technical committee on handling and …€¦ · fenwal/iep technologies 400 main street ashland,...

TECHNICAL COMMITTEE ON HANDLING AND CONVEYING OF DUSTS, VAPORS, AND GASES

NFPA 654 CMD-HAP (A2016) First Draft Meeting

The Ritz-Carlton Atlanta

Atlanta, Georgia July 30 – August 1, 2014

8 AM – 5 PM

AGENDA

1. Meeting is called to order at 8 AM

2. Welcome and Self-Introduction of Committee Members and Guests

3. Chair and Staff Liaison Remarks

4. Approve minutes from NFPA 91 CMD-HAP Second Draft Meeting (under separate cover)

5. Review of A2016 Revision Cycle and new NFPA process (Staff Liaison presentation on new process

and procedures, will include membership review and review of schedule)

6. Committee Correspondence

7. Review of Public Input to NFPA 654

8. Old Business

9. New Business and determination of next meeting date and location

10. Adjournment – Meeting will adjourn at 5 pm on all three days.

Address List No PhoneHandling and Conveying of Dusts, Vapors, and Gases CMD-HAP

Combustible Dusts

Susan Bershad07/16/2014

CMD-HAP

Mark L. Runyon

ChairMarsh Risk Consulting111 SW Columbia, Suite 500Portland, OR 97201

I 1/10/2008CMD-HAP

Brice Chastain

PrincipalGeorgia-Pacific LLC133 Peachtree Street NE, 9th FloorAtlanta, GA 30303Alternate: William C. Hilton

U 10/28/2008

CMD-HAP

John M. Cholin

PrincipalJ. M. Cholin Consultants Inc.101 Roosevelt DriveOakland, NJ 07436

SE 1/1/1992CMD-HAP

Burke Desautels

PrincipalFenwal/IEP Technologies400 Main StreetAshland, MA 01721-2150Alternate: Randal R. Davis

M 03/07/2013

CMD-HAP

Tony DiLucido

PrincipalZurich Risk Engineering Services720 Ash AvenueCollingdale, PA 19023Alternate: Robert D. Shafto

I 8/5/2009CMD-HAP

Vahid Ebadat

PrincipalChilworth Technology Inc.113 Campus DrivePrinceton, NJ 08540Alternate: C. James Dahn

SE 7/1/1996

CMD-HAP

Henry L. Febo, Jr.

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

I 4/1/1996CMD-HAP

Larry D. Floyd

PrincipalBASF1379 Ciba RoadMcIntosh, AL 36553

U 8/5/2009

CMD-HAP

Walter L. Frank

PrincipalFrank Risk Solutions, Inc.1110 Shallcross AvenueWilmington, DE 19806

SE 7/1/1994CMD-HAP

Stephen T. Greeson

PrincipalHSB Professional Loss Control3410 Navasota CircleSan Antonio, TX 78259

I 8/5/2009

CMD-HAP

Mark L. Holcomb

PrincipalKimberly-Clark Corporation2001 Marathon AvenueNeenah, WI 54956

U 7/23/2008CMD-HAP

Jerry J. Jennett

PrincipalGeorgia Gulf Sulfur CorporationPO Box 1165Valdosta, GA 31603-1165Alternate: Randall Dunlap

U 1/15/1999

CMD-HAP

David C. Kirby

PrincipalBaker Engineering & Risk Consultants, Inc.1560 Clearview HeightsCharleston, WV 25312Alternate: Philip J. Parsons

SE 1/1/1983CMD-HAP

James F. Koch

PrincipalThe Dow Chemical Company1400 BuildingMidland, MI 48667American Chemistry CouncilAlternate: Glenn W. Baldwin

U 10/28/2008

1


Combustible Dusts


CMD-HAP

Bruce McLelland

PrincipalFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263Alternate: Jérôme R. Taveau

M 3/2/2010CMD-HAP

Jack E. Osborn

PrincipalAirdusco, Inc.4739 Mendenhall Road SouthMemphis, TN 38141

M 1/10/2008

CMD-HAP

Richard Pehrson

PrincipalPehrson Fire PC7455 France Avenue South, Suite 271Edina, MN 55435International Fire Marshals Association

E 3/1/2011CMD-HAP

Jason P. Reason

PrincipalLewellyn Technology321 North 18th AvenueBeech Grove, IN 46107

SE 3/2/2010

CMD-HAP

Ali Reza

PrincipalExponent, Inc.5401 McConnell AvenueLos Angeles, CA 90066-7027Alternate: David B. Clayton

SE 03/05/2012CMD-HAP

James L. Roberts

PrincipalFluor Enterprises, Inc.100 Fluor Daniel DriveGreenville, SC 29607-2762

SE 1/1/1989

CMD-HAP

Samuel A. Rodgers

PrincipalHoneywell, Inc.15801 Woods Edge RoadColonial Heights, VA 23834-6059

U 7/20/2000CMD-HAP

Thomas C. Scherpa

PrincipalThe DuPont Company, Inc.71 Valley RoadSullivan, NH 03445Alternate: Robert L. Gravell

U 3/21/2006

CMD-HAP

Bill Stevenson

PrincipalCV Technology, Inc.15852 Mercantile CourtJupiter, FL 33478Alternate: Jason Krbec

M 1/15/1999CMD-HAP

Jeffery W. Sutton

PrincipalGlobal Risk Consultants Corporation350 Highway 7, Suite 220Excelsior, MN 55331-3170

SE 3/4/2008

CMD-HAP

Robert D. Taylor

PrincipalPRB Coal Users Group4377 Sandra Kay LaneNewburgh, IN 47630

U 8/9/2011CMD-HAP

Tony L. Thomas

PrincipalFlamex, Inc.4365 Federal DriveGreensboro, NC 27313

M 10/27/2009

CMD-HAP

Erdem A. Ural

PrincipalLoss Prevention Science & Technologies, Inc.2 Canton Street, Suite A2Stoughton, MA 02072

SE 7/23/2008CMD-HAP

Harold H. Weber, Jr.

PrincipalThe Sulphur Institute1020 19th Street, NW, Suite 520Washington, DC 20036

VL to Document: 655

U 1/1/1986

2


Combustible Dusts


CMD-HAP

Glenn W. Baldwin

AlternateThe Dow Chemical CompanyPO Box 8361South Charleston, WV 25303American Chemistry CouncilPrincipal: James F. Koch

U 03/07/2013CMD-HAP

Amy Brown

AlternateFM Global1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Principal: Henry L. Febo, Jr.

I 03/03/2014

CMD-HAP

David B. Clayton

AlternateExponent, Inc.5401 McConnell AvenueLos Angeles, CA 90066-7027Principal: Ali Reza

SE 10/29/2012CMD-HAP

C. James Dahn

AlternateSafety Consulting Engineers Inc.2131 Hammond DriveSchaumburg, IL 60173Principal: Vahid Ebadat

SE 1/1/1989

CMD-HAP

Randal R. Davis

AlternateIEP Technologies417-1 South StreetMarlborough, MA 01752-3149Principal: Burke Desautels

M 10/29/2012CMD-HAP

Randall Dunlap

AlternateGeorgia Gulf Sulfur CorporationPO Box 67Bainbridge, GA 39818Principal: Jerry J. Jennett

U 3/2/2010

CMD-HAP

Robert L. Gravell

AlternateThe DuPont Company, Inc.Chambers Works SiteExplosion Hazards LaboratoryMail Spot WWTP ‘O’Deepwater, NJ 08023Principal: Thomas C. Scherpa

U 3/4/2009CMD-HAP

William C. Hilton

AlternateGeorgia-Pacific133 Peachtree Street, NEAtlanta, GA 30303Principal: Brice Chastain

U 7/23/2008

CMD-HAP

Jason Krbec

AlternateCV Technology, Inc.15852 Mercantile CourtJupiter, FL 33478Principal: Bill Stevenson

M 3/1/2011CMD-HAP

Philip J. Parsons

AlternateBaker Engineering & Risk Consultants, Inc.1406 West Lynnwood AvenueSan Antonio, TX 78201Principal: David C. Kirby

SE 8/9/2011

CMD-HAP

Robert D. Shafto

AlternateZurich Insurance1093 Tall Pines TrailHighland, MI 48356Principal: Tony DiLucido

I 8/5/2009CMD-HAP

Jérôme R. Taveau

AlternateFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263Principal: Bruce McLelland

M 03/07/2013

3



CMD-HAP

Matthew I. Chibbaro

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

E 3/4/2009CMD-HAP

Harry Verakis

Nonvoting MemberUS Department of LaborMine Safety & Health AdministrationApproval & Certification CenterIndustrial Park Road, Box 251Triadelphia, WV 26059

E 1/1/1974

CMD-HAP

William R. Hamilton

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

E 3/4/2009CMD-HAP

Susan Bershad

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

04/16/2014

4

2016 ANNUAL REVISION CYCLE *Public Input Dates may vary according to standards and schedules for Revision Cycles may change. Please check the NFPA Website for the most up‐to‐date information on Public Input Closing Dates and schedules at

www.nfpa.org/document # (i.e. www.nfpa.org/101) and click on the Next Edition tab.

Process Stage

Process Step

Dates for TC

Dates forTC with

CC Public Input Closing Date for Paper Submittal* 6/6/2014 6/6/2014

Public Input Closing Date for Online Submittal (e‐PI)* 7/7/2014 7/7/2014

Final Date for TC First Draft Meeting 12/12/2014 9/12/2014

Public Input Posting of First Draft and TC Ballot 1/30/2015 10/24/2014

Stage Final date for Receipt of TC First Draft ballot 2/20/2015 11/14/2014

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2/27/2015 11/21/2014

Posting of First Draft for CC Meeting 11/28/2014

Final date for CC First Draft Meeting 1/9/2015

Posting of First Draft and CC Ballot 1/30/2015

Final date for Receipt of CC First Draft ballot 2/20/2015

Final date for Receipt of CC First Draft ballot ‐ recirc 2/27/2015

Post First Draft Report for Public Comment 3/6/2015 3/6/2015

Public Comment Closing Date for Paper Submittal* 4/10/2015 4/10/2015

Public Comment Closing Date for Online Submittal (e‐PC)* 5/15/2015 5/15/2015

Final Date to Publish Notice of Consent Standards (Standards that received no Comments)

5/29/2015 5/29/2015

Appeal Closing Date for Consent Standards (Standards that received no Comments)

6/12/2015 6/12/2015

Final date for TC Second Draft Meeting 10/30/2015 7/24/2015

Comment Posting of Second Draft and TC Ballot 12/11/2015 9/4/2015

Stage Final date for Receipt of TC Second Draft ballot 1/4/2016 9/25/2015

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 1/11/2016 10/2/2015

Draft) Posting of Second Draft for CC Meeting 10/9/2015

Final date for CC Second Draft Meeting 11/20/2015

Posting of Second Draft for CC Ballot 12/11/2015

Final date for Receipt of CC Second Draft ballot 1/4/2016

Final date for Receipt of CC Second Draft ballot ‐ recirc 1/11/2016

Post Second Draft Report for NITMAM Review 1/18/2016 1/18/2016

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 2/19/2016 2/19/2016

Preparation Posting of Certified Amending Motions (CAMs) and Consent Standards

4/15/2016 4/15/2016

(& Issuance) Appeal Closing Date for Consent Standards 5/3/2016 5/3/2016

SC Issuance Date for Consent Standards 5/13/2016 5/13/2016

Tech Session Association Meeting for Standards with CAMs 6/6‐9/2016 6/6‐9/2016

Appeals and Appeal Closing Date for Standards with CAMs 6/29/2016 6/29/2016

Issuance SC Issuance Date for Standards with CAMs 8/4/2016 8/4/2016

Approved:__October 30, 2012 Revised___March 7, 2013_____________________

Public Input No. 17-NFPA 654-2014 [ Section No. 1.2 ]

1.2 Purpose.

The purpose of this standard is to prescribe technical requirements for safety to life and property from fireand or explosion and to minimize the resulting damage from a fire or explosion.

Statement of Problem and Substantiation for Public Input

Changing the "and" to "or" will clarify that the purpose is to address either fire or explosions exclusive of each other.

Submitter Information Verification

Submitter Full Name: Jim Muir

Organization: Building Safety Division, Clark County, Washington

Affilliation: NFPA's Building Code Development Committee (BCDC)

Street Address:

City:

State:

Zip:

Submittal Date: Tue May 20 13:51:51 EDT 2014

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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1.2 Purpose.

The purpose of this standard is to prescribe technical requirements for necessary to manage safety to lifeand property from fire, flash fire and explosion hazards involving combustible particulate solids and/orhybrid mixtures and to minimize the resulting damage from a fire or explosion involving combustibleparticulate solids and/or hybrid mixtures .


Substantiation: The suggested change is needed to make the purpose consistent with scope of standard. In addition, the title of the standard should be modified to include hybrid mixtures, provided they are actually within the official scope of the committee’s jurisdiction.


Submitter Full Name: MARIE MARTINKO

Organization: SPI

Street Address:

City:

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Submittal Date: Sun Jul 06 21:03:56 EDT 2014


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1.3 Goal.

The goal of this standard is to provide safety measures to prevent and mitigate fires and dust explosionsreduce, to an acceptable level, the risks to safety of life and property from fire and explosion involvingcombustible particulate solids and/or hybrid mixtures in facilities that handle combustible particulate solidsand/or hybrid mixtures .


Substantiation: As recognized by Section 4.1 in NFPA 664, and the retroactivity provisions in draft NFPA 652, there is a need to clearly state the overarching goal to be achieved by a safety standard, which is reducing the risk of significant harm to an acceptable level in the most cost-effective manner. The recommended language would accomplish that objective.


This PI has not been submitted yet


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1.4 Application.

1.4.1

General

This standard shall apply to all facilities and operations manufacturing, processing, blending, conveying,repackaging, generating, or handling combustible dusts, combustible particulate solids and/or hybridmixtures.

1.4.2 Exceptions: This standard shall not apply to the following:

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

(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 orhousehold use or as building materials

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

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

1.4.3

This standard shall not apply to materials covered by the following documents, unless specificallyreferenced by the applicable document:

(1) NFPA 30B, Code for the Manufacture and Storage of Aerosol Products

(2) NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials

(3) NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and FoodProcessing Facilities

(4) NFPA 85, Boiler and Combustion Systems Hazards Code

(5) NFPA 120, Standard for Fire Prevention and Control in Coal Mines

(6) NFPA 400, Hazardous Materials Code

(7) NFPA 484, Standard for Combustible Metals

(8) NFPA 495, Explosive Materials Code

(9) NFPA 655, Standard for Prevention of Sulfur Fires and Explosions

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

(11) NFPA 1124, Code for the Manufacture, Transportation, Storage, and Retail Sales of Fireworks andPyrotechnic Articles

(12) NFPA 1125, Code for the Manufacture of Model Rocket and High Power Rocket Motors

1.4.2 4

In the event of a conflict between this standard and a specific occupancy standard, the specific occupancystandard requirements shall apply.


Substantiation: From draft NFPA 652, Section 1.3.


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Organization: SPI

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 07 14:09:50 EDT 2014


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Public Input No. 61-NFPA 654-2014 [ Section No. 1.5 [Excluding any Sub-Sections] ]

The provisions of this standard reflect a consensus, among the members of the NFPA committee thatauthored this standard, of what is necessary to provide an acceptable degree of protection from thehazards addressed in this standard at the time the standard was issued.


