Updated July 29, 2024
In today’s episode of the Dust Safety Science podcast, we’re covering NFPA 660 Development and Next Steps with Laura Moreno, Standards Lead and Industrial and Chemical Engineering at NFPA.
“As the standards lead, I manage the group of staff liaisons that work on all of our industrial and chemical safety standards,” Laura said. “I also serve as the staff liaison for NFPA 660. So that means I facilitate the standards development process and make sure that the technical committees have what they need to follow all of our NFPA regulations, that we have meetings at the right times to review all of the input and public comments that come in, and just generally make sure that we follow the ANSI process for developing new standards.”
Purpose and Development of NFPA 660
The development of NFPA 660 started following the OSHA Advanced Notice of Proposed Rulemaking in 2009. This notice highlighted issues of consistency and usability within the NFPA standards, specifically those that might affect their effectiveness. In response, the Standards Council reviewed all dust standards, including 484, 61, 664, 654, and 652. They tasked the committees with the goal of creating standards that did not conflict with each other, to ensure a uniform approach to combustible dust across various industries and spaces.
The committees considered merging these documents into a single standard or finding an alternative solution. Eventually, the Combustible Dust Correlating Committee, along with a task group, decided that creating a single standard was the best approach. This decision led to the creation of NFPA 660.
Where Is NFPA 660 At Today?
The committees received a significant amount of valuable feedback from both committee members and the general public in addition to organizations like the Chemical Safety Board. This feedback was essential for the development process. The committees evaluated each piece of input and produced initial revisions to the document, ensuring every suggestion was considered and responded to. This process could lead to changes being accepted fully, partially, or rejected with an explanation, including technical justifications where necessary.
All five committees previously responsible for separate standards – 652, 654, 61, 484, and 664 – now work on different chapters of NFPA 660 instead of individual documents. They review all feedback and vote on proposed changes.
In August 2023, the correlating committee, which oversees the unified NFPA 660 document, met to ensure consistency across the chapters. This includes uniform application of terminology, management approaches, and other fundamental aspects. This committee also provides guidance for ensuring coherence throughout the document, such as standardizing terminology or methodologies.
“Task groups, formed during the first draft meetings, have been independently examining topics like additive manufacturing and terminology differences to integrate into the NFPA 660 standard effectively,” Laura added.
The first draft of the standard was made publicly available for review in September or early October, allowing for a second round of comments until January 4th. This open period attracted over 300 comments, offering another chance for feedback on the changes made or suggestions not previously incorporated. The committees are now set to review these latest comments for their second draft meetings, continuing the iterative process of refining and improving NFPA 660.
Where Is The Development of NFPA 660 Headed?
As mentioned earlier, many committee members are actively engaged in task groups, continuing their work right up to the second draft meetings. The primary role of these task groups is to dedicate time to thoroughly consider public feedback that requires more in-depth discussion than what might be possible during regular committee sessions. They work independently to develop solutions or reach consensus on specific issues before reporting back to the full committees.
This process is ongoing, with the next set of meetings scheduled for the fundamentals committee in February 2024 and for the other industry and commodity-specific committees in March. During these 1 or 2-day meetings, depending on the committee, members will review the outcomes of task group efforts and all the public comments received. The aim is to either update the standard based on this input or to provide detailed technical responses to the feedback providers.
The committees will vote on any proposed changes, and the correlating committee will conduct a final review in August to ensure consistency across all chapters and make any necessary adjustments. The second draft of the standard will be made available by October 3rd, offering the public one last opportunity to submit feedback through a process known as NITMAMs (Notice of Intent to Make a Motion), which can be viewed as a form of preliminary appeal. Only those who meet specific criteria, such as having previously submitted feedback that was not adopted, are eligible to file a NITMAM.
NITMAMs are then reviewed by the Standards Council to determine if they qualify as valid motions. If approved, they become certified amending motions, and the submitter is invited to present their motion at the NFPA technical meeting. The process allows for open discussion, with members speaking for or against motions before a collective vote is taken. This vote is not restricted to technical committee members but includes any NFPA member attending the meeting.
NITMAM submissions open after the second draft report is posted in October, with a deadline of December 2024 to know if any will be presented at the June 2025 conference and expo. If no NITMAMs are received, the document could be issued as early as December 2024. However, if any are received, the issuance would follow the technical meeting, potentially in August or September 2025.
Have Any Common Themes Emerged?
Much of the feedback received points out inconsistencies between chapters or suggests consolidating common requirements into the fundamentals section. This approach would allow chapters focused on specific industries or commodities to concentrate on the unique aspects of their dust types. It highlights the need for specific protections unique to each dust type that may not be necessary for others.
“The first edition won’t be perfect and all of our standards are revised every three to five years just for that reason,” Laura said. “There are new things that come up. New evidence might come out as to why a certain dust needs to be handled differently than another industry. It’ll be a living document that will continue to be improved over the next several editions.”
How Can People Get Involved?
The public is encouraged to attend the upcoming meetings. Remote attendance is possible for these and all future meetings, with guests always being welcome. Interested parties can find all necessary meeting information, including how to RSVP and receive a remote attendance link, on the specific document information page.
Participants who wish to contribute to the discussions or make a presentation can make such requests through the chair of the meeting. Following these meetings, updates and decisions made by the technical committees will be posted on the same webpage, keeping everyone informed about potential developments in the first edition of the standard.
Individuals who have been actively providing input and comments have the option to submit a Notice of Intent to Make a Motion (NITMAM) as a way to continue their involvement. Those interested in the June 2025 technical meeting should plan accordingly, especially if NITMAMs are received. Attendees at this meeting will likely include a diverse group not limited to those within the combustible dust industry. This offers a unique opportunity for individuals to present their feedback directly.
Information about participation in the NFPA standard process in general is also provided. Each NFPA standard document has a dedicated information page on nfpa.org, where individuals can sign up for email alerts to stay informed about public input periods, scheduled meetings, and other updates. This enables interested parties to participate actively, whether by attending meetings, submitting comments, or posing technical questions to NFPA staff.
Furthermore, there’s an open invitation for those interested in becoming committee members. NFPA committees have openings across various interest categories, although some categories may be at capacity due to a rule limiting any one interest category to a third of a committee’s composition. This presents an opportunity for individuals from underrepresented groups, such as enforcers, insurance companies, labor unions, and users, to apply and contribute their expertise to the development of NFPA standards.
Conclusion
The development of NFPA 660 represents a significant step forward in the standardization of safety protocols for managing combustible dust across various industries. This ongoing work ensures that NFPA 660 will remain relevant and effective in addressing the dynamic challenges of combustible dust safety.
If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Laura Moreno directly:
Email: [email protected]
LinkedIn: https://www.linkedin.com/in/laura-moreno-21118513/
Website: https://www.nfpa.org/
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
The resources mentioned in this episode are listed below.
Dust Safety Science
Combustible Dust Incident Database
Dust Safety Science Podcast
Questions from the Community
Organizations
NFPA
Standards
NFPA 660
Thanks for Listening!
To share your thoughts:
- Leave a note in the comment section below
- Ask a question to be answered on the show
- Share this episode on LinkedIn, Twitter or Facebook
To help out the show:
- Subscribe to the podcast on iTunes
- Leave a review and rate our show in iTunes to help the podcast reach more people
Download the Episode
DSS257: NFPA 660 Development and Rollout Process with Laura Moreno
