Jack Osborn, Airdusco, says:
Unfortunately, you’re correct. All industries handling or processing combustible dusts have to comply with the current National Fire Protection Association (NFPA) standards. That means complying with NFPA 652: Standard on the Fundamentals of Combustible Dust — 2019 edition and the appropriate commodity-specific NFPA standard, which in your case would be NFPA 61: Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities.
Your complaint is a common one since NFPA 652 became effective September 2015. One original purpose of NFPA 652 was to simplify the requirements necessary to protect your facility against the hazards and risks associated with combustible dusts. However, that goal to simplify has never come to fruition and interpretation between the standards has become necessary, especially concerning conflicts between the fundamental principles and exceptions in the various commodity-specific standards, which have created unwanted frustration.
The NFPA wasn’t and isn’t deaf to this complaint. In fact, the NFPA anticipated this situation and considered NFPA 652 as only the first step in its overall plan for the combustible dust standards. The plan was to use NFPA 652 as a step toward combining the existing standards into a single, comprehensive standard or code. This plan is similar to what was done with NFPA 70E: Standard for Electrical Safety in the Workplace that’s become the national electric code.
Don’t think the plan to create one central standard was done without controversy. The NFPA isn’t a dictatorial body and relied on the various combustible dust committees and committee members to determine whether the plan was the correct path forward. This plan was “cussed-and-discussed” and eventually won approval by only a slim margin.
The major fear of the various commodity-specific committees was whether they would remain as a governing body of the new standard or code. The NFPA recognized the need to maintain the integrity of the committees, resulting in the inclusion of separate chapters covering the current commodity-specific topics, such as food and agriculture, metals, wood, and chemicals. The NFPA fully understands that the various food industry combustible dust hazards are quite different than those for the wood, metal, or chemical industries.
The new standard, preliminarily designated NFPA 660, may be considered a code instead of a standard. Thus, it may become the Combustible Dust Code. Since NFPA 652 and the other combustible dust standards are now mandated by the International Building and Fire Codes, it’s likely this new combined standard will become a code with mandated general compliance.
To answer the question more specifically, the new NFPA 660 will basically consist of the first nine sections or chapters being the fundamentals. The remaining chapters will be for the various combustible dust compliance issues for the various commodity-specific industries. Thus, food and agriculture, metals, wood, and chemicals that currently fall under the purview of NFPA 654, will have their own chapter. Additionally, there’s likely to be individual chapters for NFPA 655: Standard for Prevention of Sulfur Fires and Explosions and NFPA 91: Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids. There will also be an extensive annex portion to the document that may include other topics not currently in consideration.
Please don’t think this is just haphazardly compiled together. The various committees have spent many hours discussing each part of NFPA 652 and the commodity-specific standards in order to produce a standard or code that’s reasonable, understandable, and takes into account the significant differences between the various combustible dusts.
Currently, the process is ongoing. Even when the initial process is completed, it will have to go through the National Electrical Code (NEC) Correlating Committee and then will be open to the public for review and comment. For now, you must defer to NFPA 652 and your commodity-specific standard. However, in 2 to 3 years, NFPA 660 will be the single source.
Jack Osborn is the engineering manager at Airdusco.