CORRELATING COMMITTEE ON COMBUSTIBLE DUSTS NFPA …

CORRELATING COMMITTEE ON COMBUSTIBLE DUSTS

NFPA 652 (A2015) Second Draft CC Meeting

November 4-6, 2014

Hilton Atlanta

Atlanta, GA 30303

AGENDA

1. Meeting opening, welcome members and guests, and introductions

2. Chair's remarks, Kevin Kreitman

3. Approve Minutes of Second Draft CC Meeting on April 29, 2014 for NFPA 91

4. Staff Liaison updates (Committee Roster, Schedule, and Correlating

Committee Duties and Responsibilities)

5. NFPA 652 CMD-FUN Second Draft Report

a. Review and act on Public Comments and Second Revisions

b. Review Correlating Committee Notes

c. Review NFPA 652 Second Draft TC Final Ballot Results

d. Develop Second Correlating Revisions (as appropriate) – see attached

sections on Correlating Committees from Regulations Governing

Committee Projects

6. Next meeting:

61/654/664 (A2016) Public Input Closing Date was June 6, 2014 with First

Draft Meetings on:

a. NFPA 654—FD Meeting on July 30-Aug. 1, 2014,

b. NFPA 664—FD Meeting on August 19-21, 2014,

c. NFPA 61—FD Meeting on August 26-28, 2014, and

d. CC Meeting for 654, 664, and 61 scheduled for January 6-9, 2015 in

Dallas, TX.

CORRELATING COMMITTEE ON COMBUSTIBLE DUSTS

TO: CORRELATING COMMITTEE ON COMBUSTIBLE DUSTS

FROM: G. R. Colonna, Staff Liaison

DATE: August 11, 2014

SUBJ: Minutes of NFPA 91 Second Draft Review Meeting, April 29, 2014

________________________________________________________________________

I. Attendance: (web and conference call meeting)

Members and Alternates:

Kevin Kreitman, Committee Chair, City of Redding Fire Department, CA

Chris Aiken, Cargill, Inc., MN

John Cholin, J. M. Cholin Consultants Inc., NJ

Scott Davis, GexCon US, MD

Mark Drake, Liberty Mutual Commercial Markets, KS

Henry Febo, Jr., FM Global, MA

Walter L. Frank, Frank Risk Solutions, Inc., DE

Paul F. Hart, XL Global Asset Protection Services, IL

Edward LaPine, Aon Fire Protection Engineering Corporation, AZ

Arthur Mattos, XL Global Asset Protection Services, NC

Timothy Myers, Exponent, Inc., MA

Jack E. Osborn, Airdusco, Inc., TN

Mark Runyon, Marsh Risk Consulting, OR

Bill Stevenson, CV Technology, Inc., FL

Guy R. Colonna, NFPA, Staff Liaison

II. Minutes of Meeting

1. The Chair called the meeting to order at 11:05 a.m., Tuesday, April 29, 2014 and

staff conducted a roll-call of attendees.

2. The Chair outlined the key action item for the meeting - completion of the

Correlating Committee review of the Second Draft for NFPA 91. The review includes

the Second Revisions, Public Comment (resolved items not associated with changes to

the standard), and Correlating Notes (CN) from the First Draft, as appropriate. The

Chair noted that the review guidelines document developed during prior meetings

CMD-AAC Meeting Minutes

April 29, 2014 (Conference call and web meeting)

2

would serve as the general process to be followed for this meeting. The guidelines are

attached to these minutes for reference.

3. Staff provided an update on the Committee membership. The Committee currently

has 14 principal voting members (plus a voting alternate member).

4. The Committee began work on reviewing the Second Draft of NFPA 91 according to

the guidelines. Following the review of the Public Comments, Second Revisions, and

Second Draft, the Correlating Committee created no Correlating Revisions (CR) for

NFPA 91. The Correlating Committee will receive an informational ballot affirming

their approval of the Second Draft with no further action.

5. Other Business. No other business was brought forward by the Committee.

6. Next Meeting. The Committee's next meeting will be to review the Second Draft

of NFPA 652. After discussion and review of calendars, the CC agreed to schedule the

Correlating Committee Second Draft meeting for NFPA 652 to be held in Atlanta on

November 4 - 6, 2014. The Committee also looked at dates and location for the next

required meeting, which would be the First Draft meeting for review of NFPA 61, 654,

and 664. Following a poll by staff, it was determined that the Correlating Committee

meeting for review of NFPA 61, 654, and 664 First Drafts would be in Dallas on

January 6 - 9, 2015. Separate meeting notices will be provided when hotel details are

finalized by NFPA.

7. There being no further business, the Correlating Committee Second Draft meeting

for NFPA 91 adjourned at 12:00 p.m., Tuesday, April 29, 2014.

Respectfully submitted,

G. R. Colonna, Staff Liaison

Address List 10/07/2014

Combustible Dusts CMD-AACSusan Bershad

Kevin Kreitman

CMD-AACChairCity of Redding Fire DepartmentPO Box 496071Redding, CA 96049

Phone/Cell: 530-225-4142 530-921-1711Fax: 530-225-4322Email : [email protected]

E 10/18/2011 Chris Aiken

CMD-AACPrincipalCargill, Inc.15407 McGinty Road West, MS 63Wayzata, MN 55391Alternate: Craig Froehling

Phone/Cell: 952-742-5093Fax:Email : [email protected]

U 07/29/2013

Matthew J. Bujewski

CMD-AACPrincipalMJB Risk Consulting9650 Mill Hill LaneSt. Louis, MO 63127

Phone/Cell: 314-270-3292 314-616-2098Fax:Email : [email protected]

SE 03/07/2013 John M. Cholin

CMD-AACPrincipalJ. M. Cholin Consultants Inc.101 Roosevelt DriveOakland, NJ 07436


SE 10/18/2011

Gregory F. Creswell

CMD-AACPrincipalTitanium Metals Corporation (TIMET)900 Hemlock RoadMorgantown, PA 19543


M 10/18/2011 Scott G. Davis

CMD-AACPrincipalGexCon US4833 Rugby Avenue, Suite 100Bethesda, MD 20814-3035


SE 03/07/2013

Henry L. Febo, Jr.

CMD-AACPrincipalFM GlobalEngineering Standards1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Alternate: Amy Brown

Phone/Cell: 781-255-4771Fax: 781-762-9375Email : [email protected]

I 10/18/2011 Walter L. Frank

CMD-AACPrincipalFrank Risk Solutions, Inc.1110 Shallcross AvenueWilmington, DE 19806


SE 10/23/2013

Donald Hayden

CMD-AACPrincipalClosure Systems International7702 Woodland Drive, Suite 200Indianapolis, IN 46278


U 08/09/2012 Edward R. LaPine

CMD-AACPrincipalAon Fire Protection Engineering Corporation2555 East Camelback Road Suite 700Phoenix, AZ 85016


I 10/29/2012

1



Arthur P. Mattos, Jr.

CMD-AACPrincipalXL Global Asset Protection Services3216 Tatting RoadMatthews, NC 28105-7181

Phone/Cell: 704-841-9291 603-660-2236Fax:Email : [email protected]

I 03/03/2014 Jack E. Osborn

CMD-AACPrincipalAirdusco, Inc.4739 Mendenhall Road SouthMemphis, TN 38141


M 10/18/2011

Bill Stevenson

CMD-AACPrincipalCV Technology, Inc.15852 Mercantile CourtJupiter, FL 33478Alternate: Jason Krbec


M 10/18/2011 Jérôme R. Taveau

CMD-AACPrincipalFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263Alternate: Adam Morrison


M 07/29/2013

Steve McAlister

CMD-AACVoting AlternateMichelin Tire Corporation6301 US Highway 76PO Box 308Sandy Springs, SC 29677Voting Alt. to Michelin Rep.


U 07/29/2013 Amy Brown

CMD-AACAlternateFM Global1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102FM GlobalPrincipal: Henry L. Febo, Jr.


I 03/03/2014

Craig Froehling

CMD-AACAlternateCargill, Inc.15407 McGinty Road West, MS 63Wayzata, MN 55391Principal: Chris Aiken


U 03/05/2012 Jason Krbec

CMD-AACAlternateCV Technology, Inc.15852 Mercantile CourtJupiter, FL 33478Principal: Bill Stevenson


M 10/29/2012

2



Adam Morrison

CMD-AACAlternateFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263Principal: Jérôme R. Taveau


M 03/03/2014 Matthew I. Chibbaro

CMD-AACNonvoting MemberUS Department of LaborOccupational Safety & Health Administration200 Constitution Ave. NW, Room N3609Washington, DC 20210Alternate: William R. Hamilton


E 10/18/2011

Mark W. Drake

CMD-AACNonvoting MemberLiberty Mutual14125 West 139th StreetOlathe, KS 66062-5885TC on Combustible Metals and Metal Dusts


I 10/18/2011 Paul F. Hart

CMD-AACNonvoting MemberAmerican International Group, Inc. (AIG)18257 Martin AvenueHomewood, IL 60430-2107TC on Fundamentals of Combustible Dusts


I 08/09/2011

Timothy J. Myers

CMD-AACNonvoting MemberExponent, Inc.9 Strathmore RoadNatick, MA 01760-2418TC on Agricultural Dusts


SE 10/18/2011 Jason P. Reason

CMD-AACNonvoting MemberLewellyn Technology321 North 18th AvenueBeech Grove, IN 46107TC on Wood and Cellulosic Materials Processing


SE 10/18/2011

Mark L. Runyon

CMD-AACNonvoting MemberMarsh Risk Consulting111 SW Columbia, Suite 500Portland, OR 97201TC on Handling and Conveying of Dusts, Vapors,and Gases


I 07/29/2013 William R. Hamilton

CMD-AACAlt. to Nonvoting MemberUS Department of LaborOccupational Safety & Health Administration200 Constitution Ave. NW, Room N3609Washington, DC 20210Principal: Matthew I. Chibbaro


E 10/18/2011

3



Susan Bershad

CMD-AACStaff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471


04/16/2014

4

Combustible Dusts Correlating Committee Review Guidelines

• First Revision - Review of material

o Review of Public inputs which are rejected (3.4.3 g) o Review of First Revisions which have negative votes (3.4.3 g) o Review of First Revisions which may conflict within or between NFPA Standards

(3.4.3 g) o Review of First Revisions which may result in conflicts between overlapping

functions in TC Scopes (3.4.3 g) o Review of Committee Inputs (3.4.3 g, h) o Committee members inputs/questions not previously addressed (3.4.3 g) o Review First Draft document layout for compliance with Manual of Style for NFPA

Technical Committee Documents, and if need for establishing supplemental operating procedures (3.4.3 f, g , h)

o Are there any items the CC has identified that should result in a Correlating Input to provide guidance to the Technical Committees (4.3.3; 4.3.3.1)

• Second Revision - Review of material o Review of CC notes on First Revision (3.4.3 g) o Review of Public Comments which are rejected (3.4.3 g) o Review of Second Revisions which have negative votes (3.4.3 g) o Review of Second Revisions which may conflict within or between NFPA

Standards (3.4.3 g) o Review of Second Revisions which may result in conflicts between overlapping

functions in TC Scopes (3.4.3 g) o Review of Second Revisions which have been identified by CC member (3.4.3 g) o Review Second Draft document layout for compliance with Manual of Style for

NFPA Manual of Style, and review if need exists for establishing supplemental operating procedures (3.4.3 f, g, h)

o Are there any items the CC has identified that should result in a Correlating Input to provide guidance to the Technical Committees (4.3.3; 4.3.3.1)

o Is there a potential for a CC vote that would result in return of the document to the TC for further study versus forwarding the Standard to the NFPA Technical Meeting (4.4.11.5.2 b)

Following are the Scopes for Correlating Committee and Dust Committees

Combustible Dusts (CMD-AAC)

Committee Scope This Committee shall have primary responsibility for documents on the hazard identification, prevention, control, and extinguishment of fires and explosions in the design, construction, installation, operation, and maintenance of facilities and systems used in manufacturing, processing, recycling, handling, conveying, or storing combustible particulate solids, combustible metals, or hybrid mixtures.

AGRICULTURAL DUSTS (CMD-AGR) 61

Committee Scope

This Committee shall have primary responsibility for documents on the prevention, control, and extinguishment of fire and explosions resulting from dusts produced by the processing, handling, and storage of grain, starch, food, animal feed, flour, and other agricultural products. The Technical Committee shall also be responsible for requirements relating to the protection of life and property from fire and explosion hazards at agricultural and food products facilities.

Committee Responsibility

Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities (NFPA 61)

Document Scope 1.1 Scope. 1.1.1* This standard shall apply to all of the following: (1) All facilities that receive, handle, process, dry, blend, use, mill, package, store, or ship dry agricultural bulk materials, their by-products, or dusts that include grains, oilseeds, agricultural seeds, legumes, sugar, flour, spices, feeds, and other related materials. (2) All facilities designed for manufacturing and handling starch, including drying, grinding, conveying, processing, packaging, and storing dry or modified starch, and dry products and dusts generated from these processes. (3) Those seed preparation and meal-handling systems of oilseed processing plants not covered by NFPA 36, Standard for Solvent Extraction Plants. 1.1.2 This standard shall not apply to oilseed extraction plants that are covered by NFPA 36, Standard for Solvent Extraction Plants. A.1.1.1 Examples of facilities covered by this standard include, but are not limited to, bakeries, grain elevators, feed mills, flour mills, milling, corn milling (dry and wet), rice milling, dry milk products, mix plants, soybean and other oilseed preparation operations, cereal processing, snack food processing, tortilla plants, chocolate processing, pet food processing, cake mix processing, sugar refining and processing, and seed plants.

Handling and Conveying of Dusts, Vapors, and Gases (CMD-HAP) 91 Committee Scope This Committee shall have primary responsibility for documents on the prevention, control, and extinguishment of fires and explosions in the design, construction, installation, operation, and maintenance of facilities and systems processing or conveying flammable or combustible dusts, gases, vapors, and mists.

Committee Responsibility Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids (NFPA 91) Standard for Prevention of Sulfur Fires and Explosions (NFPA 655) Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids (NFPA 654)

Document Scope (NFPA 91)

1.1.1 This standard provides minimum requirements for the design, construction, installation, operation, testing, and maintenance of exhaust systems for air conveying of vapors, gases, mists, and noncombustible particulate solids except as modified or amplified by other applicable NFPA standards. 1.1.2 This standard does not cover exhaust systems for conveying combustible particulate solids that are covered in other NFPA standards (see A.1.1).

COMBUSTIBLE METALS (CMD-CMM) 484

Committee Scope

This committee shall have primary responsibility for documents on safeguards against fire and explosion in the manufacturing, processing, handling, and storage of combustible metals, powders, and dusts.


Standard for Combustible Metals (NFPA 484)

Document Scope

1.1* Scope. This standard shall apply to the production, processing, finishing, handling, recycling, storage, and use of all metals and alloys that are in a form that is capable of combustion or explosion.

1.1.1 The procedures in Chapter 4 shall be used to determine whether a metal is in a noncombustible form.

1.1.2 Combustible Powder or Dust.

1.1.2.1 This standard also shall apply to operations where metal or metal alloys are subjected to processing or finishing operations that produce combustible powder or dust.

1.1.2.2 Operations where metal or metal alloys are subjected to processing or finishing operations that produce combustible powder or dust shall include, but shall not be limited to, machining, sawing, grinding, buffing, and polishing.

1.1.3* Metals, metal alloy parts, and those materials, including scrap, that exhibit combustion characteristics of aluminum, alkali metals, magnesium, tantalum, titanium, or zirconium shall be subject to the requirements of the metal whose combustion characteristics they most closely match.

1.1.4 Metals and metal alloy parts and those materials, including scrap, that do not exhibit combustion characteristics of alkali metals, aluminum, magnesium, niobium, tantalum, titanium, or zirconium are subject to the requirements of Chapter 10.

1.1.5* This standard shall not apply to the transportation of metals in any form on public highways and waterways or by air or rail.

1.1.6 This standard shall not apply to the primary production of aluminum, magnesium, and lithium.

1.1.7 This standard shall apply to laboratories that handle, use, or store more than 1/2 lb of alkali metals or 2 lb aggregate of other combustible metals, excluding alkali metals.

1.1.8 All alkali metals and metals that are in a form that is water reactive shall be subject to this standard.

1.1.9* If the quantity of a combustible metal listed in Table 1.1.9 is exceeded in an occupancy, the requirements of NFPA 484 shall apply.

STANDARD ON COMBUSTIBLE DUSTS (CMD-FUN) 652

Committee Scope

This Committee shall have primary responsibility for information and documents on the management of fire and explosion hazards from combustible dusts and particulate solids

Document Scope

This standard shall provide the basic principles of and requirements for identifying and managing the fire and explosion hazards of combustible dusts and particulate solids. Committee Responsibility Standard on Combustible Dusts (NFPA 652)

PREVENTION OF FIRE AND DUST EXPLOSIONS FROM THE MANUFACTURING, PROCESSING, AND HANDLING OF COMBUSTIBLE PARTICULATE SOLIDS (CMD- HAP) 654

Committee Scope

This Committee shall have primary responsibility for documents on the prevention, control, and extinguishment of fires and explosions in the design, construction, installation, operation, and maintenance of facilities and systems processing or conveying flammable or combustible dusts, gases, vapors, and mists.

Committee Responsibility Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids (NFPA 91)

Standard for Prevention of Sulfur Fires and Explosions (NFPA 655) Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids (NFPA 654)


1.1.1* This standard shall apply to all phases of the manufacture, processing, blending, pneumatic conveying, repackaging, and handling of combustible particulate solids or hybrid mixtures, regardless of concentration or particle size, where the materials present a fire or explosion hazard. 1.1.2 This standard shall apply to systems that convey combustible particulate solids that are produced as a result of a principal or incidental activity, regardless of concentration or particle size, where the materials present a fire or explosion hazard. 1.1.3 This standard shall not apply to materials covered by the following documents, unless specifically referenced by the applicable document: (1) NFPA 30B, Code for the Manufacture and Storage of Aerosol Products (2) NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Products Facilities (3) NFPA 120, Standard for Coal Preparation Plants (4) NFPA 432, Code for the Storage of Organic Peroxide Formulations (5) NFPA 480, Standard for the Storage, Handling, and Processing of Magnesium Solids and Powders (6) NFPA 481, Standard for the Production, Processing, Handling, and Storage of Titanium (7) NFPA 482, Standard for the Production, Processing, Handling, and Storage of Zirconium (8) NFPA 485, Standard for the Storage, Handling, Processing, and Use of Lithium Metal (9) NFPA 495, Explosive Materials Code (10) NFPA 651, Standard for the Machining and Finishing of Aluminum and the Production and Handling of Aluminum Powders (11) NFPA 655, Standard for Prevention of Sulfur Fires and Explosions (12) NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities (13) NFPA 1124, Code for the Manufacture, Transportation, and Storage of Fireworks and Pyrotechnic Articles (14) NFPA 1125, Code for the Manufacture of Model Rocket and High Power Rocket Motors (15) NFPA 8503, Standard for Pulverized Fuel Systems 1.1.4 In the event of a conflict between this standard and a specific occupancy standard, the specific occupancy standard requirements shall apply.

PREVENTION OF SULFUR FIRES AND EXPLOSIONS (CMD-HAP) 655

Committee Scope

This Committee shall have primary responsibility for documents on the prevention, control, and extinguishment of fires and explosions in the design, construction, installation, operation, and maintenance of facilities and systems processing or conveying flammable or combustible dusts, gases, vapors, and mists.


Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids (NFPA 91) Standard for Prevention of Sulfur Fires and Explosions (NFPA 655) Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids (NFPA 654)


1.1 Scope. 1.1.1* This standard shall apply to the crushing, grinding, or pulverizing of sulfur and to the handling of sulfur in any form. 1.1.2 This standard shall not apply to the mining of sulfur, recovery of sulfur from process streams, or transportation of sulfur.

PREVENTION OF FIRES AND EXPLOSIONS IN WOOD PROCESSING AND WOODWORKING FACILITIES (CMD-WOO) 664

Committee Scope

This Committee shall have primary responsibility for documents on the prevention, control, and extinguishment of fires and explosions in wood processing, wood working facilities and facilities that use other cellulosic materials as a substitute or additive for wood.


Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities (NFPA 664)

Document Scope

1.1 Scope. This standard shall establish the minimum requirements for fire and explosion prevention and protection of industrial, commercial, or institutional facilities that process wood or manufacture wood products, using wood or other cellulosic fiber as a substitute for or additive to wood fiber, and that process wood, creating wood chips, particles, or dust.

1.1.1 Woodworking and wood processing facilities shall include, but are not limited to, wood flour plants, industrial woodworking plants, furniture plants, plywood plants, composite board plants, lumber mills, and production-type woodworking shops and carpentry shops that are incidental to facilities that would not otherwise fall within the purview of this standard. 1.1.2* This standard shall apply to woodworking operations that occupy areas of more than 465 m2 (5000 ft2) or where dust-producing equipment requires an aggregate dust collection flow rate of more than 2549 m3/hr (1500 ft3/min).

Regulations Governing the Development of NFPA Standards – Fall 2013 and all subsequent revision cycles (excerpts pertaining to Correlating Committee and Second Draft Actions)

4.4.11 Correlating Committee Review and Action on Public Comments and the Second Draft.

4.4.11.1 Review and Permitted Actions. Where Technical Committee activities are managed and coordinated by a Correlating Committee, the Correlating Committee shall review the Public Comments and the Second Draft as balloted by the Technical Committees under its responsibility and take appropriate action within the limits of its authority and responsibilities, as set forth in 3.4.2 and 3.4.3, by creating Correlating Revisions and revising actions on Comments as set forth in 4.4.112 and 4.4.11.3.

4.4.11.2 Correlating Revisions. The Correlating Committee may, within the limits of its authority, revise the Second Draft by creating Second Correlating Revisions, with associated Correlating Statements, that delete or modify Second Revisions or other text in the Second Draft. To the extent that a Second Correlating Revision modifies or deletes a Second Revision or any portion of the Second Revision, the original text of the Second Revision or affected portion thereof shall be redesignated as a Committee Comment and shall be published in the Comment section of the Second Draft Report along with a note indicating that the text contained in the Committee Comment has been modified or deleted from the Second Draft as a result of a Second Correlating Revision.

4.4.11.2.1 Size and Content of Second Correlating Revisions.

(a) An individual Revision can contain multiple changes to the Standard text, provided that the changes are contained within a contiguous portion of the Standard that is no smaller than an individual numbered or lettered section or larger than a chapter.

(b) Exception for Global Revisions. Where the Correlating Committee wishes to revise a term or phrase throughout an NFPA Standard so as to achieve editorial consistency or correlation, the Committee may do so through a Global Revision.

4.4.11.3 Change in Actions on Comments. Where a Second Correlating Revision is inconsistent with the Technical Committee’s Committee Action on any Comment, the Action shall be changed to make it consistent with the Second Correlating Revision, and a note shall be provided with the new Action indicating that it has been changed at the direction of the Correlating Committee to be consistent with a Second Correlating Revision.

4.4.11.4 Preparation of Second Draft for Balloting.

4.4.11.4.1 When the Correlating Committee has completed its work, NFPA Staff shall prepare the complete Second Draft showing individual Second Correlating Revisions and their associated Committee Statements for Balloting.

4.4.11.4.2 Prior to the Ballot, the Second Draft and individual Second Correlating Revisions shall be reviewed by NFPA Staff for editorial consistency and conformance with the Manual of Style for NFPA Technical Committee Documents, and any required editorial changes shall be incorporated into the text of the Second Draft and individual Second Correlating Revisions prior to Balloting.

4.4.11.4.3 If, in the course of editorial review, NFPA Staff make an editorial change to text that is not part of a Second Correlating Revision, Staff may, if Committee review is deemed advisable, designate the affected text as a Second Correlating Revision. A notice shall be attached to such a Revision indicating that it was developed by Staff for editorial purposes.

4.4.11.5 Correlating Committee Ballot on Second Draft.

4.4.11.5.1 Balloting on Second Correlating Revisions.

(a) Any proposed Second Correlating Revisions to the Second Draft shall be submitted to a Ballot of the Correlating Committee. Approval of Second Correlating Revisions shall be established by a three-fourths affirmative vote of the Correlating Committee. Negative votes or abstentions on specific Second Correlating Revisions shall include the reasons for such votes.

(b) Only proposed Second Correlating Revisions that are approved by the Correlating Committee Ballot shall become Second Correlating Revisions and shall be published in the Second Draft Report. Second Correlating Revisions that fail Ballot shall not be published.

(c) For approved Second Correlating Revisions, a ballot statement as indicated in 3.3.4.3(d) shall be published with their associated Second Correlating Revisions in the Second Draft Report.

(d) Treatment of Global Revisions. Global Revisions are balloted in the same manner as other Revisions, and a Global Revision that passes Ballot is applied, as directed, throughout the Standard, independently of the results of balloting on other Revisions.

4.4.11.5.2 Ballot on the Report as a Whole. In addition to the Ballot on each of its individual Second Correlating Revisions (see 4.4.11.3.1), there shall be a Ballot of the Correlating Committee on the Second Draft. The results of the Ballot for the further processing of the NFPA Standard are as follows:

(a) Forward the NFPA Standard to the NFPA Technical Meeting. The proposed NFPA Standard shall be forwarded for consideration to the NFPA Membership unless the Correlating Committee, by a three-fourths negative vote on the Ballot (demonstrably based on considerations within its authority and responsibility as set forth in 3.4.2 and 3.4.3), directs the return of the NFPA Standard to the Technical Committee for further study. If the NFPA Standard is forwarded for consideration to the NFPA Membership, the results of the Ballot, including the reasons for negative votes, shall be included in the Technical Committee Report.

(b) Return of the NFPA Standard. If the Correlating Committee directs the return of the NFPA Standard to the Technical Committee for further study, the NFPA Standard is not forwarded to the NFPA Membership, the Second Draft Report is not published, and a notice that the Correlating Committee has directed the return of the NFPA Standard to the Technical Committee for further study shall be published in place of the Second Draft Report.

4.4.11.6 Further Processing of NFPA Standards that have been Returned to Committee by the Correlating Committee. When an NFPA Standard is returned to the Technical Committee in accordance with 4.4.11.5.2(b), the Correlating Committee shall make a recommendation to the Standards Council on further processing, and the Standards Council shall direct one of the following options:

(a) Process the NFPA Standard based on an existing First Draft, without a call for new Public Comments. This requires the Technical Committee to begin with the existing First Draft as published, reconsider and act on all Public Comments previously filed, generate any new Second Revisions, and publish and prepare an amended Second Draft.

(b) Process the NFPA Standard based on the existing First Draft, with a call for new Public Comments. This requires the Technical Committee to begin with the existing First Draft as published, call for new Public Comments that would supersede all previously filed Public Comments, and publish and prepare a new Second Draft.

(c) Process the NFPA Standard through a full Revision Cycle without a call for new Public Input. This requires the Technical Committee to reconsider all Public Input previously filed, generate any new First Revisions, and publish and prepare an amended First Draft, followed by the processing of the new Second Draft.

(d) Process the NFPA Standard through a full Revision Cycle with a call for new Public Input. This requires the Technical Committee to call for new Public Input that would supersede all previously filed Public Input, followed by the processing of the new Second Draft.

Second Revision No. 143-NFPA 652-2014 [ Global Comment ]

Move existing 7.3.3.3 and 7.3.4.3 text as new 4.2.5 and 4.2.6, respectively.

Submitter Information Verification

Submitter Full Name: Sonia BarbosaOrganization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Thu Aug 14 12:34:09 EDT 2014

Committee Statement

Committee Statement:

Existing 7.3.3.3 and 7.3.4.3 are being moved to Chapter 4 to establish the requirement for managing the effects of fire, flash fire or explosion within either processes or facility compartments as part of the General Requirements and not be limited to the DHA requirements in Chapter 7.

Response Message:

Page 1 of 168National Fire Protection Association Report

9/8/2014http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...

Second Revision No. 48-NFPA 652-2014 [ Global Comment ]

Replace "Process Hazards Analysis" with "Dust Hazards Analysis" throughout the standardReplace PHA with DHA throughout the standardReplace "Process Hazard Analysis" with "Dust Hazards Analysis" throughout the standard


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address: City:State: Zip: Submittal Date: Fri Mar 14 14:53:34 EDT 2014

Committee Statement


To make the hazard analysis more specifically applicable to NFPA 652 and the commodity-specific NFPA dust standards, the Committee recommends revising the term from process hazard (s) analysis to dust hazards analysis and PHA to DHA. This change also should remove some concern that the DHA is intended to be the same as the PHA in OSHA's Process Safety Management regulation.

Response Message:



Second Revision No. 1-NFPA 652-2014 [ Section No. 1.2 ]

1.2 Purpose.This standard shall provide the minimum general requirements anddirect necessary to manage the fire, flash fire, and explosion hazards posed by combustible dusts and directs the user to other NFPA standards for industry- and commodity-specific requirements.


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Mon Mar 10 12:26:44 EDT 2014

Committee Statement

CommitteeStatement:

The Committee has revised this requirement in the scope statement to specifically state its intent. The revisions created with the SR address the comments linked with the related Public Comment items while still conforming with the NFPA Manual of Style.

ResponseMessage:Public Comment No. 176-NFPA 652-2013 [Section No. 1.2]Public Comment No. 186-NFPA 652-2013 [Section No. 1.2]Public Comment No. 291-NFPA 652-2013 [Section No. 1.2]Public Comment No. 372-NFPA 652-2013 [Section No. 1.2]Public Comment No. 458-NFPA 652-2013 [Section No. 1.2]Public Comment No. 479-NFPA 652-2013 [Section No. 1.2]



Second Revision No. 134-NFPA 652-2014 [ Section No. 1.3.1 ]

1.3.1The provisions of this standard user shall be applied in accordance with permitted to use Figure 1.3.1for guidance when using this standard. See Figure 1.3.1 .Figure 1.3.1 Document Flow Diagram for Combustible Dust Hazard Evaluation.

Supplemental Information



File Name DescriptionFigure_1_3_1_2014-0522a.pdf

Figure 1.3.1 related to SR 134 and PC 503 for NFPA 652

G652-8r1.jpg Figure 1.3.1_1-revised G652-9r1.jpg Figure 1.3.1_2--revised


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Fri Jul 18 11:03:39 EDT 2014

Committee Statement


This document appears to be incomplete in that this section is missing and therefore not subject to Public Comment. This section should be removed since it serves no purpose as it is currently written.

The Committee has developed Figure 1.3.1 and modified the language indicating that users are permitted to use the figure as guidance when applying NFPA 652, so that the provision does not seem like the figure must be used.

Response Message:Public Comment No. 503-NFPA 652-2013 [Section No. 1.3.1]



Do you manufacture, process, blend, convey, re-package,

generate or handle combustible dusts or combustible particulate

solids? (See section 1.3.1)

Fig. 1.3.1 Flowchart for Management of Combustible Dust Hazards

Yes

No Outside the scope of NFPA 652

Is the material covered by one of the exemptions in

section 1.3.2?

Yes

Have you determined the combustibility or explosibility

hazards of the material? (See section 4.1, item 1)

Refer to methods in Chapter 5 - Hazard Identification

No

No

Yes

Is the material explosible or combustible?

Document the results in accordance with section 5.2.2.

No

Has a dust hazards analysis been performed?

Refer to methods in Chapter 7 - Dust Hazard Analysis

No

Yes

Has a plan been developed to manage the

hazard(s)?

Yes

Is the particulate solid a mixture of two or more

components?

Refer to methods in Chapter 6 - Performance Based Design Alternatives and

Chapter 8 - Hazard Management: Mitigation and Prevention

No

Have industry or commodity-specific standards been referenced

with regard to the hazard management plan(s)? NOTE:

Resolve conflicts using section 1.4.

Yes

Refer to section 5.5.2 - Mixtures Yes No

Is the particulate solid a metal or an alloy?

Is the particulate solid an agricultural or a food

product?

Is the particulate solid from wood processing or

woodworking?

