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What Fire Marshals Look for: Dust Accumulation on Rafters

4 min readMemphis High Dusting Team

Fire marshals in Shelby County and across Tennessee take combustible dust seriously. Understanding what they look for during inspections can help you avoid citations, fines, and most importantly—prevent fires.

The Dust Accumulation Threshold

According to NFPA 654, immediate cleaning is required when dust accumulation reaches 1/32 inch (about the thickness of a paperclip) over 5% of the floor area. This includes dust on:

  • Overhead beams and joists
  • Ductwork and piping
  • Tops of equipment and machinery
  • Light fixtures and cable trays
  • Any horizontal surface where dust settles

Important: The 5% Rule

For facilities over 20,000 square feet, the threshold changes to a maximum of 1,000 square feet of dust coverage—regardless of the percentage. Most Memphis warehouses and manufacturing facilities exceed this size, making the absolute limit more restrictive.

Why Dust on Rafters Is Dangerous

Combustible dust explosions often occur in two stages, which is why overhead accumulation is so dangerous:

  1. Primary Explosion: An initial ignition occurs in equipment or a confined space
  2. Secondary Explosion: The shockwave dislodges dust from rafters and overhead surfaces. When this dust becomes airborne and ignites, the secondary explosion is often far more destructive than the first.

According to the U.S. Chemical Safety Board, secondary explosions have caused numerous fatalities and catastrophic facility damage across the country.

What Fire Marshals Inspect

During a fire safety inspection, marshals will check:

Visible Dust Accumulation

Inspectors will look at rafters, ductwork, and equipment tops for visible dust layers. They may use a white glove test or simply visual observation.

Housekeeping Program

You should have documented cleaning schedules and records showing regular dust removal from elevated surfaces.

Sprinkler System Clearance

Fire suppression equipment must be clean and unobstructed. Dust on sprinkler heads can prevent proper activation during a fire.

Cleaning Methods

Inspectors may ask how you clean overhead areas. Compressed air is prohibited—only HEPA vacuuming or wet methods are acceptable.

Common Citation Triggers

Memphis facilities often receive citations for:

  • Visible dust accumulation exceeding 1/32 inch on overhead surfaces
  • No documented housekeeping program for elevated areas
  • Using compressed air or dry sweeping to remove dust
  • Blocked or dust-covered sprinkler heads
  • No Dust Hazard Analysis on file (required by NFPA 652)

How to Prepare

Before your next fire marshal inspection:

  1. Schedule professional high dusting to remove all accumulated dust
  2. Establish a documented cleaning schedule for overhead areas
  3. Ensure your cleaning contractor uses HEPA vacuums (not compressed air)
  4. Keep records of all cleaning activities
  5. Complete a Dust Hazard Analysis if you handle combustible materials

Memphis High Dusting provides fire code compliant cleaning with full documentation. Contact us to schedule service before your next inspection.

Frequently Asked Questions

What dust level triggers fire marshal citations?

Fire marshals cite facilities when dust accumulation exceeds 1/32 inch over 5% of floor area, or 1,000 square feet for facilities over 20,000 sq ft, per NFPA 654 standards.

Why is dust on rafters dangerous?

Dust on rafters creates secondary explosion risk. When a primary explosion occurs, the shockwave dislodges overhead dust. This airborne dust ignites, causing a secondary explosion that's often more destructive than the first.

What do fire marshals check during inspections?

Fire marshals check for visible dust accumulation, documented housekeeping programs, sprinkler system clearance, and verify that approved cleaning methods (HEPA vacuuming, not compressed air) are being used.

Need Help With Combustible Dust Compliance?

Our certified team can assess your facility and develop a cleaning plan that meets OSHA and NFPA requirements.

Get a Free Compliance Assessment