2015, not in any standard, and the memorandum states interpretations “cannot create additional employer obligations.” It assumes a bulk density of 75 lb/ft3 and must be adjusted for the actual dust. Citations issue under 29 CFR 1910.22 or 1910.176(c), never under the depth figure itself.
The memorandum is titled “Evaluating Hazardous Levels of Accumulation Depth for Combustible Dusts” and its stated purpose is “to provide guidance in calculating the levels of dust accumulations that may be allowed at workplaces for combustible dusts with bulk densities less than 75 lb/ft3.” It says the thickness “is based on certain assumptions, including uniformity of the dust layer,” gives an equation that adjusts layer depth for the actual bulk density, and tells compliance officers they “should take into consideration the bulk density of the dust in question prior to determining if a violation” exists. Light dusts get a deeper allowable layer. The memorandum notes that “Very low bulk density materials, such as tissue paper dust, may not create a deflagration hazard.” The emphasis program directive does not contain the number at all. It points inspectors to the memorandum.
The 5 percent figure that travels with it is also not OSHA’s. The memorandum attributes the method to NFPA 654, 2013 edition, Section 6.1.3.2, the Layer Depth Criterion Method, under which a dust explosion hazard and dust flash fire hazard are deemed to exist in any building or room where total non-separated accumulations above the layer depth criterion exceed “five percent of the footprint area,” or where a single accumulation exceeds “1000 ft2,” with parallel volume tests. The memorandum expressly notes it “does not discuss Mass Methods A and B or the Risk Evaluation Method,” so the layer depth method was one option among several even inside NFPA 654.
What that means when the citation arrives: the charge is written under 1910.22(a)(1), 1910.22(a)(2) or 1910.176(c). The memorandum confirms those citations “can be issued without the bulk density determination.” The number is how OSHA builds the case. Arguing the number without arguing the standard loses.
How much grain dust can accumulate before OSHA cites you?
1/8 inch. 29 CFR 1910.272(j)(2)(ii) requires immediate removal of fugitive grain dust “whenever they exceed 1/8 inch (.32 cm) at priority housekeeping areas,” unless the written program assures equivalent protection. Priority areas per (j)(2)(i): within 35 feet of inside bucket elevators, enclosed grinding areas, enclosed areas with indoor grain dryers.
That is the only codified numeric dust accumulation limit in Part 1910. If you run a grain elevator or a feed mill, the number is in the Code of Federal Regulations and you comply with it or demonstrate equivalent protection through the written program. If you run a sawmill or a machine shop, 1/32 inch is a calculation method and the inputs are contestable.
The two Nebraska cases, and why the grain elevator cost more than the fatal explosion
At Legacy Cooperative’s Hemingford, Nebraska grain elevator, investigators found the company “permitted more than one-eighth inch of grain dust to accumulate in priority housekeeping areas” and failed to maintain effective dust collection. The case closed at 2 willful and 22 serious violations, 24 citations, and $536,965 in proposed penalties, announced October 3, 2024.
At Horizon Biofuels in Fremont, Nebraska, an explosion on July 29, 2025 at approximately 11:56 a.m. ignited “a large release of combustible wood product, most likely wood dust from the process” and killed three people, “an operator and his two young daughters, aged 8 and 12,” per the CSB investigation update. OSHA announced citations February 10, 2026 for combustible dust buildup, failure to ensure equipment was protected from creating an ignition source, and a fall protection item, characterized willful and serious, with $147,542 in proposed penalties.
A housekeeping case with no injuries drew more than three and a half times the penalty of a three-fatality explosion. The reason is in the regulations: 1910.272(j) gives OSHA a number in the CFR and 1910.22 does not. Both facilities sit inside iSi’s drive market.
There is a documented remediation template for the aftermath. CSB closed all nine Didion Milling recommendations on August 12, 2026, nine years after the May 2017 Cambria, Wisconsin explosion that killed five employees and seriously injured 14 others. What satisfied the board: a dust hazard analysis performed with industry experts to guide the design, construction and upkeep of dust-handling equipment and the building housing it; a combustible dust management program addressing safety leadership and culture; engineered safeguards matched to the facility’s dust hazards; and improved continuity of operations, emergency response and PPE programs. That list works as a scope definition for a plant that wants to get ahead of this.
What will inspectors look for in a combustible dust inspection?
The directive tells compliance officers what to collect, and the sequence matters. Targeting comes off the Appendix B list in random order, built from a Dun and Bradstreet extract against the Appendix B NAICS codes, and the directive requires each area office to keep its generated establishment list on file for three years. A facility can come off it after a recent inspection with no dust citations, after a follow-up verified abatement, or through participation in one of OSHA’s cooperative recognition programs. Complaints, fatalities and catastrophic incidents override list position.