Is the particulate solid sulfur?

Refer to NFPA 484 - Standard for Combustible Metals

Refer to NFPA 61- Standard for the Prevention of Fires and Dust Explosions

in Agricultural and Food Processing Facilities

Refer to NFPA 664 - Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking

Facilities

Refer to NFPA 655 - Standard for Prevention of Sulfur Fires

and Explosions

Refer to NFPA 654 – Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing,

and Handling of Combustible Particulate Solids

Modify the hazard management plan if needed and implement the plan in

accordance with Chapter 9 - Management Systems

Yes

Yes

Yes

Yes

No

No

No

No

No

Yes

NOTE: The purpose of this graphic is to aid the user's understanding of the process contained within this document and how it relates to other NFPA dust-related documents. This graphic does not replace or supersede any of the detailed requirements contained within this standard.


1.3.2This standard establishes the basic principles and requirements that shall be applied shall apply to all facilities where and operations that manufacture, process, blend, convey, repackage, generate, or handle combustible dusts or combustible particulate solids are present .1.3.3This standard shall not apply to the following:

(1) Storage or use of consumer quantities of such materials on the premises of residential or office occupancies

(2) Storage or use of commercially packaged materials at retail facilities

(3) Such materials displayed in original packaging in mercantile occupancies and intended for personal or household use or as building materials

(4) Warehousing of sealed containers of such materials when not associated with an operation that handles or generates combustible dust

(5) Such materials stored or used in farm buildings or similar occupancies for on-premises agricultural purposes



Committee Statement

CommitteeStatement:

There are many ‘facilities’ that have combustible dusts that don’t pose a deflagration hazard such as storage warehouses of bagged product (flour, starch, meals, etc). Also there is no definition for a ‘facility’. This should be defined to avoid including businesses the TC did not intend the standard to be applied to such as restaurants, family farms, etc. As noted by the submitter, the Committee has addressed both what the standard applies to as well as what it is not intended to apply to. The Committee notes that the submitter of PC No. 130 has indicated a need to address the breadth of application or coverage within NFPA 652, which is what the new 1.3.3 seeks to accomplish. In addition, while the submitter intended to revise this section in a manner that would create conditions for a dust deflagration hazard that were not appropriate and not consistent with the application, the Committee has not included those revisions as proposed.

Response Message:



Public Comment No. 130-NFPA 652-2013 [Section No. 1.3.2]




1.4 Conflicts.1.4.1*For the purposes of this standard, the industry- or commodity-specific NFPAstandards shall include the following:

(1) NFPA 61 , Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities

(2) NFPA 484 , Standard for Combustible Metals

(3) NFPA 654 , Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids

(4) NFPA 655 , Standard for Prevention of Sulfure Fires and Explosions

(5) NFPA 664 , Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities

1.4.2Where a requirement in an industry industry- or commodity-specific NFPA standard is more stringent than differs from the requirement specified in this standard, the requirement in the industry industry- or commodity-specific NFPA standard shall be applied permitted to be used .1.4.3Where a requirement in an industry industry- or commodity-specific NFPA standard is less stringent than specifically prohibits a requirement specified in this standard, the owner/operator shall either comply with the requirement of this standard or justify how the prohibition in the industry- or commodity-specific NFPA standard shall be applied. the industry or commodity-specific requirement achieves the safety objectives of this standard for the situation.1.4.4Where an industry- or commodity-specific NFPA standard neither prohibits nor provides a requirement, the requirement in this standard shall be applied.1.4.5Where a conflict between a general requirement of this standard and a specific requirement of this standard exists, the specific requirement shall apply.


File Name DescriptionA.1.4.1_SR-4_edited_.docx edited 8/8/14





Committee Statement

CommitteeStatement:

The Fundamentals TC reviewed the CC Note from the First Draft and has acted to develop this Second Revision, No. 4. The Committee believes it addresses the variations possible for relating NFPA 652 to the existing industry or commodity-specific NFPA standards, so that an effective hierarchy can be established. Annex material has also been included for A.1.4.1 to note that additional NFPA standards might also be considered when determining industry-specific requirements pertaining to combustible particulate solids.

CC NOTE: The following CC Note No. 1 appeared in the First Draft Report as First Revision No. 16, and also related Public Input No. 10, 132, 1, 130, 183, 20, 330, and 66.

The Correlating Committee requests that the TC review the requirements in1.4.1 and 1.4.2 regarding application of the standard and consider whetherthe expectation in 1.4.2 that the owner/operator will resolve differencesbetween the requirements of NFPA 652 and a commodity-specific standard isappropriate. One observation is to direct the attention to requirements not otherwise covered rather than on the more subjective aspect of what is “more” or “less” stringent. For example, if a commodity-specific document does not cover one of the elements deemed fundamental within NFPA 652 then the other committee could choose to address it, to refer to NFPA 652 where it would be covered, or to justify why it is not needed in the standard. Any issues that might arise when both documents address a requirement would then be addressed for correlation by the Correlating Committee.

ResponseMessage:Public Comment No. 3-NFPA 652-2013 [Section No. 1.4]



[SR-4 Annex material]

A.1.4.1

Other industry- or commodity-specific NFPA documents that might be considered

include NFPA 30B, NFPA 33, NFPA 85, NFPA 120, NFPA 495, NFPA 820, NFPA 850, and

NFPA 1125.


1.5 Goal.The goal of this standard is to provide safety measures to prevent and mitigate fires and dust explosions in facilities that handle combustible particulate solids.



Committee Statement

CommitteeStatement:

This provision is redundant and unhelpful, and should be deleted in its entirety. The Committee agrees with the submitter of PC No. 465 and the related items, that the requirement in paragraph 1.5 is redundant and can be confusing with the objectives established in Chapter 4. This action deletes paragraph 1.5. The Committee has linked related Public Comments with this action as the substantiations for those recommendations pointed out that this goal section was redundant with other sections, so deleting it makes revision no longer necessary but is consistent with those comments pointing to redundant language.

ResponseMessage:Public Comment No. 69-NFPA 652-2013 [Section No. 1.5]Public Comment No. 188-NFPA 652-2013 [Section No. 1.5]Public Comment No. 295-NFPA 652-2013 [Section No. 1.5]Public Comment No. 377-NFPA 652-2013 [Section No. 1.5]Public Comment No. 402-NFPA 652-2013 [Section No. 1.5]Public Comment No. 465-NFPA 652-2013 [Section No. 1.5]




1.6.2Technical documentation shall be submitted made available to the authority having jurisdiction to demonstrate equivalency.



Committee Statement

CommitteeStatement:

This information is available for the AHJ to review when requested. Requiring all facilities to submit it would bog down approval processes that are already in place. The Committee revised this provision based on PC No. 133 and No. 467. Two other comments are linked with this SR; PC No. 468 recommended deletion of part of this requirement, but the change through this SR makes deletion not necessary. PC No. 15 is also covered by this revision.

Response Message:Public Comment No. 15-NFPA 652-2013 [Section No. 1.7]Public Comment No. 133-NFPA 652-2013 [Section No. 1.7.2]Public Comment No. 467-NFPA 652-2013 [Section No. 1.7.2]Public Comment No. 468-NFPA 652-2013 [Section No. 1.7.3]




2.2 NFPA Publications.National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition.

NFPA 11, Standard for Low-, Medium-, and High-Expansion Foam, 2010 2015edition.

NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2011 2015 edition.

NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems, 2009 2015edition. NFPA 13, Standard for the Installation of Sprinkler Systems, 2013 2016 edition.

NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 2013edition.

NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2012edition.

NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems, 2011 2015 edition.

NFPA 17, Standard for Dry Chemical Extinguishing Systems, 2013 edition.

NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, 2013 2016 edition.

NFPA 22, Standard for Water Tanks for Private Fire Protection, 2013 edition.

NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, 2013 2016 edition.

NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, 2011 2014 edition.

NFPA 31, Standard for the Installation of Oil-Burning Equipment, 2011 edition.

NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2009 2014 edition. NFPA 54, National Fuel Gas Code, 2012 2015 edition.

NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2013 edition.

NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 edition.

NFPA 69, Standard on Explosion Prevention Systems, 2008 2014 edition.

NFPA 70®, National Electrical Code, 2011 2014 edition.

NFPA 72®, National Fire Alarm and Signaling Code, 2013 2016 edition.

NFPA 85, Boiler and Combustion Systems Hazards Code, 2014 2015 edition.

NFPA 86, Standard for Ovens and Furnaces, 2011 2015 edition.

NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids, 2015 edition.



NFPA 221, Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier Walls, 2012 2015 edition.

NFPA 484, Standard for Combustible Metals, 2012 2015 edition.

NFPA 505, Fire Safety Standard for Powered Industrial Trucks Including Type Designations, Areas of Use, Conversions, Maintenance, and Operations, 2013edition. NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2013edition.

NFPA 655, Standard for Prevention of Sulfur Fires and Explosions, 2012 edition.

NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities, 2012 edition.

NFPA 750, Standard on Water Mist Fire Protection Systems, 2010 2015 edition.

NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2012 2015edition. NFPA 2112, Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2012 edition.

NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Short-Duration Thermal Exposures from Fire, 2012 2015 edition.


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Tue Jun 03 09:38:47 EDT 2014

Committee Statement


A reference to NFPA 61 should be inserted. Per SR No. 3, the Commodity-specific standards have been identified and are included as appropriate within the mandatory references section of Chapter 2.

Response Message:Public Comment No. 4-NFPA 652-2013 [Section No. 2.2]Public Comment No. 177-NFPA 652-2013 [Section No. 2.2]Public Comment No. 466-NFPA 652-2013 [Section No. 2.2]




2.3.2 ASTM Publications.ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM E 1226 E1226 , Standard Test Method for Explosibility of Dust Clouds, 2012 2012a .

ASTM E 1515 E1515 , Standard Test Method for Minimum ExplosibleConcentration of Combustible Dusts, 2007.


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Thu Sep 04 07:58:34 EDT 2014

Committee Statement

CommitteeStatement:

Editorial change to update the reference standard to the most current and correct edition per the ASTM listing.

Response Message:




2.4 References for Extracts in Mandatory Sections.NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2009 2014 edition.

NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2013 edition.

NFPA 69, Standard on Explosion Prevention Systems, 2008 2014 edition.

NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids, 2010 edition.

NFPA 221, Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier Walls, 2012 2015 edition. NFPA 484, Standard for Combustible Metals, 2012 2015 edition.

NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, 2013edition.

NFPA 921, Guide for Fire and Explosion Investigations, 2011 2014 edition.

NFPA 1250, Recommended Practice in Fire and Emergency Services Organization Risk Management, 2015 edition.

NFPA 1451, Standard for a Fire and Emergency Service Vehicle Operations Training Program, 2013 edition.


Submitter Full Name: Sonia BarbosaOrganization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Mon Aug 04 13:16:38 EDT 2014

Committee Statement

Committee Statement: Updated edition dates, deleted NFPA 91 and added NFPA 1250Response Message:



Second Revision No. 7-NFPA 652-2014 [ Section No. 3.3.1.1 ]

3.3.1.1 Enclosureless AMS.An air-material separator designed and used to remove dust from the transport air to separate the conveying air from the material being conveyed where the filter medium is not enclosed or in a container.



Committee Statement

CommitteeStatement:

This definition is subsidiary to 3.3.1. The proposed modification makes the definition structurally consistent with 3.3.1, reducing the potential for ambiguity.

Response Message:Public Comment No. 59-NFPA 652-2013 [Section No. 3.3.1.1]



Second Revision No. 138-NFPA 652-2014 [ New Section after 3.3.2 ]

3.3.3 Bonding.For the purpose of controlling static electric hazards, the process of connectingtwo or more conductive objects by means of a conductor so that they are at thesame electrical potential but not necessarily at the same potential as the earth.


Submitter Full Name: Sonia BarbosaOrganization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Fri Jul 25 14:48:57 EDT 2014

Committee Statement


The Committee is adding a definition for the term bonding as it is used in the standard as part of protection against static electrical ignition hazards.

Response Message:




See SR-64

3.3.7* Combustible Particulate Solid.Any solid material composed of distinct particles or pieces, regardless of size, shape, or chemical composition that presents a fire hazard. [ 654, 2013] , that, when processed, stored, or handled in the facility, has the potential to produce a combustible dust.3.3.8 Compartment.A subdivision of an enclosure.



Committee Statement

CommitteeStatement:

The current definition is too broad, as it would include virtually anything that burns, regardless of size. This approach is scientifically erroneous, creates uncertainty and imposes inappropriate burdens on facility operators that cannot be fixed simply by making a statement in the Annex for related terms (e.g., "Dust"). The proposed definition provides the context that the standard is trying to achieve and is consistent with the intent expressed in the draft annexes for Combustible Dust, Combustible Particulate Solid, and Dust. This is also consistent with the proposed changes to the Scope section of the document. The Committee considered the input in these various Public Comments and used PC No. 381 as the basis for developing this Second Revision. The change is now consistent with how combustible particulate solid and combustible dust are used throughout the standard.

ResponseMessage:Public Comment No. 74-NFPA 652-2013 [Section No. 3.3.6]Public Comment No. 171-NFPA 652-2013 [New Section after 3.3.6]Public Comment No. 193-NFPA 652-2013 [Section No. 3.3.6]Public Comment No. 237-NFPA 652-2013 [New Section after 3.3.6]Public Comment No. 274-NFPA 652-2013 [Section No. 3.3.6]Public Comment No. 381-NFPA 652-2013 [Section No. 3.3.6]Public Comment No. 471-NFPA 652-2013 [Section No. 3.3.6]Public Comment No. 490-NFPA 652-2013 [Section No. 3.3.6]



Second Revision No. 9-NFPA 652-2014 [ Sections 3.3.9, 3.3.10 ]

3.3.11 Detachment.To be located Location in a separate building with physical clear space between or in an outside area located away removed from other structures of interest to be protected by a distance as required by this standard .3.3.12 Duct.Pipes, tubes, or other enclosures used for the purpose of pneumatically conveying materials. [ 91, 2010] to convey materials pneumatically or by gravity.



Committee Statement

CommitteeStatement:

The Committee agrees with the submitter's substantiation for PC No. 195 and makes the following revisions in this SR. This SR revises both Detached Construction and Duct per the recommendations in PC No. 195 with some modification. This action addresses a number of linked Public Comments asnoted.

Substantiation 3.3.9: The proposed sentence is awkward, missing punctuation, ambiguous and likely to cause confusion. The revised sentence clarifies this provision.

Substantiation 3.3.10: Some material is fed through piping by gravity and the proposed definition fails to cover that type of installation. The appropriate approach is to adopt a new and effective definition of the term rather than adopting an incomplete and misleading definition from another NFPA standard. That is one reason for the correlating committee.

ResponseMessage:Public Comment No. 76-NFPA 652-2013 [Section No. 3.3.10]Public Comment No. 195-NFPA 652-2013 [Sections 3.3.9, 3.3.10]Public Comment No. 276-NFPA 652-2013 [Section No. 3.3.9]Public Comment No. 277-NFPA 652-2013 [Section No. 3.3.10]Public Comment No. 380-NFPA 652-2013 [Section No. 3.3.10]




3.3.13 Dust.A particulate material composed of particles typically having dimensions fromeffectively zero to maximum upper dimension, depending on particle shape, in therange of 200 microns to 2000 microns (2 mm).



Committee Statement

CommitteeStatement:

This definition really is not needed as 'combustible dust' is defined and the inclusion of the wide particle size range conflicts with other related definitions. The extensive Annex material provides little clarification and duplicates other annex material related to combustible dust. None of the other combustible dust documents feel a need to define 'dust'. The definition also contains what might be interpreted as criteria within it which is not consistent with NFPA Manual of Style practices for definitions. The Committee proposes that the annex to this definition be retained and relocated as additional annex for thedefinition of combustible particulate solid at A.3.3.6.

ResponseMessage:Public Comment No. 339-NFPA 652-2013 [Section No. 3.3.11]




3.3.13* Dust Collection System.A combination of equipment designed to capture, contain, and pneumatically convey fugitive dust to an AMS air-material separator (AMS) in order to remove the dust from the process equipment or surrounding area .



Committee Statement

CommitteeStatement:

Stating that the dust collection system removes dust from the "process" leaves an implication that dust is only being removed from process equipment. In actuality, dust collection systems are used to extract dust from process equipment or from the general environment external to the process equipment.





3.3.14 Dust Deflagration Hazard.The presence of explosible dust that is suspended in an oxidizing medium in concentrations at or above its minimum explosive concentration; or the presence of accumulations of explosible dust where a means of suspending the dust is present. A condition that presents the potential for harm or damage to people, property, or the environment due to the combustion of a sufficient quantity of combustible dust suspended in air or another oxidizing medium.


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Mon Jul 14 11:07:52 EDT 2014

Committee Statement




Section 3.3.13 Dust Deflagration Hazard (definition):

a. The definition does not provide any guidance on the frequency of occurrence of explosible dust concentrations above minimum explosible concentrations. The Committee should provide language consistent with (or reference) NFPA 499 (electrical classification protocol) which distinguishes between conditions that are “normal” and those that result from equipment“breakdowns”. This distinction is critical, as many processes operate for years without experiencing explosible dust concentrations in an area, but may experience an abnormal breakdown that generates excess dust in the area. Clearly these differences are material in terms of risk and what protective measures should be applied.

b. The definition also indicates that a dust deflagration hazard exists due to the “presence of accumulations of explosible dust where a means of suspending the dust is present”. This statement appears to imply that regardless of the amount of dust present (no reference to quantity or MEC), the hazard may be present. There is no guidance provided on what “a means of suspending the dust” is intended to capture. This definition triggers the requirement to make significant process and building upgrades, and clarity is essential. Recommended re-wording of this section is provided below. Additional guidance related to “normal conditions” should be provided in theappendix.

c. The presence of explosible dust that is suspended in an oxidizing medium in concentrations at or above its minimum explosive concentration under normal conditions; or the presence of accumulations of explosible dust above threshold quantities where a means of suspending the dust is present under normal conditions.

The Committee addressed the concerns of the submitter with the proposed revision to the definition.





3.3.21 Fuel Object.A combustible object or mass of particulate that can serve as a source of fuel for a fire or deflagration; sometimes referred to as a fuel package .


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Thu Mar 13 14:17:41 EDT 2014

Committee Statement

CommitteeStatement:

Clarify what is intended by the term fuel object as used in Chapter 6.

Response Message:




3.3.23 Grounding.The process of bonding one or more conductive objects to the ground so that allobjects are at zero electrical potential; also referred to as earthing .


Submitter Full Name: Sonia BarbosaOrganization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Fri Jul 25 14:52:24 EDT 2014

Committee Statement


The Committee is adding a definition for the term grounding as it is used in the standard when referring to controls for static electrical hazards.

Response Message:




3.3.24 Hot Work.Work involving burning, welding, or a similar operation that is capable of initiating fires or explosions. [51B, 2009 2014 ]



Committee Statement

CommitteeStatement:

Updated the extract reference for NFPA 51B to the most current edition date.

Response Message:




3.3.25* Hybrid Mixture.A mixture of a flammable gas at greater than 10 percent of its lower flammable limit with either a combustible dust or a combustible mist An explosible heterogeneous mixture, comprising gas with suspended solid or liquid particulates, in which the total flammable gas concentration is ≥10 percent of the lower flammable limit (LFL) and the total suspended particulate concentration is ≥10 percent of the minimum explosible concentration (MEC) . [68,2007 2013 ]



Committee Statement

CommitteeStatement:

This change updates the definition of "hybrid mixture" to be consistent with the updated term from the extract source document, NFPA 68, so that NFPA 652 is using the most current definition as the basis for the extract into the standard.

Response Message:




3.3.31 Pyrophoric Material.A chemical with an autoignition temperature in air at or below 130°F (54.4°C).[ 5000, 2015]


Submitter Full Name: Sonia BarbosaOrganization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Thu Jul 24 17:07:37 EDT 2014

Committee Statement


Because some nanoparticles can behave as pyrophoric materials, the Committee is adding the definition using the extracted definition from NFPA 5000.

Response Message:




3.3.16* Process Dust Hazards Analysis (DHA) .A systematic review of to identify and evaluate the potential fire and , flash fire, or explosion hazards associated with the presence of one or more combustible particulate solids in a process or facility compartment .


File Name DescriptionA.3.3.X_SR-14_edited_.docx edited 8/8/14



Committee Statement

CommitteeStatement:

The text is revised for clarification and to reflect the fact that the scope of the standard is limited to combustible dust and extends to other combustible particulate solids only to the extent that the other combustible particulate solids are converted to combustible dust or would influence an event involving combustible dust.

Annex A changes: The previous discussion was unclear as it used the term PHA twice in the same sentence, intending to potentially mean two different things. The point is that the PHA required by NFPA 652 need not comply with the OSHA PSM requirements for PHAs, unless it is a covered process.

ResponseMessage:Public Comment No. 46-NFPA 652-2013 [Section No. A.3.3.27]Public Comment No. 78-NFPA 652-2013 [Section No. 3.3.27]Public Comment No. 105-NFPA 652-2013 [Section No. A.3.3.27]Public Comment No. 198-NFPA 652-2013 [Section No. 3.3.27]Public Comment No. 199-NFPA 652-2013 [Section No. A.3.3.27]Public Comment No. 281-NFPA 652-2013 [Section No. 3.3.27]Public Comment No. 373-NFPA 652-2013 [Section No. A.3.3.27]Public Comment No. 383-NFPA 652-2013 [Section No. 3.3.27]



[A.3.3.X SR-14]

A.3.3.27 Process Dust Hazards Analysis (DHA)..

In the context of this definition, it is not intended that, the process dust hazards

analysis (DHA) must comply with the pProcess hHazards aAnalysis (PHA) requirements contained in

OSHA regulation (PHA) is not intended to imply performance of a PHA that is often associated

with a portion of OSHA requirements 29 CFR 1910.119, “Process Safety Management of Highly

Hazardous Chemicals.” While the DHA can comply with OSHA PHA requirementsPHA process can

be used to perform a PHA as it applies to this standard, other methods can also be used (s. (See

Annex B)..) However, some processes mightay fall within the scope of the OSHA regulation 29 CFR 1910.119, and there couldmay be a legal requirement to comply with that regulation.


3.3.35 Segregation.The establishment of a physical barrier between locations of interest the hazard area and an area to be protected .



Committee Statement

CommitteeStatement:

The Committee addressed the concerns expressed by the submitter of PC No. 549. The Committee prefers to retain the definition as segregation and separation both offer means to manage hazards from combustible particulate solids.





3.3.36 Separation.The establishment interposing of a clear space between locations of interest distance between the combustible particulate solid process and other operations that are in the same [compartment]. [ 654, 2013] .



Committee Statement

CommitteeStatement:

The Committee has addressed the concerns expressed by the submitter of PC No. 550. The Committee prefers to retain the definition as separation and segregation both offer means to manage hazards from combustible particulate solids. This also utilizes an existing term by extracting the definition for "separation" from NFPA 654. This definition has been slightly modified to replace room with compartment to be consistent with the defined term.





4.1* General.The owner/operator of a facility with potentially combustible dust shall be responsible for the following activities:

(1) Identify, sample, analyze, and test materials to determine if they are combustible or explosible Determining the combustibility and explosibility hazards of materials in accordance with Chapter 5

(2) Assess the hazards of combustible or explosible materials Identifying and assessing any fire, flash fire, and explosion hazards in accordance withChapter 7

(3) Manage the identified hazards Managing the identified fire, flash fire, andexplosion hazards in accordance with 4.2.4

(4) Communicating the hazards to affected personnel in accordance with Section 9.5


File Name DescriptionA.4.1_SR-17_edited_.docx edited 8/8/14



Committee Statement



CommitteeStatement:

Nearly every facility in the United States has dust of some sort. The Committee supports the proposed word change by adding "potentially combustible" which brings the standard back into scope of combustible dusts. The Committee has not defined facility in this change to the standard, but has addressed other issues raised through other Public Comments regarding the need to test materials and manage the hazards. This change now directs the user of the standard to the other relevant chapters for those requirements. PC No. 553 recommends deletion of this section; however, this SR addresses the issues cited in the substantiation, so the Committee believes that this action covers this comment as well.

Annex A changes: 'compatibility' should be 'incompatibility' in list item 1. The deleted text was a reminder to the committee and not intended to be in the final version of the annex.

ResponseMessage:Public Comment No. 19-NFPA 652-2013 [Section No. 4.1]Public Comment No. 53-NFPA 652-2013 [Section No. 4.1]Public Comment No. 134-NFPA 652-2013 [Section No. 4.1]Public Comment No. 165-NFPA 652-2013 [Section No. A.4.1]Public Comment No. 266-NFPA 652-2013 [Section No. 4.1]Public Comment No. 492-NFPA 652-2013 [Section No. 4.1]Public Comment No. 553-NFPA 652-2013 [Section No. 4.1]



A.4.1 SR-17

A.4.1

Combustible particulate solids and dust hazard identification, assessment, and mitigation should

address known hazards, including the following:

1. Reactivity hazards (e.g., binary incompatibilitycompatibility or water reactivity)

2. Smoldering fire in a layer or a pile

3. Flaming fire of a layer or a pile

4. Deflagration resulting in flash fire (dust cloud combustion)

5. Deflagration resulting in dust explosion in equipment

6. Deflagration resulting in dust explosion in rooms and buildings

Include table or list of applicable NAICS codes to identify occupancies that are likely to handle

combustible particulate solids and dust.


4.2.1.1The facility, processes and equipment, and human element programs shall be designed, constructed, equipped, and maintained to protect occupants not in the immediate proximity of the ignition from the effects of fire, deflagration, and explosion for the time needed to evacuate, relocate, or take refuge. 4.2.1.1.1*The facility, processes, and equipment, and human element programs shall be designed, constructed, equipped, and maintained to and management systems shall be implemented to reasonably protect occupants not in the immediateproximity of the ignition from the effects of fire, deflagration, and explosion for the time needed to evacuate, relocate, or take refuge.4.2.1.1.2The facility, processes, and equipment shall be designed, constructed, equipped, and maintained and management systems shall be implemented to reasonably prevent serious injury from flash fires.4.2.1.1.3The facility, processes, and equipment shall be designed, constructed, equipped, and maintained and management systems shall be implemented to reasonably prevent injury from explosions.


File Name DescriptionA.4.2.1.1.1_SR-18.docx



Committee Statement

CommitteeStatement:

The original wording risks ambiguity. Nowhere else, apart from 4.2.1.1 and 4.2.3, does the document use the term "human element programs." What is meant to the referred to here is the "management systems elements" addressed in Chapter 9. The proposed revision clarifies the intent of the requirement. The Committee broke the objectives into three elements, fire, flash fire, and explosion for clarity.

ResponseMessage:Public Comment No. 62-NFPA 652-2013 [Section No. 4.2.1.1]



SR-18

A.4.2.1.1.1

Given the fast acting nature of flash fire, deflagration, and explosions,

the stated Life Safety Objective recognizes the difficulty, if not the

impossibility, of protecting occupants in the immediate proximity of the

ignition. Thus, the stated objective is to protect occupants not in the

immediate proximity of ignition. However, all available practices

should be employed to ensure the safety of all persons both near and

far from the ignition. An example of this might be the standard’s

prescriptive exception relative to the less than 8 ft3 air-material

separator not requiring protection; however, the intent of the objective

is to consider the effect of deflagration to occupants in the immediate

area of the small air-material separator and mitigate this hazard if

possible. Likewise, the standard has not defined “immediate

proximity” in that this could mean within just feet of the hazard or

within the same building or structure and leaves that judgment to the

user. The intent of the objective is to employ all available and

reasonable protection, techniques, and practices to protect all

occupants understanding that it might not always be achievable.


4.2.1.2The structure shall be located, designed, constructed, and maintained to minimize the propagation of fire or explosion to adjacent properties and to avoid injury to the public reasonably protect adjacent properties and the public from the effects of fire, flash fire, or explosion .



Committee Statement

CommitteeStatement:

The word “minimize” means to prevent or reduce to risk to the lowest level possible, even if it would reduce the risk well below the acceptable risk level at completely unwarranted costs that would result in an inappropriate allocation of limited resources. The risk should be reduced to an acceptable level rather than to the lowest feasible level. The Committee believes the modification to the existing requirement addresses the use of the word "minimize" by removing it and also addresses aspects of the related comments.

Response Message:Public Comment No. 80-NFPA 652-2013 [Section No. 4.2.1.2]Public Comment No. 202-NFPA 652-2013 [Section No. 4.2.1.2]Public Comment No. 269-NFPA 652-2013 [Section No. 4.2.1.2]Public Comment No. 283-NFPA 652-2013 [Section No. 4.2.1.2]Public Comment No. 386-NFPA 652-2013 [Section No. 4.2.1.2]Public Comment No. 556-NFPA 652-2013 [Section No. 4.2.1.2]




4.2.2 Structural Integrity.The facility shall be designed, constructed, and equipped to maintain its structural integrity in spite of the effects of fire or explosion for the time necessary to evacuate, relocate, or defend in place occupants not in the immediate proximity of the ignition.


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Wed Mar 12 21:06:43 EDT 2014

Committee Statement

CommitteeStatement:

Most structures will fail as a result of a severe fire or explosion. It is impossible to design against such failure. A prominent example is the World Trade Center. This section, along with section 4.4, contain legitimate goals, but are inappropriate in a document intended for regulatory use. There appears to be recognition of this in section 4.2.5, but ambiguity remains.

Response Message:Public Comment No. 272-NFPA 652-2013 [Section No. 4.2.2]Public Comment No. 557-NFPA 652-2013 [Section No. 4.2.2]




4.2.2* Mission Continuity.The facility, processes, and equipment, and human element program shall be designed, constructed, equipped, and maintained and management systems shall be implemented to limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator.



Committee Statement

CommitteeStatement:

See 62-NFPA-652-2013 (SR No. 18). The Committee revised this requirement similar to that in SR No. 18.

ResponseMessage:Public Comment No. 63-NFPA 652-2013 [Section No. 4.2.3]Public Comment No. 624-NFPA 652-2013 [Section No. 4.2.3]



Second Revision No. 28-NFPA 652-2014 [ Section No. 4.2.4

[Excluding any Sub-Sections] ]

The facility and processes shall be designed to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments or other enclosures , emergency life safety systems, adjacent properties, adjacent storage, or the facility’s structural elements.


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address: City:State: Zip: Submittal Date: Wed Mar 12 21:25:54 EDT 2014

Committee Statement


"Prevent" by itself is too absolute. The NFPA combustible dust standards recognize that not all fires or explosions can be prevented. For this reason, some of the protective features prescribed by the standards seek to mitigate the effects of the fire or explosion, if they occur.

Response Message:Public Comment No. 64-NFPA 652-2013 [Section No. 4.2.4 [Excluding any Sub-Sections]]




4.2.3.1The structure shall be designed, constructed, and maintained to prevent fire or explosions from causing failure of load-bearing structural members, propagating into adjacent interior compartments, and incapacitating fire protective and emergency life safety systems in adjacent compartments.



Committee Statement

CommitteeStatement:

The duty that would be imposed by this provision would be completely unqualified and unachievable. One must absolutely “prevent” members from failing, absolutely “prevent” propagation and the incapacitation of safety systems. For the reasons stated with respect to other provisions in this Chapter, the provision should be struck in its entirety or qualified to apply only to the extent feasible. The related item, PC No. 628 is no longer applicable due to the action on PC No. 560 to create SR No. 29 to delete the section. The Committee recommends that the annex material to A.4.2.4.1 be retained and moved to become A.4.2.4.

ResponseMessage:Public Comment No. 560-NFPA 652-2013 [Section No. 4.2.4.1]Public Comment No. 628-NFPA 652-2013 [Section No. 4.2.4.1]




4.2.3.2The structure shall be located, designed, constructed, equipped, and maintained to prevent the propagation of fire or explosion to or from adjacent storage orstructures.



