The National Fire Protection Association (NFPA), nfpa.org, is an organization tasked with developing and maintaining fire protection and life safety standards in the United States and worldwide. In addition to subjects such as sprinkler design, flammable liquid storage, and emergency exit requirements, NFPA has standards that deal specifically with combustible dust; a topic that CTI has been focused on for over a decade. There are several NFPA Standards that address combustible dust: NFPA 652 – Standard on the Fundamentals of Combustible Dust, is the overarching standard that applies to all facilities, and there are also several commodity-specific dust standards (e.g. 61 for agricultural and food, 664 for wood products, 484 for metals). CTI is a principal member of both the NFPA 61 Technical Committee for Agricultural Dust and the NFPA 664 Technical Committee for Wood and Cellulosic Materials Processing and has worked with several of the other committees. All of these standards have updated in 2018 and 2019, and CTI is here to help our clients understand what that will mean for them.
The individual dust standards do not always align, and the presence of numerous, competing standards can create confusion and increase risk at facilities that handle combustible dust. NFPA 652 was the first step in creating a single, unified combustible dust standard that would apply to all facilities that handle potentially combustible dusts. The most recent edition of NFPA 652 was issued in May 2018. Officially, it is the 2019 edition, as NFPA standards are much like cars . . . the next year’s model comes’ out the year before. There were several specific changes to the standard: the deadline for facilities to complete Dust Hazard Analyses (DHA) was moved to September 7, 2020; DHAs are now required to be reviewed and updated every 5 years; and a much greater detail has been added to housekeeping requirements. However, the most important change to NFPA 652 was the reorganization of the chapters to prepare for the consolidation of the multiple dust standards into a single standard.
The 2020 editions of NFPA 61, 654, and 664 were all issued in late 2019. The primary change to the commodity standards is that they have all been realigned to match the new layout of NFPA 652. In all three standards, Chapters 1 – 8 are identical. Chapter 9 of each standard now addresses the industry and commodity specific details. Other than reorganizing the chapters, there have not been many changes to the requirements within the standards.
NFPA 61 did make one significant change: The deadline to complete the DHA for existing facilities and processes for food and agricultural facilities was moved to January 1, 2022. However, it is important to note that, whether the deadline is September 7, 2020 or January 1, 2022, NFPA 652 states that “The owner/operator shall demonstrate reasonable progress each year in completing DHAs prior to the deadline…” This means that even for facilities subject to NFPA 61 that have an extra 15 months to complete the DHAs, work on the DHAs needs to be underway now.
CTI has decades of experience in identifying and reducing hazards from combustible dust. We offer the following, and many more, consulting services for dust:
- Dust Hazard Analysis
- Hazardous (Classified) Location Determination
- NFPA and OSHA Compliance Review
- Explosion Protection Design and Selection
- Dust Sampling Plan and Execution
Please feel free and contact us to discuss the above-mentioned services or if you have any questions regarding the dust hazard present at your facility.