Substantiation: The recommended language would clarify the meaning of the phrase “a consensus” as used in this section. An NFPA standard is adopted on the basis of a consensus of the committee, which does not necessarily represent a consensus of all experts in a particular field or a consensus among the NFPA membership. For example, the NFPA membership is not given an opportunity to vote on a standard unless a NITMAM is filed, and then only as to the scope of the NITMAM. Furthermore, even if the NFPA membership votes to uphold a NITMAM in a floor vote at the annual technical meeting, the technical committee that authored the standard has the authority to reject the floor vote. According to the Standards Council, “This means, under NFPA rules, that no change from the existing edition [of the standard] should occur.” In the event of an appeal of the technical committee action rejecting the floor vote, the Standards Council takes the position that the appeal seeks to “overturn the action that was recommended by the codes and standards development process” and has a policy of deferring to the outcome of the standards development process as indicated by its recent decision in D#12-8, Standards Council Agenda Item: SC#12-8-5-b-1, 9 August, 2012:

On appeal, the Council accords great respect and deference to the NFPA codes and standards development process. In conducting its review, the Council will overturn the result recommended through that process only where a clear and substantial basis for doing so is demonstrated. The Council has reviewed the entire record concerning this matter and has considered all the arguments put forth in this appeal. In the view of the Council, this appeal does not present any clear and substantial basis on which to overturn the results yielded by the NFPA codes and standards development process. Accordingly, the Council has voted to deny the appeal.



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Public Input No. 62-NFPA 654-2014 [ Section No. 1.5.2 ]

1.5.2

In those cases where the authority having jurisdiction determines that the existing situation presents anunacceptable degree of risk, the authority having jurisdiction shall be permitted to apply retroactively, to theextent reasonably practical, any portions of this standard deemed appropriate. that, based on theapplication of clear criteria derived from the objectives in this standard, the AHJ determines to benecessary to achieve an acceptable degree of risk. In situations where there are multiple ways of achievingan acceptable degree of risk, the AHJ will permit the owner/operator to choose the alternative it reasonablydetermines is best suited to its situation.


Substantiation: This is a suggested modification of the language in Section 1.6.3 of draft NFPA 652. This provision is clearly directed at the situation where the AHJ is a government enforcement official. It deals primarily with the retroactive application of requirements to the design, construction and installation of structures and equipment that were approved by the local building code authority at the time of construction or installation. The existing language creates an exception to the normal rule that a requirement is not retroactive. Under those circumstances, it is only fair to place the burden on the government AHJ to demonstrate that there is an unacceptable degree of risk and that a particular measure is practical and necessary. It contains criteria designed to ensure that implementation of this potentially severe requirement will be carried out in a fair and reasonable manner, but does not clearly include the condition that retroactive application is practical. Furthermore it does not require the AHJ to provide the critical documented support for its determinations. That documentation is necessary to provide the regulated facility with the ability to verify the AHJ acted in an appropriate manner. The existing language also fails to ensure that, where there is more than one retroactive measure that can be implemented to achieve an acceptable degree of risk, the facility is given the flexibility to choose the alternative best suited to its situation.In some cases, such as where silos/bins are constructed according to a design that does not permit explosion protection, retroactive application of that requirement would be not only clearly impractical, but infeasible. It would not be appropriate to adopt a requirement that appears to authorize a government agency (AHJ) to impose an infeasible or impractical requirement on the facility owner/operator, such as protecting a silo/bin or requiring monitoring of thousands of bearings, in situations where the AHJ or another government agency issued a building permit or an electrical permit authorizing the construction/installation without that feature. It also would not be appropriate to adopt a requirement that appears to authorize a government agency (AHJ) to impose whatever measures it deems appropriate. It is essential that the AHJ make a determination based on the application of clearly stated, sound and objective criteria and impose only those requirements determined to be necessary to achieve an acceptable level of risk.



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1.5.3

The retroactive requirements of this standard shall be permitted to be modified if their application clearlywould be impractical in the judgment of the authority having jurisdiction, and only where unless it is clearlyevident that a reasonable degree of safety is provided the modification would result in an unacceptabledegree of risk. In situations where there are multiple ways of achieving an acceptable degree of risk, theAHJ will permit the owner/operator to choose the alternative it reasonably determines is best suited to itssituation .


Substantiation: Section 1.6.4 of draft NFPA 652 offers an improvement by recognizing the concept of an acceptable degree of risk. However, when imposing retroactive requirements that require changes to previously acceptable conditions or practices, the affected entity should not be required to shoulder an elevated burden of proof (“clear evidence”) before obtaining relief from the imposition of those retroactive requirements. Furthermore, where there is more than one retroactive measure that can be implemented to achieve an acceptable degree of risk, the facility should be given the flexibility to choose the alternative best suited to its situation.



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1.5.4

This standard shall apply to facilities on which construction is begun subsequent to the date of publicationof the standard.


Substantiation: This provision is not in draft NFPA 652 and is adequately addressed by (and conflicts with) existing provision 1.5.1, which reads as follows:

1.5.1 Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard. Where specified, the provisions of this standard shall be retroactive.



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1.6.1

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


Substantiation: reflects language of draft NFPA 652. This standard should not be mandating an approval process by a government agency or insurance carrier.



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1.6.2

The owner/operator shall be able to demonstrate to the authority having jurisdiction that the alternativesystem, method, or device shall be approved is suitable for the intended purpose by the authority havingjurisdiction .


Substantiation: The alternative should not be limited to those approved by the AHJ or automatically require the approval of the AHJ.



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Public Input No. 20-NFPA 654-2014 [ Chapter 2 ]

Chapter 2 Referenced Publications

2.1 General.

The documents or portions thereof listed in this chapter are referenced within this standard and shall beconsidered part of the requirements of this document.


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2.2 NFPA Publications.


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

NFPA 10, Standard for Portable Fire Extinguishers, 2010 edition 2013 .

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

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

NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems, 2009 edition .

NFPA 13, Standard for the Installation of Sprinkler Systems, 2013 edition .

NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 2010 edition 2013 .

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

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

NFPA 17, Standard for Dry Chemical Extinguishing Systems, 2009 edition 2013 .

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

NFPA 30B, Code for the Manufacture and Storage of Aerosol Products, 2011 edition .

NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials, 2011 edition .

NFPA 51B, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2009 edition 2014.

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

NFPA 68, Standard on Explosion Protection by Deflagration Venting, 2007 edition 2013 .

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

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

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

NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 edition .

NFPA 85, Boiler and Combustion Systems Hazards Code, 2011 edition .

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

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

NFPA 101® , Life Safety Code®, 2012 edition 2015 .

NFPA 120, Standard for Fire Prevention and Control in Coal Mines, 2010 edition .

NFPA 220, Standard on Types of Building Construction, 2012 edition .

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

NFPA 400, Hazardous Materials Code, 2013 edition .

NFPA 484, Standard for Combustible Metals, 2012 edition .

NFPA 495, Explosive Materials Code, 2010 edition 2013 .

NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment, 2008 edition 2013.

NFPA 505, Fire Safety Standard for Powered Industrial Trucks Including Type Designations, Areas of Use,Conversions, Maintenance, and Operations, 2011 edition 2013 .

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 WoodworkingFacilities, 2012 edition .

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


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NFPA 780, Standard for the Installation of Lightning Protection Systems, 2011 edition 2014 .

NFPA 1124, Code for the Manufacture, Transportation, Storage, and Retail Sales of Fireworks andPyrotechnic Articles, 2013 edition .

NFPA 1125, Code for the Manufacture of Model Rocket and High Power Rocket Motors, 2012 edition .

NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2012 edition .

NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments forProtection of Industrial Personnel Against Flash Fire, 2012 edition 2015 .

2.3 Other Publications.

2.3.1 AMCA Publications.

Air Movement and Control Association International, Inc., 30 West University Drive, Arlington Heights, IL60004-1893.

AMCA 99-0401-86, Classifications for Spark Resistant Construction , Standards Handbook , 2010.

2.3.2 ASME Publications.

American Society of Mechanical Engineers, Three Park Avenue, New York, NY 10016-5990.

ASME B31.3, Process Piping, 2008 2012 .

ASME Boiler and Pressure Vessel Code, 2007 2013 .

2.3.3 ASTM Publications.

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

ASTM E 2019, Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air, 2003 (2007) ,reapproved 2013 .

ASTM E 1226, Standard Test Method for Explosibility of Dust Clouds, 2010 2012A

2.3.4 IEC Publications.

International Electrotechnical Commission, 3, rue de Varembé, P.O. Box 131, CH-1211 Geneva 20,Switzerland.

IEC 61340-4-4, Electrostatics — Part 4-4: Standard Test Methods for Specific Applications — ElectrostaticClassification of Flexible Intermediate Bulk Containers (FIBC), 2005 2012 .

2.3.5 ISA Publications.

Instrumentation, Systems, and Automation Society, P.O. Box 12277, Research Triangle Park, NC 27709.

ISA 84.00.01, Functional Safety: Application of Safety Instrumented Systems for the Process IndustrySector - Part 1: Framework , Definitions, System, Hardware and Software Requirements , 2004.

2.3.6 NEMA Publications.

National Electrical Manufacturers Association, 1300 North 17th Street, Suite 1847, Rosslyn, VA 22209.

NEMA 250, Enclosures for Electrical Equipment, 2008.

2.3.7 U.S. Government Publications.

U.S. Government Printing Office, Washington, DC 20402.

Title 29 CFR Part 1910.242(b), “Hand and Portable Powered Tools and Equipment, General.”

2.3.8 Other Publications.

Merriam-Webster's Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.

2.4 References for Extracts in Mandatory Sections.


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

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

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


Referenced current editions and titles.


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Related Public Inputs for This Document

Related Input Relationship

Public Input No. 21-NFPA 654-2014 [Chapter G]


Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jun 12 22:34:56 EDT 2014


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ASTM E 2019, Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air, 2003(2007 2013 ).

ASTM E 1226, Standard Test Method for Explosibility of Dust Clouds, 2010 2012a


Update the year date for standard(s)


Submitter Full Name: Steve Mawn

Organization: ASTM International

Street Address:

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ASTM E 2019 E2019 , Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air, 2003(2007 2013 ).

ASTM E 1226 E1226 , Standard Test Method for Explosibility of Dust Clouds, 2010 2012a.

ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 Degrees C(2012)

ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-shapedAirflow Stabilizer, at 750 Degrees C (2012)

ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials (2012a).


update



Public Input No. 49-NFPA 654-2014 [New Section after 4.7]


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

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Submittal Date: Thu Jul 03 13:07:45 EDT 2014


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3.3.3 * Air-Moving Device (AMD).

A power-driven fan, blower, or other device that establishes an airflow by moving a given volume of air perunit time.[ 91 , 2010]


Picked up the same reference for extracted material that is used in NFPA 61 after the same definition.


Submitter Full Name: Bill Galloway

Organization: Southern Regional Fire Code De

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Submittal Date: Thu Apr 17 16:52:11 EDT 2014


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3.3.4 * Centralized Vacuum Cleaning System.

A fixed-pipe system utilizing variable-volume negative-pressure (i.e., vacuum) air flows from pneumaticconveying system using remotely located hose connection stations to allow the removal vacumming ofcombustibe dust accumulations from surfaces and conveying those dusts to an air-material separator(AMS).(61)


The language of the definition is flawed. The proposed definition mirrors the language used in NFPA 61 for the same system.




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Delete this complete definition and its Annex

3.3.5* Combustible Dust.

A finely divided combustible particulate solid that presents a flash fire hazard or explosion hazard whensuspended in air or the process-specific oxidizing medium over a range of concentrations.


It appears that limitations imposed upon the Committee by the NFPA Style manual prevent properly identifying the complexity of combustible dusts as a defined term. Additionally placing critical information into an Annex which is only considered a source of information and not requirements further dilutes the essential aspects of why combustible dusts are potential hazards requiring extra precautions. Combustible dusts need to be addressed with specific requirements. Therefore rather than continue to struggle with achieving agreement on a single sentence statement which cannot contain requirements, but needs valid critieria to enable proper understanding of the nature of identification of the potential hazards, removal of the term needs to be done with action to provide a section under PI 34 which addresses 'combustible dusts'.


Submitter Full Name: David Wechsler


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3.3.5* Combustible Dust.

A finely divided combustible particulate solid that presents a flash fire hazard or explosion hazard whensuspended in air or the process-specific oxidizing medium over a range of concentrations. A dust found tobe explosible using one of the following test methodologies is considered to be a combustible dust:

(1) The "Go/No-Go" screening test methodology described in ASTM E 1226

(2) ASTM E 1515

(3) An equivalent test methodology


Substantiation: The proposed standard fails to make an explicit link between the determination that a dust is explosible and the identification of that material as a combustible dust. This suggested language provides that linkage.



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Delete this defined term and the Annex material

3.3.6* Combustible Particulate Solid.

Any solid material composed of distinct particles or pieces, regardless of size, shape, or chemicalcomposition that presents a fire hazard.


This term attempts to define Combustible Particulate Solids using terms (Combustible, Particulate, Solids) having meanings already contained in Merriam-Webster's Collegiate Dictionary and therefore under 3.1 General should not require the suggestion that these are unique or special terms. The term fire hazard may be understood as being 'combustible' however in the context with this document, this understanding is also not clear. Actions taken by the introduction of a new section to full discuss this important material aspect has been made and this material does address these important concerns about the material potential hazards related to fire incidents. This new section also makes providing a definition no longer a need.




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3.3.6* Combustible Particulate Solid.

Any solid material composed of distinct particles or pieces, regardless of size, shape, or chemicalcomposition that presents a fire hazard. when processed, stored or handled in the facility has the potentialto produce a combustible dust. A dust that would ignite and propagate combustion in a screening testbased on the UN Recommendations on the Transport of Dangerous Goods: Model Regulations - Manual ofTests and Criteria, Part III, Subsection 33.2.1, Test N.1 is considered a combustible particulate solid.


Substantiation: The concept of producing a combustible dust is provided by draft NFPA 652, Section 3.3.6. The phrase “presents a fire hazard” does not provide meaningful guidance and does not reflect the requirements of the standard, which are specified in proposed Paragraph 5.4.1.1. The recommended language achieves the objective of the standard by defining the term “combustible” in the way intended by the standard – i.e., based on the objective testing criteria specified in proposed Paragraph 5.4.1.1.



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3.3.10 Detachment.

Locating a combustible particulate solid process in the open air or in Location in a separate building or anoutside area removed from other structures to be protected by a distance as required by this standard .


Substantiation: From draft NFPA 652, Section 3.3.9. The meaning of “open air” was ambiguous.



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Public Input No. 70-NFPA 654-2014 [ New Section after 3.3.11 ]

3.3.xx Duct.

Pipes, tubes or other enclosures used for the purpose of conveying materials pneumatically or by gravity.


From draft NFPA 652, Section 3.3.10. This term is used extensively and needed to be defined.



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3.3.X.1 Dust Deflagration HazardThe presence of explosible dust that is suspended in an oxidizing medium in concentrations at or above itsminimum explosive concentration; or the presence of accumulations of explosible dust where a means ofsuspending the dust is present.


Substantiation: From draft NFPA 652, Section 3.3.13.



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3.3.X.2 Dust Explosion Hazard

A dust deflagration hazard in an enclosure that is capable of bursting or rupturing the enclosure due to thedevelopment of internal pressure from the deflagration.





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3.3.X.3* Enclosure.A confined or partially confined volume. [68, 2007]





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3.3.12* Dust Collection System.

A combination of equipment designed to capture, contain, and pneumatically convey , collect, and removeairborne dusts from the airstream fugitive dust to an AMS in order to remove the dust from the proccessequipment or surrounding area .





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3.3.X.4 Fire Hazard.Any situation, process, material, or condition that, on the basis of applicable data, can cause a fire orprovide a ready fuel supply to augment the spread or intensity of a fire and poses a threat to life or property.





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3.3.21* Noncombustible Material.

A material that, in the form in which it is used and under the conditions anticipated, will not ignite, supportcombustion, burn, or release flammable vapors when subjected to fire or heat. (see 4.7).


The definition from NFPA 101 is being extracted and placed where it belongs, within a mandatory section of the document. The Manual of Style states that definitions are not enforceable. Moreover, this definition conflicts with those in other NFPA documents. Note that the reference in parentheses addresses the proposed new section and not the existing 4.7 section. Note also that the annex note is not proposed to be changed.