Committee Statement

CommitteeStatement:

This provision is another one of those that is infeasible because it requires absolutely risk-free workplaces regardless of costs; one must absolutely “prevent” propagation, without qualification. The duty as stated is not feasible and needs to be qualified. Because the Committee has created SR No. 30 based on the recommendation of PC No. 561, paragraph 4.2.4.2 is deleted and the alternative approach recommended by PC No. 561 and 629 by the same submitter is no longer relevant as the section has been deleted by thisaction and is no longer in the standard to be modified.

ResponseMessage:Public Comment No. 561-NFPA 652-2013 [Section No. 4.2.4.2]Public Comment No. 629-NFPA 652-2013 [Section No. 4.2.4.2]




4.2.4* Compliance Options.The goal in Section 1.5 and the objectives in Section 4.2 shall be achieved by either of the following means:

(1) The A prescriptive provisions approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any additional prescriptive provisions of applicable commodity-specific NFPA standards.

(2) The A performance-based provisions approach in accordance with Chapter 6.



Committee Statement



CommitteeStatement:

Chapter 6, alone, is not sufficient to implement the performance-based approach.

Chapter 5, Hazard Identification, is required to characterize the hazardous properties of the combustible dusts that must be addressed in both the prescriptive and performance-based options.

Chapter 7, Process Hazard Analysis, is also required to support the performance-based approach.

In Chapter 8, the following sections are required regardless of whether theprescriptive or performance-based approach is used:

8.4 - Housekeeping

8.5 - Ignition source control

8.6 - Personal protective equipment

8.7 - Dust control

Portions of Section 8.9, Fire protection, might be addressed via the performance-based approach, but other portions are equally valid to both the prescriptive and performance-based approach. For this reason, it is proposed that all of 8.9 be required for the performance-based approach.

Chapter 9, Management Systems is equally applicable to both the prescriptive and performance-based approach.




Second Revision No. 25-NFPA 652-2014 [ Sections 5.1, 5.2 ]

5.1 Responsibility.The owner/operator of a facility with potentially combustible dusts shall be responsible for identifying and assessing the material to determine determiningwhether the materials are combustible or explosible, and to ensure their combustibility and explosibility hazards are adequately assessed , if so, for characterizing their properties as required to support the DHA .5.1.1If the dust is known to be combustible or explosible, the hazards shall be assessed by the requirements in Where dusts are determined to be combustible or explosible, the hazards associated with the dusts shall be assessed in accordance with Chapter 7.5.1.2If the dust is not combustible or explosible, the owner/operator shall maintain documentation to demonstrate that it is not combustible or explosible Where dusts are determined to be combustible or explosible, controls to address the hazards associated with the dusts shall be identified and implemented in accordance with 4.2.4 .5.2* Overview Screening for Combustibility or Explosibility .5.2.1Dusts shall be assessed under Section 5.4 to determine their combustibility and explosibility characteristics. The determination of combustibility or explosibility shallbe permitted to be based upon either of the following:

(1) Historical facility data or published data that are deemed to be representative of current materials and process conditions

(2) Analysis of representative samples in accordance with the requirements of 5.4.1 and 5.4.3

See SR-117

5.2.2*The assessment of combustibility or explosibility shall be based, at a minimum, on the following items for test, historical, or published data of representative samples and materials, including in-process and fugitive dusts:

Material properties

Composition

Pure materialsMixtures (including diluents or grinding media)

Treatment such as oxidation

Aging

Moisture content

Form

Particle size distribution

Morphology (angular, acicular, spherical, fiber, irregular, or agglomerate)



Friability of solids and particle attrition through the process

Particle agglomeration

Test method

Test results, historical data, and published data shall be documented and, when requested, provided to the authority having jurisdiction (AHJ).5.2.3Published or historical data shall be permitted to be used to determine whether a dust is combustible or explosible. If there is no such data or it is not otherwise clear whether a dust is combustible or explosible, samples shall be subject to screening tests for combustibility or explosibility hazard characteristics described in Section5.4 The absence of previous incidents shall not be used as the basis for deeming a particulate to not be combustible or explosible .5.2.4If the assessment of sample or historical test data for combustibility or explosibility produces a positive result, the dust shall be considered a combustible dust and the hazards shall be addressed by 4.2.5 Where dusts are determined to not be combustible or explosible, the owner/operator shall maintain documentation to demonstrate that the dusts are not combustible or explosible .5.2.5Test results and historical data analysis shall be documented and provided whenrequested by the authority having jurisdiction (AHJ).5.2.6*For dusts that are combustible or explosible, additional specific tests shall be performed as required to comply with the requirements for performance-based design described in Chapter 6, for process hazards analysis described in Chapter 7, and for hazard mitigation and prevention specified in Chapter 8.5.2.7A sampling plan shall be developed and documented per Section 5.5 to provide data needed to comply with the requirements of this chapter.5.2.8The owner/operator shall be permitted to use the worst-case characteristics of themost hazardous material being handled as a basis for design.



Committee Statement



CommitteeStatement:

This is one of series of public comments intended to improve the organization and focus of chapter 5.

The revisions to section 5.2 seek to better focus the section on its intended goal, to screen materials to determine whether they are combustible or explosible. Content extraneous to the that focus has been proposed for deletion or was moved to other sections of Chapter 5. See subsequent publiccomments.

Section 5.1 was revised in keeping with proposed changes to section 5.2 and other sections addressed in subsequent public comments.

One or more of the Public Comments linked with this SR recommended deleting some of the requirements; the Committee is not accepting those proposed changes and believes that the changes made in sections 5.1 and 5.2 address the various issues raised in the numerous public comments recommending changes to these requirements.

Annex A: It is proposed that the entire annex item for 5.1 be deleted. Some of the basic content is covered by the annex material proposed for 5.4.4.1per public comment 116-NFPA 652-2013. Further, much of the content is notrelated to common analytical testing for screening for or quantifyingcombustibility or explosibility. The Committee is recommending that annexbe relocated from A.5.1 to A.5.2 with no other changes.

ResponseMessage:Public Comment No. 58-NFPA 652-2013 [Section No. 5.2.2]Public Comment No. 113-NFPA 652-2013 [Sections 5.1, 5.2]Public Comment No. 118-NFPA 652-2013 [Section No. A.5.1]Public Comment No. 120-NFPA 652-2013 [Section No. A.5.2.3]Public Comment No. 135-NFPA 652-2013 [Section No. 5.1 [Excluding any Sub-Sections]]Public Comment No. 136-NFPA 652-2013 [Section No. 5.2.2]Public Comment No. 144-NFPA 652-2013 [Section No. 5.2]Public Comment No. 286-NFPA 652-2013 [Section No. 5.1 [Excluding any Sub-Sections]]Public Comment No. 287-NFPA 652-2013 [Section No. 5.2.6]Public Comment No. 382-NFPA 652-2013 [Section No. 5.2.1]Public Comment No. 384-NFPA 652-2013 [Section No. 5.2.2]Public Comment No. 387-NFPA 652-2013 [Section No. 5.2.2]Public Comment No. 396-NFPA 652-2013 [Section No. 5.2.4]Public Comment No. 562-NFPA 652-2013 [Section No. 5.1]Public Comment No. 563-NFPA 652-2013 [Section No. 5.1.2]Public Comment No. 564-NFPA 652-2013 [Section No. 5.2.3]Public Comment No. 565-NFPA 652-2013 [Section No. 5.2.4]Public Comment No. 566-NFPA 652-2013 [Section No. 5.2.6]




5.4 Combustibility and Explosibility Tests.Where combustibility or explosibility screening tests are required, they shall be conducted on representative samples obtained in accordance with Section 5.5 .5.4.1 Determination of Combustibility.5.4.1.1Where the combustibility is not known, determination of combustibility shall be determined by a screening test based on the UN Recommendations on the Transport of Dangerous Goods: Model Regulations — Manual of Tests and Criteria, Part III, Subsection 33.2.1, Test N.1, or other equivalent fire exposure testmethods. one of the following tests:

(1) A screening test based on the UN Recommendations on the Transport ofDangerous Goods: Model Regulations — Manual of Tests and Criteria, Part III, Subsection 33.2.1, Test N.1, “Test Method for Readily CombustibleSolids”

(2) Other equivalent fire exposure test methods

5.4.1.2*For the purposes of determining the combustibility of dust, if the dust in the formtested ignites and propagates combustion, or ejects sparks from the heated zoneafter the heat source is removed, the material shall be considered combustible and the standard shall apply , if the dust in the form tested ignites and propagates combustion or ejects sparks from the heated zone after the heat source is removed, the material shall be considered combustible .5.4.1.3If the dust is known to be explosible, it shall be permitted to assume that the dust is combustible and the requirements of 5.4.1.1 shall not apply.5.4.2 Determination of Flash- Fire Hazard. (Reserved)5.4.3 Determination of Explosibility.5.4.3.1When determining explosibility, it shall be permitted to test the as-received sample. Where the explosibility is not known, the determination of explosibility of dusts shall be determined according to one of the following tests :

(1) The “Go/No-GO Go ” screening test methodology described in ASTM E1226, Standard Test Method for Explosibility of Dust Clouds

(2) ASTM E1515, Standard Test Method for Minimum Explosible Concentration of Combustible Dusts

(3) An equivalent test methodology

5.4.3.2*When determining explosibility, it shall be permitted to test a sample sieved to less than 200 mesh (75 μm ).5.4.3.3*When determining explosibility, it shall be permitted to test the as-received sample.5.4.3.2*It shall be permitted to test a sample sieved to less than 200 mesh (75 microns) from the location in the process or facility that has the finest particle sizedistribution.



5.4.3.4Where the explosibility is not known, the determination of explosibility of dusts shall be determined according to one of the following:

The “Go/No-GO” screening test methodology described in ASTM E1226, Standard Test Method for Explosibility of Dust Clouds

ASTM E1515, Test Method for Minimum Explosible Concentration of Combustible Dusts

An equivalent test methodology

5.4.3.4It shall be permissible permitted to assume a material is explosive, forgoing the “Go/No-GO” screening test explosible, forgoing the requirements of 5.4.3.1 .5.4.3.5*When the representative sample has a characteristic particle size smaller than 0.5 μm, the explosibility screening test method shall account for possible ignitions in the sample injection apparatus.5.4.3.6*If explosible, additional testing shall be performed as required for the performance-based design method described in Chapter 6, process hazard analysis described in Chapter 7, risk assessments described in Chapter 8, or hazard mitigation and prevention described in Chapter 8 using standard test methods.5.4.4 Quantification of Combustibility and Explosibility Characteristics.5.4.4.1*If Where dusts are determined to be combustible or explosible, additional testing shall be performed, as required, for to acquire the data necessary to support the performance-based design method described in Chapter 6; , process hazard analysis the DHA described in Chapter 7, ; the risk assessments described in Chapter 8, ; or specification of the hazard mitigation and prevention described in Chapter 8 using standard test methods .5.4.4.2The owner/operator shall be permitted to use the worst-case characteristics of thevarious materials being handled as a basis for design.


File Name DescriptionSR-20_Annex.docx



Committee Statement



CommitteeStatement:

The changes in section 5.4 are proposed in conjunction with the changes proposed in Public Comment 113-NFPA 652-2013.

The subsections in Sections 5.4.1 and 5.4.3 were reordered to provide a more logical sequence for the requirements in these sections.

Section 5.4.4 was added to receive content relocated from other sections in 5.2 and 5.4. The new structure reinforces the concept that 5.4.1 and 5.4.3 address screening testing to determine whether dusts are, respectively, combustible or explosible. The new 5.4.4 then established the requirement that, if a dust is determined to be combustible or explosible, additional testing will be required to quantify the combustibility or explosibility, as required to support implementation of other portions of the standard.

Annex A: The proposed change to combine annex section text presupposes that Public Comment 114-NFPA 652-2013 has been adopted. Old A.5.2.1 has been edited to make it suitable to be the annex material for A.5.4.4.1. Content from old A.5.2.6 (proposed for deletion under another public comment) has been relocated and incorporated. Content from old A.5.4.3.2 and A.5.4.3.5 have been incorporated into the revised annex material.

The entire annex item to 5.4.1 is unnecessary. Section 5.4.1.1 points to the necessary testing requirement and anyone who decides that this is needed can go directly to the source and by doing so would be sure the criteria for the test is up to date. In fact, by 5.4.1.1.1 most folks will not even need to do this test. The goal should be to simply rather than complicate as this materialdoes. Therefore, it will be deleted.

The revised text for A.5.4.3.1 is more consistent with recommendations contained in ASTM standards like ASTM E1226. Additionally, it includes language explaining that sieving and drying a sample does not always produce a dust with higher hazard than the as-received material.

This explanatory information in A.5.4.3.2 is incomplete and not universally true. A previous annex item provides greater detail about this issue. The fine fraction of a sample does not always present the greatest hazard.

Assuming public comments 114 and 116 are adopted, the material in A.5.4.3.5 has been incorporated into A.5.4.4.1.

ResponseMessage:Public Comment No. 43-NFPA 652-2013 [Section No. A.5.4.3.1]Public Comment No. 44-NFPA 652-2013 [Section No. A.5.4.3.2]Public Comment No. 45-NFPA 652-2013 [Section No. A.5.4.3.5]Public Comment No. 106-NFPA 652-2013 [Section No. A.5.4.3.1]Public Comment No. 114-NFPA 652-2013 [Section No. 5.4]Public Comment No. 116-NFPA 652-2013 [Section No. A.5.2.1]Public Comment No. 123-NFPA 652-2013 [Section No. A.5.4.3.2]Public Comment No. 124-NFPA 652-2013 [Section No. A.5.4.3.5]Public Comment No. 206-NFPA 652-2013 [Section No. A.5.4.3.1]Public Comment No. 395-NFPA 652-2013 [Section No. A.5.4.3.1]Public Comment No. 404-NFPA 652-2013 [Section No. A.5.4.1]Public Comment No. 408-NFPA 652-2013 [Section No. 5.4.1.2]Public Comment No. 426-NFPA 652-2013 [Section No. A.5.4.3.5]Public Comment No. 519-NFPA 652-2013 [New Section after A.5.4.1]Public Comment No. 521-NFPA 652-2013 [Section No. A.5.4.3.1]



Public Comment No. 540-NFPA 652-2013 [New Section after 5.4.1.2]Public Comment No. 567-NFPA 652-2013 [Section No. 5.4.1.1]



SR No. 20 Annex A

A.5.4.1

This preliminary screening test used to demonstrate fire risk is the basis for the regulations

governing the transport of dangerous goods for United Nations (UN) regulations, the U.S.

Department of Transportation, International Air Transport Association (IATA), and the

International Maritime Dangerous Goods (IMDG) Code.

The preliminary screening test is conducted in the following fashion:

1. The substance in its commercial form is formed into an unbroken strip or powder train

about 9.84 in. (250 mm) long by 0.79 in. (20 mm) wide by 0.39 in. (10 mm) high on a

cool, impervious, low heat conducting base plate.

2. A hot flame [minimum temperature of 1832°F (1000°C) from a gas burner] [minimum

diameter of 0.20 in. (5 mm)] is applied to one end of the powder train until the powder

ignites or for a maximum of 5 minutes. It should be noted whether combustion

propagates along 7.87 in. (200 mm) of the train within a 20-minute test period.

3. If the substance does not ignite and propagate combustion either by burning with flame or

smoldering along 7.87 in. (200 mm) of the powder train within the 20-minute test period,

the material should not be considered a combustible dust.

4. If the substance propagates burning of the 7.87 in. (200 mm) length of the powder train in

less than 20 minutes, the full burning rate test should be conducted.

Because the specific form of the combustible dust and the properties of the form determine the

flammability and degree of combustibility of the material, it is critical that the substance be

tested precisely in the condition in which it is processed or handled. Changes in particle size

distribution, moisture content, degree of fines, and chemical composition can change the results

radically. No generic substitute is allowable for accurate determination of fire risk.

If propagation of the powder train occurs along a length of 7.87 in (200 mm) in 20 minutes or

less, the burning rate test is required. The burning rate test requires specific preparation of the

powder sample. The sample is prepared in a specific fixture as shown in Figure A.5.4.1.

Figure A.5.4.1 Fixture for Preparation of Sample for Burning Rate Test.

Preparation of the sample for the burning rate test should be done according to the following

description.

The powdered or granular substance, in its commercial form, must be loosely filled into a mold.

The mold, which must be 9.84 in. (250 mm) long with a triangular cross section of inner height

0.39 in. (10 mm) and width 0.79 in. (20 mm), is used to form the train for the burning rate test.

On both sides of the mold, in the longitudinal direction, two metal sheets are mounted as lateral

limitations that extend 0.079 in. (2 mm) beyond the upper edge of the triangular cross section.

An impervious, noncombustible, low heat conducting plate is used to support the sample train.

The mold is then dropped three times from a height of 0.79 in. (20 mm) onto a solid surface. The

lateral limitations are then removed, and the impervious, noncombustible, low heat conducting

plate is placed on top of the mold, the apparatus is inverted, and the mold is removed. Pasty

substances must be spread on a noncombustible surface in the form of a rope 9.84 in. (250 mm)

in length with a cross section of about 0.16 in.2 (100 mm2). In the case of a moisture-sensitive

substance, the test must be carried out as quickly as possible after its removal from the container.

Formatted: Font: (Default) Times New Roman, 12 pt

Test conditions are as follows:

1. The pile is arranged across the draft in a fume cupboard. The air speed is sufficient to

prevent fumes from escaping into the laboratory and is not varied during the test. A draft

screen can be erected around the apparatus.

2. Any suitable ignition source such as a small flame or hot wire of minimum temperature

1832°F (1000°C) is used to ignite the pile at one end. When the pile has burned a

distance of 3.15 in. (80 mm), the rate of burning is measured over the 3.94 in. (100 mm).

The test is performed six times using a clean, cool plate each time, unless a positive result

is observed earlier.

A.5.4.1.2 (new annex A)

Results of the preliminary screening test can have one of the following four results:

(1) No reaction

(2) Glowing but no propagation along the powder train

(3) Propagation, but too slow to include the test material in Division 4.1

(4) Propagation sufficiently fast to qualify for inclusion in Division 4.1

If the results of the screening test show no reaction or glowing in the specific form, that material can be

considered noncombustible and does not fall under the requirements of this document. If the results of the

screening test show glowing but no propagation along the powder train, the material in the specific

form should be considered a limited-combustible material. Hazard analysis should be conducted to

determine the extent to which the requirements of this document are applicable.

It is recommended for general safety that the full requirements be met. If the results of the screening test

show propagation of the powder train, the material in the specific form should be considered

a limited-combustible material and full compliance with the requirements of this document be met. If the

results of the screening test show propagation of the powder train sufficiently fast that the form is

classified as a Division 4.1 material, hazard analysis should focus on additional protocols and compliance

with other NFPA standards.

A.5.4.3.1A.5.4.3.3

In general, it is recommended to testTests should typically be performed in accordance with the

test protocol. The test protocol for ASTM 1226, forstandard recommendations. For example,

calls for drying most ASTM combustible dust test methods recommend testing the sample so that

moisture content isat less than 5 percent moisture by weight, and particle size that is at least 95

percent sub-200 mesh screen by weight. This may require drying and grinding or sieving of

samples. The thought behind this approach is to obtain near worst-case test data that could be

found within a facility (i.e., accumulations of dry fines, typically sub-200 mesh, at some

locations or changes in processes) and by doing so ensure conservatism in the hazard assessment

and design of protection equipment.

This is typically produces a built-in safety factor for the tests, as the testing laboratory does not

know if the samples are a good representation of the dust from the facility. By performing the

test in this manner, it typically assumes a worse-case scenario to account for dust accumulations

not taken into account by the facility.

On the other hand, testing material "as received" can result in a more realistic

appreciation determination of the true nature of the hazard under assessment. Additionally, in

some cases the as received material may present a greater hazard than the dried fine fraction of

the material. For instance, some samples may consist of a mixture of fine noncombustible

material and coarse combustible material, where the fine fraction is a lower hazard than the as

received material. Similarly, some water reactive materials may present a greater hazard with

some moisture present than when dried. Making the decision whether to test as received or in

accordance with protocolof the moisture content and particle size fraction of a dust sample is of

considerable importance and should be done in consultation with experts or someone familiar

with the process and material.

A.5.4.3.5 (new Annex A)

Tests conducted on iron and titanium nanoparticles using the standard 20 L test method

described in ASTM E1226, Standard Test Method for Explosibility of Dust Clouds, have resulted

in ignitions in the sample auxiliary chamber and the injection piping rather than the test vessel,

where pressures are measured. (See papers by Bouillard and Wu.)

Many nanoparticle materials are produced with special manufacturing equipment to obtain a

narrow particle size distribution with a maximum particle size of 0.1 µm (100 nm). However,

there are some applications in which nanoparticles can be produced inadvertently. For example,

micromilling or air attrition milling are processes that can create nanoparticles. In those

infrequent cases where there is a mix of particles smaller and larger than 0.5 µm, there do not

seem to be test data to specify the precise percentage of nanoparticles needed to require special

test methods or special interpretations of standard test data. Based on data for mixtures of inert

and combustible dust particulates, an approximate percentage of at least 10 weight percent would

be expected to produce results dominated by the more readily explosible material.

The applicability of other combustibility and explosibility test methods to nanoparticles has yet

to be determined; therefore, no prescriptions are offered here. However, users of this standard

should be aware of the possibility of special behavior of the nanoparticles.

A.5.4.4.1

[this section text was moved from A.5.4.3.5 (last para); Table & crossed-out text moved from A.5.4.3.2)]

Formatted: Space Before: Auto, After: Auto

Refer to Table A.5.4.3.2A.5.4.4.1 for standard test methods for determining explosibility characteristics

of dusts that are used for the process hazard analysisDHA, performance-based design method risk

assessments, and hazard management of combustible dusts.

Testing a worst-case (finest) particle size distribution will provide a conservative determination

of the combustibility of the material. (See Table A.5.4.3.2.)

Table A.5.4.3.2A.5.4.4.1 Standard Test Methods to Determine Explosibility Properties

Method Property

ASTM E 2019, Standard Test Method for

Minimum Ignition Energy of a Dust Cloud in

Air

Minimum ignition energy (MIE) of dust cloud

in air


Minimum Autoignition Temperature of Dust

Clouds

Minimum ignition temperature (Tc) of dust

clouds


Explosibility of Dust Clouds

Maximum explosion pressure (P max ), rate and

maximum rate of pressure rise (dP/dt), and

explosion severity (K St )

ASTM E 1515, Test Method for Minimum

Explosible Concentration of Combustible

Dusts

Minimum explosible concentration (MEC)

ASTM E 2021,Standard Test Method for Hot-

Surface Ignition Temperature of Dust Layers

Minimum ignition temperature (Tc) of dust

layers

ASTM WK1680, Test Method for Limiting

Oxygen (Oxidant) Concentration of

Combustible Dust Clouds

Limiting oxygen concentration (LOC)

(this section text was moved from A.5.4.3.5; all but last para)

ASTM E 2021, Standard Test Method for Hot-Surface Ignition Temperature of Dust Layers,

uses a constant temperature hot-plate to heat the dust on one side only. Routine tests use a 12.7

mm (0.5 in.) thick layer, which might simulate a substantial build-up of dust on the outside of hot

equipment. However, since the ignition temperature normally decreases markedly with increased

dust layer thickness, the method allows layer thickness to be varied according to the application.

ASTM E 2019, Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air, is

used to determine the minimum ignition energy (MIE) for any given fuel concentration. The

method uses the lowest energy, stored by a capacitor, that when released as a spark will ignite

dust cloud-oxidant mixtures. By testing a range of concentrations, the lowest MIE is determined

for the optimum mixture. Observed MIE and MIE values are highly sensitive to the test method,

particularly the spark electrode geometry and characteristics of the capacitor discharge circuit.

Dust ignition energy standard ASTM E 2019 describes test methods in current use that have been

found to yield comparable results; however, it is a “performance standard” whereby the

Formatted Table

Commented [BS1]: Take out all spaces between letter/numbers in ASTM refs

methodology adopted must produce data within the expected range for a series of reference

dusts.

ASTM E 1491, Standard Test Method for Minimum Autoignition Temperature of Dust Clouds, is

used to determine the dust cloud autoignition temperature (AIT). The test involves blowing dust

into a heated furnace set at a predetermined temperature. The dust concentration is systematically

varied to find the lowest temperature at which self-ignition occurs at ambient pressure, known as

the minimum autoignition temperature (MAIT). A visible flame exiting the furnace provides

evidence for ignition. Four different furnaces are described in ASTM E 1491 (0.27-L Godbert-

Greenwald Furnace, 0.35-L BAM Oven, 1.2-L Bureau of Mines Furnace, and 6.8-L Bureau of

Mines Furnace). Each yields somewhat different MAIT data, the largest deviations occurring at

the greatest MAIT values. However, the lower AIT range is of more practical importance and

here the agreement is better (for example 265±25°C for sulfur).

ASTM E 1226, Standard Test Method for Explosibility of Dust Clouds, is used to determine the

pressure and rate of pressure rise for suspended combustible dusts. The measurement of the

explosibility parameters (Pmax and KSt ) requires the reproducible generation of a near

homogeneous dust cloud inside a containment vessel of known volume. The explosibility

parameters Pmax (maximum pressure) and KSt (maximum rate of pressure rise of the worst case

concentration times the cube root of the test volume) are obtained from such measurements. The

determination of a Pmax and KSt for a material first establishes that it is an explosible dust. A

bench scale test method in ASTM E 1226 involves a vessel at least 20 liters in volume in which a

dust cloud is formed using the discharge of a small cylinder of compressed air. After a prescribed

time delay, the highly turbulent dust cloud is ignited using a strong ignition source of known

energy. Pressure is monitored versus time by appropriate transducers and expressed as pressure,

Pex , and pressure rate of rise, dP/dtex. Dust concentration is varied to determine the maxima of

both parameters. Particle size and moisture are other variables that must be considered. Particle

size should be less than 75 microns ensuring a design that is conservative.

The primary use of the test data Pmax and KSt is for the design of explosion protection systems:

venting, suppression, isolation. Vent designs provide a relief area that will limit damage to the

process equipment to an acceptable level. The required vent area is calculated using equations

from NFPA 68, Standard on Explosion Protection by Deflagration Venting, and requires

knowledge of the process — volume, temperature, operating pressure, design strength, vent relief

pressure — and of the fuel, Pmax and KSt . Suppression is the active extinguishment of the

combustion and again limits the explosion pressure to an acceptable level. Suppression designs

require similar process and hazard data in order to determine the hardware requirements such as

size, number, and location of containers, detection conditions, and the final or reduced explosion

pressure. Isolation, the prevention of flame propagation through interconnections, requires the

same process and hazard data to determine hardware needs and locations. The extent of testing

should depend on what the scenario or evaluation such as explosion venting for a dust collector

would require KSt and Pmax .

(this section was moved from A.5.2.1)

General categories of combustible dusts are metal dust (aluminum, magnesium, titanium, zirconium, etc.), agricultural (grain dust), wood dust (cellulosic, paper, etc.), chemicals (polymers, plastics, resins, rubber), formulations and mixtures, biosolids, coal dust, organic dust (flour, sugar, soap, etc.), and dust from certain textiles. Assessing the combustibility and explosibility can be performed by testing or by utilizing literature values. While some materials are well-characterized, testing is still the preferred

method. TablesPublished data can be used for preliminary assessment only; they should not be

used for design. While some materials are well-characterized, tables with explosibility

properties often lack specific information such as particle size; therefore, it is recommended that

literature values that do not provide particle size information be used with extreme caution.

NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food

Processing Facilities, NFPA 499, Recommended Practice for the Classification of Combustible

Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process

Areas, NFPA 68, Standard on Explosion Protection by Deflagration Venting, and NFPA 484,

Standard for Combustible Metals, have lists of combustible and explosible metals and dusts that

are used for guidance or informational use only and not to be used for design purposes.

Composition, particle size and distribution, and moisture content are the three factors that are

known to strongly influence test results. It is recognized that some industries have historical data

on the same material; therefore, the frequency, number, and extent of testing where historical

data exists should be made by informed judgment. The owner/operator assumes the risk of using

data from tables and historical data. A person or team performing a process hazard analysis

should scrutinize and make informed judgments about historical and published data and its

applicability to the process.


5.5 Sampling.5.5.1 Sampling Plan.5.5.1.1A sampling plan shall be developed and documented to provide data as needed tocomply with the requirements of this chapter.5.5.1.2Representative samples of dusts shall be identified and collected for testing according to a the sampling plan.5.5.1.3The sampling plan shall include the following:

(1) Identify Identification of locations where fine particulate particulates and dust is are present

(2) Identify Identification of representative samples

(3) Collect Collection of representative samples

(4)(5) Communication with the test laboratory regarding sample handling

(6) Documentation of samples taken

(7) Safe sample collection practices

5.5.2* Mixtures.If the dust sample is a mixture, the relative concentration of each general category of particulate solid shall be determined based on available information or laboratory analysis approximate proportions of each general category of particulate solid shall be determined and documented on the basis of available information and shall be used to assist in determining representative samples .5.5.2.1If the dust sample is a mixture, the relative concentration of each general category of particulate solid shall be determined based on available information or laboratory analysis.5.5.2.1The hazard management of a mixture shall be based on the predominant constituent by mass unless there are specific constituents imparting unique chemical reactivity issues to the mixture. 5.5.2.2.1Unique chemical reactivity issues shall include, but not be limited to, the following:

Water reactivity

Reactivity with extinguishing agents or other mixture constituent

Pyrophoricity

Chemical instability

Oxidizer

5.5.3* Representative Samples.

* Preserve Preservation of sample integrity



Samples collected from each location shall be representative of the material at that location, process, equipment, or surface. Special consideration shall be given to collecting samples from processes and equipment that result in attrition or reduction of particle size material used in the process or equipment or found on surfaces at that location .5.5.3.1Samples collected from each location shall be representative of the material at that location, process, equipment, or surface.5.5.3.2Special consideration shall be given to collecting samples from processes and equipment that result in attrition or reduction of particle size.5.5.3.3When changes in the materials or processes occur, the owner/operator shall comply with Chapter 9.5.5.4* Sample Collection.Dust samples shall be collected in a safe manner using acceptable tools, containers, and methodologies so that the sample is preserved without introducing an ignition source, dispersing dust, or creating or increasing the risk of injury toworkers .5.5.4.1*Samples shall be uniquely identified using as many identifiers such as practical including lot, origin, composition (pure, mixture), process, age, location, and datecollected.


File Name Description5.5_Annex_text_SR-22_edited_.docx 5.5 Annex text, edited 8/11/14



Committee Statement



CommitteeStatement:

The paragraph now identified as 5.5.1.1 was relocated from section 5.2 in order to consolidate all sampling-related requirements in section 5.5.

The content related to mixtures was removed for several reasons. First, the requirements for analysis of mixtures to determine the concentration of various components would impose an expensive and unnecessary analytical burden on the user. Such information is not needed to support standard testing to obtain combustible dust explosibility data.

This SR addresses multiple PC that deal with the requirements proposed for 5.5. One or more recommended deleting some of the requirements; while no requirements have been deleted, they have been modified through the various recommendations and combined into this single action. The Committee believes that the revision to the standard reflected in this SR address and satisfy all the public comments shown as related items for this SR.

Second, the requirements related to unique chemical reactivity issues are not germane to the topic of sampling.

Annex: As proposed in PC-439 the prior 5.5.2.2.1 material has been relocated to the annex and existing annex text was modified to clarify intent. In particular the need for analysis was replaced with replaced with more available and simple options to remove the potential interpretation of a need for some more expensive testing.

The associated main body text has already been proposed to be combined with section 5.5.3.1 and the annex text adds very little to what is already in that annex material. Annex text for old 5.5.3.1 and 5.5.3.2 will be relocated to 5.5.3.

