OSHA Combustible Dust Standards: Memphis Compliance Guide

If your Memphis facility handles materials that create dust—whether it's wood, metal, food products, or plastics—you need to understand OSHA's combustible dust requirements. Non-compliance can result in hefty fines and, more importantly, put your workers at serious risk.

What is Combustible Dust?

Combustible dust is any fine material that can catch fire and explode when mixed with air. This includes dust from:

• Wood and paper products – sawdust, cardboard particles
• Food processing – flour, sugar, grain dust, spices
• Metals – aluminum, magnesium, titanium dust
• Plastics and rubber – polymer dust from manufacturing
• Textiles – cotton, wool, synthetic fiber dust

When these particles accumulate on elevated surfaces like rafters, ductwork, and overhead pipes, they become a serious fire and explosion hazard.

OSHA and NFPA 652: The Key Standards

While OSHA doesn't have a specific combustible dust standard, they enforce requirements through the General Duty Clause (Section 5(a)(1)) and reference NFPA standards in citations.

NFPA 652 (Standard on the Fundamentals of Combustible Dust) is the primary standard that affects Memphis facilities. Key requirements include:

The 1/32 Inch Rule (NFPA 654)

NFPA 654 (Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids) provides specific accumulation limits. The key threshold is 1/32 inch of dust over 5% of the floor area. To put this in perspective, 1/32 inch is about the thickness of a paperclip wire.

The limit can be adjusted based on dust bulk density—lighter materials may allow slightly thicker accumulations, while heavier materials require stricter limits. For "negligible" hazard classification, accumulations must be 1/64 inch or less.

The challenge for Memphis warehouses and manufacturing facilities is that dust accumulates on surfaces that are difficult to see and reach:

• Ceiling rafters and trusses
• Overhead piping and conduit
• HVAC ductwork and vents
• Light fixtures and cable trays
• Top surfaces of equipment and machinery

Penalties for Non-Compliance

OSHA takes combustible dust seriously. As of January 2025, facilities can face fines of:

• $16,550 per violation for serious violations
• $165,514 per violation for willful or repeated violations

Beyond fines, combustible dust explosions can result in fatalities, facility destruction, and criminal charges. According to the U.S. Chemical Safety Board, there were 281 combustible dust incidents between 1980 and 2005 (excluding grain facilities), resulting in 119 deaths and 718 injuries. More recently, the U.S. averages approximately 29 dust explosions per year.

How Memphis High Dusting Can Help

Our specialized high-reach cleaning services are designed specifically for combustible dust compliance. Here's what sets us apart:

Getting Started with Compliance

If you're unsure about your facility's combustible dust status, here are the steps to get compliant:

1. Conduct a Dust Hazard Analysis – Identify all materials in your facility that could create combustible dust
2. Assess Current Conditions – Check dust accumulation levels on elevated surfaces
3. Establish a Cleaning Schedule – Create a documented housekeeping program
4. Partner with Professionals – Work with a certified high-dusting contractor for hard-to-reach areas

Memphis High Dusting offers free compliance assessments for facilities in Shelby County and the greater Memphis area. We'll inspect your overhead surfaces and provide recommendations for meeting OSHA and NFPA standards.