A: Jack Osborn, Airdusco, says:
Your frustration is more than understandable as this is a common complaint from users of the NFPA standards on combustible dusts, which include NFPA 61, 484, 652, 654, and 664. Please be aware that those of us serving on those committees are just as frustrated as you are.
Even more importantly, the staff at the NFPA is keenly aware of your justifiable confusion and frustration. The NFPA is aware of the need to remedy this situation and now has a plan to simplify the use of these standards on combustible dusts.
Before informing you about the NFPA’s plans for the future, it’s important to understand the past. The complaint about conflicting information in the standards, difficulty in using them, and multiple other problems for users aren’t new issues and has been a major concern at the NFPA. It’s important to remember that the NFPA isn’t part of the government, but it’s a private nonprofit organization that seeks to provide the necessary information to prevent fires, flashfires, and explosions from occurring in countless areas and industries. Everyone at the NFPA and the more than 5,000 volunteers who comprise the various committees truly believe in this effort to improve safety.
Due to a rash of unfortunate combustible dust explosions, resulting in multiple deaths and injuries culminating in the tragic incident at Imperial Sugar in 2008, the US government, through OSHA, finally decided to emphasize the need for industry to uniformly address combustible dust hazards. However, OSHA didn’t pursue writing its own standards and rules but instead chose to use NFPA’s standards as the basis for the campaign. This situation suddenly put all the combustible dust standards (NFPA 61, 484, 654, and 664) under intense scrutiny and resulted in the NFPA recognizing that these standards needed significant improvement.
This eventually led to the creation of NFPA 652: Standard on the Fundamentals of Combustible Dust and the correlating committee. This was a direct effort of the NFPA to establish basic fundamentals for the combustible dust hazards and risks and to correlate the commodity-specific standards (NFPA 61, 484, 654, and 664) to eliminate differences and conflicts. As of now the International Building Code and International Fire Code mandate compliance with NFPA 652, and inherently, the commodity standards on combustible dusts. Although this resulted in very significant improvements in the standards, problems remain as properly indicated by your question.
The NFPA is acutely aware of this problem but also recognizes that it’s imperative that the commodity-based combustible dust standards retain their integrity. The hazards for a food processing plant differ widely from a plant with metal or wood dusts, for example. As a result, the NFPA has decided to consolidate all its combustible dust standards into a single, extensive standard. This was a very difficult decision and was approved by the members of the committees by a slim margin.
What does this decision mean for users? Over the next 3 or more years, the various committees for combustible dust hazards will work together to provide true, basic, fundamentals for combustible dusts and combine them with chapters that will cover the unique combustible dust hazards existing in food, metals, wood, and chemical industries. All the national committees on combustible dusts will continue and be responsible for the same commodity-specific combustible dust hazard standards. The result will be a single, although large, standard that will cover all facilities that handle combustible dusts. Hopefully, this will result in a significant improvement for all users, including yourself.
Jack Osborn is the engineering manager at Airdusco.