Response Message:Public Comment No. 56-NFPA 652-2013 [Section No. 5.5.3.2]Public Comment No. 57-NFPA 652-2013 [Section No. 5.5.4.1]Public Comment No. 115-NFPA 652-2013 [Section No. 5.5]Public Comment No. 390-NFPA 652-2013 [Section No. 5.5.3.2]Public Comment No. 439-NFPA 652-2013 [Section No. 5.5.2]Public Comment No. 449-NFPA 652-2013 [Section No. A.5.5.2.2.1]Public Comment No. 452-NFPA 652-2013 [Section No. 5.5.3]Public Comment No. 454-NFPA 652-2013 [Section No. A.5.5.3.2]Public Comment No. 569-NFPA 652-2013 [Section No. 5.5.3.2]Public Comment No. 570-NFPA 652-2013 [Section No. 5.5.3.3]Public Comment No. 571-NFPA 652-2013 [Section No. 5.5.4]



[SR-22]

A.5.5.1.3(4)

Some materials are subject to change, such as oxidization or other chemical reaction ,that could affect

the test results. Precautions such as inerting or vacuum packing should be taken to preserve the test

sample integrity. Other sample preservation considerations include the possibility of moisture reactions

and polymerization reactions.

A.5.5.2

If the dust sample is a mixture of organic, inorganic, or combustible metals, the amount or concentration

of each constituent should be determined by laboratory analysis. Common methods for an analysis of

mixture composition include material seperationseparation, mass fraction analysis, energy dispersive x-

ray spectroscopy, Fourier transform infrared spectroscopy, inductively coupled plasma spectroscopy, and

x-ray fluorescence spectroscopy. Unique chemical reactivity issues could include water reactivity,

reactivity with extinguishing agents, or other mixture constituents, pyrophoricity, chemical instability,

oxidizer, and so forth. For example, for a mixture that contains some metal powder or dust should be

analyzed to determine whether that metal is reactive with water, its potential for water reactivity

should be considered based on the safety data sheet (SDS) or other public or company resources. If so,

then the entire mixture must be analyzed to determine whether it is water reactive. If sothe potential

for water reactivity exists, then the entire mixture must should be analyzed to determine whether it is

water reactive.

[COMP: The annex text for A.5.5.2 has a combination of moved text from A.5.5.2.1, A.5.5.2.2.1 and new

text. First text used is from A.5.5.2.1. Second, brand new text (only one line) and the rest of the text is

from A.5.5.2.2.1 with some changes.]

A.5.5.3

Special consideration should be given to samples from equipment in facilities such as dust collectors,

impact equipment, silos and bins, processing equipment, ovens, furnaces, dryers, conveyors, bucket

elevators, and grain elevators.

If a sample is from a dust collection or pneumatic conveying system, the sample should be a

representative of the hazard subject to evaluation.

Samples should be collected from rooms and building facilities where combustible dusts can exist

including rooms where abrasive blasting, cutting, grinding, polishing, mixing, conveying, sifting, screening,

bulk handling or storage, packaging, agglomeration, and coating are performed.

Where there are numerous or a range of products and processes, worst-case samples can be used with

process hazard analysis to assess the hazards. Performance-based design allows the user to identify and

sample select materials instead of the prescriptive approach where all materials are collected and tested.

Where multiple pieces of process equipment are present and contain essentially the same material, a

single representative sample can be acceptable. While the composition can be constant, attrition and

separation based on particle size should be assessed. If and where attrition occurs, samples should be

collected from such process equipment from start to finish and representative of the material with reduced

particle size. For example, a belt conveyor can have larger particles on the belt but finer dusts along the

sides or under or at the bottom of the conveyor. The sampling plan should include samples of the

accumulated fines as one sample and a sample from the center of the belt as a second separate sample.

Material to be used for the screening tests, and for the determination of material hazard characteristics

such as KSt, MIE, Tc, and so forth, etc., should be collected from the areas or inside equipment

presenting the worst-case risk.

Some processes, such as grinding, require further evaluation such as grinding. Grinding can result in a

broad range of particle sizesizes. A representative sample should be tested. Combustible particulate

solids include dusts, fibers, fines, chips, chunks, flakes, or mixtures of these. The term combustible

particulate solid addresses the attrition of material as it moves within the process equipment. Particle

abrasion breaks the material down and produces a mixture of large and small particulates, some of

which could be small enough to be classified as dusts. Consequently, the presence of dusts should be

anticipated in the process stream, regardless of the starting particle size of the material.

[COMP: Top part of the annex text for A.5.5.3 is being moved from A.5.5.3.1 and last para is from

A.5.5.3.2.]


5.6 Fire Identification/Hazards. (Reserved)



Committee Statement

CommitteeStatement:

This section is reserved, but has supporting Annex material. That is inconsistent, there should be no reference to reserved material for reasons previously stated, and the Annex should be deleted.

The Committee agreed with the submitters of these comments and this reserved section has been deleted.

Annex: The annex item appears to be a lonely orphan that seemed important to someone but had no real home. It adds little or nothing to the document. As an alternative to deleting if someone really feels it belongs in the document, add it to section 5.3 Self Heating where it at least makes a little sense.

ResponseMessage:Public Comment No. 83-NFPA 652-2013 [Section No. 5.6]Public Comment No. 208-NFPA 652-2013 [Section No. 5.6]Public Comment No. 285-NFPA 652-2013 [Section No. 5.6]Public Comment No. 293-NFPA 652-2013 [Section No. 5.6]Public Comment No. 493-NFPA 652-2013 [Section No. 5.6]Public Comment No. 463-NFPA 652-2013 [Section No. A.5.6]




6.1.1* Approved Qualifications.The performance-based design shall be prepared by a person with qualifications acceptable to the owner/operator. It shall be permitted to use performance-basedalternative designs for a process or part of a process, specific material, or piece of equipment in lieu of the prescriptive requirements found in Chapter 8.


File Name DescriptionA.6.1.1_SR_33_edited.docx A.6.1.1 (SR 33) edited 8/4/14



Committee Statement

CommitteeStatement:

Clarify that you can use both performance-based and prescriptive.

Response Message:



A.6.1.1

See A.4.2.5.

[NOTE TO COMP: This should link up to current A.4.2.5, ‘Usually a facility or process…design approaches

as needed.’ Clarifying section text in case of renumbering.]


6.1.2.1* General.All applicable aspects of the design, including those described in 6.1.3.1 6.1.2.2through 6.1.3.13 6.1.2.14 , shall be documented in a format and content acceptable to the authority having jurisdiction AHJ .



Committee Statement

CommitteeStatement:

Not all of the design aspects listed are required on every single project and by adding the word "applicable", clarifies that idea. Requiring the owner/operator or anyone involved in the documentation of a project to forecast format and content of what a particular AHJ wants is impractical. The difference between a state AHJ and a local AHJ could be monumental. An owner/operator is obligated to provide whatever documentation the AHJ requests.





6.1.6* Maintenance of the Design Features.To continue meeting the performance goals and objectives of this standard, the design features required for each hazard area shall be maintained for the life of thefacility subject to the management of change provisions of Section 9.9 .6.1.6.1*This shall include complying with originally documented design assumptions andspecifications.6.1.6.2*Any variation from the design shall be acceptable to the authority havingjurisdiction AHJ .


File Name Description

A.6.1.5_A.6.1.5.1_A.6.1.5.2_SR_34_edited.docx A.6.1.5, A.6.1.5.1, A.6.1.5.2 (SR 34) edited 8/4/14



Committee Statement

CommitteeStatement:

Added annex and made some changes to describe what maintenance of design features are.

Response Message:Public Comment No. 305-NFPA 652-2013 [Section No. 6.1.5 [Excluding any Sub-Sections]]Public Comment No. 574-NFPA 652-2013 [Section No. 6.1.5]



[SR No. 34 Annex A.6.1.5]

A.6.1.5

As used in this section, maintenance includes the preventive maintenance required for the design

features that are part of the performance-based design and, as well as the requirement to maintain the

design itself.

A.6.1.5.1

Design features, including protection methods and means and administrative controls, should be

included in preventative maintenance programs to ensure their continued operability.

A.6.1.5.2

This is not intended to prohibit future variations in the design features, but only that when

modified these features are again subject to AHJ review.


6.2 Risk Component and Acceptability. (Reserved)The specified performance criteria of Section 6.3 and the specified fire and explosion scenarios of Section 6.4 shall be permitted to be modified by adocumented risk assessment acceptable to the AHJ. The final performancecriteria, fire scenarios, and explosion scenarios established for the performance-based design shall be documented.



Committee Statement

CommitteeStatement:

The performance-based design option is generally intended to allow for alternative solutions that will achieve the intended level of safety prescribed by the requirements in Chapter 8 based on the process hazard analysis determined in Chapter 7. However, the prescriptive requirements in Chapter 8 can generally be modified by a documented risk assessment, which incorporates the elements of a PHA from Chapter 7. The same latitude in analyzing the hazard and the risks to the plant and its occupants should be allowed for the performance-based design option.




Second Revision No. 36-NFPA 652-2014 [ Sections 6.3.1.1, 6.3.1.2 ]

6.3.1.1*The life safety objectives of 6.3.1 4.2.1 with respect to a fire hazard shall be achieved if either of the following criteria conditions is met:

(1) Ignition has been prevented.

(2) Under all fire scenarios, no person, other than those in the immediate proximity of the ignition, is exposed to untenable conditions due to the fire, and no critical structural element of the building is damaged to the extent that it can no longer support its design load during the period of time necessary to effect complete evacuation.

6.3.1.2The life safety objectives of 6.3.1 4.2.1 with respect to an explosion hazard shall be achieved if either of the following criteria are conditions is met:

(1) Ignition has been prevented.

(2) Under all explosion scenarios, no person, other than those in the immediate proximity of the ignition, is exposed to untenable conditions, including missile impact or overpressure, due to the occurrence of an explosion, and no critical structural element of the building is damaged to the extent that it can no longer support its design load during the period of time necessary to effectcomplete evacuation.



Committee Statement

CommitteeStatement:

I believe this section should be referring back to the objectives of Chapter 4, not to itself. The Committee agreed with the submitter and corrected the references.

Response Message:Public Comment No. 430-NFPA 652-2013 [Sections 6.3.1.1, 6.3.1.2]




6.3.2 Structural Integrity.The structural integrity objective of 6.3.2 objectives embodied in 4.2.1.1 and 4.2.1.2 with respect to fire and explosion shall be achieved when no critical structural element of the building is damaged to the extent that it can no longer support its design load under all fire and explosion scenarios.6.3.3 Mission Continuity.The mission continuity objectives of 6.3.3 4.2.2 shall be achieved when damage to equipment and the facility has been limited to a level of damage acceptable tothe owner/operator.



Committee Statement

CommitteeStatement:

These objective requirements should be referencing back to the objective statements of Chapter 4 and not themselves. The Committee agreed with the submitter and made the changes in the cross references back to Chapter 4 where the objectives are established.

ResponseMessage:Public Comment No. 433-NFPA 652-2013 [Sections 6.3.2, 6.3.3]




6.3.5 Effects of Explosions.Where the prevention of damage due to explosion is to be achieved, deflagrations shall not produce any of the following conditions:

(1) Internal pressures in the room building or building compartment or equipment sufficient to threaten its structural integrity

(2) Extension of the flame front outside the building or building compartment or equipment of origin except where intentionally vented to a safe location

(3) Rupture of the building or building compartment or equipment of origin and the ejection of fragments that can constitute missile hazards



Committee Statement


The Committee modified this to be consistent with the use of the defined term compartment per work of a Committee task group that reviewed this issue and made recommendations to the full committee.

ResponseMessage:




6.4.1.1*Each fuel object in the building or building compartment or equipment of originshall be considered for inclusion as a fire scenario.



Committee Statement



ResponseMessage:




6.5.1*A proposed design’s performance shall be assessed relative to each documentedperformance objective criterion as established in Section 6.2or in Section 6.3 and in each applicable scenario in Section 6.4 documented fire and explosion scenarioestablished for the design , with the assessment conducted through the use of appropriate calculation methods acceptable to the authority havingjurisdiction. AHJ .6.5.2The design professional designer shall establish numerical performance criteria for each of the objectives in Section 6.3 documented performance objectives established for the design .



Committee Statement

CommitteeStatement:

This change is submitted in connection with Public Comment No. 440, which suggests changes to 6.2. These change to these two sections are necessary for consistency where the performance criteria and scenarios are permitted to be modified by a documented risk assessment per the suggested change to 6.2 RISK COMPONENT AND ACCEPTABILITY.

The Committee has modified the requirements in both 6.5.1 and 6.5.2 and believes that this action addresses concerns expressed by the submitter of PC No. 582; so even though the recommendation was to delete 6.5.2, the substantiation outlined concerns with the provisions in the First Draft and the edits associated with SR No. 39 should improve on the issues raised by PC No. 582, so the requirement has not been deleted.

ResponseMessage:Public Comment No. 443-NFPA 652-2013 [Sections 6.5.1, 6.5.2]Public Comment No. 582-NFPA 652-2013 [Section No. 6.5.2]




7.1.1 Responsibility.The owner/operator of a facility where combustible particulate solids are present in either a process or a facility compartment shall be responsible to ensure a process hazards analysis materials that have been determined to be combustible or explosible in accordance with Chapter 5 are present in an enclosure shall be responsible to ensure a DHA is completed in accordance with the requirements of this chapter.



Committee Statement

CommitteeStatement:

Section 7.1.1:

a. This section requires the completion of a process hazard analysis for all processes/facility compartments where combustible particulate solids are present. The mere presence of a combustible particulate solid should not trigger this requirement. Doing so would unnecessary obligate thousands of facilities without combustible dust deflagration or fire hazards to conduct process hazard analyses. The requirement to conduct a hazard analysis should be triggered by the presences of a fire or deflagration hazard,determinations that are already required by the Standard.

The Committee agrees with the submitter of PC No. 21 and approves the changes shown in this SR. The Committee also modified this to be consistent with the use of the defined term compartment per work of a Committee task group that reviewed this issue and made recommendations to the fullcommittee.





7.1.2*The requirements of Chapter 7 shall be applied retroactively apply retroactively inaccordance with 7.1.2.1 through 7.1.2.3 .7.1.2.1For existing processes and facility compartments that are undergoing materialmodification, the owner/operator shall complete DHAs as part of the project.7.1.2.2*For existing processes and facility compartments that are not undergoing materialmodification, the owner/operator shall schedule and complete DHAs of existingprocesses and facility compartments within a 3-year period from the effective date of the standard. The owner/operator shall demonstrate reasonable progress in each of the 3 years.7.1.2.3For the purposes of applying the provisions of 7.1.2 , material modification shall include modifications or maintenance and repair activities that exceed 25 percent of the original cost.


File Name DescriptionA.7.1.2_A.7.1.2.2_SR_41_edited.docx A.7.1.2 and A.7.1.2.2 (SR 41) edited 8/5/14



Committee Statement



CommitteeStatement:

Section 7.1.2 Process Hazard Analysis, Retroactivity:

a. This section indicates that the requirements of Chapter 7 shall be applied retroactively. This would require a facility owner to 1) have completed process hazard analyses on all existing combustible dust processes on the effective date of the Standard, and 2) according to Sections 7.3.3.3 and 7.3.4.3 “manage hazards in accordance with the Standard”. These two sections obligate a facility owner to have completed upgrades of all existing processes to NFPA 652 requirements by the effective date of the Standard. This is not only unachievable, but inconsistent with other NFPA Standards.

b. As a point of reference, when OSHA promulgated the Process Safety Standard (which appears to be the model for many of the concepts in NFPA 652), officials recognized the challenges associated with completing the initial PHA’s and did not require immediate completion.

c. A reasonable approach (and one used extensively by the EPA when it promulgates new regulations) is to require conformance for new processes and when existing processes undergo material modifications. As an alternative, a 5-year period for completion of initial PHA’s (approach taken by OSHA) could be followed. Recommended options for changes to section 7.1.2 are provided below.

d. Option 1: The requirements of Chapter 7 shall apply to new processes and to existing processes that are undergoing material modification. Material modification shall include modifications or maintenance/repair that exceeds 25% of the original process cost.

e. Option 2: The owner/operator of a facility shall prepare a schedule for completing process hazard analyses of affected process/facility compartments within a 5-year period of effective date of the Standard. The schedule shall demonstrate reasonable progress in each of the five years (all process hazard analyses cannot be completed in the 5th year).

The Committee agreed with the principle outlined in Public Comment No. 22 and used it as the basis for developing this SR.

ResponseMessage:Public Comment No. 8-NFPA 652-2013 [Section No. 7.1.2]Public Comment No. 22-NFPA 652-2013 [Section No. 7.1.2]Public Comment No. 316-NFPA 652-2013 [Section No. 7.1.2]



SR No. 41 Annex A.7.1.2

A.7.1.2 A DHAdust hazards analysis is a careful review of the fire and explosion hazards to

determine the consequences of what could go wrong and to determine what safeguards could be

implemented to prevent or mitigate those consequences. DHAsust hazards analyses should be

completed as soon as possible. For existing facilities, those processes with the greatest perceived

risk should be evaluated first.

A.7.1.2.2 It is not the intent of this requirement to permit a delay in the completion of all

DHAsdust hazards analyses until the third 3rd year.


7.2.1* Overview.The process hazards analysis DHA shall consider evaluate the fire, deflagration, and explosion hazards and provide recommendations to ensure that manage theobjectives hazards in Section accordance with Section 4.2 are met .7.2.1.1The process hazards analysis shall determine where a fire, deflagration, and explosion hazard exists.


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Fri Mar 14 09:09:32 EDT 2014

Committee Statement

CommitteeStatement:

These requirements for PHA not only requires identification of hazards, but also recommendations, which implies completing a risk evaluation. The definition of Process Hazard Analysis should be updated accordingly.





7.2.3 Minimum Interval.A revalidation of the process hazards analysis shall be performed a minimum ofevery 5 years.



Committee Statement

CommitteeStatement:

The requirement for periodic revalidation will certainly be interpreted as PSM driven whether intended by the committee or not. While I agree that managing change is important in any hazardous operation, requiring the PHA be repeated on any size operation and even if prescriptive solutions from other codes are completed is unnecessary. I suggest the current requirements in paragraph 9.9 are perfectly sufficient in achieving what is intended by this section without the cost, documentation, etc. The related Annex material should also be removed.

This is submitted as a possible alternative should PC-245 be rejected by the committee





7.3.1 General.The process hazards analysis DHA shall include the following:

(1) Identify the portions Identification and evaluation of the process or facility areas where a fire, deflagration flash fire , and explosion hazards exists exist

(2) Where such a hazard exists, identification and evaluation of specific fire anddeflagration scenarios shall include the following:

(a) Identify Identification of safe operating ranges

(b)

(c) Recommendation of additional safeguards where warranted, including a plan for implementation.

Identify operating ranges

additional safeguards where warranted, including a plan for implementation.

Identify the means and develop a plan by which fire, deflagration, and explosion events can be prevented or mitigated

Identify operating ranges

additional safeguards where warranted, including a plan for implementation .


File Name DescriptionA.7.3.1_4_SR-44_edited_.docx edited 8/8/14



Committee Statement

* Identification of the safeguards that are in place to manage fire, deflagration, and explosion events

* fire, deflagration, and explosion events

* fire, deflagration, and explosion events



CommitteeStatement:

The proposed language change more accurately and clearly describes the PHA activities. The Process Hazard Analysis as described throughout the document should be reviewed for consistency throughout the standard. The risk assessment in Chapter 8 should be a part of PHA as described in 7.2.1 and not a separate analysis. The existing language in NFPA 652 for risk assessment and PHA is inconsistent and will be confusing to the user.

see PC139 on section 7.2.1

Annex: Added combustible dust to align with scope of this standard and remove the word minimum as this implies there are additional steps. There may be many types of activities but they all fall under the general hazard analysis steps described in the standard. see comment from Craig Froehling for 7.3.1 that suggest changes that better aligns the decription for a hazardanalysis with industry

ResponseMessage:Public Comment No. 140-NFPA 652-2013 [Section No. 7.3.1]Public Comment No. 145-NFPA 652-2013 [Section No. 7.3.1]Public Comment No. 421-NFPA 652-2013 [Section No. A.7.3.1(4)]Public Comment No. 496-NFPA 652-2013 [Section No. 7.3.1]Public Comment No. 535-NFPA 652-2013 [Section No. 7.3.1]Public Comment No. 536-NFPA 652-2013 [Section No. 7.3.1]Public Comment No. 588-NFPA 652-2013 [Section No. 7.3.1]



[SR-44]

A.7.3.1(4)

The hazard management document for all of the portions areas of the process or facility

compartment determined to be a hazardcombustible dust hazards should include, but not be

limited to, the following:

(1) Test reports

(2) Drawings

(3) Sizing calculations

Methods to prevent or mitigate the consequences of the combustible dust hazards can be

accomplished developed by using the methods permitted in this standard or other industry- or

commodity-specific NFPA standards. This informationSubsection 7.3.1 outlines the minimum

steps of a process dust hazards analysis.


7.3.2.1The process hazards analysis DHA shall be based on data used obtained in accordance with in Chapter 5 of for material that is representative of the dustpresent.



Committee Statement

Committee Statement: This seeks to clarify the intent of the requirement.Response Message:Public Comment No. 84-NFPA 652-2013 [Section No. 7.3.2.1]Public Comment No. 146-NFPA 652-2013 [Section No. 7.3.2.1]Public Comment No. 209-NFPA 652-2013 [Section No. 7.3.2.1]Public Comment No. 299-NFPA 652-2013 [Section No. 7.3.2.1]




7.3.3.1*Each part of the process system where combustible dust is present or wherecombustible particulate solids could cause combustible dust to be present shall be evaluated, and the evaluation shall address the following:

(1) Potential intended and unintended combustible dust transport between parts of the process system

(2) Potential fugitive combustible dust emissions into a building or building compartments

(3) Potential deflagration propagation between parts of the process system



Committee Statement

CommitteeStatement:

Section 7.1.1 states that a PHA is necessary where combustible particulate solids are present. This change is suggested here for consistency with 7.1.1 and other changes suggested in Ch. 1.





7.3.3.2The potential for a dust fire, deflagration, or explosion in a process system component shall be based on whether the dust fire, deflagration, or explosion hazard exists. Each part of the process that contains a combustible particulate solid and that can potentially include both of the following conditions shall be considered a fire hazard and shall be documented as such:

(1) Oxidizing atmosphere

(2) Credible ignition source

7.3.3.3*Each part of the process that contains a sufficient quantity of combustible dust to propagate a deflagration and that can potentially include all of the following conditions shall be considered a dust deflagration hazard DHA and shall bedocumented as such:


(2) Credible ignition source(3) Credible suspension mechanism



Committee Statement

CommitteeStatement:

The Committee incorporated changes into paragraph 7.3.3.2 and included a revised 7.3.3.3.

Response Message:Public Comment No. 141-NFPA 652-2013 [Section No. 7.3.3.2]Public Comment No. 591-NFPA 652-2013 [Section No. 7.3.3.2]




7.3.4 Facility Building or Building Compartments.See SR-99

7.3.4.1Each facility building or building compartment where combustible dust is present shall be evaluated.7.3.4.1.1Where multiple buildings or building compartments present essentially the same hazard, a single evaluation might be appropriate shall be permitted to be conducted as representative of all similar buildings or building compartments .7.3.4.1.2The evaluation shall address potential combustible dust migration between buildings or building compartments.7.3.4.1.3The evaluation shall address potential deflagration propagation between buildings or building compartments.7.3.4.2*The potential for a dust fire, deflagration, or explosion in a facility compartment shall be based upon whether a dust fire, deflagration, or explosion hazard exists. Each building or building compartment that contains a combustible particulate solid and that can potentially include both of the following conditions shall be considered a fire hazard and shall be documented as such:


(2) Credible ignition source

7.3.4.2.1*The evaluation of dust deflagration hazard in a facility building or buildingcompartment shall include a comparison of actual or intended dust accumulation to the threshold housekeeping dust accumulation that would present a potential for flash-fire exposure to personnel or compartment failure due to explosiveoverpressure.7.3.4.2.2Threshold housekeeping dust accumulation levels and non-routine nonroutine dustaccumulation levels (i.e e.g ., from a process upset) shall be in accordance with relevant industry- or commodity-specific NFPA standards.(See 1.3.1 .)7.3.4.3Each building or building compartment that contains a sufficient quantity of combustible dust to propagate a deflagration and that can potentially include all of the following conditions shall be considered a dust deflagration hazard and shall be documented as such:


(2) Credible ignition source (3) Credible suspension mechanism

Global SR-143

7.3.4.3



Where a dust fire, deflagration, or explosion hazard exists within a facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard.


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Tue Apr 15 08:32:30 EDT 2014

Committee Statement

CommitteeStatement:

Why create unique terms (facility compartment) when common terms (building or room) will do as well. Putting the A.7.3.4.1 material in the main body of the code is more appropriate to insure the option is equally valid to the main requirement. Adding the additional text to the basic requirement and removal of 7.3.4.2 will simplify the understanding of the need. The text in 7.3.4.2 is nearly duplication of the main requirement. The deleted text in new 7.3.4.2 (existing 7.3.4.2.1) adds nothing to the understanding of the requirement. The added text to 7.3.4.3 makes it clear the hazard may be managed by other existing standards.

Based on the recommendations in the various related item Public Comments, the Committee created this SR No. 49 to incorporate the changes to the standard.

Response Message:Public Comment No. 24-NFPA 652-2013 [Section No. 7.3.4.3]Public Comment No. 142-NFPA 652-2013 [Section No. 7.3.4.2 [Excluding any Sub-Sections]]Public Comment No. 143-NFPA 652-2013 [Section No. 7.3.4.2.1]Public Comment No. 322-NFPA 652-2013 [Section No. 7.3.4]Public Comment No. 500-NFPA 652-2013 [Section No. 7.3.4.1]Public Comment No. 501-NFPA 652-2013 [Section No. 7.3.4.2]Public Comment No. 504-NFPA 652-2013 [Section No. 7.3.4.3]Public Comment No. 515-NFPA 652-2013 [Section No. 7.3.4.2.2]Public Comment No. 593-NFPA 652-2013 [Section No. 7.3.4.2]Public Comment No. 594-NFPA 652-2013 [Section No. 7.3.4.2.2]Public Comment No. 595-NFPA 652-2013 [Section No. 7.3.4.3]




8.2 Building Design.8.2.1 Risk Assessment. A documented risk assessment acceptable to the AHJ shall be permitted to beconducted to determine the level of building design and protection features to be provided, including, but not limited to, the measures addressed in Section 8.2 .8.2.2* Construction.The type of construction shall be in accordance with the building code adopted by the authority having jurisdiction AHJ .8.2.3 Building/Room or Building Compartment Protection.8.2.3.1*Each room, building, or other enclosure or building compartment where a dust deflagration hazard exists shall be protected from the consequence of deflagration.8.2.3.2*If a room building or building building compartment contains a dust explosion hazard in a facility compartment and outside of equipment, such areas shall be provided with deflagration venting to a safe area in accordance with NFPA 68, Standard on Explosion Protection by Deflagration Venting .8.2.3.2.1Venting shall be located to relieve pressure to relieve pressure shall be locatedthrough an outside wall or roof.8.2.3.2.2The fireball, blast hazards, and missile hazards that are created by deflagration venting shall not expose additional personnel or property assets.8.2.4 Life Safety.Building configuration and appurtenances shall comply with the life safety requirements of the building and fire prevention codes adopted by the authority having jurisdiction AHJ .8.2.4.1Where a dust deflagration hazard exists in a facility building or buildingcompartment and outside of equipment, building configuration and appurtenancesshall comply with the life safety requirements of the building and fire prevention codes for a hazardous occupancy adopted by the authority having jurisdiction AHJ .8.2.4.2Where a dust explosion hazard exists in a facility building or building compartment and outside of equipment, enclosed exit and egress paths an enclosed means of egress is provided, it shall be designed to withstand potential overpressures from a dust explosion external overpressure from building deflagration .8.2.5 Methods Construction Features to Limit Accumulation.8.2.5.1*Interior surfaces where dust accumulations can occur shall be designed and constructed so as to facilitate cleaning and to minimize combustible dust accumulations.8.2.5.2Enclosed building spaces inaccessible to routine housekeeping shall be sealed to prevent dust accumulation.8.2.5.3*



Enclosed building spaces that are difficult to access for routine housekeeping shall be designed to facilitate routine inspection for the purpose of determining the need for periodic cleaning.8.2.6 Separation of Hazard Areas from Other Hazard Areas and from Other Occupancies.8.2.6.1Areas where a dust deflagration hazard exists in a facility building or buildingcompartment (excluding hazard within equipment) shall be segregated, separated,or detached from other occupancies to minimize damage from a fire or an explosion.8.2.6.2 Use of Segregation.8.2.6.2.1Physical barriers erected for the purpose of limiting fire spread shall be designed in accordance with NFPA 221, Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier Walls .8.2.6.2.2Physical barriers erected to segregate fire hazard areas, including all penetrations and openings of floors, walls, ceilings, or partitions, shall have a minimum fire resistance rating based on the anticipated fire duration.8.2.6.2.3Physical barriers, including all penetrations and openings of floors, walls, ceilings, or partitions, that are erected to segregate dust explosion hazard areas shall be designed to preclude failure of those barriers during a dust explosion in accordance with NFPA 68, Standard on Explosion Protection by Deflagration Venting .8.2.6.3 Use of Separation.8.2.6.3.1*Separation shall be permitted to be used to limit the dust explosion hazard or deflagration hazard area within a building when it is supported by a documented engineering evaluation acceptable to the authority having jurisdiction AHJ .8.2.6.3.2*The required separation distance between the dust explosion hazard or deflagration hazard area and surrounding exposures shall be determined by an engineering evaluation that addresses the following:

(1) Properties of the materials

(2) Type of operation

(3) Amount of material likely to be present outside the process equipment

(4) Building and equipment design(5) Nature of surrounding exposures

8.2.6.3.3The Either the separation area shall be free of dust, or where dust accumulations exist on any surface, the surface colors below color of the surface on which the dust has accumulated shall be readily discernible.8.2.6.3.4When Where separation is used to limit the dust explosion or deflagration hazard area determined in Chapter 7, the minimum separation distance shall not be less than 35 ft (11 m).8.2.6.3.5*When Where separation is used, housekeeping, fixed dust collection systems employed at points of release, and the use of physical barriers shall be permitted to be used to limit the extent of the dust explosion hazard or flash-fire hazard area.8.2.6.4 Use of Detachment.8.2.6.4.1



Detachment shall be permitted to be used to limit the dust hazard area to a physically separated adjacent building.8.2.6.4.2*The required detachment distance between the dust explosion hazard area or the deflagration hazard area and surrounding exposures shall be determined by an engineering evaluation that addresses the following:

(1) Properties of the materials

(2) Type of operation

(3) Amount of material likely to be present outside the process equipment

(4) Building and equipment design

(5) Nature of surrounding exposures


File Name DescriptionA.8.2.3.2_SR-65.docx edited 8/8/14


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Mon May 12 14:23:32 EDT 2014

Committee Statement


Several of the provisions in this section are inappropriately stated in absolute terms without regard to feasibility, practicality, or the level of residual risk. The addition of the proposed Risk Assessment paragraph here will make this section consistent with the other sections of this Chapter.

Based on comments 214, 302 and 88, the requirement in 8.2.3.2 wasdeleted.

Annex: Since the Committee modified this requirement to apply to enclosed means of egress within buildings or building compartments and not applicable to facility compartments, the existing annex no longer applied and new annex has been provided.

ResponseMessage:Public Comment No. 88-NFPA 652-2013 [Section No. 8.2.3.2]Public Comment No. 214-NFPA 652-2013 [Section No. 8.2.3.2]Public Comment No. 302-NFPA 652-2013 [Section No. 8.2.3.2]Public Comment No. 411-NFPA 652-2013 [Section No. 8.2.5.3.3]Public Comment No. 448-NFPA 652-2013 [Section No. 8.2]Public Comment No. 598-NFPA 652-2013 [Section No. 8.2.2.1]Public Comment No. 599-NFPA 652-2013 [Section No. 8.2.2.2]



[SR-65]

A.8.2.3.2

Damage-limiting construction should be considered for those sections of enclosed egress paths, based

on withstanding building/room overpressure determined according to NFPA 68, Standard on Explosion

Protection by Deflagration Venting. The methodology of NFPA 68 uses an evaluation of the quantity of

dust accumulation to determine the necessary building/room vent area and resulting overpressure.An

enclosed means of egress is intended to be an exit separated from other parts of the building or building

compartment as used in NFPA 101. Examples include exit stair enclosures and horizontal exit

passageways.