Public Input No. 49-NFPA 654-2014 [New Section after 4.7]




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Public Input No. 76-NFPA 654-2014 [ Section No. 3.3.23 [Excluding any Sub-Sections] ]

An equipment system that comprises transfers a controlled flow of solid particulate material from onelocation to another using air or other gases as the conveying medium, and that is comprised of the followingcomponents: a material feeding device; an and enclosed ductwork, piping , or tubing network; anair-material separator; and an air-moving device and that is used to transfer a controlled flow of solidparticulate material from one location to another using air or other gases as the conveying medium .


Substantiation: From draft NFPA 652, Section 3.3.23. The existing language is confusing and grammatically incorrect. The suggested changes clarify the language and eliminate the grammatical errors.



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3.3.25 Segregation.

The interposing establishment of a fire- and explosion-resistant physical barrier between the combustibleparticulate solid process and other operations hazard area and an area to be protected .


Substantiation: From draft NFPA 652, Section 3.3.31. The existing paragraph is ambiguous, but does not appear to be broad enough to encompass the variety of situations that may exist at a facility. The phrase “other operations” should, but does not appear to contemplate and include segregation of one combustible particulate process from another combustible particulate processes or the possibility that this segregation might effectively isolate one part of a combustible particulate process from another part of the same combustible particulate process. The recommended changes address those other possibilities.



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3.3.X.12 Threshold Housekeeping Dust Accumulations.

The maximum quantity of dust permitted to be present before cleanup is required as determined by Section6.1.3, 6.1.4, 6.1.5, or 6.1.6.


Substantiation: Need for definition is clear from inclusion in draft NFPA 652, Section 3.3.34. This suggested definition simply references the existing criteria in the standard.



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3.3.X.9 Dust Hazards Analysis.A systematic review to identify and evaluate the potential fire, flash fire, and explosion hazards associatedwith the presence of one or more combustible particulate solids in a process or facility.





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3.3.X.10 Qualified Person.A person who, by possession of a recognized degree, certificate, professional standing, or skill, and who,by knowledge, training, and experience, has demonstrated the ability to deal with problems related to thesubject matter, the work, or the project. [1451, 2013]





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3.3.X.11* Risk Assessment.

An assessment of the likelihood, vulnerability, and magnitude of the incidents that could result fromexposure to hazards.


Substantiation: From draft NFPA 652, Section 3.3.30. A risk assessment approach is needed to avoid adopting a zero risk standard in which control measures are required by the mere presence of a hazard regardless of the magnitude of the risk.



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Public Input No. 40-NFPA 654-2014 [ New Section after 4.1 ]

TITLE OF NEW CONTENT

(title change) Chapter 4 Combustible Dusts and Combustible Particulate Solid

Add new the following new sections and renumber accordingly:

4.1 General.

4.1.1 Criteria for Combustible Dust Ignition. The pertinent criteria for ignition of any combustible dust cloudor layer include the following:

(1) Air

(2) The material form either dispersed in air (oxidant) at or exceeding the minimum explosible concentration(MEC) for an explosion or in a layer at or exceeding the layer ignition temperature

(3) Ignition source(s) such as an electrostatic discharge, an electric current arc or spark, a glowing ember, ahot surface, welding slag, frictional heat, or a flame

4.1.2 Material Form.

4.1.2.1 Dust discharged or leaking from equipment into the atmosphere will exist in the air as a cloud andover time will settle due to gravity, resulting in an accumulated dust layer. In some

cases, both a cloud and a layer could exist simultaneously.

4.1.2.2 The size and density of the dust particles, the internal pressure propelling the dust out of theequipment, the size of the leak opening, the elapsed time of emission, the height of

the emission, and air currents in the vicinity all contribute to the cloud and layer presence.

4.1.2.3 Dust in process vessels, in air-material separators, or in transport systems can exist as a cloud andcould settle, resulting in an accumulated dust layer. In some cases, both a cloud and a layer could existsimultaneously.

4.1.3 Combustible Dust Clouds.

4.1.3.1 Combustible dust clouds have the potential to cause significant overpressures or explosions whenignited. Some dusts have particles that are extremely fine and light (i.e., have

a low specific particle density). Such particles could behave similar to vapors and could remain insuspension for long periods. These particles could travel far from the emitting source and could collect aslayers on surfaces above the source.

4.1.3.2* Generally, as particle size increases, the ability of the combustible dust to remain in a clouddecreases, but the creation of combustible dust layers increases.

A.4.1.3.2 Dust discharged or leaking from equipment into the atmosphere will settle relatively quickly,depending on the size of particles, the internal pressure propelling the particles from the equipment, andany air currents in the vicinity. The result is a layer of dust that settles on surfaces below the leak opening ina radial or elliptical manner, depending on the location of the opening on the equipment. Althoughhorizontal

surfaces accumulate the largest quantities of dust, vertical surfaces could in som instances alsoaccumulate significant quantities. The depth of the layer will be greatest under and

close to the source and will taper off to the outside of the circle or ellipse.

4.1.3.3 A combustible dust cloud can be ignited on contact with a hot surface. Typically, the cloud ignitiontemperature is higher than the layer ignition temperature; however, if a material melts when in a layer, theopposite is often true.

4.1.3.4 The application of hazardous area classification, while reducing the risk of ignition from electricalsources, does not address the potential overpressure effects from a combustible dust explosion or hazardsfrom a flash fire. Other NFPA standards address such hazards.

4.1.4 Combustible Dust Layers.

4.1.4.1 Not only do combustible dust layers have the potential to be ignited, but depending on the speed ofthe burning, the dust could also be dispersed into the air as a cloud. If the dust is ignited, a dust flash fire


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could result. Airflow induced by such an event will disperse more dust from the layer into the air, resulting ina larger explosion. Often, the secondary explosion

does more damage.

4.1.4.2 Combustible dust layers can cause electrical equipment to overheat because they tend to act asinsulation. The overheated electrical equipment can result in an ignition of the dust layer, which could thenresult in ignition of a dust cloud.

4.1.4.3 Generally, as solid particle size decreases, the layer ignition temperature also decreases, makingthe combustible dust easier to ignite.

4.1.4.4* The ignition temperature of a layer of organic dust on heat-producing equipment can decrease overtime if the dust dehydrates or carbonizes. For such materials, NFPA 70, National

Electrical Code, specifies that the surface temperature of the heat-producing equipment not exceed thelower of the ignition temperature or 165°C (329°F).

A.4.1.4.4 Combustible dust layers can cause electrical equipment to overheat because these layers tend toact as insulation. In many instances, the increased temperature

resulting from overheating can also cause moisture in the dust to be driven off, thus dehydrating the dust.Further heating of the dust could additionally result in the formation

of a carbonized dust layer. Both conditions are known to cause the layer ignition temperature to decrease.Unfortunately, the lack of standardized tests prevents having a means to correlate how the layer ignitiontemperature could decrease due to dehydrating

or carbonization effects.

4.1.4.5 Some dusts in layers that melt before reaching their layer ignition temperatures act more like acombustible liquid than a combustible dust. These dusts require additional testing to determine if the cloudignition temperature is lower than the layer ignition temperature.

4.2 Combustible Dust Testing.

4.2.1 Testing under this section can be done to verify if the dust is a combustible dust.

A4.2.1 Combustible Dust. Dusts traditionally were defined as material 420 μm or smaller (capable ofpassing through a U.S. No. 40 standard sieve). For consistency with other standards,

500μm(capable of passing through a U.S. No. 35 standard sieve) is now considered an appropriate sizecriterion. 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 diameter usuallydo not pass through a 500 μm sieve, yet could still pose a deflagration hazard. Many particulatesaccumulate electrostatic charge 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 asignificant hazard. Consequently, it can be inferred that any particulate that has a minimum dimension lessthan or equal to 500 μm could behave as a combustible dust if suspended in air or the process specificoxidizer. If the minimum

dimension of the particulate is greater than 500 μm, it is unlikely that the material would be a combustibledust, as determined by test. The determination of whether a sample of combustible material presents aflash fire or explosion hazard could be based on a screening test methodology such as provided in theASTM E 1226, Standard Test Method for Explosibility of Dust Clouds. Alternatively, a standardized testmethod such as ASTM E 1515, Standard Test Method for Minimum Explosible Concentration ofCombustible Dusts, could be used to determine dust explosibility.

There is some possibility that a sample will result in a false positive in the 20 L sphere when tested by theASTM E 1226 screening test or the ASTM E 1515 test. This is due to the high

energy ignition source overdriving the test. When the lowest ignition energy allowed by either method stillresults in a positive result, the owner/operator can elect to determine whether the sample is a combustibledust with screening tests performed in a larger scale (≥1 m3) enclosure, which is less susceptible tooverdriving and thus will provide more realistic

results.

This possibility for false positives has been known for quite some time and is attributed to “overdriven”conditions that exist in the 20 L chamber due to the use of strong pyrotechnic


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igniters. For that reason, the reference method for explosibility testing is based on a 1 m3 chamber, and the20 L chamber test method is calibrated to produce results comparable to

those from the 1 m3 chamber for most dusts. In fact, the U.S. standard for 20 L testing (ASTM E 1226)states, “The objective of this test method is to develop data that can be correlated to

those from the 1 m3 chamber (described in ISO 6184-1 and VDI 3673)…” ASTM E 1226 further states,“Because a number of factors (concentration, uniformity of dispersion, turbulence

of ignition, sample age, etc.) can affect the test results, the test vessel to be used for routine work must bestandardized using dust samples whose KSt and Pmax parameters are

known in the 1 m3 chamber.”

NFPA68, Standard on Explosion Protection by Deflagration Venting, also recognizes this problem andaddresses it stating that “the 20 L test apparatus is designed to simulate results of the 1 m3 chamber;however, the igniter discharge makes it problematic to determine KSt values less than 50 bar-m/sec. Wherethe material is expected to yield KSt values less than 50 bar-m/sec, testing in a 1m3 chamber might yieldlower values.”

Any time a combustible dust is processed or handled, a potential for deflagration exists. The degree ofdeflagration hazard varies, depending on the type of combustible dust and

the processing methods used. A dust deflagration has the following four requirements:

(1) Combustible dust

(2) Dust dispersion in air or other oxidant

(3) Sufficient concentration at or exceeding the minimum explosible concentration (MEC)

(4) Sufficiently powerful ignition source such as an electrostatic discharge, an electric current arc, a glowingember, a hot surface, welding slag, frictional heat, or a flame.

If the deflagration is confined and produces a pressure sufficient to rupture the confining enclosure, theevent is, by definition, an “explosion.”

Evaluation of the hazard of a combustible dust should be determined by the means of actual test data.Each situation should be evaluated and applicable tests selected. The following list represents the factorsthat are sometimes used in determining the deflagration hazard of a dust:

(1) MEC

(2) MIE

(3) Particle size distribution

(4) Moisture content as received and as tested

(5) Maximum explosion pressure at optimum concentration

(6) Maximum rate of pressure rise at optimum concentration

(7) KSt (normalized rate of pressure rise) as defined in ASTM E 1226, Standard Test Method forExplosibility of Dust Clouds

(8) Layer ignition temperature

(9) Dust cloud ignition temperature

(10) Limiting oxidant concentration (LOC) to prevent ignition

(11) Electrical volume resistivity

(12) Charge relaxation time

(13) Chargeability

It is important to keep in mind that as a particulate is processed, handled, or transported, the particle sizegenerally decreases due to particle attrition. Consequently, it is often necessary to evaluate the explosibilityof the particulate at multiple points along the process. Where process conditions dictate the use of oxidizingmedia other than air (nominally taken as 21 percent oxygen and 79 percent nitrogen), the applicable testsshould be conducted in the appropriate process specific medium.

{end Annex material}

4.2.2 Combustible Dust Cloud Explosibility Testing.

4.2.2.1 ASTM E 1226, Standard Test Method for Explosibility of Dust Clouds, should be applied as a


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screening pass/fail test. This methodology looks at two different cloud concentrations of the material form,1000 g/m3 and 2000 or more g/m3 (35 oz/ft3 and 70 oz/ft3), which are tested for explosibility within a 20 L(5.3 gal) or larger chamber using a 5 kJ or larger igniter.

4.2.2.2 If either concentration tested under 4.2.2.1 equals or exceeds the ASTM E 1226 maximum attainedpressure criteria, the sample is conditionally a combustible dust.

4.2.2.3 If both concentrations tested under 4.2.2.1 are less than the ASTM E 1226 maximum attainedpressure criteria, the sample is likely not a combustible dust.

4.2.3 Combustible Dust Layer Ignition Temperature Testing.

4.2.3.1 This test is necessary to provide design information relating to the surface temperature conditionsunder which a material form of a particular size and density, when falling out of the air or deposited ontoelectrical equipment, could heat up above ambient to its layer ignition temperature.

4.2.3.2 The ASTM E 2021, Standard Test Method for Hot-Surface Ignition Temperature of Dust Layers, testis applied using a hot plate with at least a 12.7 mm (1⁄2 in.) dust layer in the material

form to verify the ability of a material to absorb heat and lose heat by radiation. At a given surfacetemperature, a sample will continue to heat and either remain at that temperature or rise

to its ignition temperature.

4.2.3.3 If the anticipated material form layer thickness is greater than 12.7 mm (1⁄2 in.), the ASTM E 2021test would be performed at this greater thickness to determine the appropriate

temperature.

4.2.3.4 If the material ignites, the results of the combustible dust layer ignition temperature test are used todetermine the suitability of the equipment for the installation.

4.2.3.5 If the sample fails to ignite at a temperature lower than 450°C (842°F) in the layer ignition test andadditionally has been tested and not found to be a combustible dust cloud explosion hazard, the material isnot considered to be a combustible dust.

4.2.4 Combustible Dust Cloud Ignition Temperature Testing.

4.2.4.1 Dust in the form of a layer could ignite at significantly lower temperatures than the same dust in theform of a cloud. However, when the dust melts, it could become necessary to test the material form dust tounderstand if the cloud temperature can become a potential hazard.

4.2.4.2 If the material form sample melts below 450°C (842°F), another sample of the material form shouldbe tested in accordance with ASTM E 1491, Standard Test Method for Minimum

Autoignition Temperatures of Dust Clouds, to determine the cloud ignition temperature.

4.2.4.3 If the material ignites, results of the combustible dust cloud ignition temperature test are used todetermine the suitability of the equipment for the installation.

4.3 Additional Potential Combustible Dust Hazards.

4.3.1 Conductive Dusts. Group E dusts can conduct electrical current leading to ignition by spark, byresistive heating, or by causing abnormal operation of the equipment.

4.3.2 Magnesium or Aluminum Dust. Dusts containing magnesium or aluminum are particularly hazardous,and extreme caution should be used to prevent ignition and explosion.

4.4 Hybrid Mixtures. The presence of the flammable gas or vapor, even at concentrations less than theirlower flammable limit (LFL), not only will add to the violence of the dust-air

combustion but will drastically reduce the ignition energy. This situation is encountered in certain industrialoperations, such as fluidized bed dryers and pneumatic conveying systems

for plastic dusts from polymerization processes, in which volatile solvents are used. In such cases,electrical equipment should be specified that is suitable for simultaneous exposure to both the Class I(flammable gas) atmosphere and the Class II (combustible dust) atmosphere.

4.5 Electrostatic Discharges.

4.5.1 Electrostatic discharges are preceded by charge accumulation on insulated surfaces, ungroundedconductors (including human bodies), or particulate materials with high resistivities.

The subsequent electrostatic discharge is an ignition threat only if it is sufficiently energetic in comparisonto the minimum ignition energy of the pertinent dust cloud.

4.5.2 Control of electrostatics is addressed in NFPA 77, Recommended Practice on Static Electricity .


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4.6 Ignition Criteria.

4.6.1 Layer and dust cloud ignition properties are addressed in this recommended practice by temperatureclassification codes on equipment.

