In today’s episode of the Dust Safety Science podcast, we’re talking to Laura Moreno, Standards Lead in Industrial and Chemical Engineering at the NFPA, about the public input process for the NFPA 660 standard for combustible dust. She’s based in Quincy, Massachusetts, and facilitates the standards development process.
“[My team] works with the technical committees and the committee chairs to guide them through the development and revision of each edition of an NFPA standard,” Laura says. “I am involved in NFPA 660 because I am the staff liaison for what used to be six separate NFPA standards related to combustible dust. A total of five technical committees and one correlating committee deal with combustible dust. I’ve been working with them on the development of NFPA 660.”
In this episode, she answers the following questions:
- What is the background of NFPA 660?
- What are the opportunities for the public to provide feedback?
- How do people provide feedback to NFPA?
What is the Background of NFPA 660?
Laura recalled that in 2009, OSHA published its advance notice of proposed rulemaking on combustible dust.
“There were many comments from that meeting – pointing out that the NFPA standards cover all industries and occupations associated with combustible dust, but they had some inconsistent requirements. There were also comments about how [this fact] could limit the effectiveness of their use, as well as how OSHA shouldn’t adopt NFPA standards because it’s hard to determine which requirements apply where.”
Acknowledging the value of a combined combustible dust standard, the NFPA Standards Council took steps to develop one. The fundamentals document, NFPA 652, was put together at around the same time that the different dust technical committees were being formed. However, even after NFPA 652 had been published, there were still big differences in how the different committees were addressing and using NFPA 652.
“When I talk about the different committees and commodity and industry-specific dust, the ones I’m talking about are 484 for metal dust, 61 for agricultural, 664 for wood dust, 655 for sulphur and 654 for all the other dust. Each committee in each document was treating NFPA 652 slightly differently,” Laura says.
Everyone finally agreed that a combined standard was needed. The Correlating Committee, in making that recommendation, came up with a plan where each of the committees would have input on the following:
- What was considered fundamental
- Which NFPA 652 material should stay in 660
- What should be controlled by each industry or commodity-specific chapter
The document was drafted, and Laura confirmed it is open for public comment until January 5, 2023.
What are the Opportunities for the Public to Provide Feedback?
Laura confirmed that there are several opportunities for the public to provide feedback.
During the public input phase, the draft is up. Any member of the public can review it and submit input on any section they want. Even while the committees are waiting for that public input and that deadline of January 5th, they will be working on certain things in small task groups, such as coordinating definitions and terminology, for flash fires and explosions across the standard.
Once the deadline passes, each committee will meet in early 2023 and review all of that public input. Each recommendation will either be incorporated into the draft or the committee will provide a reason why they’re not incorporating it.
A first draft report will be posted in October 2023, followed by a public comment period from October 2023 to January 2024. Once all feedback has been received, the committees will have their second draft meetings to develop a second draft report.
The public then has another chance to submit input during what’s called the NITMAM stage – Notice of Intent To Make a Motion. That is where they make a notice that they’re going to come to the technical session at the NFPA conference.
“If your public comment or public input was not accepted and you are still interested in pursuing it, you would come to the session and speak to the NFPA membership,” Laura says.
How Do People Provide Feedback to NFPA?
Laura explained that anyone who wants to submit public input can go to NFPA.org/660next, which is the document information page for NFPA 660. Clicking on the ‘Submit Public Input’ link will bring you into the Teraview system where you can review the full preliminary draft. I would encourage reviewing that before you start submitting it.
“You don’t have to be an NFPA member or a member of the Technical Committees. You just have to create a free profile in NFPA.org to log in and you’re able to submit public input. Just make sure you do it by that January 5th deadline.”
She added that while input is open to non-U.S. residents, the only caveat is that submissions must be in English.
Conclusion
At the end of the interview, Laura mentioned that all committee meetings were open to the public and anyone can sign up for email alerts notifying them them of upcoming meetings and agendas.
“You can attend virtually or in person as a guest – they are open to everyone. So I really encourage you to do that. It gives you a good idea of how our process works. It might even encourage you to participate on some of the committees if you’d like to. I really recommend getting involved that way, if you’re interested.”
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
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
Input Pages
NFPA 660 Input
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