In today’s episode of the Dust Safety Science podcast, Jack Osborn, who is a combustible dust expert at Airdusco, discusses updates on the development of NFPA 660 and its impact on industry.
We touched on NFPA 660 in Episodes #128 and 129, when Jason Krbec, Engineering Manager at CV Technology, went over the events leading up to the formation of NFPA 652 and 660. Now, a year later, Jack provides an update and answers the questions:
- Where is NFPA 660 today?
- What is it?
- Is it a code or standard, and what does that mean?
- What are the major changes in the commodity-specific standards, if any?
We’ll also talk about what the public feedback looks like, what the feedback process looks like, and what these changes mean for different groups in the combustible dust community.
Where is NFPA 660 Today?
Jack explained that the goal is to name the new standard NFPA 660- Combustible Dust. He added that this is subject to change.
“This whole process started back in 2011, which is really a surprise,” he recalls. “We got a copy of the letter that the Standards Council sent out to make their people aware that they were hoping in the future to consolidate everything regarding combustible dust into one document because, frankly, one of the steps became NFPA 652 which was the Fundamentals of Combustible Dust. It’s now a much better standard than it used to be but it actually went too far. It started getting into commodity-specific standards, and there is a real need for commodity-specific information.”
The fundamentals are there. Even in the fundamentals, however, not everything is exactly right for every commodity or every situation. Jack confirmed that trying to put it all into one document has been a real challenge.
“We actually got started on this process [during] the 2018-19 era where we were talking on the telephone, going back and forth, going through various meetings for the commodity-specific standards and figuring out what to do. One of the main things that were decided was that we were going to keep the integrity of the commodity-specific standards because there are just too many differences between metals and wood and food and chemicals. There are just major differences you can’t cover in one standard without having those chapters in there.”
Another problem was that there were so many experts involved. There were five major committees- one for the fundamentals and four that were commodity-specific- so there were over 100 people trying to decide what to include in one standard.
“That’s just mind-boggling because it’s hard enough getting three or four people to do anything – that is amazing, “ Jack says. “The fact that we’re getting there is actually a part of NFPA’s effort because they’ve had very good people do things that help us make sure that we get to do it right and get it done right, and keep it organized.”
He confirmed that the first nine chapters will be fundamentals but everything from that point on will be related to the commodity-specific standard. There will be one more meeting. Once it’s completed, the NFPA will combine everything. Normally the next step is to send the results to the correlating committee, but in this case, it will likely go directly to the Standards Council, which is the overall governing body for the NFPA. If they approve it, it will go out for public comment.
“We are strongly asking the public to be involved,” Jack says. “We want this standard to be as good as we can make it when it first comes out.”
Once all the public comments are received, the committees will meet again to review them and possibly incorporate them into a second draft, which will probably be sent on to the correlating committee. Then it will be sent to the entire NFPA for their major meeting of the year.
“So with all this process involved, it is very likely all this will be delayed until 2023. And I would say the earliest this standard would come out will be the fall of 2023.”
Will NFPA 660 Be a Code or a Standard?
“It’s very likely they will call this a code,” Jack says. “There is some resistance to that. But frankly, it’s just a word. It just means it can exist as a law. It’s no different than calling it a standard. A standard is just there to provide knowledge and information for a certain goal, and that’s a very generic definition. It still could be called a standard but the reality is its purpose is to become a code and to be adopted very similarly to the National Electric Code.”
Will the Commodity-Specific Standards Change as They Become Part of NFPA 660?
Jack said that there would be some major changes in this regard, but nothing detrimental.
The wood industry, which has a greater risk of fire than probably all the others combined, will place a great deal of emphasis on fire. The food industry, on the other hand, emphasizes fire but nothing to the level that the wood industry does. The actual committees for the current standards will be responsible for the various chapters.
The first nine chapters will be covered by the fundamentals and the public will be asked in the future for comments on the contents. The other chapters emphasize what is different in their particular standard.
“A good example is the food industry or agricultural food processing,” Jack explains. “They have certain parts of their (standards) that are quite different. They allow for what’s called an ingredient transfer system – that if you meet specific standards, your pneumatic conveying system may not require explosion protection. It requires other considerations like grounding, and bonding. But in other words, there are certain parts of it that will still be there, that will not be part of the fundamentals.”
He confirmed that the fundamentals will be modified significantly.
“A good example is material feeders. You’ve got vibrating conveyors, belt conveyors, screw conveyors and slip conveyors. You can’t even begin to think of all the types of ways you can convey or feed materials into a process, and they operate quite differently. There are really no true fundamentals that would apply. It’s more oriented to the materials so that you’ll find that information in the chapters on the commodity-specific.”
What Does the Public Feedback Process Look Like?
Jack explained that the public can submit feedback by going to the NFPA website and accessing the details for the first draft phase of 660.
“There will actually be some forms that you can do electronically – whether you’re a member or not. Now, I’m going to tell you some things that you must do to have your comment actually strongly considered. First of all, if you’re a vendor, don’t try to do something that will make your equipment the only thing that can be used. Secondly, if you have a disagreement with a statement in the first draft, you need to refer to that. And, most importantly, you need to offer a solution. You may be 100% correct when you say something is wrong, [but] if you don’t give us a solution, then we’re not to consider that.”
Conclusion
Towards the end of the discussion, Jack encouraged public input on the new code, especially from industry experts.
“We may have had over a hundred people look at it, but that doesn’t mean we got it right. We need public input. This is something that will be a code. Eventually, it will be published as a law or requirement as well. So this is your chance. This is your chance to make yourself known and to make sure we get it right.”
If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Jack Osborn directly:
LinkedIn: https://www.linkedin.com/in/jack-osborn-39212869
Website: http://www.airdusco.com/
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
Companies
Airdusco Engineering and Design Services
Organizations
NFPA
Standards
NFPA 652
Previous Episodes
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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