4.6.2 Potential fire hazards, such as flash fires, and other sources of potential heat, such as hot processsurfaces, smoldering nests, self-heating, and friction source, should also be considered independently ofthe recommended practice.

4.7 Combustible Particulate Solids.

4.7.1 While not a combustible dust as addressed above, combustible particulate solids include dusts,fibers, fines, chips, chunks, flakes, or mixtures of these. The term combustible particulate solid addressesthe attrition of material as it moves within the process equipment. Particle abrasion breaks the materialdown and produces a mixture of large and small particulates, some of which could be small enough to beclassified as dusts. Consequently, the presence of dusts should be anticipated in the process stream,regardless of the starting particle size of the material.


With the removal of definitions for combustible dust and combustible particulate solid, this information now properly specifies the appropriate conditions under which materials determined to be 'combiustible dusts" or 'combustible particulate solids" are assessed. This information is contained within the document and not within an informative Annex having no required attributes. The basis for this material comes from existing NFPA documents, including but not limited too, NFPA 499.




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4.1* [new]

The owner/operator of a facility with potentially combustible dust shall be responsible for the followingactivities:

(1) Determining the combustibility or explosibility hazards of materials per Chapter 5

(2) Identifying and assessing any fire, flash fire, and explosion hazards per Chapter 7

(3) Managing the identified fire, flash fire, and explosion hazards in accordance with 4.2.5

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


Substantiation: From draft NFPA 652.



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4.1.1Owner's Obligation

The facility owner and operator shall be responsible for ensuring that the facility and systems handlingcombustible particulate solids are designed by and installed under the supervision of qualigied engineerswho are knowldegable of the defalgration hazards associated with combustible particulate solids.

Renumber existing paragraphs of this section accordingly.


There are numerous cases where the owner/operator of a facility failed to exercise any oversight and responsibility for the safety of the facility occupants in the design phase and the facility was constructed in such a manner that hazards were designed into the site. Then, after an incident, the owner has tried to lay the blame on others who had little if any design input or authority to make design decision. this paragraph is necessary to establish the legal obligation on the part of the owner/operator.


Submitter Full Name: John Cholin

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Add the following new Section:

4.3 Classification of Class II Hazardous Locations and National Electrical Code (NEC) Criteria.

4.3.1 Article 500 of NFPA 70, National Electrical Code, establishes the basis for classifying locations wherefire or explosion hazards can exist due to flammable gases, flammable liquid–

produced vapors, combustible liquid–produced vapors, combustible dusts, or ignitable fibers/flyings.

4.3.2 NFPA 70, National Electrical Code, defines a Class II hazardous (classified) location as one that ishazardous because of the presence of a combustible dust.

4.3.3 NFPA499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous(Classified) Locations for Electrical Installations in Chemical Process Areas addresses how to classifylocations found to have Class II Combustible Dusts as addressed in NFPA 70.

4.3.3 Hazardous (classified) areas shall be documented and such documentation shall be permanentlymaintained on file for the life of the facility.


While some of this information was included in existing sections 6.5.2 and 6.5.3, under another PI, these sections were removed. The material presented here is applicable and needs to be addressed under General Requirements.




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4.6 2 Objectives.

4.6 2 .1 Life Safety.

4.6 2 .1.1

The facility, combustible particulate processes, and human element programs shall be designed,constructed, equipped, and maintained

to protect occupants not in the immediate proximity of the ignition

so as to reduce the risks to all occupants from the effects of fire, deflagration, and explosion

for the time needed to evacuate, relocate, or take refuge

covered by this standard to an acceptable level . 4. 6 2 .1.2

The structure shall be located, designed, constructed, and maintained to minimize the propagation of fire orexplosion to reasonably protect adjacent properties and to avoid injury to the public.

4.6.2 Structural Integrity.

The facility shall be designed, constructed, and equipped to maintain its structural integrity in spite of thepublic from an unacceptable risk of harm from the effects of fire or explosion for the time necessary toevacuate, relocate, or defend in place occupants not in the immediate proximity of the ignition , flash fire orexplosion .

4.6 2 .3 2 * Mission Continuity.

The facility, processes and equipment, and human element program shall be designed, constructed,equipped, and maintained to limit damage to levels that ensure the ongoing mission, production, oroperating capability of the facility to a degree acceptable to the owner/operator.

4.6 2 .4 3 Mitigation of Fire Spread and Explosions.

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

4.6 2 .4 3 .1*

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

4.6 2 .4 3 .2

The structure shall be located, designed, constructed, equipped, and maintained to prevent the propagationof fire or explosion to or from adjacent storage or structures.


Substantiation for Objectives and Life Safety section: This is a modified combination of Sections 4.2.1.1.1, 4.2.1.1.2 and 4.2.1.1.3 from draft NFPA 652. There are two fundamental problems with the existing language. First, the standard has numerous provisions designed to prevent an initial ignition and deflagration. However, the life safety language completely fails to acknowledge that objective and instead erroneously implies that the standard is not concerned about the welfare of occupants “in the immediate proximity of the ignition.” Second, on the other extreme, the document seems to imply that the implemented protective measures must reduce the risk of harm to zero for all occupants not “in the immediate proximity of the ignition,” again without defining what that phrase means. The solution is to state the life safety objectives, as well as all of the other objectives in this section, using an approach based on risk assessment rather than ignoring one group of occupants and providing a risk-free environment for all others.

Substantiation for 4.2.1.2 (was 4.6.1.2): from draft NFPA 652.

Substantiation for removing Structural Integrity (was 4.6.2): This suggested change is consistent with approach of NFPA 652 draft, and is already addressed in proposed 4.2.1.2.

Substantiation for 4.2.4 (was 4.6.4): from draft NFPA 652.


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Public Input No. 109-NFPA 654-2014 [ Section No. 4.6.1.2 ]

4.6 2 .1.2

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


Substantiation: from Section 4.2.1.1.2 and 4.2.1.1.3 of draft NFPA 652.



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4.6.2 Structural Integrity.

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


Substantiation: This suggested change is consistent with approach of NFPA 652 draft, and is already addressed in proposed 4.2.1.2.



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4.6.4 3 Mitigation of Fire Spread and Explosions.

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

4.6.4 3 .1*

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

4.6.4 3 .2

The structure shall be located, designed, constructed, equipped, and maintained to prevent the propagationof fire or explosion to or from adjacent storage or structures.


Substantiation: from draft NFPA 652



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4.7 Combustibility of materials

4.7* Noncombustible material [NFPA 101, 2015]

4.7.1 A material that complies with any one of the following shall be considered a noncombustible material:(1)*The material, in the form in which it is used, and under the conditions anticipated, will not ignite, burn,support combustion, or release flammable vapors when subjected to fire or heat(2) The material is reported as passing ASTM E 136, Standard Test Method for Behavior of Materials in aVertical Tube Furnaceat 750 Degrees C(3) The material is reported as complying with the pass/fail criteria of ASTM E 136 when tested inaccordance with the test method and procedure in ASTM E 2652, Standard Test Method for Behavior ofMaterials in a Tube Furnace with a Cone-shaped Airflow Stabilizer, at 750 Degrees C [NFPA 101-2015]

A.4.7 The provisions of 4.7 do not require inherently noncombustible materials to be tested in order to beclassified as noncombustible materials. [NFPA 5000, 2015]A.4.71.1(1) Examples of such materials include steel, concrete, masonry and glass. [NFPA 101, 2015]

Also add ASTM E 2652, Standard Test Method for Behavior of Materials in a Tube Furnace with aCone-shaped Airflow Stabilizer, at 750 Degrees C (2012) into chapter 2 on referenced standards.

4.7.2* Limited-Combustible Material. A material shall be considered a limited-combustible material whereall the conditions of 4.7.2.1 and 4.7.2.2, and the conditions of either 4.7.2.3 or 4.7.2.4, are met. [NFPA 101,2015]

4.7.2.1 The material shall not comply with the requirements for noncombustible material in accordance with4.7.1. [NFPA 101, 2015]

4.7.2.2 The material, in the form in which it is used, shall exhibit a potential heat value not exceeding 3500Btu/lb (8141 kJ/kg) where tested in accordance with NFPA 259, Standard Test Method for Potential Heat ofBuilding Materials. [NFPA 101, 2015]

4.7.2.3 The material shall have the structural base of a noncombustible material with a surfacing notexceeding a thickness of 1⁄8 in. (3.2 mm) where the surfacing exhibits a flame spread index not greater than50 when tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics ofBuilding Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of BuildingMaterials. [NFPA 101, 2015]

4.7.2.4 The material shall be composed of materials that, in the form and thickness used, neither exhibit aflame spread index greater than 25 nor evidence of continued progressive combustion when tested inaccordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of BuildingMaterials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, andshall be of such composition that all surfaces that would be exposed by cutting through the material on anyplane would neither exhibit a flame spread index greater than 25 nor exhibit evidence of continuedprogressive combustion when tested in accordance with ASTM E84 or ANSI/UL 723. [NFPA 101, 2015]

4.7.2.5 Where the term limited-combustible is used in this Code, it shall also include the termnoncombustible. [NFPA 101, 2015]

A.4.7.2 Materials subject to increase in combustibility or flame spread index beyond the limits hereinestablished through the effects of age, moisture, or other atmospheric condition are considered combustible.(See NFPA 259, Standard Test Method for Potential Heat of Building Materials, and NFPA 220, Standard onTypes of Building Construction.) [NFPA 101, 2015]

Also add ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials (2014),ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials (2001) and NFPA259, Standard Test Method for Potential Heat of Building Materials into Chapter 2 on referenced standards.

Also add NFPA 259, Standard Test Method for Potential Heat of Building Materials into Annex G oninformational references.



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Throughout the NFPA system the definition of noncombustible material in chapter 3 is being replaced with a reference to a requirement in a mandatory section of the document, which contains the requirements. That permits the document to comply with the Manual of Style. The wording is extracted from NFPA 101.

This public input also addresses the definition of limited combustible material, in the same way. The reason to add this is that limited combustible material is referenced in NFPA 654 without its meaning and requirements being explained.



Public Input No. 50-NFPA 654-2014 [Section No. 3.3.21]





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5.1* Responsibility.

The owner/operator of a facility with potentially combustible dusts shall be responsible for determiningwhether the materials are combustible or explosible and, if so, to characterize their properties as required tosupport the process hazard assessment. [SR 25, related to PC 113 and 135 and others]

5.1.1

Where dusts are determined to be combustible or explosible, the hazards associated with the dusts shall beassessed in accordance with the requirements in Chapter 7.

5.1.2 Where dusts are determined to be combustible or explosible, controls to address the hazardsassociated with the dusts shall be identified and implemented in accordance with 4.2.5.

5.2 Screening for Combustibility and Explosibility.

5.2.1* The determination of combustibility or explosibility shall be permitted to be based upon either of thefollowing:

1. Historical facility data or published data that are deemed to be representative of current materialsand process conditions

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

5.2.2* Test results, historical data, and published data shall be documented and, when requested, providedto the AHJ.

5.2.3 The absence of previous incidents shall not be used as the basis for deeming a particulate to not becombustible or explosible.

5.2.4

Where dusts are determined not to be combustible or explosible, the owner/operator shall maintaindocumentation to demonstrate that the dusts are not combustible or explosible.

5.3* Self-Heating and Reactivity Hazards. (Reserved)

5.4 Combustibility and Explosibility Tests.

Where combustibility or explosibility screening tests are required, they shall be conducted on representativesamples obtained in accordance with 5.5. [SR No. 20, related to PC 114 and others]

5.4.1* Determination of Combustibility.

5.4.1.1*

Where the combustibility is not known, determination of combustibility shall be determined by a screeningtest based on the UN Recommendations on the Transport of Dangerous Goods: Model Regulations —

Manual of Tests and Criteria, 5th Revised edition, Part III, Subsection 33.2.1.4, Test N.1, “Test Method ofReadily Combustible Solids”, or other equivalent fire exposure test methods.

5.4.1.2

For the purposes of determining the combustibility of dust, if the dust in the form tested ignites andpropagates combustion, or ejects sparks from the heated zone after the heat source is removed, thematerial shall be considered combustible.

5.4.1.3

If the dust is known to be explosible, it shall be permitted to assume that the dust is combustible and therequirements of 5.4.1 shall not apply.

5.4.2 Determination of Flash Fire Hazard. (Reserved)

5.4.3 Determination of Explosibility.

5.4.3.1 Where the explosibility is not known, the determination of explosibility of dusts shall be determinedaccording to one of the following:

(1) The “Go/No-Go” screening test methodology described in ASTM E 1226


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(2) ASTM E 1515

(3) An equivalent test methodology

5.4.3.2*

It shall be permitted to test a sample sieved to less than 200 mesh (75 microns)

5.4.3.3*

When determining explosibility, it shall be permitted to test the as-received sample.

5.4.3.4

It shall be permissible to assume a material is explosive, 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 micrometers, theexplosibility screening test method shall account for possible ignitions in the sample injection apparatus.

5.4.4 Quantification of Combustibility and Explosibility Characteristics.

5.4.4.1* Where dusts are determined to be combustible or explosible, additional testing shall be performedas required to acquire the data necessary to support: for the performance-based design method describedin Chapter 6,; dust hazards analysis described in Chapter 7,; risk assessments described in Chapter 8,; orspecification of the hazard mitigation and prevention described in Chapter 8.

5.4.4.2 The owner/operator shall be permitted to use the worst-case characteristics of the various materialsbeing handled as a basis for design.

5.5 Sampling.

5.5.1 Sampling Plan.

5.5.1.1 A sampling plan shall be developed and documented to provide data as needed to comply therequirements of this chapter.

5.5.1.2 Representative samples of dusts shall be identified and collected for testing according to a thesampling plan.

5.5.1.3

The sampling plan shall include the following:

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

(2) Identification of representative samples

(3) Collection of representative samples

(4)* Preservation of sample integrity

(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 approximate proportions of each general category of particulate solidshall be determined and documented based on available information.

5.5.3 Representative Samples.Samples collected from each location shall be representative of the material at that location, process,equipment, or surface.

5.5.4* Sample Collection.

Dust samples shall be collected in a safe manner without introducing an ignition source, dispersing dust, orcreating or increasing the risk of injury to workers.

5.5.4.1*

Samples shall be uniquely identified using identifiers such as lot, origin, composition (pure, mixture),process, age, location, and date collected.



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[new chapter from draft NFPA 652]Substantiation for 5.1: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.1.1: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.1.2: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.2: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.2.2*: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.2.3: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.2.4: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.4: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.4.1.3: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.4.3.5: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.4.4.2: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.5.1.3: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.5.2: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation for 5.5.3: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.Substantiation 5.5.4.1*: From NFPA 652. This provision reflects recognition that the existing hazard identification provisions are inadequate.



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4.7 2.5 * Compliance Options.

The goal in Section 1.3 and the objectives in Section 4.6 2 shall be achieved by either of the followingmeans:

(1) The A prescriptive provisions approach in accordance with Chapters 6 through 12 5, 7, 8 and 9 ofthis standard

(2) The A performance-based provisions approach in accordance with Chapters 5, 8, 9, 11, and 12Chapter 6 of this standard


From Section 4.2.5 of draft NFPA 652.



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Public Input No. 96-NFPA 654-2014 [ Chapter 5 [Title Only] ]

Chapter 6. Performance-Based Design Option


Renumbering of section.



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5.1.2 Independent Review.

The authority having jurisdiction shall be permitted to obtain an independent third party review of theproposed design.


Substantiation: Section 5.1.2 should be deleted because, as written, it appears to restate the obvious – that the AHJ (at its discretion, for any reason) may obtain a third party review at its expense, and could otherwise be misinterpreted to suggest that the AHJ could require the owner/operator to pay for the independent review.



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Public Input No. 97-NFPA 654-2014 [ Section No. 5.1.3 [Excluding any Sub-Sections] ]

Documentation Requirements.