Second Revision No. 66-NFPA 652-2014 [ Section No. 8.3.3.1.2 ]

8.3.3.1.2*Where it is necessary to make changes to an existing system, all changes shall be managed in accordance with Chapter the management of change requirements in Section 9.9 9 .


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Tue May 13 10:41:20 EDT 2014

Committee Statement


A more specific reference to the applicable portion of chapter 9 is warranted.

Response Message:Public Comment No. 167-NFPA 652-2013 [Section No. 8.3.3.1.2]




8.3.3.1.3*The system shall be designed and maintained to ensure that the air/gas air-gasvelocity used shall meet or exceed the minimum required to keep the interior surfaces of all piping or ducting free of accumulations under all normal operatingmodes.


File Name DescriptionA.8.3.3.1.3_SR-67_edited_.docx edited 8/8/14



Committee Statement


These systems are designed to meet this requirement under normal operating ranges. The phrase ‘under all operating modes’ has been deleted as in an upset condition, these systems will be operating outside its design parameters and may fail (product choke).

Annex: Revised to clarify ambiguous language.ResponseMessage:Public Comment No. 90-NFPA 652-2013 [Section No. 8.3.3.1.3]Public Comment No. 109-NFPA 652-2013 [Section No. A.8.3.3.1.3]Public Comment No. 183-NFPA 652-2013 [Section No. 8.3.3.1.3]Public Comment No. 216-NFPA 652-2013 [Section No. A.8.3.3.1.3]Public Comment No. 217-NFPA 652-2013 [Section No. 8.3.3.1.3]Public Comment No. 304-NFPA 652-2013 [Section No. 8.3.3.1.3]Public Comment No. 399-NFPA 652-2013 [Section No. A.8.3.3.1.3]



[SR-67]

A.8.3.3.1.3

The design minimum velocity specified in the design for each of these systems differs significantly. Refer

to the specific sections to follow on thefor each type of system for that information. For guidance on

designing, acquisition, operation, and maintenance of dust collection systems, refer to ACGIH ACGIH,

Industrial Ventilation: A Manual of Recommended Practice., published by ACGIH.

Second Revision No. 135-NFPA 652-2014 [ Section No. 8.3.3.1.4.3 ]

8.3.3.1.4.3 Shutdown.(A)Pneumatic conveying, dust collection, and centralized vacuum cleaning systems shall be designed such that, on normal shutdown of the process, the systemmaintains design air velocity until material is purged from the system.(B)The requirements of 8.3.3.1.4.3(A) shall not apply during emergency shutdown of the process, such as by activation of an emergency stop button or by activation of an automatic safety interlocking device.(C)Dilute phase pneumatic Pneumatic conveying systems shall be designed such that, upon on restart after an emergency shutdown, residual materials can be cleared and design air velocity can be achieved prior to admission of new material to the system .(D)Dense Phase. (Reserved)



Committee Statement


The Committee revised this section to remove the terms dilute-phase and dense-phase pneumatic conveying from the standard, as the terms were only used here and not fully described, so there is no need to retain them in this edition of the standard.

ResponseMessage:




8.3.3.2.3*Pneumatic conveying systems conveying combustible particulate solids and posing an explosion hazard shall be protected in accordance with Section 8.9 .



Committee Statement


The current text would require protective features on conveying systems that pose no hazard. Dense-phase pneumatic conveying systems can be shown to be incapable of supporting continuing combustion but would still be subject to the requirements of this section. the revised text limits tha applicability of this section to those systes that pose a hazard.

Response Message:Public Comment No. 415-NFPA 652-2013 [Section No. 8.3.3.2.3]




8.3.3.3.1*At each collection point, the system shall be designed to achieve the minimum velocity required face velocity for dust capture over the entire opening of the hood or pickup point for capture, control, and containment of the dust source .



Committee Statement


Section 8.3.3.3.1 Dust Collection, Collection Points:

a. Section indicates that the collection point hoods or pickup points shall be designed to achieve the minimum required face velocity for dust capture over the entire opening of the hood or pickup point. There are a multitude of effective hood and dust collector designs, and not all meet this requirement. Larger hoods, in particular, often don’t have uniform airflow across the entire opening, but are designed to ensure the hood perimeter does have adequate airflow and they are therefore effective. Recommended language change:

b. At each collection point, the system shall be designed to achieve theminimum required face velocity for effective dust capture over the entireopening of the hood or pickup point.

Response Message:Public Comment No. 26-NFPA 652-2013 [Section No. 8.3.3.3.1]Public Comment No. 184-NFPA 652-2013 [Section No. 8.3.3.3.1]




8.3.3.3.5*Dust collection systems that remove material from operations that generate flames, sparks, or hot material under normal operating conditions shall not be interconnected with dust collection systems without isolation that transport combustible particulate solids or hybrid mixtures. (See 8.9.4 .)



Committee Statement


The current text does not seem to make sense. I am not convinced that isolation can be achieved. Keep the sparks and ignitions sources away from deflagrable dust clouds!

ResponseMessage:Public Comment No. 416-NFPA 652-2013 [Section No. 8.3.3.3.5]



Second Revision No. 142-NFPA 652-2014 [ New Section after

8.3.3.3.7 ]

8.3.3.3.8*Control equipment controlling the operation of the AMS shall be installed in a location that is safe from the effects of a deflagration in the AMS.


File Name DescriptionA.8.3.3.3.8_SR_142_edited.docx


Submitter Full Name: Sonia BarbosaOrganization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Fri Aug 08 11:37:51 EDT 2014

Committee Statement


The Committee has added this requirement to ensure that the location for control equipment for AMS is considered in terms of personnel safety.

Response Message:



[SR No. 110 Annex A.8.3.3.3.8]

A.8.3.3.3.8

The importance of locating the control equipment so that personnel operating the AMS are safe

can be illustrated by the following conditions:examples:

(1) Where there is no explosion protection for the dust collector, the personnel operating the

AMS would potentially be at risk.

(2) Where the AMS is provided with deflagration venting, NFPA 68 describes the danger

zone resulting from the actuation of the vent.

To address the above situations, it is possible to provide blast protection for personnel who must

needing to be in the danger zone.

Formatted: Numbered + Level: 1 + Numbering Style:

1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at:

0.25" + Indent at: 0.5"


8.3.5 Recycle of AMS Clean Air AMS Exhaust .8.3.5.1Exhaust air from the final air–material separator AMS shall be discharged outside of buildings to a restricted area and away from air intakes separated from clean air intakes for the building .8.3.5.2*Air from air–material separators AMSs shall be permitted to be recirculated directly back to the pneumatic conveying system.8.3.5.3*Recycling of air-material separator AMS exhaust to buildings or rooms building compartments shall be permitted when all of the following requirements conditionsare met:

(1) Combustible or flammable gases or vapors are not present in either in the intake or the recycled air in concentrations above applicable industrial hygieneexposure limits or 1 percent of the lower flammable limit ( LFL) , whichever is lower.

(2)

(3)

(4) Provisions are incorporated to prevent transmission of flame and pressure effects from a deflagration in an air-material separator AMS back to the facility unless a process hazards analysis DHA indicates that those effects do not pose a threat to the facility or the occupants.

(5) Provisions are incorporated to prevent transmission of smoke and flame from a fire in an air–material separator AMS back to the facility unless a processhazards analysis DHA indicates that those effects do not pose a threat to thefacility or the occupants.

(6) The system includes a method for detecting air–material separator AMSmalfunctions that would reduce collection efficiency and allow increases in the amount of combustible particulate solids returned to the building.

(7) The building or room building compartment to which the recycled air is returned meets the requirements of Section 8.4.

(8) Recycled-air ducts are inspected and cleaned at least annually.


* Combustible particulate solids are not present in the recycled air in concentrations above applicable industrial hygiene exposure limits or 1percent of the MEC minimum explosible concentration (MEC) , whichever islower.

* The oxygen concentration of the recycled air stream is between 19.5 percent and 23.5 percent by volume.




Committee Statement


The revised titl makes more sense. The revised text states the requirement more clearly.





8.4.2.1.1*Housekeeping procedures shall be documented in accordance with therequirements of Chapters 7 and 9 .



Committee Statement


The proposed requirement to document housekeeping procedures in accordance with Chapters 7 and 9 is not meaningful. Adequate guidance is provided in A.8.4.2.1.1.

ResponseMessage:Public Comment No. 92-NFPA 652-2013 [Section No. 8.4.2.1.1]Public Comment No. 220-NFPA 652-2013 [Section No. 8.4.2.1.1]Public Comment No. 306-NFPA 652-2013 [Section No. 8.4.2.1.1]Public Comment No. 455-NFPA 652-2013 [Section No. 8.4.2.1.1]




8.4.2.1.2*Surfaces shall be cleaned in a manner that minimizes the risk of generating a fire or explosion hazard The methods used for cleaning surfaces shall be selected on the basis of reducing the potential for creating a combustible dust cloud .


File Name DescriptionA.8.4.2.1.2_SR_73_edited.docx A.8.4.2.1.2 (SR 73) edited 8/5/14



Committee Statement


As written, the provision requires the user to select the cleaning method that has the lowest risk, even though another method may still have an acceptable risk. The only methods that should be prohibited are those that are unacceptable. The standard should not demand the minimum risk in any provision.




[SR No. 73 Annex A.8.4.2.1.2]

A.8.4.2.1.2

For information on selection of housekeeping methods refer to FM 7-76 (2013), Section 2.2.4, Operation

and Maintenance. Other factors can be considered in the selection of a housekeeping method, such as

the effectiveness of or compatibility of certain methods with the material.There can also be other

factors that go into selection of the housekeeping method, such as where certain methods are more

effective or more compatible with the material.


8.4.2.1.3*Cleaning methods shall be in accordance with this standard and the industry or commodity-specific NFPA standard. (See 1.3.1 .)



Committee Statement


The word “and” needs to be changed to “or”, and the cross-reference should be deleted. The feasibility of cleaning methods are so industry- or commodity-dependent that industry or commodity-specific standards should control if there is a divergence on cleaning methods between them and this standard.





8.4.2.2 Vacuum Cleaning Method.8.4.2.2.1*For residual accumulations, vacuum cleaning shall be the preferred method.8.4.2.2.1*Portable vacuum cleaners that meet the following minimum requirements shall be permitted to be used to collect combustible particulate solids in unclassified(nonhazardous) areas :

(1) Materials of construction shall comply with 8.5.7.1.

(2) Hoses shall be conductive or static dissipative.

(3) All conductive components, including wands and attachments, shall be bonded and grounded.

(4) Dust-laden air shall not pass through the fan or blower.

(5) Electrical motors shall not be in the dust-laden air stream unless listed for Class II, Division 1, locations.

(6)

(7) Vacuum cleaners used for metal dusts shall meet the requirements of NFPA484, Standard for Combustible Metals .

8.4.2.2.2*In Class II electrically classified (hazardous) locations, electrically powered vacuum cleaners shall be listed for the purpose and location, or shall be a fixed-pipe suction system with a remotely located exhauster and air-material separator an AMS installed in conformance with Section 8.3, and they shall be suitable for the dust being collected.8.4.2.2.3Where flammable vapors or gases are present, vacuum cleaners shall be listed for Class I and Class II hazardous locations.


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Wed Jul 16 13:15:38 EDT 2014

Committee Statement

* When Where liquids or wet materials are picked up by the vacuum cleaner, paper filter elements shall not be used.




The renumbering of this section presumes that public comment 150 is adopted.

The Committee accepted the recommendation of PC No. 197 and deleted the statement that vacuum cleaning is preferred.

8.4.2.3.2 is revised to clarify the committee's intent that the specified criteria define vacuums deemed to be suitable for cleaning up dust in general purpose areas.

ResponseMessage:Public Comment No. 151-NFPA 652-2013 [Section No. 8.4.2.2]Public Comment No. 197-NFPA 652-2013 [Section No. 8.4.2.2.1]




8.4.2.3* Sweeping/ , Shoveling/ , Scoop, and Brush Cleaning Method.For spills, cleaning with scoops and brushes shall be the preferred The use ofscoops, brooms, and brushes for sweeping and shoveling shall be a permittedcleaning method.



Committee Statement

Committee Statement: To not limit to spills, since not one preferred method. FIX laterResponse Message:




8.4.2.6 Compressed Air–Blow Down Air Blowdown Method.8.4.2.6.1*Blow downs Blowdowns using compressed air or steam shall be permitted to be used for cleaning inaccessible surfaces or surfaces where other methods of cleaning result in greater personal safety risk as a cleaning method in accordance with the provisions of 8.4.2.6.2 .8.4.2.6.2*Where blow down blowdown using compressed air is used, the following precautions shall be followed:

(1) Vacuum cleaning, sweeping, or water wash down methods are used first to clean surfaces that can be safely accessed prior to using compressed air Prior to using compressed air, vacuum cleaning, sweeping, or water washdown methods are used to clean surfaces that can be safely accessed .

(2) Dust accumulations in the area after vacuum cleaning, sweeping, or water wash down washdown do not exceed the threshold housekeeping dust accumulation.

(3) Compressed air hoses are equipped with pressure relief nozzles limiting the discharge pressure to 30 psi (207 kPa) in accordance with OSHArequirements in 29 CFR 1910.242(b).

(4) All electrical equipment, including lighting, potentially exposed to airborne dust in the area meets, at a minimum, NFPA 70 , National Electrical Code ; NEMA 12 as defined by NEMA 250; or the equivalent. during cleaning issuitable for use in a Class II, Division 2, hazardous (classified) location inaccordance with NFPA 70 .

(5) All ignition sources and hot surfaces capable of igniting a dust cloud or dust layer are shut down or removed from the area.

(6) After blowdown is complete, residual dust on lower surfaces is cleaned prior to re-introduction of potential ignition sources.

(7) Where metal or metal-containing dust or powder under the scope of NFPA 484, Standard for Combustible Metal , are is present, the requirements of NFPA 484 apply.


File Name DescriptionA.8.4.2.6.1_SR-77_edited_.docx edited 8/8/14





Committee Statement


The proposed revision removes reference to steam blowdown, as this is to be covered in 8.4.2.7.

Item 2 in 8.4.2.6.2 is clarified to point out where dust thresholds are determined. The Committee does not support deletion of item (2) as it only applies if item (1) is satisfied, otherwise the accumulations do not apply.

Annex: Blowdown can be an acceptable means with the appropriate safeguards. Other methods may pose other significant hazards. For example wash down with water may be an acceptable method for dust removal, but introduction of water into a facility may create an environment for microbiological growth creating a significant food safety risk.

ResponseMessage:Public Comment No. 28-NFPA 652-2013 [Section No. 8.4.2.6.1]Public Comment No. 153-NFPA 652-2013 [Section No. 8.4.2.6]Public Comment No. 201-NFPA 652-2013 [Section No. 8.4.2.6.1]Public Comment No. 204-NFPA 652-2013 [Section No. 8.4.2.6.2]Public Comment No. 424-NFPA 652-2013 [Section No. 8.4.2.6.2]Public Comment No. 429-NFPA 652-2013 [Section No. A.8.4.2.6.1]



[SR-77]

A.8.4.2.6.1

Compressed air blow-downblowdown used for cleaning purposes has been demonstrated to present

significant hazards and should only be employed where nowhen other cleaning method is

availablemethods present higher risk. Compressed air blow-downblowdown does not remove

accumulated dust, it simply moves the dust somewhere elseto another area, which will then have to be

cleaned. It is always preferable to use engineering design controls to eliminate areas that can be

inaccessible or difficult to clean by other methods.


8.4.3 Training.Operator Employee and contractor training shall include housekeeping procedures, required personal protective equipment (PPE) during housekeeping, and proper use of equipment.



Committee Statement


Employee is substituted for operator, since employees other than operators (e.g., mechanics) may be doing housekeeping.





8.4.6.3*Housekeeping frequency and provisions Provisions for unscheduled housekeeping shall include specific requirements establishing time to clean local dust spills or transient releases.



Committee Statement


Housekeeping frequency (i.e., for routine housekeeping) cannot anticipate the need for cleaning up spills and transient releases.





8.5.4.2*Heated external surfaces of process equipment and piping in dust deflagration hazard areas containing combustible dust shall be maintained at a temperature at least 50°C 112°F (50°C) below the dust layer hot surface ignition temperature and dust cloud ignition temperatures measured in a standardized test acceptable to the authority having jurisdiction AHJ .



Committee Statement


The phrase "containing combustible dust" is superfluous since dust hazards areas contain combustible dust.

The requirement should also address the potential ignition of combustible dust clouds in contact with hot surfaces.





8.5.4.3*Internal surfaces of process equipment heated with hot air and having a potential for dust accumulation shall be maintained at a temperature at least 20°C below a standard dust layer hot air ignition temperature acceptable to the authority havingjurisdiction.



Committee Statement


This section is proposed for deletion for several reasons.

First, equipment might be heated by means other than the use of hot air.

More importantly, as discussed in a prior committee meeting, some driers may operate at temperatures in excess of the dry dust AIT at the feed end of the dryer (where the solids are wet and thus, non-ignitable). By the time the solids are dry enough to ignite, they could be in a region of the dryer where the temperature is below the AIT. The concern is that the requirement, aswritten, might prohibit the operation of such dryers.




Second Revision No. 82-NFPA 652-2014 [ New Section after 8.5.6.4 ]

8.5.6.5*Zone classification for dusts in accordance with Article 506 of NFPA 70 shall not be permitted.


File Name DescriptionA.8.5.6.5_SR_82_editd.docx A.8.5.6.5 (SR 82) edited 8/5/14


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Wed May 14 10:30:34 EDT 2014

Committee Statement




Article 502 of NFPA permits the use of Zone 20 equipment installation in a Class II, Division 1 location for the same dust. If the dust is a metal dust and yet not a combustible metal dust according to the test methods for Group IIIC, based on a conductivity criterion, this would potentially have equipmentidentified for Group IIIB (suitable for non-conductive dusts) installed in a Class II, Division 1, Group E location. This would definitely not beappropriate. Contrary to the general statement in 506.6(A), a metal dust could be in Division Group E, but not conductive enough to be in Zone Group IIIC.

Another discrepancy in the requirements for Zone classification versus Division classification is that Article 506 provides no limitation on designation of Zone 22 locations for combustible metal dusts. Under the Division system in Article 500.5(C)(1)(3) if there is Group E metal dust in hazardous quantities, the location would be classifed as Division 1 and not permitted to be classified as Division 2. Under the Zone system, the less protective Zone 22 could be chosen.

Both of these discrepancies are non-conservative in comparison to the Division classification system. While the NEC has established a framework for the use of Zone classification for dusts, these non-conservative discrepancies in the boundaries between dust groups and area classification zones/divisions must be resolved before applying these concepts to industrial situations. The NFPA EECA committee has previously coordinated the boundaries between Zone and Division for gases, but has not yet addressed this significant issue for dusts. Until such time as these discrepancies can be addressed, NFPA 652 should not permit the application of Zone classification for combustible dusts in industrial occupancies.

ResponseMessage:Public Comment No. 499-NFPA 652-2013 [New Section after 8.5.6.4]



A.8.5.6.5

Article 502 of NFPA 70 permits the use of Zone 20 equipment installation in a Class II, Division 1, location

for the same dust. If the dust is a metal dust and yet not a combustible metal dust according to the test

methods for Group IIIC, based on a conductivity criterion, this would potentially have equipment

identified for Group IIIB (suitable for non-conductive dusts) installed in a Class II, Division 1, Group E,

location. This would definitely not be appropriate. Contrary to the general statement in 506.6(A) of

NFPA 70, a metal dust could be in Division Group E , but not be conductive enough to be in Zone Group

IIIC.

Another discrepancy in the requirements for zZone classification versus dDivision classification is that

Article 506 of NFPA 70 provides no limitation on the designation of Zone 22 locations for combustible

metal dusts. Under the dDivision system in Article 500.5(C)(1)(3), whereif there is Group E metal dust in

hazardous quantities, the location would be classified as Division 1 1 and would and not be permitted to

be classified as Division 2. Under the zZone system, the less protective Zone 22 could be chosen.

Both of these discrepancies are non-conservative in comparison to the dDivision classification system.

While the NEC has established a framework for the use of zZone classification for dusts, these non-

conservative discrepancies in the boundaries between dust groups and area classification

zones/divisions must be resolved before applying these concepts to industrial situations. The NFPA EECA

committee hads previously coordinated the boundaries between zZone and dDivision for gases, but has

not yet addressed this significant issue for dusts. Until such time as these discrepancies can be

addressed, NFPA 652 should not permit the application of zZone classification for combustible dusts in

industrial occupancies.

Formatted: Font: Italic





8.5.7.1.3*Bonding and grounding with a resistance of less than 1.0 × 106 ohms to ground shall be provided for conductive components.





Committee Statement


Section 8.5.7.1.3 Bonding and Grounding:

a. Specifies allowable resistance in bonding/grounding. This specification appears inconsistent (high) compared with other published data on this topic. Writer recommends review.




[SR No. 83 Annex A.8.5.7.1.3]

A.8.5.7.1.3

Where the bonding and /grounding system is all metal, resistance in continuous ground paths

typically is less than 10 ohms. Such systems include those having multiple components. Greater

resistance usually indicates that the metal path is not continuous, usually because of loose

connections or corrosion. A permanent or fixed grounding system that is acceptable for power

circuits or for lightning protection is more than adequate for a static electricity grounding

system.

See Figure A.8.5.7.1.3 for illustrations of bonding and grounding principles.

[Add Figure 7.4.1 from NFPA 77]

Figure A.8.5.7.1.3 Bonding and Grounding.

Formatted: Space After: 0 pt, Line spacing: single

Formatted: Font: Bold

Formatted: Space After: 0 pt, Line spacing: single


8.5.7.1.4 Flexible Connectors.8.5.7.1.4.1This section shall not be required to be applied retroactively.8.5.7.1.4.2Flexible connectors longer than 6.6 ft (2 m) shall have an end-to-end resistance of less than 1.0 × 108 ohms to ground even when where an internal or external bonding wire connects the equipment to which the flexible connector is attached.8.5.7.1.4.3*Flexible Where flammable vapors are not present, flexible connectors with a resistance equal to or greater than 1.0 × 108 ohms shall be permitted underall either of the following conditions:

(1) The dust has a minimum ignition energy (MIE) an MIE greater than 2000 mJ.

(2) The maximum powder transfer velocity is 10 m/s 2000 fpm (10 m/s) .

Flammable vapors are not present.



Committee Statement




This section should be stricken because the basis of this provision is that a propagating brush discharge was proven to be theoretically possible in a laboratory situation, but there is was no evidence presented to the TC that this can or has actually occurred in an industrial setting. The cost associatedwith this change will be large, as this section is not excepted from beingapplied retroactively. Furthermore, the exceptions listed 8.5.7.1.4.2 do not create safety from this so-called ignition hazard because PBD energies have been documented to exceed 2J.

The committee should not be implementing a provision based on a hazard contrived in a laboratory that has not been proven to present a significant risk in an industrial setting that will warrant the retrofitting of many thousands of hoses at an extremely high cost, where those funds could (and should) be spent identifying and correcting real risks in their plants.

The TCC agrees that this issue needs to be looked at further. Therefore, theprovision should be stricken until additional information is presented to prove the hazard is a risk in industry. If the TC decides to retain this provision, at a bare minimum, this provision should NOT be applied retroactively.

ResponseMessage:Public Comment No. 391-NFPA 652-2013 [Section No. 8.5.7.1.4.1]Public Comment No. 464-NFPA 652-2013 [Section No. 8.5.7.1.4]




8.5.7.3.1*Personnel Where an explosive atmosphere exists and is subject to ignition from an electrostatic discharge from ungrounded personnel, personnel involved in manually filling or emptying particulate containers or vessels, or handling open containers of combustible particulates, shall be grounded during such operations.





Committee Statement


This provision is missing an important component of the hazard—that the ungrounded person will be able to create an electrostatic ignition within the explosible dust cloud created by the operation. In many cases this is not a reasonable scenario. Further, simply carrying an open container of a combustible particulate is not sufficient grounds for requiring the earth grounding of the person carrying it.




[SR No. 85 Annex A.8.5.7.1.3]

A.8.5.7.3.1

The user should expect that activities such as pouring, unloading, and transferring dusts can lead

to the development of an ignitible atmosphere above the settled material in the receiving vessel.

Second Revision No. 86-NFPA 652-2014 [ Sections 8.5.8.1, 8.5.8.2 ]

8.5.8.1*Production, maintenance, or repair activities that can release or lift combustible dust shall not be conducted within 35 ft (11 m) of an open flame or pilot flame.8.5.8.2Fuel fired Fuel-fired space heaters drawing local ambient air shall not be located within 30 ft of equipment transporting, processing, or storing combustible dust a Class II hazardous (classified) area .



Committee Statement


Revised the distances noted for consistency, and added metric equivalent.

Response Message:Public Comment No. 474-NFPA 652-2013 [Sections 8.5.8.1, 8.5.8.2]Public Comment No. 522-NFPA 652-2013 [Section No. 8.5.8.2]




8.5.8.6In facility locations where airborne dust or dust accumulations on horizontal surfaces are apt to occur, heating units shall be provided with a source of combustion air ducted directly from the building exterior or from an unclassifiedlocation .



Committee Statement


Section 8.5.8.6 “In facility locations where airborne dust or dust accumulations on horizontal surfaces are apt to occur, heating units shall be provided with a source of combustion air ducted directly from the building exterior which comply with Section 8.5.8.2.” Consistency within the standard.





8.5.11.2Provisions Where a self-heating hazard is identified, provisions shall be in place for managing the consequences of self-heating in storage silos or bins.



Committee Statement


As written, the standard would require provisions for managing self-heating hazards whether or not they exist. The suggested change remedies this.




Second Revision No. 89-NFPA 652-2014 [ New Section after 8.6 ]

8.7 Pyrophoric Dusts. (Reserved)



Committee Statement


Pyrophoric dusts need special ignition prevention measures to be developed later. So, the Committee is approving a new "reserved" section 8.7.

ResponseMessage:Public Comment No. 541-NFPA 652-2013 [New Section after 8.6]




8.9.1 General.If an Where a dust explosion hazard exists within a building, an enclosure, orprocess system, measures shall be taken as specified in Section 8.9 8.8 to protect personnel from the consequences of an explosion a deflagration in that enclosure .



Committee Statement


revised wording to be more consistent witht eh definitions of terms in Chapter 3





8.9.3.1* General.Where an explosion hazard exists within an any operating enclosure equipmentgreater than 8 ft3 (0.23 m) of containing volume, the enclosure equipment shall beprotected from the effects of a deflagration.



Committee Statement


The Committee modified this to be consistent with the use of the defined term enclosure per work of a Committee task group that reviewed this issue and made recommendations to the full committee.

ResponseMessage:




8.9.4 Equipment Isolation.8.9.4.1* General.Where a dust explosion hazard exists within any operating equipment , isolation devices shall be provided to prevent deflagration propagation between connected enclosures equipment in accordance with NFPA 69, Standard on Explosion Prevention Systems .8.9.4.2Where a dust explosion hazard exists within any operating equipment, isolation devices shall be provided to prevent deflagration propagation to any work space in accordance with NFPA 69 , Standard on Explosion Prevention Systems . The requirement of 8.9.4.1 shall not apply where all the following conditions are met:

(1) The material being conveyed is not a metal dust or hybrid mixture.

(2) The connecting ductwork is smaller than 4 in. (100 mm) nominal diameter.

(3) The maximum concentration of dust conveyed through the duct is less than 25 percent of the MEC of the material.

(4) The conveying velocity is sufficient to prevent accumulation of combustible dust in the duct.

(5) All connected equipment is properly designed for explosion protection by means other than deflagration pressure containment.

8.9.4.3Where a dust explosion hazard exists within any operating equipment, isolation devices shall be provided when recycling enclosure exhaust to building interiors to prevent deflagration propagation and transmission of energy from a fire or explosion in accordance with NFPA 69 , Standard on Explosion PreventionSystems . Isolation devices shall not be required where oxidant concentration has been reduced or where the dust has been rendered noncombustible in accordance with 8.9.3.2(1) or 8.9.3.2(6) .8.9.4.4* Isolation of Upstream Work Areas.Isolation devices shall be provided when recycling enclosure exhaust Where a dust explosion hazard exists, isolation devices shall be provided to building interiors to prevent deflagration propagation and transmission of energy from a fire or explosion from equipment through upstream ductwork to the work areas in accordance with NFPA 69, Standard on Explosion Prevention Systems .


File Name DescriptionA.8.8.4.4_SR_113_edited.docx A.8.8.4.4 (SR 113) edited 8/5/14




Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Thu Jul 17 11:12:02 EDT 2014

Committee Statement


CC NOTE: The following CC Note No. 7 appeared in the First Draft Report as First Revision No. 244 and also related to Public Input No. 326.

The Correlating Committee requests that the TC review the requirement in this paragraph. The TC should consider the ease of ignition of the particulate, the presence of credible ignition sources, and address the practicality of implementation and the basis for application to every installation. Examples of “enclosures” found in facilities where isolation could be impractical include: mechanical conveyors, such as screw conveyors, spouting. The CC notes that requirements in NFPA 654 and 664 might provide some guidance to the TC as they consider this request.

The Committee has used requirements from NFPA 654 as suggested by the Correlating Committee. This SR addresses a number of other Public Comments to revised these requirements.

ResponseMessage:Public Comment No. 160-NFPA 652-2013 [Section No. 8.8.4.4]Public Comment No. 392-NFPA 652-2013 [Section No. 8.8.4]Public Comment No. 434-NFPA 652-2013 [Section No. 8.8.4.3]Public Comment No. 436-NFPA 652-2013 [Section No. 8.8.4.4]Public Comment No. 507-NFPA 652-2013 [Section No. 8.8.4.4]Public Comment No. 537-NFPA 652-2013 [Section No. 8.8.4.2]



[SR No. 113 Annex A.8.8.4.4]

A.8.8.4.4

Exposures of concern include, but are not limited to, bagging operations and hand-dumping

operations where the discharge of a fireball from the pickup point endangers personnel. A

common example for the application of such isolation would be in the upstream ductwork

associated with a dust collection system servicing a work area. Loading chutes less than 10 ft (3

m) in length and designed for gravity flow are not considered ductwork. Common design factors

that can reduce the risk of explosion propagation include the following:

(1) The material being conveyed is not a metal dust or hybrid mixture.

(2) The connecting ductwork is smaller than 4 in. (0.1 m) in diameter.

(3) The maximum concentration of dust conveyed through the duct is less than 25 percent of the

MEC of the material.

(4) The conveying velocity is high enough to prevent accumulation of combustible dust in any

portion of the duct.

(5) The air-material separator is properly designed for explosion protection by means other than

explosion containment.

(6) The upstream work areas do not contain large quantities of dust that can be entrained by a

pressure pulse from an explosion in the air-material separator.


8.10.1.1Where a fire hazard exists in a building or operating an enclosure as determined in Chapter 7, manual or automatic fire protection means shall be provided in accordance with Section 8.10 .



Committee Statement


Use consistent language for enclosure, building or building compartment.

Response Message:




8.10.1.2*Automatic fire protection systems shall be provided when at least one of the following conditions exists:

(1)

(2)

(3) They Automatic fire protection systems are required by the local building code adopted by the authority having jurisdiction AHJ .



Committee Statement

Committee Statement: Eliminates potential ambiguity with the work "They" Response Message:Public Comment No. 509-NFPA 652-2013 [Section No. 8.9.1.2]

* Manual fire-fighting fire fighting poses an unacceptable risk to facility personnel and emergency responders.

