J A S O N K R B E C
NFPA 660
UPCOMING CHANGES AND
WHAT THEY MEAN FOR
COMBUSTIBLE DUST SAFETY
EXPERTS TO HELP YOU NAVIGATE SAFETY REGULATION APPLICATION
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
NATIONAL FIRE
PROTECTION CONSOLIDATION OF THE
NFPA DUST STANDARDS
ASSOCIATION (NFPA)
• The NFPA Standards related to
combustible dust are in the process of
• NFPA is a non-profit organization being consolidated into a new Code
• NFPA is not affiliated with the government or enforcement/policies • New combined Code to take the
• Go to NFPA website for the latest up to date information www.nfpa.org number of NFPA 660
• The current model of Combustible
Dust Standards is a split based on
industry- or commodity- specific
segment
• A long history of combustible safety
has led us here……..
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
CHEMICAL SAFETY BOARD
Independent federal agency that
investigates chemical accidents
From 2006-2017 they have
documented 59 fatalities and 303
injuries in Combustible Dust incidents
Issued recommendations of proposed
rulemaking for combustible dust
hazards to OSHA in 2007
www.csb.gov
1980-2012
148 879
fatalities injuries
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
COMBUSTIBLE DUST INCIDENT BY INDUSTRY
Other
Coal and Carbons
Food and Beverage
Chemicals
2006
Metals Wood
Coal and Carbons Metals Wood Food and Beverage Chemicals Others Source: 2006 CSB Study
Coal Raw Metal Board Grain and Feed Plastics Specialty Items
Cement Metal Parts Wood Pellet Bakery and Snack Specialty Chemical Mixtures
Carbon Black 3D Printing Woodworking Pet Food Resins
Sawmill Dairy
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
COMBUSTIBLE DUST INCIDENT BY INDUSTRY
Other
Food and Beverage
Coal and Carbons
Chemicals
2018
Wood
Metals
Coal and Carbons Metals Wood Food and Beverage Chemicals Others Source: 2018 CSB Study
Coal Raw Metal Board Grain and Feed Plastics Specialty Items
Cement Metal Parts Wood Pellet Bakery and Snack Specialty Chemical Mixtures
Carbon Black 3D Printing Woodworking Pet Food Resins
Sawmill Dairy
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
COMBUSTIBLE DUST INCIDENT BY INDUSTRY
Other
Coal and Carbons Chemicals
Metals 2019 Food and Beverage
Wood
Coal and Carbons Metals Wood Food and Beverage Chemicals Others Source: 2019 DSS Incident Report
Coal Raw Metal Board Grain and Feed Plastics Specialty Items
Cement Metal Parts Wood Pellet Bakery and Snack Specialty Chemical Mixtures
Carbon Black 3D Printing Woodworking Pet Food Resins
Sawmill Dairy
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
“
DRIVER OF
CRITICAL CHEMICAL
SAFETY CHANGE.”
The CSB has issued four
recommendations to OSHA calling for
the issuance of a comprehensive general
industry standard for combustible dust as
the Board’s first:
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
BACKGROUND
NFPA STANDARDS AND
OSHA HISTORY
OSHA NEP released in 2007
NEP refreshed again in 2008
(Imperial Sugar)
NFPA started the process
for a better Standard on
combustible dust
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
STAKEHOLDER
MEETINGS
OSHA held a series of Stakeholder
Meetings following the NEP
release and notice of proposed
rulemaking (2009-2011)
“ “ “
NFPA 654 is a good Many NFPA standards are unclear, and NFPA guidelines are complex and
starting point. often small businesses do not know do not use consistent language
However, OSHA that their facilities have a problem. (different committees write
should not focus Liability insurers could be a key different sections). OSHA should
solely on NFPA 654 element to the process by explaining use more straightforward and
given that many the standards to small businesses in cohesive language to explain
other standards are a way that they can understand and what is required.
involved. implement.
