Panel Discussion | Current Status of NFPA 660 Development - Part 2

Today’s episode of the Dust Safety Science podcast is part two of a two-part series on a panel discussion on the current status of NFPA 660 development. This is a replay from the 2024 Global Dust Safety Conference that happened in March of 2024.

On day two, we had a keynote with several panelists discussing NFPA 660. They talked about its current status and what to expect in the next 12 months as it becomes a standard for combustible dust. In the second part of today’s episode, we’ll revisit the disclaimers from last week’s episode. These are important:

The opinions shared are those of the panelists and Dr. Chris Cloney not the NFPA.
Our discussion is subject to change because the committee members are still reviewing and voting on changes for the standard development.

How Do You See Additive Manufacturing Being Integrated Into NFPA 660?

Tim Myers: Yes, there’s been a lot happening with adding it to NFPA 484 or the metals chapter. Historically, this area has had significant issues. I know it’s been included in the first draft of NFPA 484, and work is continuing on it for the second draft. I’m not as familiar with what’s included in additive manufacturing in the fundamentals. Maybe Jason or Kev can provide more details on that.

To address your earlier question, I should mention that in the NFPA process, there’s an option for a Tentative Interim Amendment (TIA). This allows changes to be made to the standard outside of the regular cycle if there’s a new hazard or an error that needs to be addressed. Now, I’ll get back to the topic of additive manufacturing.

Chris Cloney: Yes, and I’ll add that, as Kevin mentioned, there might be tighter revision cycles after NFPA 660, allowing for more input. Initially, additive manufacturing mainly involved metals, but that’s changing. In the next few years, we might even be 3D printing food like hamburgers. So, it’s not just about metals anymore. Does anyone on the panel today have experience with how this is evolving?

Ashok Dastidar: Right now, the focus is on the metal chapter because of the fusion type of additive manufacturing. However, there are also situations where polymer plastic beads or powders are fused together with a resin additive or by melting. Eventually, I think we’ll see this covered in the fundamentals chapter as well, where handling powders and bulk materials, whether metals or plastics, will be addressed. Later, there will be specific chapters discussing the hazards and risks associated with different powders. Currently, this is still a developing technology, so many of the hazards and risks are still being evaluated.

Chris Cloney: That makes a lot of sense. We have a question about NFPA 820, the standard for fire protection in wastewater treatment and collection facilities. The question is, why isn’t NFPA 820 included in NFPA 660, especially since NFPA 820 specifically mentions the potential for dust explosions in a table? We have seen dust explosions in wastewater treatment plants, sludge dryers, and similar areas, indicating there’s a history of such incidents. Do any panel members have experience with NFPA 820 and discussions about incorporating elements of it into NFPA 660 in the future?

Kevin Kreitman: Yes, we’ve worked with NFPA 820 in wastewater treatment facilities. Currently, you follow the 820 hazard review and compliance process. If dust hazards come up, you refer to NFPA 652 or 654 to handle dust explosions and fires. In the future, for combustible dust hazards, you’ll reference NFPA 660 directly to address specific hazards, like those associated with Milorganite.

Chris Cloney: Excellent, thank you for that. Now, let’s talk about retroactivity. I have a question for you about this. How will moving to NFPA 660 affect the existing dust hazard analyses that I’ve done at my sites in the US? Will this change impact the work that has already been completed on-site?

Ashok Dastidar: For most people, the change won’t have a big impact. You should already have your dust hazard analyses (DHA) done for your facility, whether it’s under standards 61, 44, 654, or 664. If it’s a pre-existing facility or a new one, you need to have these analyses completed.

There won’t be many changes for most people because some DHA functions have moved to the fundamental section. However, some unit operations that were previously exempt might now be covered. We might still have ways to mark out exemptions, but they could change in the future.

Jason mentioned that in the past, multiple housekeeping components were listed in each standard, but now they might be consolidated into one unified methodology. So, if housekeeping was part of your DHA and commented on, it might take a slightly different approach now that it’s part of the fundamentals. You’ll just need to revisit it.

Since you’re doing your DHAs on a five-year cycle, when you come to your next five-year cycle, you’ll use NFPA 660 and incorporate the changes from your original DHA under standards 44 or 654 to the new 660 DHA.

Tim Myers: NFPA 61 is where you might see changes in retroactivity. Previously, it only required a DHA for the highest risk processes, like bucket elevators, in existing facilities. However, in the first and second drafts, there have been moves to expand this list to include more processes, and there have been public comments suggesting it should cover all processes. So, this is still evolving, and it’s unclear if it will remain retroactive for just certain processes, expand to more processes, or apply to all processes.