* Manual fire-fighting fire fighting is not expected to be effective for a fire hazard assessed in accordance with Chapter 7.




9.4.2The inspection, testing, and maintenance program shall include the following:

(1) Fire and explosion protection and prevention equipment in accordance with the applicable NFPA standards

(2) Dust control equipment

(3) Housekeeping(4) Potential ignition sources

(5)

(6) Process changes

(7) Lubrication of bearings


File Name DescriptionA.9.4.2_5_SR_50_edited.docx


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Tue Apr 15 11:06:36 EDT 2014

Committee Statement

CommitteeStatement:

All the equipment listed is important to protecting the workplace from combustible dust deflagrations. Dust control equipment systems are critical to minimizing fugitive dust accumulations but a very common gap today is lack of commissioning or proof of performance at new system startup or after system modifications. There have been incidents where the failure of the dust control system contributed to the severity of the incident. NFPA 91 has clear direction in Section 10.3 to confirm local exhaust ventilation systems (dust control systems are one example) performance over its lifetime. A clear reference to the types of equipment covered by inspection, testing, and maintenance and the expectations for dust control systems will greatly improve control of fugitive dust over the long haul.

Response Message:

* Electrical, process, and mechanical equipment, including process interlocks



Public Comment No. 518-NFPA 652-2013 [New Section after 9.4.1]



[SR No. 50 Annex A.9.4.2 (5)]

[Annex A.9.4.2 (5) take from NFPA 654, A.12.1.2 (5)]

A.9.4.2

Process interlocks should be calibrated and tested in the manner in which they are intended to

operate, with written test records maintained for review by management. Testing frequency

should be determined in accordance with the AIChE Guidelines for Safe Automation of Chemical

Processes. [654:A.12.1.2(5)]




9.5.3Refresher training shall be provided as required by the authority havingjurisdiction AHJ and as required by other relevant industry- or commodity-specific NFPA standards. (See 1.3.1 .)


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Thu Apr 24 10:31:46 EDT 2014

Committee Statement

CommitteeStatement:

Section 1.3.1 does not contain relevant information as it is currently written.





9.6.2*Only qualified contractors shall be employed for work involving the installation, repair, or modification of buildings (interior and exterior), machinery, and fire protection and explosion protection equipment that could adversely affect the prevention, control, or mitigation of fires and explosions.


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Mon Apr 28 08:17:38 EDT 2014

Committee Statement

CommitteeStatement:

This requirement should also apply to explosion protection equipment

Response Message:Public Comment No. 161-NFPA 652-2013 [Section No. 9.6.2]Public Comment No. 510-NFPA 652-2013 [Section No. 9.6.2]




9.6.3.3*Contractors working on or near a given process shall be made aware of the potential hazards from and exposures to fire, explosion, or toxic releases fires and explosions .


File Name DescriptionA.9.6.3.3_SR_53_edited.docx A.9.6.3.3 (SR 53) edited 8/6/14



Committee Statement

Committee Statement: This document does not cover toxic releases.Response Message:Public Comment No. 233-NFPA 652-2013 [Section No. 9.6.3.3]



[SR No. 53 Annex A.9.6.3.3]

A.9.6.3.3 In addition to the combustible dust fire and explosion hazards, contractors should also

be made aware of other potential process and occupational hazards. There can be other

combustible materials other than, besides the combustible dusts, in the equipment or immediate

vicinity where contractors might be working. Combustion of dusts can generate toxic products,

and some combustible dusts are acutely toxic.


9.7.1*A written emergency response plan shall be developed for preventing, preparing for, for preparing for and responding to work-related emergencies including, but not limited to, fire and explosion.



Committee Statement

CommitteeStatement:

An emergency response plan is designed for response not prevention of fires and explosions. The facility's Fire/Explosion Prevention Plan is designed and developed to communicate the appropriate information to prevent an incident from occurring. By leaving the word "preventing" in this section would require the inclusion of the Fire/Explosion Prevention Plan to be incorporated into the Emergency Response Plan.





9.8.1*The owner/operator shall have a system to ensure that every incident incidents thatresults result in a fire, deflagration, or explosion is are reported and investigated in a timely manner.


File Name DescriptionA.9.8.1_SR_61_edited.docx A.9.8.1 (SR 61) edited 8/6/14


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocStreet Address:City: State: Zip:Submittal Date: Mon May 05 15:51:56 EDT 2014

Committee Statement

CommitteeStatement:

Deleted the word 'every'. The owner needs to have a system in place to process incidents and investigations. Which incidents get entered could depend on severity and may not include every incident. Added comments to Annex material to include the concept of near-miss and how including near-miss reporting into an investigation program can strengthen the overall incident investigation program.




A.9.8.1

Events where there are injuries, equipment damage, or significant business interruption are

subject to investigation.

In addition to investigation of fires and explosions, it is also a good practice to investigate near

misses (events that reasonably could have resulted in fires or explosions under different

circumstances) andas well as all activations of active fire and explosion mitigation systems. It is

important to educate facility personnel on the concept of what a near -miss is and to clearly

communicate their responsibility for reporting both incidents and near -misses.

These Near-miss events often indicate an underlying problem that should be corrected. See

NFPA 654, Standard for the Prevention of Fire and Dust Explosions from Manufacturing,

Processing, and Handling of Combustible Particulate Solids, for additional information. Barriers

to reporting should be removed, as described in ANSI/AIHA Z10-2012, Occupational Health

and Safety Management Systems. Investigations should include workers and their

representatives, as appropriate


9.9.2The procedures shall ensure that the following are addressed prior to any change:

(1)

(2)

(3) Whether the change is permanent or temporary, including the authorized duration of temporary changes

(4) Modifications to operating and maintenance procedures

(5) Employee training requirements

(6) Authorization requirements for the proposed change

(7) Results of characterization tests used to assess the hazard, if conducted


File Name DescriptionA.9.9.2_1_SR_55_edited.docx A.9.9.2(1) (SR 55) edited 8/6/14



Committee Statement

* The technical basis for the proposed change

* Safety and health implications



CommitteeStatement:

The first numbered item “(1) The technical basis for the proposed change,” should be struck. Persons experienced with the way that a parallel requirement in OSHA’s PSM Standard has been implemented inform us that, because the phrase has no apparent meaning or relation to safety, employers do not know what this phrase requires of them. Some think that it requires a statement of the purpose of the change (such as “environmental compliance” or “equipment reliability”) but such a statement is unrelated to safety and does not enhance the quality of the MOC procedure. More importantly, the phrase “safety and health implications” in clause (2) adequately covers whatever point clause (1) is trying to make.

We also question whether this provision is too elaborate to be imposed on every facility with combustible dust. It should be struck in its entirety or simplified.

The annex added shows examples of hazards not limited to fire and explosions that are also to be considered.

ResponseMessage:Public Comment No. 99-NFPA 652-2013 [Section No. 9.9.2]Public Comment No. 228-NFPA 652-2013 [Section No. 9.9.2]Public Comment No. 489-NFPA 652-2013 [Section No. 9.9.2]Public Comment No. 618-NFPA 652-2013 [Section No. 9.9.2]



[SR No. 55 Annex A.9.9.2 (1)]

A.9.9.2 (1)

The basis should describe Tthe proposed change and why it is needed should be described. It

should include sufficient technical information to facilitate review by the approvers, address

adverse effects that could occur, and describe how such effects would be mitigated by the

proposed change.


9.10.1The owner/operator shall establish a program and implement a process to manage the retention of documentation, including, but not limited to, the following:

(1) Training records

(2) Equipment inspection, testing, and maintenance records

(3)(4) Process Dust hazards analyses

(5)

(6)

(7) Emergency response plan documents

(8)


File Name DescriptionA.9.10.1_5_SR_136_edited.docx A.9.101(5) (SR 136) edited 8/6/14



Committee Statement

CommitteeStatement:

Substantiation : The meaning of the phrase “process and technology information” is unclear and the suggested change provides clarification. It is important to have a required retention period for these documents so that they will be available to the operator of the facility on an ongoing basis as needed to ensure controls remain in place and remain effective.


* Incident investigation reports

* Process and technology information

* Management of change documents

* Contractor records



[SR No. 63 Annex A.9.10.1 (5)]

Process and technology information includes process performance parameters, properties of the

materials being handled, and documents such as design drawings, design codes and standards

used as the basis for both the process and the equipment, equipment manufacturers’ operating

and maintenance manuals, standard operating procedures, and safety systems operation.


9.11.1The owner/operator shall evaluate the effectiveness of the management systems presented in this standard by conducting a periodic review of each managementsystem.



Committee Statement

CommitteeStatement:

The requirement should establish that periodic reviews are required for on-going monitoring of the management systems elements. The committee added a frequency but does not agree with the 3 years proposed in PC 101 or 231 and prefers to leave it to be based on conditions.





9.12* Employee Participation.Owner/operators shall establish and implement a system to ensure effective participation of consult with and actively involve affected personnel and their representatives in the implementation of this standard.



Committee Statement

CommitteeStatement:

We question whether this provision should be in an NFPA technical standard. It should be struck or at best placed in the annex.

There is also a problem with the wording of the draft provision. As the provision is now written, an AHJ might think that the duty to “ensure” the “participation” of employees in the “implementation of this standard” literally gives employees a say in the running of the owner’s business. OSHA has always been careful when drafting employee-participation provisions to avoid wording them so as to suggest intrusions into management or property rights. If the provision is not struck or moved to the annex, it should be re-worded as shown above.




Second Revision No. 64-NFPA 652-2014 [ Section No. A.3.3.11 ]

A.3.3.13 Dust.The terms particulate solid, dust, and fines are interrelated. It is important torecognize that while these terms refer to various size thresholds or ranges, most particulate solids are composed of a range of particle sizes making comparison to a size threshold difficult. For example, a bulk material that is classified as a particulate solid could contain a significant fraction of dust as part of the particle size distribution.

While hazards of bulk material are addressed in this document using the provisions related to particulate solids, it might be necessary to apply the portions of the document relating to dust where there is potential for segregation of the material and accumulation of only the fraction of the material that fits the definition of dust. Furthermore, it is difficult to establish a fractional cutoff for the size threshold, such as 10 percent below the threshold size or median particle size below the threshold size, as the behavior of the material depends on many factors including the nature of the process, the dispersibility of the dust, and the shape of the particles.

For the purposes of this document, the term particulate solid does not include an upper size limitation. This is intended to encompass all materials handled as particulates, including golf balls, pellets, wood chunks and chips, etc.

The term particulate solid is intended to include those materials that are typically processed using bulk material handling techniques such as silo storage, pneumatic or mechanical transfer, etc. While particulate solids can present a fire hazard, they are unlikely to present a dust deflagration hazard unless they contain a significant fraction of dust, which can segregate and accumulate within the process or facility.

Dusts traditionally were defined as material 420 μm or smaller (capable of passing through a U.S. No. 40 standard sieve). For consistency with other standards, 500 μm (capable of passing through a U.S. No. 35 standard sieve) is now considered an appropriate size criterion. Particle surface area–to-volume ratio is a key factor in determining the rate of combustion. Combustible particulate solids with a minimum dimension more than 500 μm generally have a surface-to-volume ratio that is too small to pose a deflagration hazard. Flat platelet-shaped particles, flakes, or fibers with lengths that are large compared to their diameters usually do not pass through a 500 μm sieve, yet could still pose a deflagration hazard. Many particulates accumulate electrostatic charges in handling, causing them to attract each other, forming agglomerates. Often, agglomerates behave as if they were larger particles, yet when they are dispersed they present a significant hazard. Consequently, it can be inferred that any particulate that has a minimum dimension less than or equal to 500 μm could behave as a combustible dust if suspended in air or the process specific oxidizer. If the minimum dimension of the particulate is greater than 500 μm, it is unlikely that the material would be a combustible dust, as determined by test.

Typically, the term fines refers to the fraction of material that is below 75 μm or that will pass through a 200-mesh sieve. Alternately, fines can be characterized as the material collected from the final dust collector in a process or the material collected from the highest overhead surfaces in a facility. Fines typically represent a greater deflagration hazard than typical dusts of the same composition becausethey are more likely to remain suspended for an extended period of time and tohave more severe explosion properties (higher K st , lower MIE, etc.).





Committee Statement

CommitteeStatement:

The definition in the main document has been proposed The extensive Annex material provides little clarification and duplicates other annex material related to combustible dust. The Committee is deleting it as recommended by the PC as the definition has been deleted through a separate action. The Committee intends to retain the annex and move it to become annex to the definition for combustible particulate solid (3.3.6).

ResponseMessage:Public Comment No. 341-NFPA 652-2013 [Section No. A.3.3.11]




A.3.3.20 Flash Fire.A flash fire requires an ignition source and a hydrocarbon or an atmosphere containing combustible a flammable gas, a flammable vapor , or finely divided combustible particles (e.g., coal dust or grain) having a concentration greater than the lower explosive limit of the chemical. Both hydrocarbon sufficient to allow flame propagation. Flammable gas, flammable vapor, and dust flash fires typically generate temperatures from 1000°F to 1900°F ( 538°C to 1038°C (1000°F to 1900°F) ) . The extent and intensity of a flash fire depends depend on the size and concentration of the gas, vapor, or dust cloud. When ignited, the flame frontexpands outward in the form of a fireball. The resulting effect of the fireball’s energy with respect to radiant heat significantly enlarges the hazard areas around the point of ignition.



Committee Statement

CommitteeStatement:

The proposed revisions avoids the use of the term "lower explosive limit" which NFPA does not apply to either flammable vapors or combustible dusts.

Response Message:Public Comment No. 163-NFPA 652-2013 [Section No. A.3.3.18]




A.3.3.26 Industry- or Commodity-Specific NFPA Standard.It is possible that within a single building or enclosure, more than one industry- or commodity-specific NFPA standard could apply. The following documents are commonly recongized recognized as commodity-specific standards:

(1) NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities

(2) NFPA 120, Standard for the Fire Prevention and Control in Coal Mines

(3) NFPA 484, Standard for Combustible Metals

(4) NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Dusts Particulate Solids

(5) NFPA 655, Standard for Preventing Prevention of Sulfur Fires and Explosions

(6) NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities



Committee Statement

Committee Statement: Corrected typo in "recognized".Response Message:




A.3.3.34 Risk Assessment.A risk assessment is a process that performs the following:

(1) Identifies hazards

(2) Quantifies the consequences and probabilities of the identified hazards

(3) Identifies hazard control options(4) Quantifies the effects of the options on the risks of the hazards

(5) Establishes risk acceptability thresholds (minimum acceptable tolerance criteria (maximum tolerable levels of risk)

(6) Selects the appropriate control options that meet or exceed the risk acceptability thresholds

Steps 1 through 3 are typically performed as part of a process hazardsanalysis dust hazards analysis (DHA) .Risk assessments can be qualitative, semi-quantitative semiquantitative , orquantitative. Qualitative methods are usually used to identify the most hazardous events. Semi-quantitative Semiquantitative methods are used to determine relative hazards associated with unwanted events and are typified by indexing methods or numerical grading. Quantitative methods are the most extensive and use a probabilistic approach to quantify the risk based on both frequency and consequences.

See SFPE Engineering Guide to Fire Risk Assessment or AIChE Center for Process Safety, Guidelines for Hazard Evaluation Procedures for moreinformation.



Committee Statement

CommitteeStatement:

"Risk tolerance" is the term preferred by risk practitioners (as opposed to "risk acceptance").

In any event... the criteria establish the maximum levels of risk, not the minimum.

ResponseMessage:



Public Comment No. 164-NFPA 652-2013 [Section No. A.3.3.30]




A.5.2.2This is Such an assessment is to determine whether the dust is a combustible dust and if further assessment is necessary. Data can be from samples within the facility that have been tested or data can be based on whether the material is known to be combustible or not. There are some published data of commonly known materials, and the use of this these data is adequate to determine whether the dust is a combustible dust. For well-known commodities, published data are usually acceptable. Generally, such data can be considered conservative if they are obtained from a reliable source, such as other NFPA documents. A perusal of published data illuminates that there is often a significant spread in values. It is useful, therefore, to compare attributes (such as particle distribution and moisture content) for in published data with the actual material being handled in the system whenever possible. Doing so would help to verify that the data are pertinent to the hazard under assessment.

This section Subsection 5.2.2 does not require the user to know all these items for the assessment but to review ; rather, it reviews the important items in order to determine whether the material data are representative of the material in the facility. Even test data of material can be different from the actual conditions. The users Users should review the conditions of the test method as well to ensure that it is representative of the conditions of the facility. When Where that is not possible, the use of the worst-case values should be selected.

Composition and particle size are two parameters that are useful to identify the number and location of representative samples to be collected and tested. (See Section 5.5 for information on sampling.)

Refer to Tables A.5.2.2(a) through A.5.2.2(k) for guidance only and not as substitutes for actual test data. These tables are not all- inclusive of all combustible dusts and noncombustible dusts. Additionally, material properties and testing methods can provide varied results than that vary from those presented in these tables.

Table A.5.2.2(a) 20-L Sphere Test Data – Agricultural Dusts



Dust NamePmax(bar g)

(1)KSt(bar

m/sec)

PercentMoisture

Particle Size(μm)

MinimumExplosiveConcentration

(g/m3)

Percent Greater

Than 200

MeshAlfalfa 6.7 94 2.1 36Apple 6.7 34 155 125Beet root 6.1 30 108 125Carrageen 8.5 140 3.8 98Carrot 6.9 65 29Cocoa bean dust 7.5 152

Cocoa powder 7.3 128

Coconut shell dust 6.8 111 6.5 51

Coffee dust 6.9 55 4.8 321Corn meal 6.2 47 8.2 403Cornstarch 7.8 163 11.2Cotton 7.2 24 44 100Cottonseed 7.7 35 245 125Garlic powder 8.6 164

Gluten 7.7 110 150 125Grass dust 8.0 47 200 125Green coffee 7.8 116 5.0 45

Hops(malted) 8.2 90 490

Lemon peel dust 6.8 125 9.5 38

Lemon pulp 6.7 74 2.8 180Linseed 6.0 17 300Locust bean gum 7.8 78 1.7 53

Malt 7.5 170 10.5 72Oat flour 6.4 81 8.6Oat grain dust 6.0 14 295 750

Olive pellets 10.4 74 125Onion powder 9.0 157

Parlsey (dehydrated) 7.5 110 5.4 26

Peach 8.4 81 140 60Peanut meal and skins 6.4 45 3.8



Dust NamePmax(bar g)

(1)KSt(bar

m/sec)

PercentMoisture

Particle Size(μm)

MinimumExplosiveConcentration

(g/m3)

Percent Greater

Than 200

MeshPeat 8.3 51 74 125Potato 6.0 20 82 250Potato flour 9.1 69 65 125Potato starch 9.4 89 32

Raw yucca seed dust 6.2 65 12.7 403

Rice dust 7.7 118 2.5 4Rice flour 7.4 57 60Rice starch 10.0 190 18 90Rye flour 8.9 79 29Semolina 7.6 79 9Soybean dust 7.5 125 2.1 59

Spice dust 6.9 65 10.0Spice powder 7.8 172 10.0

Sugar (10×) 8.4 154Sunflower 7.9 44 420 125Tea 7.6 102 6.3 77 125Tobacco blend 8.8 124 1.0 120

Tomato 200 100Walnut dust 8.4 174 6.0 31Wheat flour 8.3 87 12.9 57 60 6Wheat grain dust 9.3 112 80 60

Wheat starch 9.8 132 20 60

Xanthan gum 7.5 61 8.6 45

Notes:

(1) Normalized to l m3 test vessel pressures, per ASTM E1226, Standard Test Method for Explosibility of Dust Clouds.)

(2) See also Table F.1(a) in NFPA 68, Standard on Explosion Protection by Deflagration Venting, for additional information on agricultural dusts with known explosion hazards.

(3) For those agricultural dusts without known explosion data, the dust should be tested in accordance with ASTM E1226, Standard Test Method for Explosibility of Dust Clouds.

© 1995 FM Global. Reprinted with permission. All rights reserved.© 1995 FM Global. Reprinted with permission. All rights reserved.



[61:Table A.6.2.1]

Table A.5.2.2(b) 1 m3 Vessel Test Data from Forschungsbericht Staubexposionen – Agricultural Dusts

MaterialMass Median Diameter (μm)

MinimumFlammable

Concentration(g/m3)

Pmax(bar)

KSt(bar-m/s)

Dust HazardClass

Cellulose 33 60 9.7 229 2Cellulosepulp 42 30 9.9 62 1

Cork 42 30 9.6 202 2Corn 28 60 9.4 75 1Egg white 17 125 8.3 38 1Milk,powdered 83 60 5.8 28 1

Milk, nonfat, dry 60 — 8.8 125 1

Soy flour 20 200 9.2 110 1Starch, corn 7 — 10.3 202 2Starch, rice 18 60 9.2 101 1Starch,wheat 22 30 9.9 115 1

Sugar 30 200 8.5 138 1Sugar, milk 27 60 8.3 82 1Sugar, beet 29 60 8.2 59 1Tapioca 22 125 9.4 62 1Whey 41 125 9.8 140 1Wood flour 29 — 10.5 205 2

[68:Table F.1(a)]

Table A.5.2.2(c) 1 m3 Vessel Test Data from Forschungsbericht Staubexposionen – Carbonaceous Dusts



Material Mass Median Diameter (μm)

MinimumFlammable

Concentration(g/m3)

Pmax(bar)

KSt(bar-m/s)

Dust Hazard Class

Charcoal, activated 28 60 7.7 14 1

Charcoal, wood 14 60 9.0 10 1

Coal,bituminous 24 60 9.2 129 1

Coke,petroleum 15 125 7.6 47 1

Lampblack <10 60 8.4 121 1Lignite 32 60 10.0 151 1Peat, 22%H2O — 125 84.0 67 1

Soot, pine <10 — 7.9 26 1

[68:Table F.1(b)]

Table A.5.2.2(d) 1 m3 Vessel Test Data from Forschungsbericht Staubexposionen – Chemical Dusts


MinimumFlammable

Concentration(g/m3)

Pmax(bar)

KSt(bar-m/s)

Dust Hazard Class

Adipic acid <10 60 8.0 97 1Anthraquinone <10 — 10.6 364 3Ascorbic acid 39 60 9.0 111 1Calcium acetate 92 500 5.2 9 1Calcium acetate 85 250 6.5 21 1Calcium stearate 12 30 9.1 132 1Carboxy- methyl-cellulose 24 125 9.2 136 1

Dextrin 41 60 8.8 106 1Lactose 23 60 7.7 81 1Lead stearate 12 30 9.2 152 1Methyl-cellulose 75 60 9.5 134 1Paraformaldehyde 23 60 9.9 178 1Sodium ascorbate 23 60 8.4 119 1Sodium stearate 22 30 8.8 123 1Sulfur 20 30 6.8 151 1

[68:Table F.1(c)]

Table A.5.2.2(e) 1 m3 Vessel Test Data from Forschungsbericht Staubexposionen – Metal Dusts




MinimumFlammable

Concentration(g/m3)

Pmax(bar)

KSt(bar-m/s)

Dust Hazard Class

Aluminum 29 30 12.4 415 3Bronze 18 750 4.1 31 1Iron carbonyl <10 125 6.1 111 1Magnesium 28 30 17.5 508 3Phenolicresin 55 — 7.9 269 2

Zinc 10 250 6.7 125 1Zinc <10 125 7.3 176 1

[68:Table F.1(d)]

Table A.5.2.2(f) 1 m3 Vessel Test Data from Forschungsbericht Staubexposionen (except where noted) – Plastic Dusts



MaterialMass

Median Diameter

(μm)

MinimumFlammable

Concentration(g/m3)

Pmax(bar)

KSt(bar-m/s)

Dust Hazard Class

(poly) Acrylamide 10 250 5.9 12 1(poly) Acrylonitrile 25 — 8.5 121 1(poly) Ethylene (low-pressure process) <10 30 8.0 156 1

Epoxy resin 26 30 7.9 129 1Melamine resin 18 125 10.2 110 1Melamine, molded (wood flour and mineral filled phenol-formaldehyde)

15 60 7.5 41 1

Melamine, molded (phenol-cellulose) 12 60 10.0 127 1

(poly) Methyl acrylate 21 30 9.4 269 2(poly) Methyl acrylate, emulsion polymer 18 30 10.1 202 2

Phenolic resin <10 15 9.3 129 155 7.9 269 2

(poly) Propylene 25 30 8.4 101 1Terpene-phenol resin 10 15 8.7 143 1Urea-formaldehyde/ cellulose, molded 13 60 10.2 136 1

(poly) Vinyl acetate/ ethylene copolymer 32 30 8.6 119 1

(poly) Vinyl alcohol 26 60 8.9 128 1(poly) Vinyl butyral 65 30 8.9 147 1(poly) Vinyl chloride 107 200 7.6 46 1(poly) Vinyl chloride/vinyl acetylene emulsion copolymer

35 60 8.2 95 1

(poly) Vinyl chloride/ethylene/vinyl acetylene suspension copolymer

60 60 8.3 98 1

[68:Table F.1(e)]

Table A.5.2.2(g) 20 L and 1 m 3 Vessel Test Data, PVC and Copolymer PlasticResins and Dusts



PVC Resin Sample

GP a

DispersionVA b

Copolymer

Baghouse Dust from GP Pipe

(asreceived)

GP Pipe

Resinc

Baghouse Dust from GP Pipe

(asreceived)

GP Pipe Resin (as received)

High Molecula

Weight Resin (asreceived)

Type of polymerizationprocess

Emulsion Suspension

Plantdesignator

A B C C D D E

Test lab Chilworth Chilworth Chilworth Fike Chilworth Chilworth (20 L), Fike (1 m 3 )

Fike

Minimum Ignition Energy (MIE), Joules

>10 J >10 J >500 mJ >4653 mJ

>10 J >10 J >4468 mJ

Explosionseverity, K St(bar-m/s), 20 L test chamber

91 68 84 18 54 9 81

Dust explosion class in 20 L test chamber

ST 1 ST 1 ST 1 ST 1 ST 1 ST 1 ST 1

Explosionseverity, K St(bar-m/s), 1 m 3 test chamber

Not tested Not tested Not tested 0 Not tested 0 0

Dust explosion class in 1 m 3

test chamber

Not tested Not tested Not tested ST 0 Not tested ST 0 ST 0

Particle size, avg. (µm)

1 (est.) N.A. N.A. 162 N.A. 158 128

Dust fraction (<75 µm, %)

100 100 100 0.1 97 0 0.6

Note: Sponsored by the Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314.a GP: General Purposeb VA: Vinyl Acetatec Date for MIE and 20 L test were performed by Fike on sample screened to <150 µm and data for 1 m 3 tests were performed by Fike on ‘as received’ sample.

Source: Krock, R., et. al., “OSHA’s Combustible Dust National Emphasis Program and Combustibility Characteristics Testing of PVC Resins and PVC Dusts”, SPE ANTEC, April, 2012.

Table A.5.2.2(h) Explosibility Properties of Metals



MaterialMedian

Diameter(μm)

Kst

(bar-m/s)

Pmax

(bar g)

Cloud Ign

Temp (°C)

MIE(mJ)

MEC(g/m3)

UN Combustibility

Category2LOC1

(v%)Data

Source

Aluminum ~7 — 8 — — 90Cashdollar

& Zlochower4

Aluminum 22 — — — — — — 5 (N) BGIA3

Aluminum <44 — 5.8 650 50 45 2 ( C) BuMines RI6516

Aluminumflake <44 6.1 650 20 45 <3

( C)BuMines RI

6516Aluminum <10 515 11.2 560 — 60 — — BGIA3

Aluminum 580 NotIgnited — — — — — — BGIA

Beryllium 4 NotIgnited — — — — — — BuMines RI

6516

Boron <44 — — 470 60 <100 — — BuMines RI 6516

Boron ~3 — 6.0 ≈110Cashdollar

& Zlochower

Bronze 18 31 4.1 390 — 750 BZ 4 Eckhoff

Chromium 6 — 3.3 660 5120 770 14 ( C)

BuMines RI 6516

Chromium 3 — 3.9 580 140 230 — — BuMines RI 6517

Copper ~30 NotIgnited

Cashdollar &

Zlochower

Hafnium ~8 — 4.2 — — ~180 — —Cashdollar

& Zlochower

Iron 12 50 5.2 580 500 — Eckhoff

Iron ~45 — 2.1 — — ~500 — —Cashdollar

& Zlochower

Iron < 44 — 2.8 430 80 170 — 13 ( C)

BuMines RI6516

Iron,carbonyl < 10 111 6.1 310 125 BZ 3 Eckhoff

Manganese < 44 — — 460 305 125 — BuMines RI 6516

Manganese(electrolytic) 16 157 6.3 330 — — — — Eckhoff

Manganese(electrolytic) 33 69 6.6 — — — — — Eckhoff

Magnesium 28 508 17.5 — — — — EckhoffMagnesium 240 12 7 760 500 BZ 5 Eckhoff

Magnesium <44 — — 620 40 40 — BuMines RI 6516



MaterialMedian

Diameter(μm)

Kst

(bar-m/s)

Pmax

(bar g)

Cloud Ign

Temp (°C)

MIE(mJ)

MEC(g/m3)

UN Combustibility

Category2LOC1

(v%)Data

Source

Magnesium <44 — 600 240 30 — <3( C)

BuMines RI6516

Magnesium ~16 — 7.5 — — 55 — —Cashdollar

& Zlochower

Molybdenum <10 Not Ignited Eckhoff

Nickel ~6 NotIgnited

Cashdollar &

ZlochowerNiobium 80 238 6.3 560 3 70 6 (Ar) IndustryNiobium 70 326 7.1 591 3 50 5 (Ar) IndustrySilicon <10 126 10.2 >850 54 125 BZ 3 EckhoffSilicon, from dust collector

16 100 9.4 800 — 60 — Eckhoff

Silicon, from filter <10 116 9.5 >850 250 60 BZ 1 Eckhoff

Tantalum <44 — — 630 120 <200 3 (Ar) BuMines RI6516

Tantalum ~10 ≈3 ≈400Cashdollar

& Zlochower

Tantalum 100 149 6.0 460 <3 160 2 (Ar) IndustryTantalum 80 97 3.7 540 <3 160 2(Ar) IndustryTantalum 50 108 5.5 520 <3 160 2(Ar) IndustryTantalum 65 129 5.8 460 <3 160 2(Ar) IndustryTantalum 21 5.6 430 <3 125 <2(Ar) IndustryTantalum 25 400 >1<3 30 <2(Ar) Industry

Tin ~8 — 3.3 — — ~450 — —Cashdollar

& Zlochower

Titanium 36 Not Ignited BZ 2 BGIA

Titanium 30 — — 450 — — — Eckhof

Titanium ~25 4.7 — — 70 —Cashdollar

& Zlochower

Titanium 10 — 4.8 330 25 45 6 (N) 4 (Ar)

BuMines RI 6515

Tungsten ≤1 — ~2.3 — — ~700 — —Cashdollar

& Zlochower

Tungsten ~10 Not Ignited

Cashdollar &

Zlochower



MaterialMedian

Diameter(μm)

Kst

(bar-m/s)

Pmax

(bar g)

Cloud Ign

Temp (°C)

MIE(mJ)

MEC(g/m3)

UN Combustibility

Category2LOC1

(v%)Data

Source

Zinc (from collector) <10 125 6.7 570 — 250 BZ 3 Eckhoff

Zinc (from collector) 10 176 7.3 — — 125 BZ 2 Eckhoff

Zinc (from Zn coating) 19 85 6 800 — — BZ 2 Eckhoff

Zinc (from Zn coating) 21 93 6.8 790 — 250 — Eckhoff

Zirconium <44 — 5.2 20 5 45 —Ignites in N2

& CO2

BuMines RI 6516

Zirconium (Zircalloy-2) 50 — 3.0 420 30 — — — BuMines RI

6516

(1) Limiting Oxygen Concentration. The letter in parenthesis in the LOC column denotes the inert gas used to reduce the oxygen concentration as follows: Ar = argon, C = carbon dioxide, N = nitrogen

(2) UN Dust Layer Combustibility Categories are as follows: UN Dust LayerCombustibility Categories are as follows:

BZ1 No self-sustained combustion;BZ2 Local combustion of short duration;

BZ3 Local sustained combustion, but no propagation;

BZ4 Propagating smoldering combustion;

BZ5 Propagating open flame;

BZ6 Explosive combustion.

