National Fire Protection Association Blog

Earlier closing dates for paper submission of public input and comments

As NFPA continues to move forward with implementation of the Standards Development Process, many of the new benefits of online submission process continue to take hold.  When Public Input/Comments are submitted online the proposed changes are integrated in-line on the draft document.  Once the closing date has passed online submissions allow the Committee Members to see all of the proposed changes integrated into one complete document virtually immediately, maximize the amount of time each Committee Member has to review all of the proposed changes and prepare for any upcoming committee meeting.  However, while we want to provide as much extra time as possible to our Committee Members, we also want to consider the needs of those who still want to submit their Public Input/Comments on the “paper forms” via e-mail, fax or mail.  Beginning with the Fall 2014 submittals of Public Comments, we have implemented an earlier closing date for “paper submissions” of Public Input/Comments.  The earlier closing date will allow the necessary time to key and proof any proposed change to ensure the changes are presented for Committee consideration at the same time as the changes submitted online. 

Paper Submission Closing Dates.  The closing date for paper submissions, (this includes forms sent via e-mail, fax or mail), for the Fall 2014 comments will be October 11, 2013 and the closing date for the electronic submission system will be  November 15, 2013.  All revised schedules can be located on the respective document information page or http://www.nfpa.org/schedules.

Please be advised, that it is anticipated that in the future, “paper submissions” will not be accepted so please take this opportunity to try out the new system – we think you’ll really like it!  As always we are here to help you participate in the NFPA process.  If you have any questions or concerns please contact us at 617-984-7240 or via email at standardsdev_support@nfpa.org .

For additional information on NFPA Standards Development Process, please visit NFPA’s website at www.nfpa.org/newprocess.

OSHA publishes new resource to protect emergency responders from fires involving combustible dust

Monday, April 1st, the Occupactional Safety and Health Administration published Firefighting Precautions at Facilities with Combustible Dust. The primary purpose of this document is to outline safe procedures for emergency responders who may be face fires in facilities with combustible dust. The document describes how combustible dust explosions occur and uses previous incidents to illustrate how firefighting operations can prevent combustible dust explosions. The document explains the preparations emergency responders can make before a response and how these preparations will affect the operational plan during a response.

For more information on OSHA visit www.osha.gov and OSHA's Combustible Dust web page.

 

Industry's Hot Topic: Fundamentals of Combustible Dusts

Since the Standards Council approval to enter into a revision cycle, the NFPA 652, Standard on Combustible Dusts, draft entered into revision cycle, Fall 2014, and was open for Public Input (PI).  Now that the closing date has past, we finally tallied the number of PIs for NFPA 652. The final count is 470 PIs!

To receive this much input reminds us the impact that the document will have on the industry. It also shows how involved the industry is with our standards development process. Having the industry involved at the birth of a new standard is great as it will only strengthen the docuemnt and make it more applicable to the "real world". The Technical Committee (TC) meets at NFPA in a month (February 12-14) for an exciting First Draft Meeting.

Read the December issue of NFPA News, our free codes and standards newsletter

The December issue of NFPA News, our codes and standards newsletter, is now available.

In this issue:

• Animal Housing Facilities Committee Restructuring
• Comments sought on proposed TIAs on NFPA 13R, 25, and 58
• TIAs issued on NFPA 25, 30B, 51, 55, 101, 1983, and 2001
• Errata issued on NFPA 1582
• NFPA 1965 processed as consent document
• New document drafts approved for NFPA 475, 652, 951, and 1072
• Public input closing date for Fall 2014 documents
• Committees seeking members
• Committees soliciting public input
• Committee meetings calendar

NFPA News is a free newsletter, and includes special announcements, notification of public input closing dates, requests for comments, notices on the availability of Standards Council minutes, and other important news about NFPA’s standards development process.

Free subscription
Sign-in on NFPA’s web site and then select “NFPA News” from your e-mail options.

What are the fundamentals of combustible dusts?

With the request to enter into a revision cycle approved by the Standards Council, the Preliminary Daft of NFPA 652, Standard on Combustible Dust, is now accepting public input until January 4, 2013.  The big question circling this document, what are the fundamentals of combustible dusts?

 Fundamentals

If you were to go through the different NFPA dust standards, you will notice similar requirements.  The requirements may not be exactly the same throughout the standards, but the general underlying ideas are there.

The Technical Committee (TC) started the draft out with four main chapters that circle around four basic concepts in each of the dust standards: hazard identification, hazard assessment, hazard management, and management systems.

 Hazard Identification

The very first thing you are going to do is to Identify whether a hazard exists in your facility. Before getting overwhelmed by the combustible dusts standards, you need to determine if the dust in your facility is a combustible dust and if it presents a flash-fire or explosion hazard.  Can the dust burn? Yes, then you will need to determine if it can cause a flash-fire and/or explosion.  To determine if the the dust can present an explosion hazard, the simplest test that can be performed is known as the “go/no-go” test or ASTM E 1226 Standard Test Method for Explosibility of Dust Clouds.  Further tests may be required based on the hazard management methods you wish to use in your facility.  Knowing whether the dust in your facility has a potential for a flash-fire or explosion hazard is essential to determine where you need to go next within the standard and the other standards.  If you do not properly manage the hazards, you are increasing the chance (or risk) of an incident occurring in your facility. 