Performance-based designs shall be documented with all calculations, references, assumptions, andsources from which material characteristics and other data have been obtained or on which the designerhas relied for some material aspect of the design per Chapter 5 of NFPA 101 , Life Safety Code . inaccordance with 6.1.3.

6.1.3.1 General. All aspects of the design, including those described in 6.1.3.2 through 6.1.3.14,shall be documented. The format and content of the documentation shall be acceptable to theauthority having jurisdiction.

6.1.3.2 Technical References and Resources. The authority having jurisdiction shall beprovided with sufficient documentation to support the validity, accuracy, relevance, and precision ofthe proposed methods. The engineering standards, calculation methods, and other forms ofscientific information provided shall be appropriate for the particular application and methodologiesused.

6.1.3.3 Building Design Specifications. All details of the proposed building, facilities, equipmentand process designs that affect the ability of the facility to meet the stated goals and objectivesshall be documented.

6.1.3.4 Performance Criteria. Performance criteria, with sources, shall be documented.

6.1.3.5 Occupant Characteristics. Assumptions about occupant characteristics shall bedocumented.

6.1.3.6 Design Fire and Explosion Scenarios. Descriptions of combustible dust fire andexplosion design scenarios shall be documented.

6.1.3.7 Input Data. Input data to models and assessment methods, including sensitivity analyses,shall be documented.

6.1.3.8 Output Data. Output data from models and assessment methods, including sensitivityanalyses, shall be documented.

6.1.3.9 Safety Factors. The safety factors utilized shall be documented.

6.1.3.10 Prescriptive Requirements. Retained prescriptive requirements shall be documented.

6.1.3.11 Modeling Features.

6.1.3.11.1 Assumptions made by the model user, and descriptions of models and methods used,including known limitations, shall be documented.

6.1.3.11.2 Documentation shall be provided to verify that the assessment methods have beenused validly and appropriately to address the design specifications, assumptions, and scenarios.

6.1.3.12 Evidence of Modeler Capability. The design team's relevant experience with themodels, test methods, databases, and other assessment methods used in the performance-baseddesign proposal shall be documented.

6.1.3.13 Performance Evaluation. The performance evaluation summary shall be documented.

6.1.3.14 Use of Performance-Based Design Option. Design proposals shall includedocumentation that provides anyone involved in the ownership or management of the building withnotification of the following:

(1) Approval of the building, facilities, equipment or processes, in whole or in part, as aperformance-based design with certain specified design criteria and assumptions

(2) Need for required re-evaluation and reapproval in cases of remodeling, modification,renovation, change in use, or change in established assumptions


Substantiation: This section raises several concerns. First, Section 5.1.3 is internally ambiguous as to whether the


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reference to NFPA 101 is intended to incorporate by reference: (1) all aspects of performance-based design in Chapter 5 of NFPA 101; (2) all documentation requirements in Chapter 5 of NFPA 101; or (3) all documentation requirements in Chapter 5 of NFPA 101 that would be required by NFPA 652. Second, the reference to NFPA 101 is ambiguous as to whether it refers to all of the extensive documentation requirements in Chapter 5 of the Life Safety Code (e.g., Sections 5.1.5, 5.4.1, 5.4.2, 5.4.3, 5.4.6, 5.4.7, 5.4.8, 5.4.10, 5.6.3, and 5.8), or the fairly substantial, but more limited documentation requirements in Section 5.8 (which we believe would be more appropriate). Reference to the more extensive documentation requirements of Chapter 5 of NFPA 101 would require the user to sort through the complicated substance of the NFPA 101 documentation requirements because some of them would not be appropriate for NFPA 654. That is impractical and inappropriate, especially when NFPA 101 is ambiguous as to what it requires. Even if the incorporation by reference is limited to the documentation requirements of Section 5.8 of NFPA 101, they would still need to be interpreted and restated because the focus of NFPA 101 is on the building and does not appropriately address the equipment and processes in the building. Third, as a general rule, every effort should be made to avoid incorporating materials from other standards by reference rather than restating them in this standard. Given the importance of these requirements to this standard, they should be revised to reflect the context of NFPA 654 and fully stated in this standard.



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Public Input No. 98-NFPA 654-2014 [ New Section after 5.1.5.2 ]

6.2 Risk Component and Acceptability.The specified performance criteria of 6.3 and the specified fire and explosion scenarios of 6.4 may be modified by a documented risk assessment that, based on the application of clear criteria derived from theobjectives in this standard, the AHJ determines will achieve an acceptable degree of risk. The finalperformance criteria, fire scenarios, and explosion scenarios for the performance-based design shall bedocumented.


Substantiation: This concept is taken from Section 6.2 of draft NFPA 652, and reflects the principles in Section 4.2.1.1, which speak to measures being implanted to reasonably prevent injury. A risk assessment approach is needed to avoid adopting a zero risk standard in which control measures are required by the mere presence of a hazard regardless of the magnitude of the risk. There are two fundamental problems with the existing language. First, the standard has numerous provisions designed to prevent an initial ignition and deflagration. However, the life safety language completely fails to acknowledge that objective and instead erroneously implies that the standard is not concerned about the welfare of occupants “in the immediate proximity of the ignition.” Second, on the other extreme, the document seems to imply that the implemented protective measures must reduce the risk of harm to zero for all occupants not “in the immediate proximity of the ignition,” again without defining what that phrase means. The solution is to state the life safety objectives, as well as all of the other objectives in this section, using an approach based on risk assessment and acceptable risk rather than ignoring one group of occupants and providing a risk-free environment for all others.



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6.1.1.1

Those portions of the process and facility interior where dust accumulations exist external to equipment insufficient depth to prevent discerning the underlying contrasting surface color shall be evaluated todetermine if a dust explosion hazard or flash fire hazard exists.


If the color of the dust and the substrate are too similar then the determination of dust layer thickness outlined in the existing 6.1.1.1 is not readily discernible. By adding the word "contrasting" the intent of this paragraph becomes clear.


Submitter Full Name: Bill Stevenson

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6

A6 .1.3.2 *

A dust explosion hazard and dust flash fire hazard shall be deemed to exist in any building or room whereany of the following conditions exists:

(1) The total area of nonseparated dust accumulations exceeding the layer depth criterion is greaterthan 5 percent of the footprint area

(2) The area of any single nonseparated dust accumulation exceeding the layer depth criterion is

greater than 1000 ft 2 (92.9 m 2 )

(3) The total volume of nonseparated dust accumulations is greater than the layer depth criterionmultiplied by 5 percent of the footprint area

(4) The total volume of any single nonseparated dust accumulation is greater than the layer depth

criterion multiplied by 1000 ft 2 (92.9 m 2 )


The area restrictions were added by means of a TIA to the 2006 edition without any experimental or historical validation. The area limitations in Section 6.1.3.2 are an hypothesis. This hypothesis has NOT been validated either experimentally or through retrospective loss analysis. Indeed, I have been unable after 6 years of searching to find a single loss incident where the dust accumulations were at the prescribed depth criteria of the 2006 edition and a propagating dust deflagration ensued, even when the areas were orders of magnitude greater than that permitted by this section. There is a serious operations cost increment to the owner/operator to achieve this limit on fugitive dust accumulation without a demonstrable benefit in terms of occupant life-safety or mission continuity and property protection. This text should be edited and returned to the annex as advisory text. A hypothesis does NOT belong in the enforceable body of the document.




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6

A6 .1.3.

2 *

2

A dust explosion hazard and dust flash fire hazard

shall be deemed to exist in

should be considered a potentiality in any building or room where any of the following conditions exists:

(1) The total area of nonseparated dust accumulations exceeding the layer depth criterion is greaterthan 5 percent of the footprint area

(2) The area of any single nonseparated dust accumulation exceeding the layer depth criterion is

greater than 1000 ft 2 (92.9 m 2 )

(3) The total volume of nonseparated dust accumulations is greater than the layer depth criterionmultiplied by 5 percent of the footprint area

(4) The total volume of any single nonseparated dust accumulation is greater than the layer depth

criterion multiplied by 1000 ft 2 (92.9 m 2 )


The area limitations of this section were added as a TIA to the 2006 edition without any experimental or loss history validation. It is an hypothesis - not a proven scientific fact. It is inappropriate to make an hypothesis and enforceable criterion in a minimum-compliance standard. After more than 6 years of searching I have been unable to identify a single loss incident where the dust layers were anywhere near the permissible layer depth established by this standard even without the area limitations. There is a substantial incremental cost of operations and facility design to operate some facilities at the dust layer criteria established without any demonstrable benefit in terms of life-safety or property and mission continuity. This language has been edited and placed in the Annex where it belongs.




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6

A6 .1.

4

2 * Mass Method A.

A dust flash fire or dust explosion hazard area exists when the total accumulated dust external toprocess equipment exceeds the quantities determined from the equations in 6.1.4.1 and 6.1.4.2 .

6.1.

4

2 .1

The threshold dust mass establishing a building or room as a dust explosion hazard area, M basic-exp, shall be determined by the following equation:

where:

M basic-exp = threshold dust mass (kg) based on building damage criterion

A floor = lesser of enclosure floor area (m 2 ) or 2000 m 2

H = lesser of enclosure ceiling height (m) or 12 m

6.1.

4

2 .2

The threshold dust mass establishing a building or room as a dust flash fire hazard area, M basic-fire ,

shall be determined by the following equation:.

where:

M basic-fire = threshold dust mass (kg) based on personnel fire exposure criterion

A floor = lesser of enclosure floor area (m 2 ) or 2000 m 2

H = lesser of enclosure ceiling height (m) or 12 m


The Mass Method A is based upon an equation that has not been validated either experimentally or through a retrospective historical loss analysis. Consequently, it is an hypothesis - not established scientific fact. It is inappropriate for an hypothesis to be incorporated into the enforceable text of a minimum-compliance engineering standard.

This proposal moves the text to the annex as an example of how one might use a computational method in lieu of the simple prescriptive layer depth method where there is a justification for doing so.





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6

A6 .1.

5

2 .

2 *

2

The threshold dust mass establishing a building or room as a dust flash fire hazard area, M fire , shall

be determined by the following equation:

where:

M fire = threshold dust mass (kg) based on personnel fire exposure criterion

ρ = probability of flame impingement on a person, not to exceed 0.05 (5 percent probability)

C w = worst-case dust concentration (kg/m 3 ) at which the maximum rate-of-pressure-rise resultsin tests conducted per ASTM E 1226

P initial

= 1 bar absolute

P max = maximum pressure (bar g) developed in ASTM E 1226 tests with the accumulated dustsample

A floor = enclosure floor area (m 2 )

D = nominal height of a person (2 m)

η D = entrainment fraction = 0.25

6.1.

5

2 .2.1 *

It shall be permitted to use an alternative value of η D , based on a risk evaluation that is acceptable to

the authority having jurisdiction.


The equation is currently an hypothesis that has not yet been validated either experimentally or through a retrospective analysis of historical losses. An hypothesis does not belong as an enforceable part of a minimum-compliance engineering standard. I have been unable to find a single incident in the historical loss record where a deflagration propagated through the interior of a facility where the accumulated dust layers were as low as the criteria established by this section. the historical record does exist for facilities where the dust accumulation layer thickness was 300 to 400 times the layer depth permitted by this section. Is it the intent of the TC to operate with a safety margin of 300 to 400? If so, then why isn't that same safety margin applied to the other hazard management methods?

This proposal along with others moves this text to the Annex where is can serve as advisory material for those who wish to develop a pe4rformance-equivalent to the prescribed layer depth in the body of the document.


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6.1.8 Risk Assessment.

A documented risk assessment that, based on the application of clear criteria derived from the objectives inthis standard, is acceptable to the authority having jurisdiction shall be permitted to be conducted todetermine the level of protection to be provided per each of the provisions ofthis chapter.


Substantiation: The suggested change is consistent with Section 8.3 of draft NFPA 652.



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6.2.2.1

Physical barriers that are erected to segregate dust flash fire hazards areas, including seals at allpenetrations of floors, walls, ceilings, or partitions shall have a 1-hour fire resistance rating when tested inaccordance with ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials.


In every instance where fire resistance rating is mentioned the fire test (ASTM E119) must be included, as a clarification.



Public Input No. 54-NFPA 654-2014 [Section No. 6.2.2.3]





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6.2.2.3

Doors and openings shall not be permitted in physical barriers unless they are normally closed and have atleast the strength and fire resistance rating required of the physical barrier. These doors shall be installedaccording to NFPA 80, Standard for Fire Doors and Other Opening Protectives.


Consistency taken from section 6.3.6.2


Submitter Full Name: John Chartier

Organization: Northeastern Regional Fire Cod

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Submittal Date: Fri Nov 08 07:57:22 EST 2013


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6.2.2.3

Doors and openings shall not be permitted in physical barriers unless they are normally closed and have atleast the strength and fire resistance rating required of the physical barrier when tested in accordance withASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials .


Adds the test method.







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6.3.5

Interior walls erected for the purpose of limiting fire spread shall have a minimum 1-hour fire resistancerating, when tested in accordance with ASTM E119,Standard Test Methods for Fire Tests of BuildingConstruction and Materials , and shall be designed in accordance with NFPA 221, Standard for HighChallenge Fire Walls, Fire Walls, and Fire Barrier Walls.


adds test method








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6.3.6.1

Openings in fire walls and in fire barrier walls shall be protected by self-closing fire doors that have a fireresistance rating protection rating, when tested in accordance with NFPA 252, Standard Methods of FireTests of Door Assemblies, equivalent to the wall design.

Also, add NFPA 252 into chapter 2 on referenced standards.


The rating of fire doors is called fire protection rating and the testing is done in accordance with NFPA 252.







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6.3.7.1 Normally occupied spaces/rooms where hazardous dust accumulation may occur shall bedesigned according to ‘Special Provisions for Occupancies with High Hazard Contents’ in NFPA101.


Prescribed housekeeping measures to prevent or reduce dust generation and dispersal can do much to lessen the hazards of combustible dust, but cannot eliminate them. LSC 101:7.11 addresses exit egress provisions specific to this type hazard.




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6.3.8 Penetrations.

Where floors, walls, ceilings, and other partitions have been erected to control the spread of fire ordeflagrations, penetrations in these structures shall be sealed to maintain their fire endurance resistancerating and maintain physical integrity in a deflagration. (See 7.6.7.)


The term fire endurance has been replaced in all NFPA documents (and also in ASTM and ICC) by the term fire resistance.




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6.3.9 Fire Resistance Rating.

6.3.9.1

Interior stairs, elevators, and manlifts shall be enclosed in dusttight shafts that have a minimum fireresistance rating of 1 hour, when tested in accordance with ASTM E119, Standard Test Methods for FireTests of Building Construction and Materials .

6.3.9.2

Doors that are the automatic-closing or self-closing type and have a fire resistance protection rating of 1hour, when tested in accordance with NFPA 252, Standard Methods of Fire Tests of Door Assemblies, shallbe provided at each landing.

6.3.9.3

Stairs, elevators, and manlifts that serve only open-deck floors, mezzanines, and platforms shall not berequired to be enclosed.


Adds the relevant test methods and the correct designation.








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6.3.9.1

Interior stairs, elevators, and manlifts shall be enclosed in dusttight shafts that have a minimum fireresistance rating of 1 hour rating in accordance with NFPA 101 .


For consistency with 6.3.7. NFPA 101 requires a 2-hour fire resistance rating if 4 or more stories.


Submitter Full Name: John Chartier

Organization: Northeastern Regional Fire Cod

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Submittal Date: Fri Nov 08 07:58:28 EST 2013


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6.4.1 *

If a room or building contains a dust explosion hazard as specified in 6 in 6 . 2 1 .3. 1 2 that is external toprotected equipment, such areas shall be provided with deflagration venting to a safe outside location.