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
NFPA 652 Scope:
THE GAME The standard shall provide the basic
principles of and requirements for
CHANGER
identifying and managing the fire
and explosion hazards of combustible
dusts and particulate solids.
NFPA 652 Standard on • Specific Chapter structure and
introduction of retroactive requirements.
Combustible Dust • All other standards have revised to match
the 652 format and chapter structure.
• Correlating Committee also formed to
Released September 2015 oversee all “Dust Standards”.
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
CORRELATING
COMMITTEE
Correlates between the industry
specific standard and the
fundamental standard
Goal is to have continuity between
combustible dust standards:
Definitions Structure References
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
DUST HAZARD
ANALYSIS (DHA)
NFPA 652 introduced the Dust Hazard
Analysis (DHA)
Critical requirement that has improved
combustible dust safety and awareness
Deadlines started within NFPA
Standards to complete DHA’s based on
the industry
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
HOW DID WE NFPA
GET HERE? LAUNCH OF
61 DHA
DEADLINE
JAN 2022
NFPA 652
SEP 2015
NFPA
OSHA 652 DHA
CD NEP OSHA CD
RESOURCE DEADLINE
OCT 2007
CSB APR 2013 SEP 2020
DUST OSHA CD
STUDY RULEMAKING
NOV 2006 APR 2009
2003 2006 2007 2008 2009 2011 2012 2013 2014 2015 2017 2020 2022
CTA
ACOUSTICS MAJOR
FOREST
FEB 2003
PRODUCTS MAJOR CORN
HOEGANAES EVENT MILLING EVENT
JAN 2011 JAN 2012 MAY 2017
WEST IMPERIAL MAJOR GRAIN MAJOR FOREST
PHARMACEUTICAL SUGAR EVENT PRODUCTS EVENT
JAN 2003 FEB 2008 OCT 2011 APR 2014
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
NFPA COMBUSTIBLE
DUST STANDARDS
NFPA 652 NFPA 654
Fundamentals of Chemicals and Plastics
Combustible Dust Other industries as well
NFPA 61 NFPA 655
Agricultural or Food Sulfur
Products
NFPA 484 NFPA 664
Metals and Alloys Wood and Wood Processing
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
NFPA STANDARD USAGE FLOW
Fundamentals document NFPA 652
NFPA 61
NFPA 654
Industry/commodity NFPA 655
specific documents NFPA 664
NFPA 484
How to documents NFPA 68 NFPA 69
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
CURRENT NFPA DUST
STANDARD STRUCTURE
Chapter 1 – Administration
Chapter 2 – Referenced Publications
Chapter 3 – Definitions
Chapter 4 – General Requirements
Chapter 5 – Hazard Identification
Chapter 6 – Performance-Based Design Option
Chapter 7 – Dust Hazard Analysis (DHA)
Chapter 8 – Management Systems
Chapter 9 – Hazard Management: Mitigation and Prevention
Annex X
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
“HOW TO” Standards that the fundamentals
STANDARDS
or industry documents reference
to for applying or design of
specific systems or requirements
NFPA 68 NFPA 69 NFPA 70 & 499
venting and suppression, isolation, electrical
flameless venting inerting, prevention classification
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
INTERNATIONAL
NFPA 652 now included in the IFC code as a Standard to comply
with when equipment, processes, and operations involve dust
explosion hazards.