 Hazard Assessment

After identifying whether the dust in your facility can present a fire, flash-fire, or explosion hazard, the next step to assess the type of hazard you have and where these hazards exist.  The method can be as simple as going through your facility and determine where these hazards exist and develop a means in which they can be managed (see hazard management).  Simply, this method of accessing your facility for hazards  is known as a process hazard analysis. A process hazard analysis (or PHA) is not intended to be complex analysis requiring a facility to hire consultants.  There are many ways to preform this analysis and the TC is developing some guidance to better help the user understand how to perform a PHA. However, if you do not know the hazards or process equipment well enough to make informed decisions, it wouldn’t hurt to have a 3^rd party assist in the review.

 Hazard Management

These are going to be your tools on how to manage the different hazards in the facility: building construction, explosion protection, equipment construction, ignition source control, housekeeping, etc.  There are requirements that will apply to the facility itself and different pieces of equipment.  Some will not apply to your particular facility and other requirements will give you different options that you can apply.

Management Systems

The last major concept when dealing with combustible dusts is management systems.  Management systems cover operating procedures, inspection, testing and maintenance of equipment, training for employees and contractors, emergency planning, incident investigation, management of change, and document retention. Basically, make sure that you use and maintain your equipment properly, train your employees and anyone working in your facility, investigate fire and explosion incidents, keep constant documentation, and procedures for managing any changes in the process, equipment, material, facility, etc.

 

When taking a high-level view at the concepts in each of the dust standards, there are basic concepts that standout no matter what type of dust your facility has. 

The Fundamentals of Combustible Dusts Committee goes to the Standards Council with a preliminary draft.

“Are we at 80%?” The chair kept asking the Technical Committee during their meeting in late August.

The Technical Committee (TC) on the Fundamentals of Combustible Dusts (CMD-FUN) met to finish work on a preliminary draft to submit to the Standards Council. Their goal was to have a draft of a document that was close to completion, about 80%. This 80% was a milestone that the Committee set for themselves inorder to stay on track with the development of the new standard on the fundamentals of combustible dusts.

Driving this draft forward will allow the public to submit input and comments sooner for the Committee to consider, making this document stronger in the end.

 All new documents must get approval from the Standards Council before entering into a revision cycle.  This will allow the preliminary draft to enter into a revision cycle and to solicit input from the public.  The Committee was able to get the preliminary draft submitted in time for the October Standards Council Meeting (Agenda Item 12-10-15).

 

Coming Soon: NFPA 652

Be prepared to submit your input to the draft on the fundamentals of combustible dusts, pending the Standard Council approval to enter into cycle.

Why is there a technical committee on the fundamentals of combustible dusts?

 

Courtesy Fike Corp. From Deflagration Vent Demonstration at NFPA Combustible Dust Symposium 2010

 

A Brief Background:

In 2003, three major explosions occurred in separate industries and involved three different types of combustible dusts: polyethylene, phenolic resin, and aluminum.  These incidents sparked a study by the U.S. Chemical Safety and Hazard Investigation Board (CSB), Combustible Dust Hazard Investigation.  The study identified 281 incidents involving combustible dust between 1980 and 2005 that resulted in 119 deaths and 718 injuries. 

From this investigation (and others that followed), the CSB recommended to facilities that handle, store, use, process, and/or generate any type of combustible dust follow the NFPA dust standards. In addition, the CSB recommended that Occupational Safety and Health Administration (OSHA) develop a comprehensive regulatory standard that protects employees from combustible dust fires and explosions based on current NFPA standards.  Some of the major concerns that came out of the OSHA stakeholder meetings for the development of a comprehensive dust standard were:

• NFPA dust documents have some inconsistencies between them
• NFPA standards can be confusing to implement
• NFPA standards provide little guidance on the “how” part of the requirements
• Impact to small businesses

There are other concerns about the adoption of NFPA dust documents, but I believe these to be the key factors that started NFPA to consider a restructure of the current Dust committees.

 

NFPA Dust Technical Committee Restructure:

Currently, NFPA develops five major dust standards that target specific dust types:

• NFPA 61, Standard for the prevention of fires and dust explosions in agricultural and food processing facilities
• NFPA 484, Standard for Combustible Metals
• NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids
• NFPA 655, Standard for Preventing Sulfur Fires and Explosions
• NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities 

These five documents are the responsibility of four technical committees:

• CMD-AGR: TC on Agricultural Dusts (NFPA 61)
• CMD-CMM: TC on Combustible Metals and Metal Dusts (NFPA 484)
• CMD-HAP: TC on Handling and Conveying of Dusts, Vapors, and Gases (NFPA 91, 654, and 655)
• CMD-WOO: TC on Wood and Cellulosic Materials Processing (NFPA 664)

Following the OSHA stakeholder meetings, NFPA staff made a request to restructure the current NFPA dust committees and documents.  The Standards Council in the March 2010 Standards Council Meeitng (Minute Item 10-3-19) voted to publish the notice to solicit comments from the public regarding the restructing of the NFPA dust committees and documents.