I believe this to be a typo. NFPA 654-2006 was amended to change the reference from 6.2.3.1 to 6.1.1.3, but it appears that NFPA 654-2013 reverted to the old reference instead of starting with the new equivalent of 6.1.1.3. In other words, I believe that the reference in Article 6.4.1 should be to 6.1.3.2 which is the article that defines the conditions when a dust explosion and dust flash fire hazard exists.


Submitter Full Name: JOHN KRIEGSHAUSER

Organization: Black & Veatch Corp.

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Submittal Date: Wed Aug 21 13:40:28 EDT 2013


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6.5.1

All electrical equipment and installations shall comply with the requirements of NFPA 70, National ElectricalCode, or NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment . .


As written the current text incorrectly suggests that compliance with the NEC (NFPA 70) or NFPA 496 is equivalent when in fact the electrical installations need to comply with the NEC NFPA 70. NFPA 496 is addressed a protection method which is included in Chapter 5 of the NEC.




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Delete Section 6.5.2*

In local areas of a plant where a hazardous quantity of dust accumulates or is suspended in air, the areashall be classified and all electrical equipment and installations in those local areas shall comply withArticle 502 or Article 503 of NFPA 70 , National Electrical Code , as applicable.

and its Annex


With action on new 4.3, Section 6.5.2 is not needed here. Additionally while the 6/5/2 Annex material contains some information dealing with hazardous classification of Class II Combustible Dust locations, the information does not provide all the needed material contained in NFPA 499. Rather than attempting to highlight some aspects of NFPA 499, the users would be better advised to use the complete NFPA 499 to address those hazardous clarification requirements/needs.




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Chapter 7 Dust Hazard Analysis

7.1* General Requirements.

7.1.1 Responsibility.

The owner/operator of a facility where materials that have been determined to be combustible or explosiblein accordance with Chapter 5 are present in either a process or a facility compartment shall be responsibleto ensure a dust hazards analysis is completed in accordance with the requirements of this chapter.

7.1.2*

The requirements of Chapter 7 shall apply retroactively in accordance with this section.

7.1.2.1 For existing processes/facility compartments that are undergoing material modification, theowner/operator shall complete a dust hazard analysis as part of the project.

7.1.2.2* For existing process/facility compartments that are not undergoing material modification, theowner/operator shall schedule and complete dust hazards analyses of existing process/facilitycompartments within a 3-year period of the effective date of the standard. The owner/operator shalldemonstrate reasonable progress in each of the three years.

7.1.2.3 For the purposes of applying the provisions of 7.1.2, material modification shall includemodifications or maintenance/repair activities that exceed 25 percent of the original cost.

7.2 Criteria.

7.2.1* Overview.

The dust hazards analysis shall evaluate the fire, deflagration, and explosion hazards and providerecommendations to manage the hazards in accordance with 4.2.

The process hazards analysis shall be performed or led by a qualified person.

7.2.2 Documentation.

The results of the process hazards analysis review shall be documented, including any necessary actionitems requiring change to the process materials, physical process, process operations, or facilitiesassociated with the process.

7.3 Methodology.

7.3.1 General.

The dust hazards analysis shall:

(1) Identify and evaluate the portions of the process or facility areas where a fire, deflagration, andexplosion hazard exists

(2) Identify and evaluate specific fire and deflagration scenarios and their potential consequences

(3) Identify safe operating ranges

(4) Identify the safeguards that are in place to manage fire, deflagration, and explosion events

(5) Recommend additional safeguards where warranted, including a plan with anticipated dates forimplementation

7.3.2 Material Evaluation.

7.3.2.1

The dust hazards analysis shall be based on data obtained in accordance with Chapter 5 for material that isrepresentative of the dust present.

7.3.3 Process Systems.

7.3.3.1*

Each part of the process system where combustible dust is present or where combustible particulate solidscould cause combustible dust to be present shall be evaluated.

7.3.3.1.1 The evaluation shall address the following:


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

(1) Potential fugitive combustible dust emissions into facility compartments.

(1) Potential of deflagration propagation between parts of the process system.

7.3.3.2*

Each part of the process that includes all of the following shall be considered a fire hazard and documentedas such:

(1) Combustible particulate solid

(2) Oxidizing atmosphere

(3) Credible ignition source

7.3.3.3*

Each part of the process that includes all of the following shall be considered a dust flash fire or explosionhazard, as appropriate, and documented as such:




(4) Suspension mechanism

(5) Sufficient quantity of dust to propagate deflagration

7.3.4 Facility Compartments.

7.3.4.1*

Each facility compartment where combustible dust is present shall be evaluated.

7.3.4.1.1 Where multiple facility compartments present essentially the same hazard it shall be permitted toconduct a single evaluation as representative of all similar facility compartments.

7.3.4.1.2 The evaluation shall address the potential of combustible dust migration between facilitycompartments.

7.3.4.1.3 The evaluation shall address the potential of deflagration propagation between facilitycompartments.

7.3.4.2*

Each facility compartment that includes all of the following shall be considered a fire hazard anddocumented as such:

(1) Combustible particulate solid



7.3.4.3 Each facility compartment that includes all of the following shall be considered a dust flash fire orexplosion hazard, as appropriate, and documented as such:




(4) Suspension mechanism

(5) Sufficient quantity of dust to propagate deflagration

7.3.4.3.1*

The evaluation of dust deflagration hazard in a facility compartment shall include a comparison of actual orintended dust accumulation to the threshold housekeeping dust accumulation that would present a potentialfor flash-fire exposure to personnel or compartment failure due to explosive overpressure.

7.3.4.3.2


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Threshold housekeeping dust accumulation levels and non-routine dust accumulation levels (i.e., from aprocess upset) shall be in accordance with relevant industry or commodity-specific NFPA standards.(See1.3.1.)

7.3.2.6.5* Branch lines shall not be added to an existing system without first confirming that the modifiedsystem will maintain required and balanced airflow.


[new chapter from draft NFPA 652 needed to provide adequately detailed and comprehensive requirements for effective dust hazard analysis]

Substantiation for new 7.3.2.6.5*: This proposed change is consistent with draft NFPA 652. There is no need to redesign an entire dust collection system when branch lines (duct) additions are made. It is only necessary to ensure that the minimum conveying velocity for the specific type of dust handled is ensured in all branches. ACGIH Ventilation Manual provides guidance for conveying velocities for the type of dust handled.



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Delete Section 6.5.3

Hazardous (classified) areas that are identified in accordance with 6.5.2 shall be documented, and suchdocumentation shall be permanently maintained on file for the life of the facility.


This information has been restated under new Section 4.3 as 4.3.3 in the Public Input as General Requirement. Therefore retaining this text in this section is not needed.




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7.1.3* Risk Evaluation Assessment .

A documented risk evaluation assessment that, based on the application of clear criteria derived from theobjectives of this standard, is acceptable to the authority having jurisdiction, shall be permitted to beconducted to determine the level of protection to be provided per each of the provisions of this chapter.


Substantiation: The suggested change is designed to clarify the intent of this provision and is consistent with Section 8.3 of draft NFPA 652.



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PROCESS EQUIPMENT THAT MAY NOT REQUIRE EXPLOSION PROTECTION/PREVENTIONSYSTEMS

Subject to the approval of AHJ, the following process equipment is excluded from the requirementof explosion protection.

1) Outdoor installed equipment.

2) Fixed bulk storage vessels/air material separators of total volume less than 8 cuft.

3) Wet-air material separators meeting special criterion (as per 7.13).

4) Enclosure-less air material separators meeting special criterion (as per 7.1.3).

5) Portable or transport vessels.

6) Sifters/screens.

7) Handling combustible dusts with dust concentrations less than 25% MEC (or LFL) if notmonitored continuously or less than 60% if monitored continuously, (In case MEC is not available,assume 30g/m3).

8) Air exhaust ducts with dust concentrations less than 25% MEC (or LFL)

9) Handling combustible dusts in atmosphere where oxygen concentration is less than 2% belowLOC (less than 60% of LOC if LOC less than 5%) if oxygen concentration is continuouslymonitored.

10) Handling combustible dusts in atmosphere where oxygen concentration is less than 60%of LOC (less than 40% of LOC if LOC less than 5%) if oxygen concentration is not continuouslymonitored

11) Handling combustible dusts in atmosphere where partial vaccum is applied followed by inertgas purging and oxygen concentration is not continuously monitored

12) Non solvent dryers (without product recirculation) with dust fill fraction(volume of dust tovolume of enclosure) is less than ratio of Pred/Pmax


This statement would substantiate the equipment that could be safely excluded from the requirement of explosion protection/prevenation systems. Most of this are covered in other NFPA standards. But to included this at start of the section will help and easy to undertand

Item 1 : NFPA 654 2013 - (7.2.3.2.1)Item 2: NFPA 654 2013 - (7.2.3.3.3)Item 3: NFPA 654 2013 - (7.13.1.1.2(3)Item 4: NFPA 654 2013 - (7.13.1.1.2(4))Item 5: NFPA 654 2013 - (7.12.2.4)item 6: NFPA 654 2013 - (7.1)Item 7 NFPA 69 2008 - (8.3.1))(NFPA 654 2013 - (7.1.2.4)Item 8 NFPA 91 2008 - (3.3.5 &4.1.3)Item 9 NFPA 69 2008 - (7.7.2.5)Item 10 NFPA 69 2008 - (7.7.2.7)Item 11 NFPA 69 2008 - (7.7.2.7.2)Item 12 NFPA 68 2012 -(8.3.2)


Submitter Full Name: Venkateswara Bhamidipati

Organization: Powder Process Solutions

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Submittal Date: Fri May 31 16:16:27 EDT 2013


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7.1.6.2

The requirement of 7.1.6.1 shall not apply where all of 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 theminimum explosive concentration (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 thandeflagration pressure containment.

(6) An expert review and documented risk assessment acceptable to the authority having jurisdictionhas completed to accept the reduced propagation risk.


The current language does not address that the exemption of small lines sizes should only be done if the reduced probability of propagation is acceptable.


Submitter Full Name: Jason Krbec


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7.1.6.2

The requirement of 7.1.6.1 shall not apply where all of 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.

The maximum concentration of dust conveyed through the duct is less than 25 percent of the minimumexplosive concentration (MEC) of the material

(1) .

(2) The conveying velocity is sufficient to prevent accumulation of combustible dust in the duct.

(3) All connected equipment is properly designed for explosion protection by means other thandeflagration pressure containment.


Subparagraph (C) incorrectly implies that flame propagation is less likely and can be prevented by reducing dust concentrations to levels well below MEC. Research conducted by Alfert and reported to the 68 committee and both published and directly reported by Alfert, based on his research at CMI directly refutes this notion. In fact the probability for flame propagation goes up as concentration goes down. This was confirmed with Alfert in private conversation last month in Chicago. Moreover, it has been agreed in the 652 committee that all pneumatic conveyors will be treated the same with no distinctions based on dust concentration so removing this section from 654 would serve the interests of consistency moving forward.




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A7.2.2

Historically, this section required that the fixed bulke storagee vessel be constructed of non-combustiblematerials. This usually meant steel of some other metallic material. However, there are some pariculatesthat represent a serious corrosion threat or where contamination from the materials of cntstructionintroduces product quality issues. Consequently the technical committee took a performance-basedapproach. The materials of contruction for a bulk stoarge vessel should not increase the fire protectionchallenge.


While the existing text clearly states the objective the annex text provides some background showing why the language was selected the way that it was.




Affilliation: none

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Public Input No. 24-NFPA 654-2014 [ New Section after 7.2.3.2.2 ]

Add new annex material A7.2.3.2.2

The 8 cubic foot limit is provided for guidance only as a dust explosion could still occur in a vessel of thissize or smaller. The decision to forego protection on small vessels assumes that the predictedconsequences of an explosion are acceptable.


The 8 cubic foot limit was established in the first place based on accepting the consequences. This factor has been lost in the 2013 document as near as I can tell. This would re-establish the principal upon which the guidance is based.




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Public Input No. 6-NFPA 654-2013 [ Section No. 7.2.3.3.2 ]

7.2.3.3.2 *

The explosion protection requirements of 7.1.4 shall not be required provided that the volume of the fixed

bulk storage container is less than 8 ft3 (0.2 m3), and the fixed bulk storage container does not servemetal grinders, hot work processes, or machinery that can produce sparks . .


NOTE: This proposal appeared as Comment 654-26 (Log #28) which was held from the A12 ROC on Proposal 654-31.

We believe this provision should be consistent with the proposed enclosureless AMS provision in 7.13.1.1.2(4).


Submitter Full Name: George Petino

Organization: Hazards Research Corporation

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Submittal Date: Fri Aug 09 13:44:28 EDT 2013


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7.3.2.8

Operator controls for air-material separators associated with pneumatic conveying, dust collection orcentralized vacuum cleaning systems shall be installed in a location that is safe from the effects of a venteddeflagration in the air-material separator.


A recent incident resulted in personnel injury because the operator controls were located at the base of the air-material separator. When the deflagration occurred the person at the operator controls was injured due to the radiant flux form the vented deflagration. This standard should require that all operator controls associated with air-material separators be located in a safe location.




Affilliation: none

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Public Input No. 25-NFPA 654-2014 [ Sections 7.3.2.5.1, 7.3.2.5.1 ]

Sections 7.3.2.5.1, 7.3.2.5.1

7.3.2.5.1*

Where a pneumatic conveying system or any part of such systems operates as a positive-pressure-typesystem and the air-moving device's gauge discharge pressure is 15 psi (103 kPa) or greater, the systemshall be designed in accordance with Section VIII of the ASME Boiler and Pressure Vessel Code or ASMEB31.3, Process Piping, or international equivalent .

7.3.2.5.1*

Where a pneumatic conveying system or any part of such systems operates as a positive-pressure-typesystem and the air-moving device's gauge discharge pressure is 15 psi (103 kPa) or greater, the systemshall be designed in accordance with Section VIII of the ASME Boiler and Pressure Vessel Code or ASMEB31.3, Process Piping, or international equivalent .


As currently worded it would be difficult to utilized equipment designed, manufactured and supplied off shore even though that equipment is entirely suitable. The German DIN standard comes to mind as an example. It is not the intent of this document to exclude products or solutions suitable for the circumstances without proper grounds to do so.




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7.3.2.5.2

All components of pneumatic conveying systems that handle combustible particulate solids shall bedesigned to be dusttight, except for openings designed for intake and discharge of air and material.


This same text is in section 7.3.2.3, above. It is an important concept but does it really need to be stated twice twice?




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7.6.6 *

Changes in duct sizes shall be designed to prevent the accumulation of material by utilizing atapered transformation piece with the included angle of the taper not more than 30 degrees taper tobe 30 degrees or less (preferred) to 45 degrees if necessary .


This proposed change will ensure consistency in the design directive language provided by NFPA 654, SMACNA and ACGIH standards relating to the entering branch angle in duct design.


Submitter Full Name: Allison Fee

Organization: SMACNA

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Submittal Date: Thu May 02 13:53:07 EDT 2013


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7.10.9.4

The requirement of 7.10.9.1 shall not apply to elevators that have belt speeds below 500 ft/min (150

m/min) or capacities less than 3750 ft 3 /hr (106 m 3 /hr).


The limits stated in this paragraph are a relic from an earlier age. I can find no basis for them and others who have looked could not find one either. Moreover I have personally investigated an accident involving a bucket elevator that suffered a dust explosion that was not even in operation at the time of the incident. This loophole needs to be closed.




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7.10.9.4

The requirement of 7.10.9.1 shall not apply to elevators that have belt speeds below 500 ft/min (150

m/min) or capacities less than 3750 ft 3 /hr (106 m 3 /hr).


NOTE: This proposal appeared as Comment 654-27 (Log #33) which was held from the A12 ROC on Proposal N/A.

