Panel Discussion | Current Status of NFPA 660 Development - Part 1

Today’s episode of the Dust Safety Science podcast features a panel discussion on the current status of NFPA 660. This is based on a panel discussion from the second day of the 2024 Global Dust Safety Conference held in March. We will feature the replay in two parts. This week, we’ll cover the first part, which includes background information on combustible dust standards, the reasons behind the rewrite into NFPA 660, and the current standards. We’ll also address the primary concern from the audience about NFPA 660 potentially burdening their work in the industry.

Next week, we’ll play the second part, focusing on specific audience questions about topics like additive manufacturing, retroactivity of dust hazard analysis, international standards considerations, checklists, and templates. We’ll also discuss using NFPA 660 as a technical reference.

Today’s session focuses on the upcoming changes and roadmap for NFPA 660. We have an excellent panel:

Kevin Kreitman, chair of the NFPA Combustible Dust Correlating Committee, based in Middlesbrough.
Dr. Ashok Dastidar, chair of NFPA 654 from Foster and Associates in Chicago.
Dr. Timothy Myers, chair of NFPA 61, principal engineer, and office director at Exponent. He will give a keynote on lessons from large-scale incident investigations.
Jason Krbec, Director of Business Development for CV Technology and member of NFPA committees 68 and 69, among others.

Today’s Q&A session on NFPA 660 will address the need to resolve contradictions between current NFPA standards. This effort is partly driven by the OSHA rule making notice from 2009 and recommendations from the US Chemical Safety Board. NFPA 652 provides a general framework for assessing combustible dust hazards and connects to standards like 61, 655, 484, 664, and 654, which cover specific materials and industries. The challenge has been to harmonize these standards and remove any contradictory statements.

In NFPA 652, you might face differences compared to standards like NFPA 61 for wood processing dust. This is why bringing these under one document, NFPA 660, was necessary. Other relevant standards include 68, 69, and 70, which cover explosion prevention, protection, and electrical codes. The goal of NFPA 660 is to combine these standards into one document, making it easier to manage and update them to avoid contradictions.

The first version of NFPA 660 was released two years ago, followed by public input, leading to the first draft. Last year, Jason Krbec and Laura Moreno presented on this draft. Now, the committee is reviewing public comments to create a second draft, which will be released on October 4, 2024. The final stage involves another round of public input, known as the NITMAM (Notice of Intent to Make a Motion), where unresolved issues can be addressed at the NFPA Technical Committee meeting in June 2025. If there are no NITMAMs, NFPA 660 could be rolled out by the end of this year. Now, let’s start the panel discussion!

Panel Discussion- Part One

Chris: Thank you, everyone, for joining this panel session. Some of our panelists are currently attending the NFPA Technical Committee meetings, so I appreciate them taking the time to be here. We’ve had a few panels on this topic before, and I’m excited to discuss it again.

Let’s start with a roundtable while we gather questions from the audience. I’d like each panelist to introduce themselves, tell us which committee they chair or are involved in, and provide some background on that committee. Jason, we can discuss NFPA 68 and 69 in your case since they play a crucial role in NFPA 660’s development.

Please also mention how many members are on your committee, which industries typically work with that standard, and what the development process has been like up to now. We’ll begin with Kevin, then move to Tim, Ashok, and finally Jason. Kevin, you’re on the correlation committee, so let’s start with you. What committee are you involved in, and what has the process been like to get us to where we are today with NFPA 660?

Kevin Kreitman: I started on NFPA 44 in 1998, and the work on NFPA 660 really began around 2000. In 2011, the Standards Council recommended bringing all the dust standards together under one group, leading to the creation of NFPA 652, which covers the fundamentals. This was when the idea of developing a correlating committee came up, and I was asked to chair it.

The correlating committee was formed to look at all the individual dust standards, find overlaps, and address inconsistencies. The work done by the correlating committee from 2011 until now laid the groundwork for developing NFPA 660. By identifying and addressing overlaps and inconsistencies, we set the stage for the current efforts on NFPA 660.

Chris: Thanks for highlighting that. The groundwork goes back even further than 2011, but that’s when the initial efforts began. Just to clarify the timeline, when did the push to combine the standards into NFPA 660 start? Was it in 2011, or did it happen later?

Kevin: Yes, the push to combine the standards started when the Standards Council approached the correlating committee around 2019 or 2020. They asked us to consider how to best merge the documents. There was a lot of discussion and we formed a task group with several chairs and team members.

Based on requests from the Standards Council, we developed the process we’re following today. Just as we were about to move forward, the pandemic hit. We had one of our last meetings right before the pandemic began, which slowed things down a bit.

Chris: We got faster as we learned how to hold remote meetings instead of in-person ones. I like sharing this background because some of the 150 people checked in now might be hearing about NFPA 660 for the first time. We also have attendees from 28 countries, including Canada and the US, so it’s important to provide context. A lot of effort has gone into this process.