The following Standards Council meeting in August 2010 (Minute Item 10-8-36), the Standards Council reviewed the public input of the request to restructure the NFPA dust committees and documents, and established a task group to consider the issues and determine the best option for NFPA dust committee and documents. 

The task group consisted of the current chairs of the four dust committees, four additional representatives from the four dust committees, NFPA staff and a Standards Council member.  They met in early 2011 and from that meeting came up with recommendations and sent them to the Standards Council.  The following was the Standards Council's decision at the March 2011 Meeting (Minute Item 11-3-24):

• Establish a Technical Correlating Committee (CMD-AAC) to oversee the work of the 4 dust committees and the proposed new committee
• Establish a Technical Committee on the fundamentals of combustible dusts (CMD-FUN)
• Task CMD-FUN with development of a new document that contains general requirements used to prevent and protect users of combustible dust from fires and explosions AND directed users to the appropriate industry or commodity-specific standard

The correlating committee’s role over the next few years is to help make the dust documents more consistent with each other while taking into account there will be differences due to industry specific processes and hazards. The fundamental committee's role over the next few years is to develop a draft to solicit public comment and from that a standard that contains general requirements used to prevent and protect users of combustible dust from fires and explosions and directed users to the appropriate industry or commodity-specific standard.

Balance:

For all NFPA technical committees, each committee member is assigned a classification based on their principle interest in the activity of the Committee. The interest classifications that NFPA uses to categorize the committee members are:

• Manufacturer
• User
• Installer/Maintainer
• Labor
• Applied Research/Testing Laboratory
• Enforcing Authority
• Insurance
• Consumer
• Special Expert

No more than 1/3 from any interest category can make up a committee.  This is the key to keeping the balance of the NFPA technical committees. There was one other element when establishing the Technical Committee on the Fundamentals of Combustible Dusts, ensuring proper representation from the different industries that deal with combustible dusts.

From all the applications and over the course of the year (2011), the Standards Council appointed 28 voting members, 6 alternates, and 2 representatives from OSHA.  From these members, the representation from the different industries are as follows:

Again, balance is the key in this technical committee that has been tasked with the development of a standard to develop the general requirements for all combustible dusts and then direct the users to the industry and commodity-specific standard.

 

What's going on now?

Both CMD-AAC and CMD-FUN have submitted their scope for approval from the Standards Council at the August 2012 Meeting.  Additionally, the fundamentals committee has been working over this past year on a draft document to present to the Standards Council.

Fundamentals of Combustible Dusts? Yes, we have that.

It has been almost a year since the formation of the Technical Committee on the Fundamentals of Combustible Dusts.  Since its formation, the committee has begun work to develop a document on the fundamentals of combustible dusts. 

What is “Fundamentals of Combustible Dust”?

When handling, storing, conveying, processing, or doing pretty much anything with a combustible particulate solid, there is a chance that you could be creating some unwanted or fugitive dust in your facility.  This dust can present not only a fire hazard but also an explosion hazard under the right conditions.  You will turn to NFPA to figure out how to handle these hazards.

 Currently, NFPA develops five major dust standards that target specific dust types:

• NFPA 61, Standard for the prevention of fires and dust explosions in agricultural and food processing facilities
• NFPA 484, Standard for Combustible Metals
• NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids
• NFPA 655, Standard for Preventing Sulfur Fires and Explosions
• NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities

On your lazy Sunday when reading your favorite NFPA standards and while drinking your favorite beverage, you may notice that with the major dust documents there are several key themes throughout the different standards. Starting out the committees goals with this document will be the following:

• Developing key requirements to reduce the hazards associated with combustible dusts
• Developing a road map to direct you to the proper dust document

NFPA wants to make it easier for anyone involved with the combustible dust hazard to know the basic requirements to avoid the hazards associated with combustible dust and to point them to the correct document that is applicable to their industry/dust type.  This was a perfect opportunity for a new committee.

What is the Committee doing?

The Committee met up at the beginning of this year to begin work on a draft document.  From this meeting, the committee had established that some basic elements to prevent dust fires and explosions:

• Hazard Identification - Do you have a combustible dust?
• Hazard Assessment – If combustible dust is present does a hazard or hazards exists?
• Hazards Management – How do you manage the hazards?
• Management Systems – Maintaining the management programs and procedures

Keeping up the Fundamentals:

The TC on Fundamentals of Combustible Dust will be meeting August 14 through 16 in Kansas City, MO.  Here they will be finishing their draft to present to the Standards Council to release to the public.  Interested in what this committee is doing, send me an email.