The belt speed or capacity has no influence on the reduced explosion pressure or the likely hood of an event occurring in a bucket elevator. The Health and Safety Executive (HSE) published a paper by Holbrow, P., Lunn, G. A., Tyldesley, A. titled Explosion Venting of Bucket Elevators in the Journal of Loss Prevention in the Process Industries, 15 (2002), 373-383. The article provides extensive test data for the design of explosion venting with regards to bucket elevators. The paper concludes that belt speed had no noticeable effect on the reduced explosion pressure. Belt misalignment, hot bearing temperatures and excessive vibration should all be monitored as they are credible ignition sources independent of the capacity of a bucket elevator.


Submitter Full Name: Jason Krbec


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Submittal Date: Fri Aug 09 13:47:53 EDT 2013


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Flexible Screw Conveyors

7.11.1.2.1 The requirements of 7.11.1.2 shall not apply to specially engineered flexible screw conveyorswhich shall be permitted to be used.


It was never the intent of this committee to excluded the use of flexible screw conveyors where appropriate. The requirement for metal housings in all cases has inadvertently done so.




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7.12.2.4

Where the MEC value is unknown, a value of 0.03 oz/ft 3 (30 g/m 3 )shall be permitted to be assumed.

Comment" Move this statement to general section as it might be applicable to other areas also"


Dust concentration is always a concern to the end users and it is useful to what are the limits.


Submitter Full Name: Venkateswara Bhamidipati

Organization: Powder Process Solutions

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Submittal Date: Mon May 13 16:43:10 EDT 2013


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7.13.1.1.2 *

The requirement of 7.13.1.1.1 shall not apply to the following:

(1) Air-material separators that are protected in accordance with 7.1.4

(2) Air-material separators that have a dirty-side volume of less than 8 ft3 (0.2 m3)

(3) Wet air-material separators that meet all of the following criteria:

(a) Interlocks are provided to shutdown the system if the flow rate of the scrubbing medium is lessthan the designed minimum flow rate.

(b) The scrubbing medium is not a flammable or combustible liquid.

(c) The separator is designed to prevent the formation of a combustible dust cloud within theair-material (AMS).

(4)

(5)

(6)

(7)

(8)

of 3000

(a)

1

(a)

(b)

(c)

(d)

(e)

(f)

(g)

(h)


NFPA 664 has used 5,000 CFM as the upper limit for a number of revisions. With the requirement of MIE >500mJ the risk factor is not higher for dusts covered by this standard that the dust handled by dust covered by NFPA 664. Since this style AMS is not enclosed the risk assesment only covers fire hazards and with the high MIE the risk is significantly reduced. Using the limit of 5,000 CFM to be the same as for NFPA 664 the confusion in the marketplace is reduced.

* Enclosureless air-material separators meeting all the following criteria shall be permitted to be used:

The filter medium is not shaken or pressure-pulsed to dislodge dust during operation.

The AMS is not used to vent or serve metal grinders, hot work processes, or machinery thatcan produce sparks.

The AMS is not used to vent or serve sanders, abrasive planers, or similar sanding processequipment.

* Each collector system has a maximum air flow–handling capacity

of 5000 cfm (

2 .4 m 3 /sec).

The fan motor is suitable for Class II, Division 2, or Class III, as appropriate.

The collected dust is removed daily or more frequently if necessary to ensure efficient operationand to limit the collected dust to less than 22 lb (10 kg).

The collector is located at least 20 ft (6.1 m) from any means of egress or area routinelyoccupied by personnel.

* Multiple collectors in the same room are separated from each other by at least 20 ft (6.1 m).

* The minimum ignition energy (MIE) of the collected materials is greater than 500 mJ.

The fan construction is spark resistant and meets the criteria in 7.12.2.5 .

The filter medium is not located within 35 ft (10.7 m) of any open flame or hot surface capableof igniting a dust cloud of the material it contains.


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Submitter Full Name: Niels Pedersen

Organization: Nederman LLC

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7.13.1.1.2 *





(a) Interlocks are provided to shutdown the system if the flow rate of the scrubbing medium is lessthan the designed minimum flow rate.

(b) The scrubbing medium is not a flammable or combustible liquid.

(c) The separator is designed to prevent the formation of a combustible dust cloud within theair-material (AMS).

(4)

(5)

(6)

(7)

(8)

(9)

appropriate

(a)

(b)

(c)

(d)

(e)

(f)

(g)


The statement "as appropiate for Class II div. 2" leads the reader to assume he must apply a motor rated for Class II div. 2. These motors are not readily available or only available rated both for div. 1 and div. 2. NFPA 70 - handbook has a segment where it says that TEFC motor meets Class II div. 2 provided that the motor meets the temperature rating for the area of the motor location.







* Each collector system has a maximum air flow–handling capacity of 3000 cfm (1.4

m 3 /sec).

The fan motor is suitable for Class II, Division 2, or Class III, as

appropriateThis include the use of TEFC(Totally Enclosed Fan Cooled) .

The collected dust is removed daily or more frequently if necessary to ensure efficient operationand to limit the collected dust to less than 22 lb (10 kg).


* Multiple collectors in the same room are separated from each other by at least 20 ft (6.1 m).





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7.13.1.1.2*





(4) Interlocks are provided to shutdown the system if the flow rate of the scrubbing medium is lessthan the designed minimum flow rate.

(5) The scrubbing medium is not a flammable or combustible liquid.

(6) The separator is designed to prevent the formation of a combustible dust cloud within theair-material (AMS).

(7)

(8)

(9)

(10)

(11)

3000

(a)

m 3

(a)

(b)

(c)

(d)

(e)

(f)

(g)

(h)


3000 CFM banks in paper dust applications are too restrictive for paper dust applications. Corrugated Box Plants and Printing Plants who are entry level privately owned corporations typically cannot afford a cartridge or baghouse filter. The added cost of multiple 3000 cfm units is cost prohibitive. 8,000 CFM or banks of 8,000 cfm modules are typically more economically feasible.





* Each collector system has a maximum air flow–handling capacity of

8000 cfm ( 3.77 m 3 /sec) for class 1 dust, and 3,000 CFM (1 .4

m3 /sec) for higher class dusts .

The fan motor is suitable for Class II, Division 2, or Class III, as appropriate.

The collected dust is removed daily or more frequently if necessary to ensure efficientoperation and to limit the collected dust to less than 22 lb (10 kg).


* Multiple collectors in the same room are separated from each other by at least 20 ft (6.1m).





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Submitter Full Name: GREG BUMB

Organization: GF PUHL

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Public Input No. 42-NFPA 654-2014 [ New Section after 7.13.1.6.3 ]


Type your content here ...

Where a filter such as but not limited to a flame arresting element or a HEPA filter is used to preventparticulate solids from entering return air ducts or the work place a means to isolate said filter shall beprovided to prevent flame contact with the device.


Under the current provisions outlined in 7.13.1.6.3 it is not clear that the use of a device that would trap flame or particulate solids from re-entering the work space could become contaminated and present a secondary hazard in the form of blockage. Such an occurrence could result in excessive pressure beyond safe limits and could fuel additional flame spread into the work place.




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8.1.1

Continuous suction to minimize the escape of dust shall be provided for processes where combustible dustis liberated in normal operation in amounts that, under established housekeeping procedures, would beexpected to exceed the allowable threshold housekeeping dust accumulation in the affected areas ..


Substantiation: The requirement to install continuous suction for any process that liberates any quantity of combustible dust during processing during normal operation is cost prohibitive in industry and is unwarranted where minimal dust is liberated that does not exceed allowable threshold housekeeping dust accumulations.



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8.2.2.1

Surfaces To the extent practical, surfaces shall be cleaned in a manner that minimizes the risk ofgenerating a fire or explosion hazard.


Substantiation: This provision, which seems to imply that all surfaces must be vacuumed or wet cleaned, and never blown down, is impractical and inconsistent with Section 8.2.2.3 and 8.2.2.4.



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Public Input No. 1-NFPA 654-2013 [ Sections 8.2.3.1, 8.2.3.2, 8.2.3.3 ]

Sections 8.2.3.1, 8.2.3.2, 8.2.3.3

8.2.3.1 *

Portable vacuum cleaners that meet the following minimum requirements shall be permitted to be used tocollect combustible particulate solids:

(1) Vacuum cleaners shall meet the hazard classification of the area where they will be used as definedin 6.5 and shall be electrically grounded and bonded

(2) In Class II Division 1 electrically classified (hazardous) locations, vacuum cleaners shall be NRTLcertified for use in Class II Division 1 electrically classified (hazardous) locations. Vacuum cleanersNRTL certified for use in Class II Division 2 electrically classified (hazardous) locations shall not beused in Class II Division 1 electrically classified (hazardous) locations.

(3) In Class II Division 2 electrically classified (hazardous) locations, vacuum cleaners shall be NRTLcertified at least for use in Class II Division 2 electrically classified (hazardous) locations. Vacuumcleaners NRTL certified for use in Class II Division 1 electrically classified (hazardous) locations canbe used in Class II Division 2 electrically classified (hazardous) locations.

(4) * Paper filter elements shall not be used when combustible particulate solids: are collected andwhen liquids or wet material are picked up by the vacuum cleaner.

(5) Materials of construction shall comply with 7.13.2 and 9.3.2 .

(6) Hoses shall be conductive or static dissipative.

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

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

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

(10)

(11) Vacuum cleaners used for metal dusts shall meet the requirements of NFPA 484, Standard forCombustible Metals .

8.2.3.2 *

In Class II electrically classified (hazardous) locations, vacuum cleaners shall be listed NRTLcertified for the purpose and location or shall be a fixed-pipe suction system with remotelylocated exhauster and air-material separator installed in conformance with Section 7.13 and shallbe suitable for the dust being collected.

8.2.3.3

Where flammable vapors or gases are present, vacuum cleaners shall be listed for NRTLcertified for Class I and Class II hazardous locations.


I have some concerns with regards to the changes made in the 2013 edition of the NFPA 654, specifically changes made to paragraph 8.2.3.1 “Portable vacuum cleaners”.

I understand that the goal of the NFPA TC was to better define the requirements when using vacuum cleaners to clean in non-classified areas. Unfortunately, based on the feedback that I’ve received from our existing customers (I work for a manufacturer of NRTL certified explosion-proof vacuum cleaners) and from new potential customers in the field, it appears that the changes made in the 2013 edition of NFPA 654 are being misinterpreted.

Since the new edition of the NFPA 654 focuses on the “minimum requirements” for a vacuum permitted to be used to collect combustible particulate solids, clients are telling us that, based on their interpretation of the new edition of the standard, Class II listed vacuums are no longer required to collect combustible particulate solids.

* When liquids or wet material are picked up by the vacuum cleaner, paper filter elements shall notbe used.


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I believe that it would have been useful to include a statement in section 8.2.3.1 of NFPA 654 to specify that vacuum cleaners that will be used to collect combustible particulate solids must meet the hazard classification of the area where they will be used. I also believe that a reference should be made in 8.2.3.1 of NFPA 654 to section 6.5 for a guideline on how to make the determination about the classification.

I are also concerned about paragraph 8.2.3.1 of NFPA 654 item 6 which states that paper filter bag should not be used when the vacuum is used to recover liquids or wet material. Although this statement is correct, the wording can be easily misinterpreted and give the impression that it is OK to use vacuums equipped with paper filter elements to collect combustible particulate solids without taking into consideration the flammability of the paper filter elements.

Thank you,

Stefan Briquet


Submitter Full Name: STEPHANE BRIQUET

Organization: TIGER VAC INTERNATIONAL INC

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Submittal Date: Tue Apr 30 12:33:21 EDT 2013


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9.1.1 Risk Evaluation Assessment .

A documented risk evaluation assessment that, based on the application of clear criteria derived from theobjectives in this standard is acceptable to the authority having jurisdiction, shall be permitted to beconducted to determine the level of protection to be provided according to by each of the provisions of thischapter.


The suggested change is intended to provide clarity.



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Materials that self-heat

Certain materials that can self-heat to ignition shall require means to minimize the hazard. It shall bepermitted but not limited to utilize methods such as mechanically disturbing the material to interrupt thechemical reaction, inerting any equipment containing self-heating materials, reducing moisture content tostop the chemical reaction, or reducing the mass of the material.


Self-heating is a common if not always well understood mechanism for ignition. It fits in well with 9.1.3.




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Public Input No. 35-NFPA 654-2014 [ Section No. 9.3.4.4 [Excluding any Sub-Sections] ]

Type C FIBCs shall be permitted to be used with combustible particulate solids and in locations whereflammable vapors having MIE >0.14 mJ vapors are present.


According to IEC 61340-4-4 the only acceptance criterion for a Type C FIBC is that resistance to ground from any conductive element be less than 1.E7 ohms. Non-conductive surface area between conductive threads should be insufficient for incendive brush discharges provided that the bag is constructed according to this standard, meaning that there should not be a lower MIE limit. By contrast qualification of a Type D FIBC requires demonstrating that discharges from a charged bag are not capable of igniting a flammable vapor/air mixture having an MIE less than 0.14 mJ.


Submitter Full Name: Robert Gravell

Organization: The DuPont Company, Inc.

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9.3.4.4.1

Conductive FIBC elements shall terminate in a grounding tab, and resistance from these elements to the

tab shall be or less than 108 10 7 ohms.


Recommended change in resistance to ground for Type C FIBC reflects requirements from current version of international FIBC standard IEC 61340-4-4, Rev. 2.0, in which value was lowered from 108 to 107 ohms


Submitter Full Name: Robert Gravell

Organization: The DuPont Company, Inc.

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9.8 Industrial Trucks, railcars or similar conveyances .

9.8.1

Where used, industrial trucks, railcars or similar conveyances shall be listed or approved for the electricalclassification of the area, as determined by Section 6.5, and shall be used in accordance with NFPA 505,Fire Safety Standard for Powered Industrial Trucks Including Type Designations, Areas of Use,Conversions, Maintenance, and Operations.

9.8.2*

Where industrial trucks, railcars or similar conveyances in accordance with NFPA 505, Fire SafetyStandard for Powered Industrial Trucks Including Type Designations, Areas of Use, Conversions,Maintenance, and Operations, are not commercially available, a documented risk assessment acceptableto the authority having jurisdiction shall be permitted to be used to specify the fire and explosion preventionfeatures for the equipment used.


It has been pointed out in evaluations by OSHA inspectors that any type of vehicle that is to be used in a classified area needs to be suitable for use in such an area. The additional language is provided to convey that it is not just trucks that need to be addressed.




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10.2.6

All fire detection initiating devices shall be connected to the fire detection control panel via Style D or Ecircuits via class A or B circuits as described in NFPA 72, National Fire Alarm and Signaling Code.


The wiring stiles have been removed from NFPA 72 so this requirement is no longer correct.


Submitter Full Name: Tony Thomas

Organization: Flamex, Inc.

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10.2.7

All fire detection notification appliances shall be connected to the fire detection control panel via Style Y orZ circuits via Class A or B circuits as described in NFPA 72, National Fire Alarm and Signaling Code.


The wiring styles have been removed from NFPA 72 so this requirement is no longer correct.




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10.2.8.1

All fire-extinguishing system releasing devices, solenoids, or actuators shall be connected to the firedetection control panel via Style Z circuits via Class A or B circuits as described in NFPA 72, National FireAlarm and Signaling Code.


The wiring style have been removed from NFPA 72 so this requirement is no longer correct.




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10.2.9

All supervisory devices that monitor critical elements or functions in the fire detection and extinguishingsystem shall be connected to the fire detection control panel via Style D or E circuits via Class A orB circuits as described in NFPA 72, National Fire Alarm and Signaling Code.


The wiring styles have been removed from NFPA 72 so this requirement is no longer correct.




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10.2.10.3

When the abort gate is connected via a Class D circuit the position of the abort gate shall be supervised bythe fire detection control panel.


Class D is fail safe and the abort would operate upon a failure. The position of the abort gate must be monitored to alert the personnel that a failure has occurred.