Dr. Myers, could you talk about the committee you’re part of and the journey to get to where we are with NFPA 660?

Tim Myers: I’m the chair of NFPA 61, which covers agricultural dust. This standard was one of NFPA’s first combustible dust standards, established over 100 years ago. When NFPA 652 came out, the committee for NFPA 61 worked hard to ensure NFPA 61 could still be used as a standalone document, incorporating everything from NFPA 652 so facilities wouldn’t need to refer to both.

With the shift to NFPA 660, NFPA 61 now includes only the information unique to agricultural dust, while the core content is in the general chapters (1 through 10) of NFPA 660. This was a significant change for the committee members, as there was debate about whether this approach would complicate things for users by making them refer to different sections for specific details. However, for industries already dealing with multiple standards (like wood, plastic, and metal), consolidating the information into one document simplifies things.

Chris: Yeah, that makes sense. Dr. Dastidar- Ashok- can you explain a bit about NFPA 660?

Ashok: The names for the standard have changed a few times over the years. Its origins go back to the early 1930s, primarily focusing on polymers and plastics. The concept of combustible or explosive dust being a hazard has been understood in the industry for about 100 years and in the scientific community for at least two centuries.

Originally, NFPA 654 focused on plastics and fine chemicals. When NFPA 652 was developed, it was found to duplicate much of what was in NFPA 654. In fact, some of the initial drafts of NFPA 652 were based on NFPA 654. As we worked on consolidating the standards, we realized many fundamental principles of combustible dust clouds in NFPA 654 were also covered in NFPA 652.

In creating NFPA 660, we’ve eliminated much of the duplication from NFPA 654, making it one of the shortest chapters now. NFPA 660 serves as a catch-all standard. We’re consolidating and simplifying the documents to reduce confusion about which one to use. As we identify unique aspects of different materials—like agricultural products, wood, metals, polymers, resins, and plastics—we will add specific details back in to address these nuances.

Chris: That makes a lot of sense. If someone wants access to NFPA 660, we’ll show you how. You can find an overview with the conference replays in the Dust Safety Academy. There will be a module called NFPA Workshop, NFPA 660 Workshop, or NFPA 660 Information. It includes about a dozen videos of me walking through NFPA 660 and at least four hours of various experts discussing different sections of it. This content will cover at least the version from two years ago and will be available with the conference replays next week.

Jason, I’d like to get your input on the correlating committee and how NFPA 68 and 69 contribute to the development of NFPA 660.

Jason Krbec: Thanks, Chris. I’m glad to be here. Kevin does a great job leading our correlating committee. Right now, we’re finalizing the alignment within the different chapters of the fundamental section and wrapping up any loose ends. This is what we’re focusing on at the NFPA meetings this week and in the coming weeks for the commodity-specific chapters. We’re going through the correlating committee notes and public comments to ensure alignment between chapters and finalize the fundamentals section by removing duplicate content from the commodity-specific standards.

We started this effort seriously in 2019. The definition of what is fundamental has been debated across different committees because of the varying perspectives from each commodity standard. As we work on this, some revision cycles for commodity standards were paused. The only one that continued was NFPA 484 (the metal standard), which went through a revision cycle in parallel with our work on NFPA 660.

NFPA 68 and 69 weren’t part of this consolidation process. These standards cover not just dust, but also vapors and gases. They continued their revision cycles independently and came out with new revisions during this process. While there’s been some alignment, NFPA 68, 69, and 67 have mostly observed the development of NFPA 660 from a distance because they operate independently. They focus on the methods for implementing explosion prevention and protection across different scenarios.

Chris: Let’s dive into some questions from the audience. We gathered questions through LinkedIn and our email channel. If you have a question about NFPA 660, how it impacts you, or anything you’ve heard, now is the time to ask. We’ll spend the next 35 minutes on this part of the panel discussion, so please put your questions in the chat or Q&A.

The top concern from our polls was that NFPA 660 might place a major burden on the industry. Let’s address this, starting with Kevin, who oversees the oversight committee. Kevin, do you have any comments on whether NFPA 660 will place more burden on the industry and what that might look like over the next 1 to 5 years?

Kevin: I don’t think so. The goal from the beginning has been to create a document that’s easier for the industry to use. This direction came strongly from the Standards Council and the correlating committee. They emphasized the need to ensure that the fundamentals chapter only includes essential elements, now found in chapters 1 through 10 of NFPA 652.

The new layout allows you to find what you need more easily. If you’re looking at the fundamentals in chapters 1 through 10, and then you need specifics for metals, you only refer to the metals chapter. Everything you need is in one place without needing multiple standards.

The aim is to make NFPA 660 more user-friendly, not more difficult. Although it will take some time to get there, we’re working hard to achieve this. The chairs and team members have invested a lot of time and effort into this project. As people start using and getting familiar with the new document, they’ll see it’s much easier to understand and apply to their specific areas.

