A recent agency memo provides OSHA compliance safety and health officers (CSHOs) with guidance on determining whether manufacturers and importers have properly classified their products for combustible dust hazards under the revised Hazard Communication (HazCom) Standard.
OSHA released its revised HazCom Standard, aligning it with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS), in March 2012. Because GHS does not currently contain a classification for combustible dust hazards, OSHA amended the definition of "hazardous chemical" to include combustible dust in its HazCom Standard to maintain coverage of combustible dust hazards.
According to the memo, where there is evidence that a product has been involved in a deflagration or dust explosion event, it should be classified as a combustible dust. Further, if results of accepted tests are available for a product, it should be classified in accordance with those results. But if a product has not been involved in a deflagration or explosion event and test data is unavailable, manufacturers and importers may use published test data on similar materials or use information on particle size to determine a product's combustible dust hazard.
Read the memo on OSHA's website.