(3) BGIA is the GESTIS-DUST-EX database maintained by BGIA-online.hvbg.de

(4) Cashdollar, Kenneth, and Zlochower, Isaac,“Explosion Temperatures and Pressures of Metals and Other Elemental Dust Clouds,” J. Loss Prevention in the Process Industries, v 20, 2007.

[484:Table A.1.1.3(b)]

Table A.5.2.2(i) Atomized Aluminum Particle Ignition and Explosion Data



Particle Size(d50)(μm)

BET(m2/g)

MEC(g/m3)

Pmax

(psi)dP/dtmax

(psi/sec)KSt

(bar·m/sec)

SampleConcentrationThat

Correspondsto Pmax

anddP/dtmaxMIE (mJ) LOC (%)

Ign

Nonspherical, Nodular, or Irregular Powders53 0.18 170 123 3,130 59 1,250

42 0.19 70 133 5,720 107 1,250 (Pmax), 1,000(dP/dtmax)

32 0.34 60 142 7,950 149 1,250 10

32 0.58 65 133 8,880 167 750 (Pmax), 1,500 (dP/dtmax)

11

Ignition @ 8.0%

Nonignition @ 7.5%

30 0.10 60 10

28 0.11 55 140 6,360 119 1,000 (Pmax), 1,250(dP/dtmax)

11

28 0.21 55 146 8,374 157 1,500 11

9 0.90 65 165 15,370 288750 (Pmax), 1,000

(dP/dtmax) 4

7 0.74 90 153 17,702 332 1,000 (Pmax), 500(dP/dtmax)

12

6 0.15 80 176 15,580 292 750 3.5

6 0.70 75 174 15,690 294 500 (Pmax), 1,000 (dP/dtmax)

3

5 1.00 70 4

4 0.78 75 167 15,480 291 1,000 (Pmax), 750(dP/dtmax)

3.5

Spherical Powders

63 0.15 120 101 1,220 23 1,250 (Pmax), 1,000(dP/dtmax)

N.I.Ignition

@1 8.0% Nonignition

@ 7.5%36 0.25 60 124 4,770 90 1,250 1330 0.10 60 140 5,940 111 1,000 1315 0.50 45 148 10,812 203 1,000 715 0.30 55 86 0.53 75 174 16,324 306 750 6

5 1.30 167 14,310 269 750Ignition @

6.0% Nonignition

@ 5.5%

5 1.00 70 155 14,730 276 1,250 6Ignition @

6.0% Nonignition

@ 5.5%3 2.50 95 165 15,900 298 1,250 42 3.00 130



For U.S. conversions: 1 m2/g = 4884 ft2/lb; 1 g/m2 = 0.000062 lb/ft2; 1 bar/sec = 14.5 psi/sec; 1 bar·m/sec = 0.226 psi·ft/sec.

BET: surface area per unit mass; MEC: minimum explosible concentration; MIE: minimum ignition energy; LOC: limiting oxygen (O2) concentration.

Notes:

(1) The powders tested are representative samples produced by various manufacturers utilizing a variety of methods of manufacture, submitted for testing to a single, nationally recognized testing laboratory, at the same time.

(2) Data for each characteristic were obtained using the following ASTM methods: MEC: ASTM E1515, Standard Test Method for Minimum Explosible Concentration of Combustible Dusts; MIE: ASTM E2019, Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air; maximum pressure rise (Pmax), maximum pressure rise rate (dP/dt), and deflagration index (KSt): ASTM E1226, Standard Test Method for Explosibility of DustClouds; LOC: ASTM E2079, Standard Test Methods for Limiting Oxygen(Oxidant) Concentration in Gases and Vapors.

(3) Particle size data represent the d50 measurement determined by the laser light–scattering technique.

(4) Test results represent only the characteristics of those samples tested and should not be considered to be universally applicable. Users are encouraged to test samples of powders obtained from their individual process.

[484:Table A.4.3.1]

Table A.5.2.2(j) Explosion Characteristics of Unalloyed Magnesium Dust in Air ( [ 200 mesh (75μm)) ]

Explosion Characteristics Values

Explosibility indexa 10 KSt

Ignition sensitivityb 3.0 KSt

Explosion severityc 7.4 KSt

Maximum explosion pressure (gauge) 793 kPa (115 psi)Maximum rate of pressure rise (gauge) 793 kPa/sec (15,000 psi/sec)Ignition temperature cloud 1040°F (560°C)Minimum cloud ignition energy 0.04 J (26.4 W/sec)Minimum explosion concentration 0.328 kg/m3 (0.03 oz/ft3)

Limiting oxygen percent for spark ignitiond —

Note: KSt values vary for specific particle sizes.aExplosibility index = ignition sensitivity × explosion severity.bIgnition sensitivity =

cExplosion severity =cExplosion severity =



dBurns in carbon dioxide, nitrogen, and halons.

[484: Table D.2]

Table A.5.2.2(k) Selected Combustible Dusts Layer or Cloud Ignition Temperature



Chemical NameCAS No.

NEC Group Code

Layer orCloud

IgnitionTemperature(°C)

Acetal, linear G NL 440

Acetoacet-p-phenetidide 122-82-7 G NL 560

Acetoacetanilide 102-01-2 G M 440

Acetylamino-t-nitrothiazole G 450Acrylamide polymer G 240Acrylonitrile polymer G 460Acrylonitrile-vinyl chloride-vinylidenechloride copolymer (70-20-10)

G 210

Acrylonitrile-vinyl pyridine copolymer G 240

Adipic acid 124-04-9 G M 550

Alfalfa meal G 200Alkyl ketone dimer sizing compound G 160

Allyl alcohol derivative (CR-39) G NL 500Almond shell G 200

Aluminum, A422 flake 7429-90-5 E 320

Aluminum, atomized collector fines E CL 550

Aluminum—cobalt alloy (60-40) E 570Aluminum—copper alloy (50-50) E 830Aluminum—lithium alloy (15% Li) E 400Aluminum—magnesium alloy(dowmetal) E CL 430

Aluminum—nickel alloy (58-42) E 540Aluminum—silicon alloy (12% Si) E NL 670

Amino-5-nitrothiazole 121-66-4 G 460

Anthranilic acid 118-92-3 G M 580

Apricot pit G 230Aryl-nitrosomethylamide G NL 490

Asphalt 8052-42-4 F 510

Aspirin [acetol (2)] 50-78-2 G M 660

Azelaic acid 109-31-9 G M 610

Azo-bis-butyronitrile 78-67-1 G 350Benzethonium chloride G CL 380




NEC Group Code

Layer orCloud


Benzoic acid 65-85-0 G M 620Benzotriazole 95-14-7 G M 440Beta-naphthalene-axo-dimethylaniline G 175

Bis(2-hydroxy- 5-chlorophenyl) methane 97-23-4 G NL 570

Bisphenol-A 80-05-7 G M 570Boron, commercial amorphous (85% B)

7440-42-8 E 400

Calcium silicide E 540Carbon black (more than 8% total entrapped volatiles) F

Carboxymethyl cellulose 9000-11-7 G 290

Carboxypolymethylene G NL 520Cashew oil, phenolic, hard G 180Cellulose G 260Cellulose acetate G 340Cellulose acetate butyrate G NL 370Cellulose triacetate G NL 430

Charcoal (activated) 64365-11-3 F 180

Charcoal (more than 8% total entrapped volatiles) F

Cherry pit G 220Chlorinated phenol G NL 570Chlorinated polyether alcohol G 460

Chloroacetoacetanilide 101-92-8 G M 640

Chromium (97%) electrolytic, milled

7440-47-3 E 400

Cinnamon G 230Citrus peel G 270Coal, Kentucky bituminous F 180Coal, Pittsburgh experimental F 170Coal, Wyoming F 180Cocoa bean shell G 370Cocoa, natural, 19% fat G 240Coconut shell G 220Coke (more than 8% total entrapped volatiles) F

Cork G 210Corn G 250




NEC Group Code

Layer orCloud


Corn dextrine G 370Corncob grit G 240Cornstarch, commercial G 330Cornstarch, modified G 200Cottonseed meal G 200Coumarone-indene, hard G NL 520

Crag No. 974 533-74-4 G CL 310

Cube root, South America 83-79-4 G 230Di-alphacumyl peroxide, 40-60 on CA 80-43-3 G 180

Diallyl phthalate 131-17-9 G M 480

Dicyclopentadiene dioxide G NL 420Dieldrin (20%) 60-57-1 G NL 550Dihydroacetic acid G NL 430

Dimethyl isophthalate 1459-93-4 G M 580

Dimethyl terephthalate 120-61-6 G M 570

Dinitro-o-toluamide 148-01-6 G NL 500

Dinitrobenzoic acid G NL 460Diphenyl 92-52-4 G M 630

Ditertiary-butyl-paracresol 128-37-0 G NL 420

Dithane m-45 8018-01-7 G 180

Epoxy G NL 540Epoxy-bisphenol A G NL 510Ethyl cellulose G CL 320Ethyl hydroxyethyl cellulose G NL 390Ethylene oxide polymer G NL 350Ethylene-maleic anhydridecopolymer G NL 540

Ferbam™ 14484-64-1 G 150

Ferromanganese, medium carbon

12604-53-4 E 290

Ferrosilicon (88% Si, 9% Fe) 8049-17-0 E 800

Ferrotitanium (19% Ti, 74.1% Fe, 0.06% C) E CL 380

Flax shive G 230




NEC Group Code

Layer orCloud


Fumaric acid 110-17-8 G M 520

Garlic, dehydrated G NL 360

Gilsonite 12002-43-6 F 500

Green base harmon dye G 175Guar seed G NL 500Gulasonic acid, diacetone G NL 420Gum, arabic G 260Gum, karaya G 240Gum, manila G CL 360

Gum, tragacanth 9000-65-1 G 260

Hemp hurd G 220

Hexamethylene tetramine 100-97-0 G S 410

Hydroxyethyl cellulose G NL 410Iron, 98% H2 reduced E 290

Iron, 99% carbonyl 13463-40-6 E 310

Isotoic anhydride G NL 700L-sorbose G M 370Lignin, hydrolized, wood-type,fine G NL 450

Lignite, California F 180Lycopodium G 190Malt barley G 250

Manganese 7439-96-5 E 240

Magnesium, grade B, milled E 430Manganese vancide G 120Mannitol 69-65-8 G M 460Methacrylic acid polymer G 290Methionine (l-methionine) 63-68-3 G 360Methyl cellulose G 340

Methyl methacrylate polymer 9011-14-7 G NL 440

Methyl methacrylate-ethyl acrylate G NL 440

Methyl methacrylate-styrene-butadiene G NL 480

Milk, skimmed G 200N,N-dimethylthio- formamide G 230




NEC Group Code

Layer orCloud


Nitropyridone 100703-82-0 G M 430

Nitrosamine G NL 270

Nylon polymer 63428-84-2 G 430

Para-oxy-benzaldehyde 123-08-0 G CL 380

Paraphenylene diamine 106-50-3 G M 620

Paratertiary butyl benzoic acid 98-73-7 G M 560Pea flour G 260Peach pit shell G 210Peanut hull G 210

Peat, sphagnum 94114-14-4 G 240

Pecan nut shell 8002-03-7 G 210

Pectin 5328-37-0 G 200

Pentaerythritol 115-77-5 G M 400

Petrin acrylate monomer 7659-34-9 G NL 220

Petroleum coke (more than 8% total entrapped volatiles) F

Petroleum resin 64742-16-1 G 500

Phenol formaldehyde 9003-35-4 G NL 580

Phenol formaldehyde, polyalkylene-p

9003-35-4 G 290

Phenol furfural 26338-61-4 G 310

Phenylbetanaphthylamine 135-88-6 G NL 680

Phthalic anydride 85-44-9 G M 650Phthalimide 85-41-6 G M 630

Pitch, coal tar 65996-93-2 F NL 710

Pitch, petroleum 68187-58-6 F NL 630

Polycarbonate G NL 710Polyethylene, high pressureprocess

9002-88-4 G 380

Polyethylene, low pressure process

9002-88-4 G NL 420




NEC Group Code

Layer orCloud


Polyethylene terephthalate 25038-59-9 G NL 500

Polyethylene wax 68441-04-8 G NL 400

Polypropylene (no antioxidant) 9003-07-0 G NL 420

Polystyrene latex 9003-53-6 G 500

Polystyrene molding compound 9003-53-6 G NL 560

Polyurethane foam, fire retardant 9009-54-5 G 390

Polyurethane foam, no fireretardant

9009-54-5 G 440

Polyvinyl acetate 9003-20-7 G NL 550

Polyvinyl acetate/alcohol 9002-89-5 G 440

Polyvinyl butyral 63148-65-2 G 390

Polyvinyl chloride-dioctyl phthalate G NL 320

Potato starch, dextrinated 9005-25-8 G NL 440

Pyrethrum 8003-34-7 G 210

Rayon (viscose) flock 61788-77-0 G 250

Red dye intermediate G 175Rice G 220Rice bran G NL 490Rice hull G 220

Rosin, DK 8050-09-7 G NL 390

Rubber, crude, hard 9006-04-6 G NL 350

Rubber, synthetic, hard (33% S) 64706-29-2 G NL 320

Safflower meal G 210Salicylanilide 87-17-2 G M 610Sevin 63-25-2 G 140

Shale, oil 68308-34-9 F

Shellac 9000-59-3 G NL 400




NEC Group Code

Layer orCloud


Sodium resinate 61790-51-0 G 220

Sorbic acid (copper sorbate orpotash)

110-44-1 G 460

Soy flour 68513-95-1 G 190

Soy protein 9010-10-0 G 260

Stearic acid, aluminum salt 637-12-7 G 300

Stearic acid, zinc salt 557-05-1 G M 510

Styrene modified polyester-glass fiber

100-42-5 G 360

Styrene-acrylonitrile (70-30) 9003-54-7 G NL 500

Styrene-butadiene latex (>75%styrene)

903-55-8 G NL 440

Styrene-maleic anhydride copolymer

9011-13-6 G CL 470

Sucrose 57-50-1 G CL 350Sugar, powdered 57-50-1 G CL 370

Sulfur 7704-34-9 G 220

Tantalum 7440-25-7 E 300

Terephthalic acid 100-21-0 G NL 680

Thorium (contains 1.2% O) 7440-29-1 E CL 270

Tin, 96%, atomized (2% Pb) 7440-31-5 E 430

Titanium, 99% Ti 7440-32-6 E CL 330

Titanium hydride (95% Ti, 3.8%H)

7704-98-5 E CL 480

Trithiobisdimethylthio- formamide G 230

Tung, kernels, oil-free 8001-20-5 G 240

Urea formaldehyde molding compound

9011-05-6 G NL 460

Urea formaldehyde-phenolformaldehyde

25104-55-6 G 240

Vanadium, 86.4% 7440-62-2 E 490




NEC Group Code

Layer orCloud


Vinyl chloride-acrylonitrile copolymer

9003-00-3 G 470

Vinyl toluene-acrylonitrilebutadiene

76404-69-8 G NL 530

Violet 200 dye G 175Vitamin B1, mononitrate 59-43-8 G NL 360Vitamin C 50-81-7 G 280Walnut shell, black G 220Wheat G 220

Wheat flour 130498-22-5 G 360

Wheat gluten, gum 100684-25-1 G NL 520

Wheat starch G NL 380Wheat straw G 220Wood flour G 260Woodbark, ground G 250

Yeast, torula 68602-94-8 G 260

Zirconium hydride 7704-99-6 E 270

Zirconium (contains 0.3% O) 7440-67-7 E CL 330

Notes:

(1) Normally, the minimum ignition temperature of a layer of a specific dust is lower than the minimum ignition temperature of a cloud of that dust. Since this is not universally true, the lower of the two minimum ignition temperatures is listed. If no symbol appears in the “Code” column, then the layer ignition temperature is shown. “CL” means the cloud ignition temperature is shown. “NL” means that no layer ignition temperature is available, and the cloud ignition temperature is shown. “M” signifies that the dust layer melts before it ignites; the cloud ignition temperature is shown. “S” signifies that the dust layer sublimes before it ignites; the cloud ignition temperature is shown.

(2) Certain metal dusts might have characteristics that require safeguards beyond those required for atmospheres containing the dusts of aluminum, magnesium, and their commercial alloys. For example, zirconium and thorium dusts can ignite spontaneously in air, especially at elevated temperatures.

(3) Due to the impurities found in coal, its ignition temperatures vary regionally, and ignition temperatures are not available for all regions in which coal ismined.

[499:Table 5.2.2]




File Name DescriptionTable_A.5.2.2_g_SR-117.docx



Committee Statement


The proposed change presupposed that public comment 113-NFPA 653=2-2013 has been adopted. The text have been edited to make it suitable annex material for 5.2.1 under public comment 113.

New table: The data provided for PVC polymers is limited and is not characterized as to the type of polymer.

ResponseMessage:Public Comment No. 42-NFPA 652-2013 [Section No. A.5.2.2]Public Comment No. 119-NFPA 652-2013 [Section No. A.5.2.2]Public Comment No. 388-NFPA 652-2013 [Section No. A.5.2.2]Public Comment No. 403-NFPA 652-2013 [New Section after A.5.2.2]



SR-117

Table A.5.2.2(g) 20 L and 1 m3 Vessel Test Data, PVC and Copolymer Plastic Resins and Dusts*

PVC Resin Sample

GP(2) Dispersion

VA(3) Copolymer

Baghouse Dust from GP Pipe (as received)

GP Pipe Resin (1)

Baghouse Dust from GP Pipe (as received)

GP Pipe Resin (as received)

High Molecular Weight Resin (as received)

Type of polymerization process

Emulsion

Suspension

Plant designator

A B C C D D E

Test lab Chilworth Chilworth Chilworth Fike Chilworth Chilworth (20 L),

Fike (1 m3)

Fike

Minimum Ignition Energy (MIE), Joules

>10 J >10 J >500 mJ >4653 mJ

>10 J >10 J >4468 mJ

Explosion severity, KSt (bar-m/s), 20 L test chamber

91 68 84 18 54 9 81

Dust explosion class in 20 L test chamber

ST 1 ST 1 ST 1 ST 1 ST 1 ST 1 ST 1

Explosion severity, KSt (bar-m/s), 1 m3 test chamber

Not tested Not tested Not tested

0 Not tested

0 0

Dust explosion class in 1 m3 test chamber

Not tested Not tested Not tested

ST 0 Not tested

ST 0 ST 0

Particle size, avg. (µm)

1 (est.) N.A. N.A. 162 N.A. 158 128

Dust fraction (<75 µm, %)

100 100 100 0.1 97 0 0.6

*Sponsored by the Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314.

Notes:

(1) Date for MIE and 20 L test were performed by Fike on sample screened to <150 µm and data for 1 m3

tests were performed by Fike on ‘as received’ sample.

(2) GP: General Purpose

(3) VA: Vinyl Acetate

Source: Krock, R., et. al., “OSHA’s Combustible Dust National Emphasis Program and Combustibility

Characteristics Testing of PVC Resins and PVC Dusts”, SPE ANTEC, April, 2012.

Second Revision No. 122-NFPA 652-2014 [ Section No. A.5.5.3.3 ]

A.9.9.1It is essential to have thorough written documentation, as the slightest changes to procedures, processes, resources, staffing, and equipment, including equipment from suppliers, can have a dramatic impact on the overall hazard analysis. Change includes something as benign as process materials sourcing from a different manufacturer, the same raw material manufacturer using new methods to produce the product, or changes in formulation. These changes from a supplier’s end can impact the characteristics of the processes and materials. Individuals involved should include those involved in the process such as maintenance, engineering, and purchasing personnel, and all others as deemed necessary. Staffing and job tasks are not intended for shift changes, but for overall staff and their representative tasks. For reference, see the documentation form in ANSI/AIHAZ10-2012 , Occupational Health and Safety Management Systems.

The following changes in material or process can initiate the should warrant amanagement of change in Chapter 8 review per Section 9.9 , and new samples should be collected and analyzed:

(1) New process equipment is installed that presents new hazards.

(2) New operating conditions for existing equipment create a new hazard.

(3) A new material is used in the process.


File Name DescriptionSR-122_moved_annex_text.docx



Committee Statement

Committee Statement: If A.5.5.3.3 is retained, the citation should be corrected to cite 9.9.Response Message:Public Comment No. 168-NFPA 652-2013 [Section No. A.5.5.3.3]



A.9.9.1

It is essential to have thorough written documentation, as the slightest changes to procedures, processes,

resources, staffing, and equipment, including equipment from suppliers, can have a dramatic impact on

the overall hazard analysis. Change includes something as benign as process materials sourcing from a

different manufacturer, the same raw material manufacturer using new methods to produce the product,

or changes in formulation. These changes from a supplier’s end can impact the characteris tics of the

processes and materials. Individuals involved should include those involved in the process such as

maintenance, engineering, and purchasing personnel, and all others as deemed necessary. Staffing and

job tasks are not intended for shift changes, but for overall staff and their representative tasks .For

reference, see the documentation form in ANSI/AIHA Z10-2012, Occupational Health and Safety

Management Systems.

The following changes in material or process can initiate theshould warrant a management of

change in Chapter 8review per Section 9.9, and new samples should be collected and analyzed:

1. New process equipment is installed that presents new hazards.

2. New operating conditions for existing equipment create a new hazard.

3. A new material is used in the process.

Commented [BS1]: The following para was moved from A.5.5.3.3


A.7.3.4.1Where multiple compartments present essentially the same hazard, a single evaluation might be appropriate.


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Thu May 15 12:24:22 EDT 2014

Committee Statement


This Annex material has been moved to the body of the code where it will be given equal validity as an alternate to the main requirement

Response Message:Public Comment No. 336-NFPA 652-2013 [Section No. A.7.3.4.1]




A.8.5.6.1The best method to eliminate the need for electrically classified areas is to prevent the release of dust from equipment. The next best method to eliminate the need for electrically classified areas is to remove the removal the dust, by developingproper housekeeping procedures to clean up dust . If you cannot prevent the release of dust from equipment, cannot be prevented , or clean up the dust cannot be cleaned up , then that area might be an electrically classified area. NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous (Classified) Locations for Electrical Installations in Chemical Process Areas , can be used as for guidance to supplement the criteria in Article 500.5 of NFPA 70, National Electrical Code , . This guidance depends on a determination of whether the dusts combustibility of dust in a particular area are combustible ,the ignitability ignitibility properties of the dust, and the nature of possible dust cloud formation and dust layer accumulations within and outside the electrical equipment near these the dusts. There is limited guidance in identifying Class III locations. NFPA 499 is a good source for the guidance on the identification of identifying Class III areas.

The user of this document should be aware that the dust layer accumulation criteriain Articles 500–505 of NFPA 70 and NFPA 499 is intended to address electrical ignition hazards due to overheating or shorting of electrical equipment. The threshold housekeeping dust accumulation criteria in this standard are based on a dust flash-fire or dust deflagration hazard. These differing criteria can lead todifferent layer depth requirements. It is possible that even where electricallyclassified equipment is installed the area can still be considered a flash-fire or deflagration hazard.


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Wed Jul 16 17:08:53 EDT 2014

Committee Statement


The Committee expanded the annex to highlight that both flash fire and explosion hazard conditions and electrical area classification use a criteria based on layer depth to indicate the need for further protective measures.

Public Comment No. 9-NFPA 652-2013 [Section No. 8.5.6.1]




A.8.5.11.1Particulate materials that are notorious known to self-heaters during extended bulkstorage conditions heat under various circumstances include, but are not limitedto, resinous sawdust, sub-bituminous sewage sludge, powdered metals, wet agricultural materials, low rank coal, activated carbon and charcoal, and bagasse. Tabulations of materials prone to self-heating can be found in the following references: P.C. NFPA Fire Protection Handbook ; Bowes, Self-Heating: Evaluating and Controlling the Hazards; U.S. Department of Energy handbook,Primer on Spontaneous Heating and Pyrophoricity; and V. Babrauskas, Ignition Handbook Database.. Test methods to assess the propensity for self-heating, , and to determine critical storage pile sizes, and time to self-heating heat are alsodescribed in the Bowes and Babrauskas references . Methods of self-heating detection include temperature monitors within the pile or silo and carbon dioxide monitors in the silo. Self-heating management can be accomplished, for example,through timely processing of the affected particulate through the storage system before self-heating can become an issue.

Self-heating can also be controlled managed through control of the temperature of the material as it is added to the storage and by controlling through control of the residence time in storage. The permissible temperature and residence time can be determined based on the basis of the characteristics of the material, the size of the pile, and the environment around the pile.


Submitter Full Name: [ Not Specified ]Organization: [ Not Specified ]Street Address: City:State: Zip: Submittal Date: Mon Aug 18 09:04:07 EDT 2014

Committee Statement


ICAC believes activated carbon is not a combustible hazard in long-term storage and should be removed from the list. The Committee revised the Annex item to address the concerns identified by the submitter and have included the reference to the NFPA Fire Protection Handbook as a reference for information on self-heating.

ResponseMessage:Public Comment No. 473-NFPA 652-2013 [Global Input]Public Comment No. 475-NFPA 652-2013 [Global Input]




A.8.10.3.1Refer to NFPA 484 , Standard for Combustible Metals , for specific requirements regarding combustible metals.



Committee Statement

Committee Statement: This has been moved into the body of the document in PC-533 Response Message:Public Comment No. 534-NFPA 652-2013 [Section No. A.8.9.3.1]




A.9.3.1The operating procedures should address both the normal operating conditions aswell as and the safe operating limits. Where possible, the basis for establishing the limits and the consequences of exceeding the limits should also be described. The operating procedures should address all aspects of the operation, including the following (as applicable):

(1) Normal startup

(2) Continuous operation

(3) Normal shutdown

(4) Emergency shutdown

(5) Restart after normal or emergency shutdown

(6) Anticipated process upset conditions

(7) System idling

For manual operations, the procedures and practices should describe techniques, procedural steps, and equipment that are intended to minimize or eliminate combustible dust hazards.

Operating procedures and practices should be reviewed on a periodic basis, typically annually, to ensure that they are current and accurate.



Committee Statement

Committee Statement: modified to align with scope of standardResponse Message:Public Comment No. 437-NFPA 652-2013 [Section No. A.9.3.1]



Second Revision No. 103-NFPA 652-2014 [ Section No. B.1 ]

Global SR-48

B.1 Introduction.This annex is intended to illustrate one example of how to develop a process hazard analysis DHA for a facility. There are other methods to develop a processhazard analysis that Other methods include, but are not limited to, “what-if” analysis, failure mode and effects analysis, fault tree analysis, “Haz-Op,” etc and Hazop . Additional guidance on performing a process hazard analysis DHA is available in the NFPA Guide to Combustible Dusts Dust and in the AIChE Guidelines for Hazard Evaluation Procedures . It is not the intent of this standard to require all users to comply with OSHA Process Safety Management Regulation apply the PHA provisions of OSHA regulations in 29 CFR 1910.119, “Process Safety Management of Highly Hazardous Chemicals,” in developing a DHA . The requirement example is intentionally vague to allow users to match the complexity and extent of the analysis to the complexity and extent of the facility and its process.



Committee Statement


Substantiation: The recommended language identifies valuable additional references for performing process (dust) hazard analyses. The word “all” was struck to avoid the implication that most but not all users would be expected to apply the PHA provisions of the OSHA Process Safety Management Standard.

ResponseMessage:Public Comment No. 102-NFPA 652-2013 [Section No. B.1]Public Comment No. 129-NFPA 652-2013 [Section No. B.1]Public Comment No. 229-NFPA 652-2013 [Section No. B.1]Public Comment No. 323-NFPA 652-2013 [Section No. B.1]Public Comment No. 447-NFPA 652-2013 [Section No. B.1]



Second Revision No. 129-NFPA 652-2014 [ Section No. B.3.3


Each building compartment, room, or identifiable space should be or building compartment is considered for potential deflagration hazard.



Committee Statement



ResponseMessage:



Second Revision No. 130-NFPA 652-2014 [ Section No. B.4.5


Each point of the following points in the process is identified and considered a “compartment” in which a deflagration could occur, as follows is identified :

(1) Each duct

(2) Each conveyor

(3) Each silo, bunker, or other vessel

(4) Each fan

(5) Each piece of process equipment

Usually a volume exemption of 8 ft3 (0.2 m3) or smaller less is applied to enclosed pieces of process equipment in deflagration hazard management. This exemption comes from the difficulty in designing deflagration suppression for vessels that size small , as well as the modest hazard such small vessels represent. Assuming an 8-to-1 volumetric expansion from a dust deflagration, an 8 ft3 (0.2 m3) enclosure will yield a fireball volume of approximately 64 ft3 (1.8 m3), the volume of a sphere with a 10 ft (3m) diameter sphere . This is the estimated maximum extent of the fireball volume. This fact can be used to select the parts of the process system to be considered in the analysis. If a piece of process equipment includes a column of less than 8 ft3 (0.2m3), it should be documented as such in the process hazard analysis DHA .

The process hazard analysis DHA also considers the building compartment (room)compartment(s) where combustible particulates are being handled or processed. These compartments should be evaluated for both deflagration hazard and building rupture/ and collapse (explosion) hazard. (See Figure B.4.5.)

Figure B.4.5 An Example Process. (Source: J. M. Cholin Consultants, Inc.)





Committee Statement



ResponseMessage:



Second Revision No. 124-NFPA 652-2014 [ Section No. C.1 ]

C.1 Accumulated Fugitive Dust.[Need to add a text reference to the figure.] As noted elsewhere in the standard, there are two considerations for assessing accumulated fugitive dust hazards —one that indicates that a dust flash-fire or dust explosion hazard exists and the other that indicates where protected electrical equipment might be needed. Figure C.1 is a representation of provisions defined in Articles 500–505 of NFPA 70 to assist in determining where hazardous (classified) locations can exist.

Other factors associated with accumulated fugitive dust include the following:

(1) The Accumulated fugitive dust is the single most important factor in propagating a deflagration within a building.

(2) Dust layers trigger critical hazard management decisions

See NFPA 499

Electrical Equipment for Hazardous

Occupancies

All electrical equipment must be “listed” for use in the occupancy based upon the Class, Division and Group classification.

When all electrical equipment in the occupancy is listed for use in that occupancy the electrical system is not deemed to be a likely igniter.

The extent of the electrically classified area is controlled by the rate of dust release and the frequency of clean-up.

Figure C.1 Comparison of Accumulated Fugitive Dust Thicknesses. (Source: J. M. Cholin Consultants, Inc.)

Process Building Compartments

Where the management of the hazard is dependent upon routine cleaning, that cleaning program should be outlined in the PHA.

Where the management of the hazard is dependent upon routine cleaning, that cleaning program should be outlined in the PHA.

Explosion Hazards



Dust explosion hazards exist where ever combustible particulate solids are handled or produced.

There is no alternative to pro-actively managing the hazard.

Is there accumulated fugitive dust? If so – how much and where is it?

What is the MEC, MIE and K St of the particulate in the duct?

Does the building compartment pose a deflagration hazard?

Does it pose and explosion hazard?

Does it pose a fire hazard?

The majority of the property damage and personnel injury is due to the fugitive dust accumulations within the building or process compartment.

Control, limitation, or elimination of accumulated fugitive dust is CRITICAL and the single most important criterion for a safe workplace.