Chris: Absolutely. I didn’t get to play the video from a previous panel session, but I made one explaining how to train people on combustible dust using NFPA 660 compared to the old standards. With NFPA 660, someone can spend an hour reading chapters 1 to 9 for a good overview of combustible dust, and then spend 20 minutes on the specific sections for metals or grain. Today, it’s nearly impossible to do the same thing with the old standards. Instead of reading whole documents like NFPA 61 or 484, which takes a long time and requires mentally matching the differences, NFPA 660 simplifies the process.

I’ll try to include that video in the NFPA training module in the Dust Safety Academy. Does anyone else have comments on the impact of NFPA 660 as it rolls out over the next 12 to 18 months?

Tim: Jason mentioned that during this consolidation process, there have been fewer changes and less new material added to the standards than usual. So, there won’t be many new requirements for facilities. It’s mainly about how the material is organized and simplified. The committees have worked hard to eliminate the need for facilities to analyze differences between standards themselves. We’ve done that work for them.

This new approach will evolve over time. In future cycles, you’ll see more consolidation and less content in the individual chapters. However, there will always be some need for differences in the commodity-specific standards.

Chris: Yeah, it makes a lot of sense to me. Any other input from the group?

Ashok: To add to what Jason and Tim said, this effort has focused on making things easier to use, not on adding compliance hurdles. Instead of buying multiple volumes, you’ll have one comprehensive document. If your business changes and you start working with metals or wood dust, you won’t need to find and learn a new standard—everything you need will be in the same volume from the start.

Chris:That makes sense. Anything you want to say, Jason?

Jason: Ashok explained it well. When people ask me about the impact on their facility and what changes they need to make, I like to use an example. If you run an engineered lumber facility, the impact isn’t significant. You’ll just be using a different standard, but the content from NFPA 664 is still there. It might be reorganized, with some parts in the fundamentals section, but it’s all included.

For industries that previously had to refer to multiple standards, like a pet food facility, this consolidation is particularly beneficial. Before, they might have needed to look at NFPA 61, 654, and 652, which could be confusing. Now, everything is streamlined in the new NFPA 660. For example, the management of change requirements are clearly outlined in one place, rather than spread across different standards.

The main benefit of this consolidation is ease of use, as Kevin mentioned. It simplifies the process and makes it easier to find the information you need.

Chris: That makes a lot of sense. There are some administrative questions about public input, so I’ll direct this one to Kevin. Can you confirm if it’s too late to submit public comments on the latest draft of NFPA 660? Could you also explain where we are in the process of collecting public comments and what steps need to be taken before and what can be done now to influence the document’s development?

Kevin: Chris, one of your earlier slides covered this well. We’re currently reviewing comments from the second draft of NFPA 660. The Fundamentals Committee is doing this now, and in two weeks, the commodity-specific standards will review their second drafts. The comment period is closed, so the committees are addressing the public comments we’ve received.

Next, the correlating committee will review these comments to ensure everything is appropriately addressed. We’re through the public comment phase for now. The second draft report will be released in October. If someone has serious concerns, they can submit a NITMAM (Notice of Intent to Make a Motion) after the second draft is published.

Once NFPA 660 is adopted, we might move to shorter revision cycles, possibly less than the usual 3 to 5 years, to allow for quicker feedback and adjustments. For now, additional public comments are not accepted until the next cycle, except through the NITMAM process.

Chris: Yes, that makes sense. I’ll have the production team pull up the slide for clarity. There are two key points to note. First, public input has already been collected, and public comments have been submitted. Now, NFPA committee members are reviewing these comments and creating the next draft.

Public comments can only be made on previously submitted public inputs, and NITMAMs (Notices of Intent to Make a Motion) can only be based on public comments. This process ensures there’s an end to the revisions. For example, if someone suggests removing dust collectors from the standards, it needs to go through the proper review process.

So, while it’s too late to submit new public comments, you can still submit a NITMAM later this year. However, it must be based on previous public comments or inputs and aimed at changing the outcome of those specific issues. Is that a fair summary, Kevin?

Kevin: Yes, that’s correct. I would just add that one role of the correlating committee is to review public comments that were rejected by the committees. We gather and look at these to see if there’s anything that needs to be reconsidered.

Conclusion

The development and consolidation of NFPA 660 aim to simplify and streamline the combustible dust standards, making them more user-friendly for the industry. By combining multiple documents into one comprehensive standard, NFPA 660 reduces the need for facilities to navigate through several standards, thus easing compliance and training processes. The committees have put significant effort into ensuring the new standard is clear and practical without adding unnecessary burdens on the industry.

We appreciate the hard work of the committee members and the valuable input from the public. As we move forward, the goal remains to create a safer, more efficient framework for managing combustible dust hazards. Stay tuned for the rest of the panel discussion, where we will cover more topics and answer additional questions.

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.