FIRE CODES
Also reference to industry- or commodity-specific Standard
A code local jurisdictions use to determine building occupancy,
new construction requirements, and safety
State or local
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
WHY
• Conflicts and gaps still exist between Standards
• Improves accessibility to combustible dust safety
CHANGE? • Hard for companies with multiple industry functions to comply
• Standards on different revision cycles depending on the industry
• Combined standard brings more expertise into safety, streamlines
improvement
• A clearer Standard = less combustible dust incidents
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
EXAMPLES
• Limited guidance on prescriptive requirements
for different types of dryers
OF
CONFLICTS
• Self heating and reactivity information on dusts
OR GAPS
• Sections of processes that don’t require a
retroactive DHA based on industry
• Wood Bioenergy or Biomass processes not really
considered in NFPA 664
• Lack of information for additive manufacturing
(some for metals)
• Fire protection requirements and methods
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
NFPA 660
A special task group was formed amongst the dust
committees
The decision to consolidate the standards into one has
been moved forward by the Standards Council
The goal is to create a combined Standard or Code in
the next 3 to 5 years
Extensive process involving multiple committees to
make this happen
Proposed title and document number still in the works
NFPA 660 Combustible Dust Code
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
NFPA
STANDARDS
VS
CODES
NFPA Standard VS NFPA Code
Tends to be a more detailed A set of rules put together by
elaboration, like the nuts and knowledgeable people
bolts of meeting a code
Will spell out what kind of Tends to spell out that you need
system and how it must work a system and points you to where
you find details on what kind
Tells you how to do it Tells you what you need to do
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
PROPOSED STRUCTURE
OF NFPA 660
Chapters 1 through 9 would be fundamental requirements
What is truly fundamental?
Chapter 10 would be dedicated to Fire Protection
Chapters 11 to 16 would contain industry specific requirements
Chapter 11 – NFPA 61 (Food and Ag)
Chapter 12 – NFPA 484 (Metals)
Chapter 13 – NFPA 654 (Chemical/Plastic)
Chapter 14 – NFPA 655 (Sulfur)
Chapter 15 – NFPA 664 (Wood)
Chapter 16 – NFPA 91 (Exhaust Systems)
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
KNOWLEDGE OF
EXISTING TECHNICAL
COMMITTEES
Each existing Industry specific Fundamentals Correlating
technical committee will committee will Committee will
committee will be responsible for be responsible for continue to review
remain intact chapter associated the front chapters content
with the respective with “common/
industry fundamental”
sections
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
POSSIBLE Chapter 1 in the new Code will address conflicts
Structure is in place now with current separate
SECTION
documents
CONFLICTS If conflict between
fundamentals and
industry
→ you can choose
If industry prohibits → you follow industry
If not addressed in
industry → you follow
fundamental
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
“
THE WORK
BEGINS
Technical committees are providing input currently on which
requirements should be “universal” or “fundamental”
The correlating committee will then combine that input into a
draft of the fundamentals section
The other technical committee then review the respective
industry- or commodity- specific chapter to see address any gaps
in material or repetitive items
Correlating committee then forms the draft document
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
NFPA STANDARDS 01
Public Input Stage
DEVELOPMENT Public input opens and closes, first draft
meeting, and first draft report
PROCESS Public Comment Stage
02 Public comment opens and closes on the first
draft, second draft meeting, and a second draft
ANTICIPATED TO
START IN 2022 NFPA Technical Meeting
03 Notice of Intent to Make a Motion (NITMAM)
Process that begins after an initial reviewed and certified. Vote.
draft standard is published and
enters a formal revision cycle
Issuance of the Standard
04 NFPA Standard Council meets to review any
appeals, decision to issue the Code/Standard
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
ANTICIPATED TIMELINE
2021 2022 2023 2024
INITIAL DRAFT FORMAL STANDARDS FINAL STANDARD
RELEASED PROCESS VERSION EFFECTIVE
Anticipated August 2021 timeline NFPA Standard development Final version finalized and Approved and issued in 2024
(subject to change) process, public input issued for release and 7 original documents
replaced
NFPA 660: UPCOMING CHANGES AND WHAT THEY MEAN FOR COMBUSTIBLE DUST SAFETY
CURRENT
STANDARDS
WHAT
HAPPENS?
Typical revision Revision process Should remain NFPA 484 was
cycle is every has been put on in current form mid cycle so a 2021
3 year for the pause for most until 660 arrival release of a new
dust Standards existing Standards version is likely
For More Information and Future Updates
www.cvtechnology.com/nfpa www.nfpa.org
561-694-9588 Jkrbec@cvtechnology.com www.cvtechnology.com