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10.2.10.1

All fire protection abort gates or abort dampers shall be connected to the fire detection control panel viaStyle Z circuits via Class B or D circuits as described in NFPA 72, National Fire Alarm and Signaling Code.


Both Class B and Class D wiring should be recognized by this standard for the connection to an abort gate. Class B is supervised while Class D has fail safe operation. No fault is annunciated with Class D but the intended operation is performed in the event of a failure. Most abort gates are currently connected with the Class D method and it is recognized in both NFPA 72 and NFPA 15.




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10.2.10.1

All fire protection abort gates or abort dampers shall be connected to the fire detection control panel viaStyle Z either Class A circuits, as described in Chapter 12 of the NFPA 72, National Fire Alarm andSignaling Code or via normally-energized, fail-safe circuits .


NFPA 72 has been revised. The proposed revision updates the reference to NFPA 72 and adds the option of using a normally-energized, fail-safe circuit as a performance-equivalent alternative to monitoring for integrity.




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10.2.10.2

The When the abort gate is connected via a Class B circuit the supervision shall include the continuity ofthe abort gate or abort damper releasing device, whether that device is a solenoid coil, a detonator(explosive device) filament, or other such device.


This statement would differentiate the supervision requirements for an abort connected via Class B from an abort connected via Class D.




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Public Input No. 30-NFPA 654-2014 [ Section No. A.3.3.9.1 ]

A.3.3.9.1 Dust Explosion Hazard Area.

Where the dust cloud concentration is equal to or greater than the MEC, it poses a dust explosion hazard.See NFPA 68, Standard on Explosion Protection by Deflagration Venting, for evaluating strength ofenclosures.


This is an editorial change duplicating the existing language from A.3.3.9.2 to keep the discussion on dust explosion hazards with the annex material for dust explosion hazard area. I have submitted a follow on suggestion to remove the language about the dust explosion hazard from A.3.3.9.2.



Public Input No. 31-NFPA 654-2014 [Section No. A.3.3.9.2]


Submitter Full Name: Amy Brown

Organization: FM Global

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Submittal Date: Mon Jun 30 13:28:09 EDT 2014


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Public Input No. 31-NFPA 654-2014 [ Section No. A.3.3.9.2 ]

A.3.3.9.2 Dust Flash Fire Hazard Area.

Where the dust cloud concentration is equal to or greater than the MEC, it poses a dust explosion and dustflash fire hazard. A propagating deflagration yields a flash fire through the hazard area. In Dust Explosionsin the Process Industries, Eckhoff observes for coal dust that if the cloud obscures a 25 W lightbulb over a6.6 ft (2 m) length, the concentration is probably close to the MEC. It is customary to consider a dust cloudhazardous when the concentration exceeds 25 percent of the MEC. It is recognized that it is often verydifficult or impractical to measure airborne dust concentration in this range in an industrial setting. For thisreason, it is often necessary to rely on subjective measures to determine the dust cloud concentration.


This input is associated with PI 30. This is an editorial suggestion to relocate the discussion on dust explosion hazards with the previous section A.3.3.9.1.



Public Input No. 30-NFPA 654-2014 [Section No.A.3.3.9.1]

Relocation of material from A.3.3.9.2 toA.3.3.9.1


Submitter Full Name: Amy Brown

Organization: FM Global

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Submittal Date: Mon Jun 30 13:33:16 EDT 2014


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Public Input No. 16-NFPA 654-2014 [ New Section after A.3.3.12 ]

A.3.3.14 Explosion. For the purposes of this standard, the term explosion is equivalent to the termdeflagration as identified in NFPA 68, Standard on Explosion Protection by Deflagration Venting.


The words explosion and deflagration are used interchangeably throughout the standard. (The proposed appendix language is used in NFPA 654:A3.3.8. NFPA 654 defines deflagration and explosion with the same verbiage as NFPA 654.)




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Public Input No. 44-NFPA 654-2014 [ New Section after A.7.1.8 ]


7.1.8.1 Pre-deflagration in form of a listed spark detection system in combination with a tested abort gatesystem is a method to handle deflagration hazards. Protected vessels with a fire hazard must be equippedwith a secondary detection zone downstram of the protected vessel and upstream of the abort gate. Testingof the abort gate must be doneby third partyrecognized testing facilityand show full dirvertion of adeflagration detected by the connected spark detection system. This deflagration protection system canonly be relied on in pneumatic conveying systems with concentrations less than LFL or MEC.


Current and prior edition does not recognize the benefits of the use of the combination of spark detection and abort gates to provide life safety. Up to this point the community has not been provided with evidence of the effective operation of a properly tested and installed systems. The industry does have suppliers that has not properly designed and tested the strength and functionallity of these systems. The community recognize that the majority of incident develops as a fire event without entering into a deflagration stage. Without deflagation no pressure rise happens and a pressure activated isolation system will not prevent a flame front of traveling down a return air duct.The community also recognize that the majority of incidents are caused due to conpetent igniters traveling in pneumatic systems with concentrations below LFL or MEC. These competent igniters will be detected by the spark detection system before they enter a risk zone with an explosible concentration. With proper positioning of the spark detection system upstream of the risk zone and considering the proven reaction time of the abort gate the system provide required protection level.Installation of a second detection zone downstream of the risk zone provide for detection of developing fire within the risk zone.The writer request the opertunity to share his finding with the committee.



Public Input No. 45-NFPA 654-2014 [Section No. A.7.14]




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Public Input No. 43-NFPA 654-2014 [ Section No. A.7.1.8 ]

A.7.1.8

These devices reduce the frequency or likelihood that the sparks will cause a deflagration but do noteliminate the need for deflagration isolation devices. The abort gate cannot be relied on to serve as adeflagration isolation device because the response time is relatively slow and construction is usuallyunsuitable for withstanding explosion pressures unless tested by third party testing facility .

Additional information on spark extinguishing systems can be found in Annex C.


The general statement that an abort gate is not strong enough is incorrect. The writer has supervised multiple tests con ducted by recognized testing facility that has show to proerly isolated and deflect a deflagration when the abort function has been initiated by a properly installed pre-deflagration device (spark detection system).




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Public Input No. 28-NFPA 654-2014 [ Section No. A.7.10.1 ]

A.7.10.1

Where deflagration vents are used on bucket elevators, they should be distributed along the casing side inpairs, opposite each other, next to the ends of the buckets. Each deflagration vent should be a minimum oftwo-thirds of the cross-sectional area of the leg casing, and the vents should be located approximately 20 ft(6 m) apart. Vent closures should be designed to open at an internal gauge pressure of 0.5 psi to 1.0 psi(3.4 kPa to 6.9 kPa). Vent closure devices should be secured to eliminate the possibility of the closuresbecoming missiles. Vent materials should be of lightweight construction.

Bucket elevator head sections are recommended to have 5 ft 2 (0.5 m 2 ) of vent area for each 100 ft 3

(2.8 m 3 ) of head section volume.

Vents should not be directed at work platforms, building openings, or other potentially occupied areas.

For bucket elevators inside buildings, vent ducts should be designed with a cross-sectional area at least aslarge as the vent, should be structurally as strong as the bucket elevator casing, and should be limited inlength to 10 ft (3 m). Since any bends cause increases in the pressure developed during venting, ventducts should be as straight as possible. If bends are unavoidable, they should be as shallow angled (i.e.,have as long a radius) as practicable.


This is older text taken from 61 I believe. In any case it is not compliant with the more comprehensive material in the current 68 standard. In 7.1.4.1(2) the user is directed to use 68 for venting, hence this paragraph is inconsistent with that directive.




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Public Input No. 45-NFPA 654-2014 [ Section No. A.7.14 ]

A.7.14

Abort gates cannot be relied upon to manage deflagrations unless designed and installed as outlined in PI44 (7 .1.8.1). See also Annex C.


The standard only provides for pressure activated systems to provide isolation. With testing performed the writer has provided to alternative method oulined in PI 44 to prvode reliable protection using the combination of spark detection and abort gate.



Public Input No. 44-NFPA 654-2014 [New Section after A.7.1.8]




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Public Input No. 21-NFPA 654-2014 [ Chapter G ]

Annex G Informational References

G.1 Referenced Publications.

The following documents or portions thereof are referenced within this standard for informational purposesonly and are thus not part of the requirements of this document unless also listed in Chapter 2.

G.1.1 NFPA Publications.

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

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

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


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

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

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

NFPA 77, Recommended Practice on Static Electricity, 2007 edition 2014 .

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

NFPA 101 ®, Life Safety Code ®, 2012 edition 2015 .

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

NFPA 499, Recommended Practice for the Classification of Combustible Dusts and of Hazardous(Classified) Locations for Electrical Installations in Chemical Process Areas, 2013 edition.

NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments forProtection of Industrial Personnel Against Flash Fire, 2012 edition 2015 .

NFPA 5000 ®, Building Construction and Safety Code ®, 2012 edition 2015 .

SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings, 2000

2 nd edition , 2007 .

G.1.2 Other Publications.

G.1.2.1 ACGIH Publication.

American Conference of Governmental Industrial Hygienists, 1330 Kemper Meadow Drive, Cincinnati, OH45240-1634.

Industrial Ventilation: A Manual of Recommended Practice for Design , 25th 28 th edition, 2004 2013 .

G.1.2.2 AIChE Publications.

American Institute of Chemical Engineers, 345 East 47th Street, New York, NY 10017.

AIChE Center for Chemical Process Safety AICHE G-18 , Guidelines for Hazard Evaluation Procedures,

2nd 3 rd edition with Worked Examples , 1992 2008 .

AIChE Center for Chemical Process Safety, Guidelines for Safe Automation of Chemical Processes, 1993.

G.1.2.3 ASME Publication.

American Society of Mechanical Engineers, Three Park Avenue, New York, NY 10016-5990.

ASME Boiler and Pressure Vessel Code, Section VIII, Division 1, 2001 2013 .

ASME B.31.3, Process Piping, 2008 2012 .


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G.1.2.4 ASTM Publications.

American Society for Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959.

ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750°C, 20032012 .

ASTM E 582, Standard Test Method for Minimum Ignition Energy and Quenching Distance in GaseousMixtures, 2007 2013e1 .

ASTM E 1226, Standard Test Method for Explosibility of Dust Clouds, 2010 2012A .

ASTM E 1491, Test Method for Minimum Autoignition Temperature of Dust Clouds, 2006, reapproved2012 .

ASTM E 1515, Standard Test Method for Minimum Explosible Concentration of Combustible Dusts, 20032007 .

ASTM E 2012, Standard Guide for the Preparation of a Binary Chemical Compatibility Chart, 2000 2006,reapproved 2012 .

ASTM E 2019, Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air, 2003,reapproved 2013 .

ASTM E 2021, Standard Test Method for Hot-Surface Ignition of Dust Layers, 2009, reapproved 2013 .

G.1.2.5 IEC Publications.

International Electrotechnical Commission, 3, rue de Varembé, P.O. Box 131, CH-1211 Geneva 20,Switzerland.

IEC 61340-4-4, Electrostatics — Part 4-4: Standard Test Methods for Specific Applications — ElectrostaticClassification of Flexible Intermediate Bulk Containers (FIBC), 2005 2012 .

G.1.2.6 ISO Publications.

International Standards Organization, 1 rue de Varembé, Case Postale 56, CH-1211 Genève 20,Switzerland.

ISO 6184-1, Explosion Protection Systems — Part 1: Determination of Explosion Indices of CombustibleDusts in Air, 1985.

ISO 6184-4, Explosion Protection Systems — Part 4: Determination of Efficiency of Explosion SuppressionSystems, 1985.

G.1.2.7 USBM Publication.

U.S. Bureau of Mines Publications, National Technical Information Service (NTIS), 5285 Port Royal Road,Springfield, VA 22161.

Conti, R. S., K. L. Cashdollar, M. Hertzberg, and I. Liebman. 1983. “Thermal and Electrical Ignitability ofDusts.” U.S. Bureau of Mines, Report of Investigations, RI 8798.

G.1.2.8 U.S. Government Publication.

U.S. Government Printing Office, Washington, DC 20402.

Title 29, Code of Federal Regulations, Part 1910.146, “Permit-Required Confined Space.”

Title 30, Code of Federal Regulations, Part 36, “Approved Requirements for Permissible Mobile Diesel-Powered Transportation Equipment.”


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G.1.2.9 Other Publications.

FPRF, Report Towards Estimating Entrainment Fraction for Dust Layers, 2011.

Eckhoff, R., Dust Explosions in the Process Industries, 3rd Edition, 2003.

Lazzara, C., and Y. Miron. 1988. “Hot Surface Ignition Temperatures of Dust Layers.” Fire and MaterialsJournal 12:115–126.

Tamanini, F., “Dust Explosion Propagation in Simulated Grain Conveyor Galleries,” ESV-83-067, NationalGrain and Feed Association Fire and Explosion Research Report, prepared by Factory Mutual ResearchCorporation, Norwood, MA, July 1983.

VDI 3673, Pressure Venting of Dust Explosions, 2002.

G.2 Informational References.

FM Data Sheet 7-76, “Prevention and Mitigation of Combustible Dust Explosions and Fire,” January 2012.

Britton. 1999. Avoiding Static Ignition Hazards in Chemical Operations. New York: CCPS, pp. 199–204.

Ebadat, V., and J. C. Mulligan. “Testing the Suitability of FIBCs for Use in Flammable Atmospheres.” Paper10a, 30th Annual Loss Prevention Symposium, AIChE, 1996 Spring National Meeting, New Orleans, LA,February 26-28, 1996.

G.3 References for Extracts in Informational Sections.



Referenced current editions and titles.



Public Input No. 20-NFPA 654-2014 [Chapter 2] Referenced current editions and titles.


Submitter Full Name: Aaron Adamczyk


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Submittal Date: Thu Jun 12 23:42:11 EDT 2014


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Public Input No. 106-NFPA 654-2014 [ Section No. G.1.2.4 ]



ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750°C,2003 2012 .

ASTM E 582, Standard Test Method for Minimum Ignition Energy and Quenching Distance in GaseousMixtures, 2007(2013)e1 .

ASTM E 1226, Standard Test Method for Explosibility of Dust Clouds, 2010 2012a .

ASTM E 1491, Test Method for Minimum Autoignition Temperature of Dust Clouds, 2006(2012) .

ASTM E 1515, Standard Test Method for Minimum Explosible Concentration of Combustible Dusts,2003 2007 .

ASTM E 2012, Standard Guide for the Preparation of a Binary Chemical Compatibility Chart,2000 2006(2012) .

ASTM E 2019, Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air, 2003(2013) .

ASTM E 2021, Standard Test Method for Hot-Surface Ignition of Dust Layers, 2009(2013) .


Update the year date for standard(s)


Submitter Full Name: Steve Mawn

Organization: ASTM International

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137 of 138 7/8/2014 4:08 PM

Public Input No. 52-NFPA 654-2014 [ Section No. G.1.2.4 ]



ASTM E 136 E136 , Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750°C,2003 2012 .

ASTM E 582 E582 , Standard Test Method for Minimum Ignition Energy and Quenching Distance inGaseous Mixtures, 2007 (2013) e1 .

ASTM E 1226 E1226 , Standard Test Method for Explosibility of Dust Clouds, 2010 2012a .

ASTM E 1491 E1491 , Test Method for Minimum Autoignition Temperature of Dust Clouds, 2006 (2012) .

ASTM E 1515 E1515 , Standard Test Method for Minimum Explosible Concentration of Combustible Dusts,2003 2007 .

ASTM E 2012 E2012 , Standard Guide for the Preparation of a Binary Chemical Compatibility Chart,2000 2006 (2012) .

ASTM E 2019 E2019 , Standard Test Method for Minimum Ignition Energy of a Dust Cloud in Air, 2003(2013) .

ASTM E 2021 E2021 , Standard Test Method for Hot-Surface Ignition of Dust Layers, 2009 (2013) .


update




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138 of 138 7/8/2014 4:08 PM

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