Chris Cloney: Thanks, Tim. I also saw that Guy Colonna, our NFPA expert and past presenter at the Dust Safety Conference, posted a note on the process in the chat. You can check that out.

Now, a question for Jason about VDI, the German standards for industry and combustible materials, and other international standards like IEC. Is there any discussion on integrating these into NFPA 660 or learning from them? You might touch on this in your presentation later, but how do we keep an eye on international standards to make NFPA 660 compatible or comparable? How does this influence the committee’s decisions?

Jason Krbec: Sure, that’s a good question. We do receive and consider input from members of international committees on various topics, including standards like VDI and others from around the world. It’s not just international standards; sometimes, we even face challenges with other NFPA standards. For example, we have ongoing issues with electrical classification questions and requirements from the electrical code that relate to dust, electrical components, ingress ratings, and potential ignition sources.

We get public comments from various entities on these matters, such as what should be included in SDS sheets or how the electrical code should apply to our components. We take all this input into account and try to harmonize with other standards. However, our primary focus is on our standards and what we believe is the best way forward.

Chris Cloney: Yeah, that makes sense. There are probably thousands of things to consider in this area, not all of them problems. Some involve harmonization, like applying standards across different areas and integrating the best practices from various places. For example, while we could recommend that all SDS sheets include certain information, NFPA doesn’t control SDS sheets globally, and there are things beyond our control.

Some decisions might be implemented by committees with different experiences, so there’s variation. The point is that the NFPA and VDI approaches, among others, involve large groups of experienced people working together to figure things out. So, when discussing how to adopt different standards, leaning on the expertise of these groups is a solid approach.

Jason Krbec: I’d like to add that many of the technical experts on our NFPA committees are also familiar with VDI, CEN, IEC, and ATEX standards. They bring this knowledge to our discussions, helping us consider what other organizations are doing globally. We look at whether our approaches are appropriate, if we need to improve, or if we’re being too strict.

Our members include not just technical experts but also end users, like food and polymer manufacturers with plants worldwide. They often face different standards in Europe and North America and look for ways to harmonize these requirements. This input is valuable during our technical meetings as we strive to align our standards with global practices.

Chris Cloney: Great points. We have a question about NFPA 660 and the timing for recommendations from a DHA. Let’s turn this over to Kevin. Will NFPA 660 provide more clarity on the timing for completing recommendations from a DHA?

This is something we’ve discussed at the conference. Currently, NFPA 660 and the fundamentals chapter still use a five-year cycle for dust hazard analyses. There’s no proposed change to this timeline. The proposal is to review the document and necessary actions within that five-year period.

If you already have a DHA, 660 doesn’t require immediate updates unless there are specific changes, like those related to agricultural dust. But overall, the language remains the same, maintaining the five-year review cycle.

Tim, do you have any additional comments on this?

Tim Myers: I think part of the question is about what to do when a DHA on an existing facility finds a hazard that wasn’t previously known or is not compliant with the current standards. Facilities might find themselves in a tricky spot where they know about a hazard, but fixing it could require significant capital expenditure. It’s not always clear if the standards require them to address this retroactively.

At this stage, we’re not adding any new language to resolve this issue. However, it’s a common problem when conducting a retroactive DHA. The standards do provide some guidance: if a new requirement comes out or you identify a hazard, you can’t be expected to make changes overnight, like installing a new dust collection system.

It’s understood that addressing significant issues can take time, especially when you need budget approval for large expenses. The standards suggest developing a plan to address these issues. When working with clients, we often recommend implementing interim controls, like administrative measures, to mitigate the risk until more extensive, capital-intensive solutions can be put in place.

Chris Cloney: Thanks, Tim. The example mentioned yesterday is spot on. If the recommendation is to clean up a spill with a dustpan and broom, it should be done immediately. However, if the recommendation is to install a $1 million dust collection system, the timeline will obviously be longer. This is the challenge with setting standards.

You made two important points. First, a reputable and experienced consultant doing a dust hazard analysis should provide implementation guidance. If they don’t, you should ask them about it when hiring. You need to know if they will just give recommendations or if they will also provide an implementation plan or risk ranking.

Second, if you’re dealing with a medium to high hazard, what are the intermediate steps you can take until a long-term solution is implemented? For extreme hazards, immediate action, like a plant shutdown, is necessary. For medium hazards, administrative controls can be put in place until the issue is fully addressed.

We have about five minutes left for questions, so keep them coming. Any additional comments from Jason, Kevin, or Ashok on the timing of DHA recommendations? Anything useful for the audience?