C.2 Electrical Equipment for Hazardous Occupancies.All electrical equipment must be listed for use in the occupancy based on the class, division, and group classification. When all electrical equipment in theoccupancy is listed for use in that occupancy, the electrical system is deemed to not be a likely igniter. The extent of the electrically classified area is controlled by the rate of dust release and the frequency of clean-up.C.3 Building Compartments.Where management of the hazard is dependent on routine cleaning, that cleaning program should be outlined in the DHA.C.4 Explosion Hazards.Dust explosion hazards exist wherever combustible particulate solids are handled or produced. There is no alternative to proactively managing the hazard, and thefollowing questions should be considered when assessing the risk:

(1) Is there accumulated fugitive dust? If so – , how much is there and where isit?

(2) What is the MEC, MIE, and KSt of the particulate in the duct dust ?

(3) Does the building compartment pose a deflagration hazard?

(4) Does it the building compartment pose and an explosion hazard?

(5) Does it the building compartment pose a fire hazard?

Most instances of property damage and personnel injury are due to fugitive dust accumulations within building compartments. Control, limitation, or elimination of accumulated fugitive dust is are CRITICAL critical and the single most important criterion criteria for a safe workplace.


File Name DescriptionG652-7r1.jpg Figure C.1--revised





Committee Statement


The Committee approved minor editorial changes to the text for Annex C and included an updated Figure C.1. The Committee also modified this to be consistent with the use of the defined term compartment per work of a Committee task group that reviewed this issue and made recommendations to the full committee.

ResponseMessage:

DELETED

DELETEDDELETED



Correlating Committee Note No. 2-NFPA 652-2013 [ Section No. 1.2 ]


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocSubmittal Date: Fri Jun 21 14:25:19 EDT 2013

Committee Statement and Meeting Notes


The Correlating Committee requests that the TC reconsider the inclusion of the word “minimum” within this paragraph. Refer to the NFPA Standards Council minutes of February 28 – March 1, 2011 meeting (item 11-3-24) that instructs the committee to develop general requirements and directs the user to the appropriate industry or commodity-specific standard.

First Revision No. 15-NFPA 652-2013 [Section No. 1.2]

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Correlating Committee Note No. 1-NFPA 652-2013 [ Section No. 1.4 ]


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocSubmittal Date: Fri Jun 21 14:16:46 EDT 2013



The Correlating Committee requests that the TC review the requirements in 1.4.1 and 1.4.2 regarding application of the standard and consider whether the expectation in 1.4.2 that the owner/operator will resolve differences between the requirements of NFPA 652 and a commodity-specific standard is appropriate. One observation is to direct the attention to requirements not otherwise covered rather than on the more subjective aspect of what is “more” or “less” stringent. For example, if a commodity-specific document does not cover one of the elements deemed fundamental within NFPA 652 then the other committee could choose to address it, to refer to NFPA 652 where it would be covered, or to justify why it is not needed in the standard. Any issues that might arise when both documents address a requirement would then be addressed for correlation by the Correlating Committee.





Correlating Committee Note No. 10-NFPA 652-2013 [ Section No.

2.2 ]


Submitter Full Name: Guy ColonnaOrganization: National Fire Protection AssocSubmittal Date: Mon Jun 24 17:02:39 EDT 2013



The Correlating Committee requests that the TC review the current combustible dust occupancy standards that are within the CC purview to ensure all applicable standards are included within the references contained in 2.2.





Correlating Committee Note No. 11-NFPA 652-2013 [ New Section

after 3.3.10 ]





The Correlating Committee requests that the TC review the definition for “dust” found in 3.3.11 with regard to the range of sizes that are currently proposed to be included in this definition. The NFPA Manual of Style discourages the inclusion of requirements within definitions and the range of sizes proposed seems to specify requirements. In addition, the CC is questioning the basis forwhether a particle size criterion is warranted and, if so, what are the endpoints. The CC suggests the TC consider combining the annex material for the definitions of “dust” and “combustible dust” as one means for resolving the issue raised by the CC.

First Revision No. 181-NFPA 652-2013 [New Section after 3.3.10]




Correlating Committee Note No. 12-NFPA 652-2013 [ New Section

after 3.3.28 ]





The Correlating Committee requests that the TC review the requirement in 4.1 (1) regarding the consistency between this provision and the requirement in Chapter 5, where historical data might be used in lieu of conducting testing of dust samples.

First Revision No. 19-NFPA 652-2013 [New Section after 3.3.28]





4.6.4.2 ]





The Correlating Committee requests that the TC review the use of possibly unenforceable language within this requirement (“special consideration”). As written, the CC believes the objective of this text might be better placed as advisory within the annex.

First Revision No. 33-NFPA 652-2013 [Section No. 4.6.4.2]




Correlating Committee Note No. 3-NFPA 652-2013 [ Chapter 6 [Title

Only] ]





The Correlating Committee requests that the TC reconsider the use of the term “PHA” or “Process Hazards Analysis” to avoid confusion with the formalized PHA requirement that comes in through the Process Safety Management (PSM) regulation of OSHA, 29 CFR 1910.119.

First Revision No. 67-NFPA 652-2013 [Chapter 6 [Title Only]]





7.1.2 ]





The Correlating Committee requests that the TC consider establishing some time frame for phasing in the development of an implementation plan for the PHA requirement on a retroactive basis.





6.3.4.3 ]





The Correlating Committee requests that the TC review the resolution of PI 243 as it appears not to match the recommendation and substantiation contained in the PI.

First Revision No. 78-NFPA 652-2013 [Section No. 6.3.4.3]





8.5.6.1 [Excluding any Sub-Sections] ]





The Correlating Committee requests that the TC develop annex material explaining the differences between the two applications of layer accumulation criteria – one for determining the presence of a dust flash fire or dust deflagration hazard and the other for determining electrical area classification.





7.5.7.1.4.1 ]





The Correlating Committee requests that the TC review the basis for the flexible connector requirements and consider separating the requirements for short flexible connections versus such items as conveying hose. The TC should also look at Tom Scherpa’s negative vote on FR 120 regarding the unit conversion error.

First Revision No. 119-NFPA 652-2013 [Section No. 7.5.7.1.4.1]





7.8.5 ]





The Correlating Committee requests that the TC review the requirement in this paragraph. The TC should consider the ease of ignition of the particulate, the presence of credible ignition sources, and address the practicality of implementation and the basis for application to every installation. Examples of“enclosures” found in facilities where isolation could be impractical include: mechanical conveyors, such as screw conveyors, spouting. The CC notes that requirements in NFPA 654 and 664 might provide some guidance to the TC as they consider this request.

First Revision No. 244-NFPA 652-2013 [Section No. 7.8.5]





8.8.1 ]





The Correlating Committee requests that the TC review PI 279 and develop a technical basis for its action on this PI and include that in the response for this item.

First Revision No. 56-NFPA 652-2013 [Section No. 8.8.1]




Correlating Committee Note No. 8-NFPA 652-2013 [ Sections 8.9.1,

8.9.2, 8.9.3 ]





The Correlating Committee requests that the TC review the submitter’s recommendation in PI 114 and its response which refers the submitter to the section of the standard on “documentation”, since that section on documentation does not currently address the submitter’s proposed change to include a period of retention for the documentation. The CC also notes that the TC might review and revise the annex to 9.10 which implies that retention times are provided somewhere in the standard.

First Revision No. 60-NFPA 652-2013 [Sections 8.9.1, 8.9.2, 8.9.3]


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/TerraView/Content/652-proposed.ditamap/2/C1372108098611.xml/TerraView/Content/652-proposed.ditamap/2/C1372108260904.xml/TerraView/Content/652-proposed.ditamap/2/C1372076545504.xml

/TerraView/Content/652-proposed.ditamap/2/C1372076720172.xml/TerraView/Content/652-proposed.ditamap/2/C1372092999460.xml/TerraView/Content/652-proposed.ditamap/2/C1372106591999.xml







National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M

TO: NFPA Technical Committee on Fundamentals of Combustible Dusts

FROM: Joanne Goyette, Administrator, Technical Projects

DATE: October 2, 2014

SUBJECT: NFPA 652 Second Draft TC FINAL Ballot Results (A2015)

According to the final ballot results, all ballot items received the necessary affirmative votes to pass ballot. 31 Members Eligible to Vote 2 Not Returned (C. Carbone and W. Frank) 18 Members Voting Affirmative on All Revisions 11 Members Voting Affirmative with Comment on one or more Revisions (E. Buc, J. Cholin,

R. Feldkamp, R. Gombar, D. Hansen, J. Koch, T. Myers, J. Norris, S. Rodgers, T. Scherpa, and R. Zalosh)

11 Members Voting Negative on one or more Revisions (J. Cholin, M. Drake, R. Feldkamp, R. Gombar, J. Koch, T. Myers, J. Norris, S. Rodgers, T. Scherpa, E. Ural, and R. Zalosh)

1 Member Voting to Abstain on one or more Revisions: (R. Gombar) The attached report shows the number of affirmative, negative, and abstaining votes as well as the explanation of the vote for each second revision.

There are two criteria necessary for each second revision to pass ballot: (1) simple majority and (2) affirmative 2/3 vote. The mock examples below show how the calculations are determined.

(1) Example for Simple Majority: Assuming there are 20 vote eligible committee members, 11 affirmative votes are required to pass ballot. (Sample calculation: 20 members eligible to vote ÷ 2 = 10 + 1 = 11)

(2) Example for Affirmative 2/3: Assuming there are 20 vote eligible committee members and 1 member did not

return their ballot and 2 members abstained, the number of affirmative votes required would be 12. (Sample calculation: 20 members eligble to vote – 1 not returned – 2 abstentions = 17 x 0.66 = 11.22 = 12 )

As always please feel free to contact me if you have any questions.

Eligible to Vote: 31

Not Returned : 2

Cheryl B. Carbone and Walter L. Frank

Vote Selection Votes Comments

Affirmative 28

Affirmative with Comment 1

Robert C. Gombar It is understood that the language in the new Sections 4.2.5 and 4.2.6 is subject to the current wording in

Conflicts, Section 1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 27


Jim E. Norris There will still be confusion between a DHA an PHA. I personally think the two processes will likely look

very similar, and in reality that is the objective of the committee as OSHA has indicated its' desires for

PSM type elements for regulation of dust. The title of Chapter is still Process Hazard Analysis which

causes additional confusion. Is at dust hazard analysis intended to refer to Hazard Identification in

Chapter 5 or Process Hazard Analysis in Chapter 7.

Robert C. Gombar Although a good part of the change to DHA is to “remove some concern that the DHA is to be the same as

the PHA in OSHA’s Process Safety Management regulation,” the change does not fully accomplish that

purpose. Instead, NFPA 652’s DHA requirement could be viewed as imposing requirements that are more

specific and onerous than those applicable to PHAs, such as the DHA requirement to “identify safe

operating ranges.” The only requirement of a PHA that does not appear in the body of the DHA

requirements is the requirement that a PHA be performed by a “team” (29 CFR 1910.119(e)(4)). With all

respect, the Committee Statement is not entirely accurate.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar The word "minimum" in Section 1.2 is arguably inconsistent with the current language in Section 1.4.2.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 27


NFPA 652 CMD-FUN (A2015) Second Draft Ballot

Final Ballot Results

SR-134, Section No. 1.3.1, See SR-134

SR-1, Section No. 1.2, See SR-1

Total Voted : 29

Total Voted : 29

SR-48, Global Comment, See SR-48

October 2, 2014Results by Revision

SR-143, Global Comment, See SR-143

Total Voted : 29

http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/Content/652-proposed.ditamap/2/C1405695819936.xml&viewmode=nfpa/xslt/nfpaviewmode.xsl




Samuel A. Rodgers The figure does not include NFPA 120 while A 3.3.26 does include NFPA 120 as a commodity-specific

standard

Dale C. Hansen Need to be sure the section references in the diagram point to the right paragraphs within the standard

before final publication.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar It is understood that Section 1.3.2 is subject to the current wording in Section 1.4.2.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 26


Negative 3

Samuel A. Rodgers This standard should be clearly the minimum requirement for all commodities. The section also does not

include NFPA 120 as a commodity-specific standard while NFPA 120 is included in A 3.3.26

Robert G. Zalosh I am voting negative on this item because the revised paragraph 1.4.3 allows the commodity specific

standard to prohibit a NFPA 652 requirement without showing how the NFPA 652 life safety objectives

can still be achieved. I would be in favor of adding the following proviso to the end of the Second Draft

1.4.3: providing the prohibition includes an explanation of how it would still allow the NFPA 652 life

safety objectives to be achieved.

Erdem A. Ural Revisions defeat the purpose of having 652 because they allow commodity specific standards to override

the minimum safety requirements set forth by 652

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0



Total Voted : 29


Total Voted : 29

Total Voted : 29


Total Voted : 29






Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2




SR-138, New Section after 3.3.2, See SR-138

Total Voted : 29

SR-7, Section No. 3.3.1.1, See SR-7

Total Voted : 29

Total Voted : 29



Total Voted : 29


Total Voted : 29

Total Voted : 29







Affirmative 28


Robert C. Gombar It is understood that Section 3.3.6 (now Section 3.3.7) is subject to the current wording in Conflicts,

Section 1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar It is understood that Section 3.3.9 (now Section 3.3.11) is subject to the current wording in Conflicts,

Section 1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 26


Robert C. Gombar The revised language is better than the First Draft language, but it still does not provide sufficient

guidance with respect to a minimum threshold quantity, such as in subparagraph "c" in the Committee

Statement.

Negative 2

Erdem A. Ural Does this definition capture the combustible metal dust?

John M. Cholin The revised text takes a clearly expressed description of the two sets of circumstances that can pose a

deflagration hazard and replaces it with something that is vague. The TC went from OK to unacceptable in

this definition. Since the whole standard is intended to protect employees from a deflagration hazard it is

critical that the user be given a clear explicit description of what constitutes such a hazard. While not

perfect, the first draft language came far closer to fulfilling that need than the second draft language.

Abstain 0


Total Voted : 29



Total Voted : 29

SR-9, Sections 3.3.9, 3.3.10, See SR-9

Total Voted : 29

Total Voted : 29






Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Negative 1

Robert C. Gombar The definition is not necessary in NFPA 652.

Abstain 0


Not Returned : 2




Total Voted : 29



Total Voted : 29


Total Voted : 29

Total Voted : 29



Total Voted : 29

Total Voted : 29







Affirmative 28


Negative 1

Erdem A. Ural Add combustible metal

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 27


Robert C. Gombar It is understood that the language in Section 3.3.32 (now Section 3.3.36) is subject to the current wording

in Conflicts, Section 1.4.

Negative 1

Erdem A. Ural I would also add distance between combustible dust deposits

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar It is understood that the language in Section 4.1 is subject to the current wording in Conflicts, Section 1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 26


Robert G. Zalosh I suggest either deleting the word reasonably or adding the following to the existing Annex paragraph for

4.2.1.1.1, and having it also in Annex paragraphs for 4.2.1.1.2 and 4.2.1,1.3. The word reasonably in this

paragraph is intended to mean in a sensible way rather than to a moderate degree that would knowingly

fall short of the objective.

Robert C. Gombar It is understood that the language in Sections 4.2.1.1.1 through 4.2.1.13 is subject to the current wording

in Conflicts, Section 1.4.

Negative 1

John M. Cholin The insertion of the word "reasonably" makes the entire standard irrelevant. Any owner can decide that

all these protection features are "unreasonable" in view of the cost and declare the facility in compliance.

652 will never rise to the level of a nationally recognized standard of care with this language in it.



Total Voted : 29

Total Voted : 29



Total Voted : 29

Total Voted : 29





Abstain 0


Not Returned : 2



Affirmative 26


Robert G. Zalosh I suggest either deleting the word reasonably or adding the following to the existing Annex paragraph for

4.2.1.1.1, and having it also in Annex paragraphs for 4.2.1.1.2 and 4.2.1,1.3. The word reasonably in this

paragraph is intended to mean in a sensible way rather than to a moderate degree that would knowingly

fall short of the objective.

John M. Cholin the word reasonably should be deleted.

Robert C. Gombar It is understood that the language in Section 4.2.1.2 is subject to the current wording in Conflicts, Section

1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 27


Negative 2

Thomas C. Scherpa The structural integrity objective should be retained. It is possible to design structures to maintain

structural integrity despite the effects of an explosion. NFPA 68 provides specific requirements for

designing explosion vents to do just this. A facility that has lost structural integrity due to an explosion

presents a hazard to building occupants and emergency responders.

John M. Cholin when dealing with explosion hazards how can one not have as an objective to prevent the building from

falling down at least long enough for the occupants to escape. This deletion is utterly wrong!

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar It is understood that the language in Section 4.2.4 (excluding sub-sections) is subject to the current

wording in Conflicts, Section 1.4.

Negative 0

SR-28, Section No. 4.2.4 [Excluding any Sub-Sections], See SR-28


Total Voted : 29


Total Voted : 29

Total Voted : 29


Total Voted : 29





Abstain 0


Not Returned : 2



Affirmative 27


Negative 2

Robert G. Zalosh This paragraph is still needed because the revised paragraph 4.2.4 does not include facility construction

and maintenance, and the mention of structures in 4.2.4 sounds like just an add on to the end of the

paragraph, when in fact it should be the focus of the paragraph.

John M. Cholin The whole objective of venting building compartments or the use of damage limiting construction is to

achieve the objective this action deletes.

Abstain 0


Not Returned : 2



Affirmative 28


Negative 1

John M. Cholin We design facilities to achieve this objective all the time. the committee statement that it requires

something that is unachievable is not .

Abstain 0


Not Returned : 2



Affirmative 26


Robert C. Gombar It is understood that the language in Section 4.2.4 (now Section 4.2.5) is subject to the current wording in


Negative 2

Samuel A. Rodgers The modification to this section is inconsistent with the substantiation. Indicated necessary adjuncts to

Chapter 6 are not in the performance-based ooption statement.

Timothy J. Myers The committee statement and SR are in conflict. The committee statement argues that more than

chapter 6 is needed to comply with performance based option, while the SR does not require compliance

with more than chapter 6.

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar It is understood that the language in Sections 5.1 and 5.2 is subject to the current wording in Conflicts,

Section 1.4. Also, the word "sole" should be inserted before the word "basis" in Section 5.2.3.

Negative 0

Abstain 0

SR-25, Sections 5.1, 5.2, See SR-25

Total Voted : 29



Total Voted : 29


Total Voted : 29

Total Voted : 29






Not Returned : 2



Affirmative 27


Elizabeth C. Buc In order for any test data to be meaningful, even with respect to establishing consistency with 'historical'

data, there should be some characterization of the material. There is no guidance in the UN Test N.1 for

characterizing the material. Basic minimum information should include form (e.g. particle size,

morphology), composition and concentration.


Negative 0

Abstain 0


Not Returned : 2



Affirmative 27



Negative 1

Mark W. Drake I believe it is necessary to keep; 5.5.3.3 - When changes in the materials or processes occur, the

owner/operator shall comply with Chapter 9. Material change can greatly impact the overall hazard

analysis and should be thoroughly documented like any other process change, as stated in Chapter 9.

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2




Total Voted : 29


Total Voted : 29

Total Voted : 29



Total Voted : 29

Total Voted : 29







Affirmative 27


James F. Koch There is no reference 6.1.3.1 through 6.1.3.13. It must have changed with other updates.

Robert C. Gombar It is understood that the language in Section 6.1.2.1 is subject to the current wording in Conflicts, Section

1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 28




Negative 0

Abstain 0


Not Returned : 2



Affirmative 28



Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar It is understood that the language in Sections 6.3.1.1 and 6.3.1.2 is subject to the current wording in


Negative 0

Abstain 0


Not Returned : 2



Affirmative 26


Thomas C. Scherpa While I agree that the references should be corrected to refer to Chapter 4, the deletion of the structural

integrity objective per SR-26 left no structural integrity objective in the standard to which a reference

could be made. Instead, the reference is to two sections addressing life safety objectives that make no

reference to structural integrity. It would be more appropriate to retain the deleted structural integrity

objective and provide a reference to it here.


Total Voted : 29

SR-36, Sections 6.3.1.1, 6.3.1.2, See SR-36


Total Voted : 29


Total Voted : 29

Total Voted : 29





John M. Cholin Weren't the structural integrity objectives of 4.2.1.1 and 4.2.1.2 removed? They should be put back in.

Robert C. Gombar It is understood that the language in Sections 6.3.2 and 6.3.3 is subject to the current wording in


Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar It is understood that the language in Section 6.3.5 is subject to the current wording in Conflicts, Section

1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 28



1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 27



Total Voted : 29


Total Voted : 29

Total Voted : 29



Total Voted : 29

Total Voted : 29








1.4.

Negative 1

Robert G. Zalosh I am voting negative on the Second Draft revisions because they significantly weaken the standard and

have significant ambiguities. To whom and how does the owner/operator demonstrate progress in each

year? To what does the 25% of the original cost refer; the cost of the original plant, the original process

being modified; capital cost or operating costs? If the modification is a change in particulate material

combustibility that significantly increases the hazard without at least 25% of some original cost, doesn't

the Committee still want a Dust Hazard Analysis to be performed?

Abstain 0


Not Returned : 2



Affirmative 28



1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 27


Timothy J. Myers The committee statement appears to be the statement of the submitter, and not the committee.

Negative 1

Samuel A. Rodgers Without a specified formal review period for the DHA, it is conceivable that the overall effect of some

changes on facility safety will not be fully evaluated.

Abstain 0


Not Returned : 2



Affirmative 28



1.4. The first sentence of Section 7.3.1(2) should read: "Where such a hazard exists, identification and

evaluation shall include the following:" Subsection 7.3.1(2)(a) should be deleted.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 29



Total Voted : 29



Total Voted : 29


Total Voted : 29

Total Voted : 29





Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Robert C. Gombar As written, this section is triggered regardless of the amount of combustible dust that may be present.

There needs to be some threshold amount. In any event, it is understood that the language in Section

7.3.3.1 is subject to the current wording in Conflicts, Section 1.4.

Negative 0

Abstain 0


Not Returned : 2



Affirmative 23


Timothy J. Myers Dust deflagration hazard should not be replaced by DHA, they are two different things. This appears to be

an editorial error that should be corrected.

Thomas C. Scherpa In section 7.3.3.3, the term "dust deflagration hazard" should not be replaced with "DHA". The DHA refers

to a hazards analysis, whereas this section is describing the hazard itself

Robert C. Gombar The insertion of "DHA" in Section 7.3.3.3 appears to be a mistake. Also, it is understood that the language

in Sections 7.3.3.2 and 7.3.3.3 is subject to the current wording in Conflicts, Section 1.4.

Negative 3

Samuel A. Rodgers The change to 7.3.3.3 that replaces "dust deflagration hazard" with "DHA" is not appropriate and was not

intended by the committee. The change to 7.3.3.2 is intended, but both of the correct changes are

included in SR-49 in section 7.3.4

James F. Koch The change (replacing dust deflagration hazard with DHA) in paragraph 7.3.3.3 doesn't make sense. Keep

the original wording.

Robert J. Feldkamp Agree with the other, "dust deflagration hazard" should not have been replaced with "DHA".

Abstain 0


Not Returned : 2



Affirmative 26


John M. Cholin Section 7.3.4.2.2 should include a maximum permissible dust layer thickness that would be enforceable in

the event that some other "dust standard" did not establish a maximum layer thickness. NFPA 664 and

654 have maximum permissible dust layer criteria that are roughly analogous when corrected for net

heat of combustion and bulk density. On that basis, the 1/8th inch layer depth criterion would be

applicable to most of the organic, cellulosic and biogenic particulates when also corrected for bulk

density. This is a major omission that could lead to a proposed amendment by the membership.


1.4.

Negative 1


Total Voted : 29



Total Voted : 29

Total Voted : 29




Erdem A. Ural 7.3.4.2.1 and 7.3.4.2.2 are inadequate for the users and enforcers to establish the threshold dust

accumulations for DHA. I could not find this critically important information anywhere else in the

standard.

Abstain 0


Not Returned : 2



Affirmative 27


Jim E. Norris Unless you look at A.8.2.2.1 the term building compartment may still be interpreted to be conclusive of

bin, tanks, and silos. PC 598 and 599 attempted to address this issue but hiding the intended application

in the annex may present issues for some users.


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


SR-68, Section No. 8.3.3.2.3, See SR-68

SR-135, Section No. 8.3.3.1.4.3, See SR-135

Total Voted : 29


Total Voted : 29

Total Voted : 29



Total Voted : 29

Total Voted : 29






Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 28


Negative 1

Robert G. Zalosh The revised wording does not make sense. If the Committee really does not have confidence in explosion

isolation systems, the revised paragraph should read as follows: shall not be interconnected with {other}

dust collection systems [DELETE: without isolation that transport combustible particulate solids or hybrid

mixtures. (See 8.9.4.)]

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

Abstain 0


Not Returned : 2



Affirmative 29


Negative 0

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Total Voted : 29

SR-142, New Section after 8.3.3.3.7, See SR-142


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Affirmative 29


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Affirmative 28


Samuel A. Rodgers The committee statement includes the phrase "FIX Later", which should be deleted from the final record.

Negative 0

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Affirmative 26


Robert G. Zalosh I suggest the following be added to the end of item 5 in the list of requirements. and an assessment is

conducted of the electrostatic hazard potential of the compressed air equipment. I also suggest that an

eighth item be added as follows: (8) Personnel exposed to the dust cloud formed from blowing be

outfitted with appropriate flash fire resistant garments, gloves, and head protection.

James F. Koch The word "lower" in 8.4.2.6.2 (6)should be removed. Dust could accumulate on surfaces above the area

being cleaned.


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Robert J. Feldkamp It should be a requirement for the air hose be grounded. An ungrounded air hose with a metal blow-off

gun that does not use clean dry air could be a source of ignition to the dust cloud being produced during

the cleaning process. We should add this to the requirements for blow-down.

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Affirmative 29


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Affirmative 29


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Affirmative 28


Negative 1

Robert G. Zalosh The stated fear that dryers operating at temperatures above the AIT at the feed end would be prohibited

is unfounded providing, as stated, that measures are implemented to prevent accumulation of product in

those areas above the AIT. This is current good practice.

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Affirmative 29


Negative 0

SR-82, New Section after 8.5.6.4, See SR-82


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Not Returned : 2



Affirmative 29


Negative 0

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Affirmative 27


Samuel A. Rodgers Statement 8.5.7.1.4.3 should read "The maximum powder transfer velocity is less than 2000 fpm (10

m/s)" to be clearer.

Negative 1

Robert G. Zalosh The second draft changes to this section are not warranted, and the Committee Statement rationalizing

this change is erroneous. Flexible connector electrostatic discharges capable of igniting combustible dusts

have been observed in industrial practice, and the cost of obtaining compliant flexible connectors is not

prohibitive. There is no technical substantiation for the 6/6 ft threshold for applicability.

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Affirmative 29


Negative 0

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Affirmative 29


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Affirmative 29


Negative 0

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SR-86, Sections 8.5.8.1, 8.5.8.2, See SR-86

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Affirmative 29


Negative 0

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Affirmative 28


Negative 0

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Robert C. Gombar We would prefer not creating new "Reserved" section at this point in the process.


Not Returned : 2



Affirmative 28


Robert C. Gombar The word "reasonable" should be inserted before the word "measures" in Section 8.8.1 (now Section

8.9.1).

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Affirmative 29


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Affirmative 28




Negative 0

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Total Voted : 29

SR-89, New Section after 8.6, See SR-89

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Not Returned : 2



Affirmative 28


Robert C. Gombar It is understood that the language in Section 8.9.1.1 (now Section 8.10.1.1) is subject to the current

wording in Conflicts, Section 1.4.

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Affirmative 29


Negative 0

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Affirmative 28


Negative 1

Robert C. Gombar The new section adds nothing to what is already covered in Section 9.4.1 and, therefore, is unnecessary.

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Affirmative 29


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Affirmative 29


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Affirmative 29


Negative 0

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Affirmative 26


Timothy J. Myers Delete extra for in "developed for for preparing"

Thomas C. Scherpa Typographical error: There is an extra word "for" in the revised statement. Expand the deleted text to

include the word "for" immediately before it.

Robert C. Gombar There is an extra "for" in the sentence. It presently reads: "A written emergency response plan shall be

developed for for . . . . '

Negative 0

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Affirmative 29


Negative 0

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Affirmative 28



1.4. This section also should be simplified for small employers and small facilities, perhaps by allowing

Section 9.9.2 to be satisfied using a system whereby all changes that could affect a combustible dust

hazard must go to a knowledgeable person. Also, rather than stating the "basis" for the proposed change,

Subsections 9.9.2(1) and (2) should be revised into a single subsection that would read: "The safety and

health implications of the proposed change."

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Affirmative 29


Negative 0

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Affirmative 29


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Affirmative 27


Robert C. Gombar The revised language of Section 9.12 is better, but we question whether the section should be in an NFPA

standard at all. Moreover, the words "actively involve" could be misinterpreted to mean that employees

and their representatives would have a role in running the owner's business. OSHA has been careful to

avoid wording such provisions in standards so as to suggest intrusions into management rights. The

words "actively involve" should be deleted.

Negative 1

Jim E. Norris The addition of "and their representatives" implies the establishment has organized labor representatives

which often is not the case. If it is the case the employer is bound to abide by contractual obligations,

which is where this type of requirement should reside vs. a consensus document. This was not the intent

of PC 621.

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Affirmative 29


Negative 0

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Affirmative 29


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Negative 0

SR-125, Section No. A.3.3.22, See SR-125

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Affirmative 29


Negative 0

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Affirmative 27


Samuel A. Rodgers In the headings for Tables A.5.2.2(b) through A.5.2.2(f), Staubexplosionen is incorrectly spelled, without

the "l". In Table A.5.2.2(i)the heading "Sample Concentration That Corresponds to Pmax anddP/dtmax"

should have indicated units of (g/m3). In Table A.5.2.2(j) the explosibility index,ignition sensitivity and

explosion severity entries all include a superfluous KSt after the number (units do not apply to these

ratios).

Negative 1

Timothy J. Myers My comment (PC 42) to remove the sentence “Generally, such data can be considered conservative if

they are obtained from a reliable source, such as other NFPA documents.” was not addressed by the

committee. As I stated in PC-42: "The statement is ambiguous because the term conservative does not

indicate whether the values are conservatively high or conservatively low. Additionally, there is no basis

to say whether sources such as the NFPA provide conservatively high or low values."

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Not Returned : 2



Affirmative 28


James F. Koch I believe that the word "change" was inadvertently deleted in the second paragraph "management of

change".

Negative 0

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Affirmative 28


Samuel A. Rodgers Text failed to delete the words "management of". Text should be "The following changes in material or

process should warrant a review per Section 9.9, and new samples should be collected and analyzed:"

Negative 0

Abstain 0

SR-99, Section No. A.7.3.4.1, See SR-99

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Affirmative 29


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Affirmative 29


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Affirmative 29


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Affirmative 28


Timothy J. Myers Hazop should be in all capitals, i.e. HAZOP as it is an acronym.

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Affirmative 29


SR-129, Section No. B.3.3 [Excluding any Sub-Sections], See SR-129

SR-103, Section No. B.1, See SR-103

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Negative 0

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Affirmative 28


James F. Koch The word "column" in the following sentence appears to be incorrect "If a piece of process equipment

includes a column of less than 8 ft3 (0.2m3), it should be documented as such in the process hazard

analysisDHA." Was this intended to be "volume"?

Negative 0

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Affirmative 28


Samuel A. Rodgers In the figure text the dust Class is incorrectly shown as arabic "2", and should be roman numeral "II". Also

in the figure, the typical hazard depth for NFPA 664 is listed as .125 inches and this text and arrow should

be referenced to the same 1/8 inch depth for Class II, Div 1. As shown both a 0.031 and a 0.125 inch

depth text statement are connected to a single layer thickness of around 0.031 inches.

Negative 0

Abstain 0

SR-124, Section No. C.1, See SR-124

Total Voted : 29

Total Voted : 29

SR-130, Section No. B.4.5 [Excluding any Sub-Sections], See SR-130

Total Voted : 29



CORRELATING COMMITTEE ON COMBUSTIBLE DUSTS NFPA …

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