On arrival, inspectors establish history: fires, flash fires, deflagrations inside vessels and buildings, and explosions. They interview employees, review OSHA logs, pull insurance claims, access local fire department records, and look for discoloration, bulging, repairs and missing or damaged appendages on equipment. They read your safety data sheets for combustible dusts. They ask for electrical area classification drawings covering Class II Division 1 and Division 2 areas. Under 1910.307(b), areas designated under the Class and Division system must be properly documented if they were established after August 13, 2007, and the directive tells inspectors to review those drawings.
Then they do their own dust hazard analysis, near the end of the inspection, to support the citation rather than at the beginning to set scope. Observation surfaces are horizontal structures, conduits and pipe racks, cable trays, floors, above suspended ceilings, and equipment surfaces, especially elevated ones. They take depth measurements and area dimensions, and they bring cameras on poles to reach high places. If you have your own analysis, they collect it.
Sampling goes to the OSHA Salt Lake Technical Center. Collect side-by-side samples at the same locations. Without your own data you are arguing against the agency’s lab with nothing.
The control checklist they work through narrows to a short list of decisions. Explosion prevention or suppression and deflagration propagation prevention on dust collectors and dust handling equipment. Protection on any system returning clean air to an occupied building. Equipment that handles, transports or stores dust designed and maintained against leakage. Cleaning by vacuums rated for the dust class, with compressed air kept under 30 psi with chip guards where it is used at all, and remembering that the fire code prohibits forced air for dust removal from surfaces outright. Ductwork conductive, bonded and grounded, with proper transport velocity and cleanout ports. Magnetic or tramp metal separators in the process stream. Electrical equipment, lighting and powered industrial trucks rated for the classified area. An ignition control program that names hot work and hot surfaces, bearings, self-heating materials, open flames, fuel-fired and heated process equipment, frictional and impact sparks, electrical equipment and electrostatics. Documentation they will ask for includes process flow and piping diagrams, room dimensions, dust collector make, model, serial number, installation date and operator manuals, dirty and clean side volumes, engineering controls, and the warning signage on equipment and entrances.
What to do when the request lands
Pull your primary NAICS code and check it against Appendix B. If it is listed, assume you are in the programmed pool.
Identify who is asking. A fire marshal letter, an OSHA inspection, a carrier loss control report and a corporate directive produce four different scopes, and you scope to the document in hand.
Email the AHJ and ask which fire code edition and which referenced standard they enforce. The answer decides whether your analysis is legally required or advisable.
Determine the combustibility of every dust you handle, by test or defensible published data, before anything downstream.
Commission the analysis with a qualified person leading it under Section 7.2.2, require documented qualifications in the proposal, and require a prioritized corrective action list in the deliverable under Section 7.2.3.
Put dust in your hazard communication program. 1910.1200 treats combustible dust as a hazardous chemical, so drums, bins and cyclone outputs carry labels and your SDSs carry the combustible dust hazard statement.
Write a housekeeping program with a frequency and a method attached to each area, verify electrical area classification against the drawings that prove it, close the ignition control loop, and calendar the 5-year review with a re-run triggered by any renovation or process change. Retain results for the life of the process.
The housekeeping half of that list is where most plants stall, because the work is high, confined, and has to be done with equipment rated for the dust. iSi’s industrial cleaning crews handle elevated structural dust removal, dust collector and ductwork interiors, and the documentation that proves the cleaning happened, which is the part an insurer reads. If a carrier letter or a fire marshal finding is on your desk now, a conversation with a same-day response will establish which of the four authorities you are answering before anyone writes a scope. Facilities that also need the inspection-readiness side can start with our safety consulting services.
Sources
All verified October 14, 2026.
