What an SDS Doesn’t Tell You About Combustible Dust

If you work with powders, fibers, or bulk solids, you’ve probably seen a Safety Data Sheet (SDS) for the materials you handle. The SDS is meant to be the go-to resource for hazard information, flammability, toxicity, reactivity, health effects, and more. But when it comes to combustible dust, the SDS often raises more questions than it answers. Too often, they read more like a marketing brochure than a technical document.So, what happens if you don’t read between the lines?

The Risks of Ignoring Combustible Dust Hazards

1. Worker Injuries and Fatalities

• Burns, blast trauma, and smoke inhalation are the most immediate risks.
• Long-term health issues may result from exposure to airborne particulates.
• Incidents erode trust, morale, and retention among employees.

2. Equipment and Facility Damage

• Explosions can destroy dust collectors, ductwork, silos, and processing equipment.
• Shock waves may compromise building integrity.
• Recovery requires downtime, machinery replacement, and costly reconstruction.

3. Regulatory and Legal Fallout

• OSHA citations: OSHA has cited companies under the General Duty Clause for combustible dust hazards, even when SDSs were vague.
• NFPA non-compliance: NFPA 660 requires facilities to conduct a Dust Hazard Analysis (DHA). Failing to comply can be considered negligence.
• Civil and criminal liability: Injuries or fatalities can trigger lawsuits, insurance disputes, or even criminal charges.

4. Financial Consequences

• Direct costs: equipment replacement, medical expenses, regulatory fines.
• Indirect costs: lost production, supply chain disruption, increased insurance premiums.
• Long-term costs: reputational damage, loss of customer confidence, potential shutdowns.

This worksheet will help the user conduct a cost benefit analysis for conducting a Dust Hazard Analysis and implementing a Combustible Dust Safety Program.

5. Lost Opportunities for Prevention

• If you don’t know your dust is combustible, you miss the chance to implement simple, cost-effective measures, like housekeeping, grounding, explosion venting, or inerting systems, that could prevent catastrophe.

What Most SDSs Miss About Combustible Dust

Red Flags to Watch For in Safety Data Sheets (SDS)

When reviewing an SDS, phrases like these should raise concern:

• “Stable under normal conditions”
• “Not classified as flammable or explosible (in solid form)”
• “Avoid whirling or creating dust clouds”
• “May form combustible dusts when finely divided”
• “Explosion hazard, Not Available / No Data”

Each of these signals a potential blind spot that warrants further review of your safety practices.

The Basics: What an SDS Must Provide

By law, manufacturers and importers must prepare an SDS in a standardized 16-section format. For combustible dust, the most relevant sections are:

• Section 2: Hazard Identification
  May include “may form combustible dust concentrations in air.” OSHA requires this if the hazard is known.
• Section 5: Firefighting Measures
  Lists extinguishing media such as water fog, foam, or CO₂, guidance aimed at bulk fires, not dust explosions.
• Section 9: Physical and Chemical Properties
  Provides particle size, bulk density, or volatility, but rarely the explosion data you actually need (MEC, Kst, Pmax).
• Section 10: Stability and Reactivity
  Often repeats generic language like “when finely divided, dust may form explosive mixtures with air.”
• Section 16: Other Information
  Sometimes the only place a vague dust warning appears.

The Limits of SDS Data for Combustible Dust Hazards

SDSs almost never include the technical test data required to design or verify explosion protection systems. Missing values often include:

• Minimum Explosive Concentration (MEC)
• Maximum Explosion Pressure (Pmax)
• Deflagration Index (Kst)
• Minimum Ignition Energy (MIE)

Instead, you’ll typically see the catch-all disclaimer:

“This product, is not classified as flammable or combustible as shipped, avoid creating suspended clouds when finely divided”

That wording applies equally to flour and to aluminum powder, yet the risks and protective measures are completely different.

Why the Gaps Exist

• Testing is expensive. Full combustible dust testing can cost thousands of dollars.
• Not legally required. OSHA’s HazCom standard mandates a hazard statement but not detailed explosion data.
• Manufacturers play it safe. To avoid liability, suppliers often add generic disclaimers, meeting the legal bare minimum without providing actionable detail.

How to Identify and Manage Combustible Dust Hazards

If you expect an SDS to fully define combustible dust hazards, you’ll be disappointed. Instead:

1. Use the SDS as a starting point. Treat it as initial guidance, not the final word.
2. Check known lists. NFPA, OSHA, and industry case studies identify many commonly combustible materials.
3. Request or commission testing. For significant quantities of powder, get lab data for Kst, Pmax, MIE, and MEC. Know your dust.
4. Conduct a Dust Hazard Analysis (DHA). Required under NFPA 660, a DHA evaluates actual facility conditions, not just paper hazards.

Get a FREE Dust Hazzard Analysis quote

FAQs About SDS and Combustible Dust

Q: Is every powder or fiber considered a combustible dust?
A: Not necessarily. Combustibility depends on particle size, concentration, and ignition source. Testing provides definitive answers.

Q: Can I rely on the SDS for combustible dust data?
A: No. Most SDSs lack critical values like Kst or Pmax, so lab testing and a DHA are essential for safety and compliance.

Q: Who regulates combustible dust hazards?
A: OSHA enforces safety under the General Duty Clause, while NFPA 660 provides the technical standard for Dust Hazard Analysis.

Key Takeaways on SDSs and Combustible Dust Safety

An SDS can hint at combustible dust hazards if you know what to look for, but it won’t tell you how hazardous your material truly is. Think of it like a smoke alarm: it warns of possible danger, but it doesn’t tell you how big the fire will get.

For real protection, you need proper testing, engineered safeguards, and a comprehensive Dust Hazard Analysis.

About the Author

Eric spent 15 years in manufacturing before coming to Hallam-ICS in 2021. He is a project manager working on a variety of engineering projects and a combustible dust/hazardous materials specialist. He enjoys being outdoors and wood working. Eric sits on the board of directors for a local non-profit, Clean Jordan Lake, who organize trash clean ups across 180 miles of shoreline and public recreational areas. 

 Read My Hallam Story

About Hallam-ICS

Hallam-ICS is an engineering and automation company that designs MEP systems for facilities and plants, engineers control and automation solutions, and ensures safety and regulatory compliance through arc flash studies, commissioning, and validation. Our offices are located in Massachusetts, Connecticut, New York, Vermont North Carolina  and Texas and our projects take us world-wide.