Written by: Gary Huddleston | February 22, 2023
The National Fire Protection Association’s (NFPA) combustible dust standards have been around for a long time. If you have been tasked with managing a manufacturing facility in the animal food industry, you have probably heard of them, but may be confused with how they could apply to your facility.
The first thing to note is that unless you are in an area where your local fire department or insurance carrier requires compliance, compliance with the standards is voluntary. The NFPA combustible dust standards are offered as best practices and procedures to help prevent fires and explosions in environments that have the potential to contain combustible dust.
NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, is the standard that the feed and grain industries have typically used. There are currently five additional NFPA standards that deal with combustible dust:
In 2018, the NFPA standards council began work on combining the six individual NFPA combustible dust standards into one comprehensive standard.
Our industry opposes the formation of this single comprehensive combustible dust standard since we know other industries have vastly different equipment and hazards than our industry. Facility and operating practices across industries differs, requiring different prevention solutions.
The current NFPA 61 standard has been carefully developed over nearly 100 years and reflects the best practices and needs of the feed and grain industries. Despite the opposition from the NFPA 61 committee, the NFPA standards council has proceeded with the development of NFPA 660, which will be the combination of all six current NFPA combustible dust standards.
The draft NFPA 660 standard is a massive document (962 pages) consisting of 14 chapters. Chapters 1-9 will include fundamental requirements for all industries. Chapter 11 will feature the old NFPA 61 content.
A combined standard will be more generic, less specific and confusing to standard users. As a result, merging NFPA 61 with the other combustible dust standards will have little to no benefit, as well as having the unintended effect of potentially discouraging its use.
The Occupational Safety and Health Administration (OSHA) promulgated the grain-handling standard (29 CFR 1910.272) in 1988, principally to address combustible dust fires and explosions in the feed and grain industries. The frequency of grain facility explosions have declined dramatically following the implementation of the OSHA grain-handling standard. While voluntary, oftentimes, the NFPA standards provide the most comprehensive set of solutions available to protect facilities and their employees from the hazards of fires and explosions.
On Feb. 14-15 (yes, I spent Valentine’s Day away from my lovely bride of 39 years), I attended the NFPA 660 first draft meeting of the technical committee on agricultural dusts. This technical committee is the old NFPA 61 committee, which I’ve been a part of since 2015. It was a typical NFPA committee meeting, with the normal amount of disagreements among committee members. We spent the better part of two days discussing public comments submitted on the content of NFPA 660, Chapter 11.
After the combustible dust settled (pun intended!), one thing became very clear: once the NFPA combines all combustible dust standards into NFPA 660, we will have an even more confusing environment for our industry facilities concerning combustible dust.
It became apparent that our industry is going to need a lot of explanation on what to do with this massive set of standards. The trade associations representing industry facilities that were a part of this meeting started making plans to begin working on a guidance document to do just that.
So, in the coming months, be on the lookout for an industry guidance document to help you understand how NFPA 660 affects your facility. Just know that in the meantime, if you have questions, you are not alone, and you can feel free to contact me, Gary Huddleston.
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