- OSHA Directive CPL 03-00-008, Revised Combustible Dust National Emphasis Program, effective 01/30/2023: https://www.osha.gov/sites/default/files/enforcement/directives/CPL_03-00-008.pdf
- OSHA NEP directives index: https://www.osha.gov/enforcement/directives/nep
- OSHA news release, revised Combustible Dust National Emphasis Program, January 27, 2023: https://www.osha.gov/news/newsreleases/osha-trade-release/20230127
- OSHA memorandum, Evaluating Hazardous Levels of Accumulation Depth for Combustible Dusts, April 21, 2015: https://www.osha.gov/laws-regs/standardinterpretations/2015-04-21
- 29 CFR 1903.15, Proposed penalties: https://www.ecfr.gov/current/title-29/part-1903/section-1903.15
- OSHA memorandum, 2026 Annual Adjustments to OSHA Civil Penalties, May 21, 2026: https://www.osha.gov/memos/2026-05-21/2026-annual-adjustments-osha-civil-penalties
- 29 CFR 1910.22, Walking-working surfaces, general requirements: https://www.ecfr.gov/current/title-29/part-1910/section-1910.22
- 29 CFR 1910.176, Handling materials, general: https://www.ecfr.gov/current/title-29/part-1910/section-1910.176
- 29 CFR 1910.272, Grain handling facilities: https://www.ecfr.gov/current/title-29/part-1910/section-1910.272
- 29 CFR 1910.307, Hazardous (classified) locations: https://www.ecfr.gov/current/title-29/part-1910/section-1910.307
- 29 CFR 1910.1200, Hazard communication: https://www.ecfr.gov/current/title-29/part-1910/section-1910.1200
- OSHA State Plans: https://www.osha.gov/stateplans
- OSHA FY2025 current enforcement summary: https://www.osha.gov/enforcement/current-enforcement-summary
- OSHA FY2024 enforcement summary: https://www.osha.gov/enforcement/2024-enforcement-summary
- OSHA news release, Horizon Biofuels Inc., Fremont NE, February 10, 2026: https://www.osha.gov/news/newsreleases/dallas/20260210
- DOL news release, Legacy Cooperative, Hemingford NE, October 3, 2024: https://www.dol.gov/newsroom/releases/osha/osha20241003
- NFPA 660 standard development page: https://www.nfpa.org/codes-and-standards/nfpa-660-standard-development/660
- NFPA 652 standard development page: https://www.nfpa.org/codes-and-standards/nfpa-652-standard-development/652
- NFPA 654 standard development page: https://www.nfpa.org/codes-and-standards/nfpa-654-standard-development/654
- NFPA 660 F2027 First Revision Report, CMD-FUN: https://docinfofiles.nfpa.org/files/AboutTheCodes/660/660_F2027_CMD_FUN_FD_FRReport.pdf
- NFPA 660 F2024 Second Draft Second Revisions Report, CMD-FUN: https://docinfofiles.nfpa.org/files/AboutTheCodes/660/660_F2024_CMD_FUN_SD_SRReport.pdf
- NFPA 660-2025 Proposed TIA Log No. 1803: https://docinfofiles.nfpa.org/files/AboutTheCodes/660/Proposed_TIA_1803_NFPA%20_660.pdf
- NFPA Correlating Committee on Combustible Dusts, consolidation minutes, March 25, 2022: https://docinfofiles.nfpa.org/files/AboutTheCodes/654/660_CMD_AAC_ConsolidationMins_03_22.pdf
- CSB, Horizon Biofuels investigation update, September 17, 2025: https://csb.gov/assets/1/20/horizon_biofuels_investigation_update_2025-09-17_final_public.pdf
- CSB, Drivers of Critical Chemical Safety Change fact sheet, Combustible Dust: https://www.csb.gov/assets/1/6/csb_cdl_fact_sheet_-_combustible_dust.pdf
- CSB combustible dust recommendations status page: https://www.csb.gov/recommendations/combustible-dust-recommendations/
- CSB Rulemaking Watch, OSHA’s combustible dust rulemaking: https://www.csb.gov/recommendations/mw/dust/regwatch/
- CSB news release, Didion Milling recommendations closed, August 12, 2026: https://www.csb.gov/us-chemical-safety-board-closes-didion-milling-recommendations/
- Reginfo.gov Unified Agenda, RIN 1218-AC41, Combustible Dust, Spring 2017: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201704&RIN=1218-AC41
- International Fire Code Chapter 22, Combustible Dust-Producing Operations: https://www.seattle.gov/documents/Departments/SDCI/Codes/SeattleFireCode/2018SFCChapter22.pdf
- K.A.R. 22-1-3, Kansas Fire Prevention Code adopted codes and standards: https://www.law.cornell.edu/regulations/kansas/K-A-R-22-1-3
- Oklahoma OUBCC, OAC 748:20 permanent rule adopting IFC 2018: https://oklahoma.gov/content/dam/ok/en/oubcc/documents/rules/2021%2009%2014%20Permanent%20Rule%20IFC%202018.pdf
- Oklahoma OUBCC 2024 IFC pending rules: https://oklahoma.gov/content/dam/ok/en/oubcc/documents/2024-pending-rules/2024%20IFC%20Pending%20Rules.pdf
- 8 CCR 1507-101 Article 3, Colorado DFPC codes incorporated by reference: https://www.law.cornell.edu/regulations/colorado/title-8/agency-1507/division-101/article-3
- Missouri Division of Fire Safety FAQ: https://dfs.dps.mo.gov/about/faqs.php
- Nebraska State Fire Marshal, Title 153 Chapter 1: https://sfm.nebraska.gov/sites/default/files/doc/title153-ch1.pdf
- Texas State Fire Marshal’s Office FAQ: https://www.tdi.texas.gov/fire/fmfaq.html