In today’s episode of the Dust Safety Science podcast, we’re talking about the NFPA public comment workshop being hosted inside the Dust Safety Academy. We developed this workshop after our discussions with Laura Moreno in Episode #198, where we talked about understanding the public input process for NFPA 660.
This workshop ran during the first week of December, but you can still register to view the replays up until January 5, 2023, which is the due date for submitting public input for NFPA 660.
What is NFPA 660?
By developing NFPA 660, the standard for combustible dust, all previous combustible standards are being merged into one. Prior to that, we had NFPA 652, which outlined the fundamentals of combustible dust. Those are the basic things you need to do. Depending on the industry or commodity, you also had to refer to other NFPA standards. By developing NFPA 660, the goal is to eliminate conflicting requirements as well as the need for different standards and schedules.
Chapters 1 through 9 of this new standard will cover the fundamentals. Chapter 10 is currently reserved, and Chapter 11 will cover industry-specific standards. Information is grouped in a natural and intuitive style, so you can easily access and understand what you need to know about certain types of dust.
This is the big goal with NFPA 660- to combine all the other standards into that one document and use that as a tool moving forward to improve combustible dust safety.
Why Are We Running This Public Comment Workshop?
Our goal with this workshop is to develop high quality and constructive feedback for this public comment process. The focus here is on giving the option and clarifying the public comment process for those who don’t typically comment on NFPA standards and development. This includes:
- Insurance carriers
- Management and maintenance personnel at end-user sites and facilities
- Government inspectors
- Fire marshals
The goal is to gather other groups that would not normally provide feedback on the NFPA standards, and to provide them with a really simple set of instructions on how to do that during the workshop. We also want to make it easy for people to review documents. When we first used Terraview, which is the NFPA document viewer, it was quite overwhelming. There are at least 1000 pages with multiple appendices, making it difficult to know where to start, which is why we put this pre-workshop training material together.
What Does the Workshop Look Like?
When people registered, we sent them a survey to help us understand the following:
- What NFPA standards they use
- What sections they want to review and provide feedback on
- Whether they have provided feedback in the past
- What industries they work in
Once we analysed the results, we created the live workshop schedule. A week before the event began, we released pre-workshop material such as videos on how to review public comments from previous NFPA standards. We also supplied information and insights on:
- How to actually make public comments.
- What makes a good comment vs. one that the technical committee is not likely to review. This includes making the intention of your suggestion clear and providing substantiation on why that change should be made.
Attendees were able to make public comment submissions directly during the workshop or save up their notes and make public comments afterward.
Conclusion
NFPA 660’s next draft will be available in October 2023, followed by another round of public comment until January 4th, 2024. However, the public can only comment on input that has already been submitted and changes that have been made as a result of that input. You can’t bring anything new to the table in the next round.
In other words, if you have something specific you’d like to see covered or changed or identified in 660, you need to do it before January 5th. Again, if you don’t know how to do that or how to review the document, we give you all the instructions during the workshop, and all the replays are now available inside Dust Safety Academy. See you there!
If you have questions about the contents of this or any other podcast episode, you can go to our ‘Questions from the Community’ page and submit a text message or video recording. We will then bring someone on to answer these questions in a future episode.
Resources mentioned
Dust Safety Science
Combustible Dust Incident Database
Dust Safety Science Podcast
Questions from the Community
Dust Safety Academy
Dust Safety Professionals
Dust Safety Share
Organizations
NFPA
Previous Episodes
DSS198: Understanding the Public Input Process for NFPA 660 with Laura Moreno
DSS175: Update on Development of NFPA 660 & Impact on Industry with Jack Osborn
DSS128: NFPA 660-Upcoming NFPA Changes & What They Mean For Combustible Dust Safety with Jason Krbec, Part 1
DSS129: NFPA 660-Upcoming NFPA Changes & What They Mean For Combustible Dust Safety with Jason Krbec, Part 2
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