Ashok Dastidar: So one of the things, you know, you might come up with a list of recommendations from your DHA day and you’re looking at a timeline to implement. And of course, you have capital requirements and you have to go through corporate. But a lot of times it might be your AHJ that really defines your timeline. If they come in and look at it and say, listen, you know, having this stand out there for five years until you do your next day or or having it stand out there for three years to get your budget cycles going is not going to be acceptable. They’re going to sort of help you define whether it’s your insurance company, your fire marshal, building inspector, or your OSHA official. Somebody else might help you define that time horizon more so than the NFPA standard would or internal company policies.

Jason Krbec: I would add to what Ashok mentioned about the DHA. The standards themselves are just documents; enforcement depends on who adopts and enforces them. Often, NFPA standards are referenced in NFPA codes, the International Building Code, or fire codes, and sometimes by insurance companies. The Authority Having Jurisdiction (AHJ) applying the standard will often dictate what needs to be done.

Ashok made a good point. In the fire service, we’ve encountered situations where, despite a given timeframe, we determined a hazard needed immediate attention due to its severity. The AHJ typically drives these decisions based on the standards they follow.

Chris Cloney: Thanks for that. Greg mentioned in the chat that they implement interim safety measures until the final safeguards are installed, which is a good approach. We have a question about the checklist in NFPA 61, so I’ll direct this one to Tim. We have one or two questions left before we wrap up.

Tim, the 2020 version of NFPA 61 includes a significantly expanded checklist. Will this be carried forward into the new standard? What level of discussion has there been about this? I know NFPA 61 is the most complicated to integrate into NFPA 660, but is there any specific discussion about this checklist?

Tim Myers: Yes, we have task groups working on that. I don’t know exactly what will be in this edition of the standard, but there has been talk about adding more checklists for different types of agricultural facilities, like smaller grain elevators and more complex facilities. I think we’ll continue to see checklists, but I’m not sure if they’ll be expanded from what’s already there. Got it.

Chris Cloney: Excellent. Let’s wrap up with this question, as it’s a good way to conclude. Can NFPA 660 be used as a technical reference now, even before it becomes active? Let’s hear from Jason, Tim, Kevin, and Ashok on this, and any closing comments they have for the audience.

Jason, do you think using NFPA 660 as a technical reference now is useful? And do you have any closing comments for the group today?

Jason Krbec: I think it’s a bit too early to use NFPA 660 as a technical reference. We’re meeting this week and again in two weeks with the commodity standards. There will be changes from the last revision, and we need to go through the public comment stage. So, it’s a bit premature for that.

However, it’s coming soon. We’re likely less than 12 months away from having a finalized standard. The goal of this process is to create a better, easier-to-follow standard that improves safety across the board. It may take a few revision cycles to perfect it, but the final product is shaping up well.

Chris Cloney: Awesome. Any final words from you, Tim?

TIm: Yeah, I agree with Jason. Once it’s published after the second draft, people should start looking at it to see how it will impact them. There can be a delay between when NFPA publishes it and when local fire code officials adopt it. So, while the requirement may not be immediate, it’s a good idea to review it as soon as possible and start planning for any changes you’ll need to make.

Chris Cloney: Yeah, makes a lot of sense. Any closing words on your side, Kevin?

Kevin Kreitman: I agree with Jason and Tim that it’s too early to use NFPA 660 right now. Stick with the current documents for now. However, it’s a good idea to start familiarizing yourself with the new standard. As for using it, I’d wait until it’s finalized.

I also want to thank everyone working on this, especially the chairs and committee members. A lot of time and effort has gone into this, and we wouldn’t be here without them and the NFPA staff. A special shout-out to Guy Colonna for his vision years ago that has brought us to this point.

Chris Cloney: Thank you. I’m adding some emoji claps for Guy in the chat—three claps! Thank you, Guy, for your vision and involvement in the process. Ashok, any final words to close us out?

Ashok Dastidar: I just want to reiterate what the other panelists have said. This is a work in progress, and there will be some changes. Continue referring to the current standards that apply to you. However, start getting familiar with NFPA 660—it won’t be drastically different. One key point is that the electronic version of NFPA 660 might be easier to navigate than the paper version. So, as you learn about and use the new standard, try using the electronic version.

Conclusion

As we move forward, it’s essential to embrace both the current standards and the forthcoming changes represented by NFPA 660. While the transition period may present challenges, it also offers an opportunity to enhance safety practices and streamline processes. By staying informed and gradually integrating these new guidelines, we can ensure a smoother implementation and a safer working environment. Let’s continue to collaborate, share knowledge, and support each other in this evolving landscape. Together, we can achieve the goal of a more comprehensive and effective standard that benefits everyone involved.

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.