A Brief Background:
In 2003, three major explosions occurred in separate industries and involved three different types of combustible dusts: polyethylene, phenolic resin, and aluminum. These incidents sparked a study by the U.S. Chemical Safety and Hazard Investigation Board (CSB), Combustible Dust Hazard Investigation. The study identified 281 incidents involving combustible dust between 1980 and 2005 that resulted in 119 deaths and 718 injuries.
From this investigation (and others that followed), the CSB recommended to facilities that handle, store, use, process, and/or generate any type of combustible dust follow the NFPA dust standards. In addition, the CSB recommended that Occupational Safety and Health Administration (OSHA) develop a comprehensive regulatory standard that protects employees from combustible dust fires and explosions based on current NFPA standards. Some of the major concerns that came out of the OSHA stakeholder meetings for the development of a comprehensive dust standard were:
- NFPA dust documents have some inconsistencies between them
- NFPA standards can be confusing to implement
- NFPA standards provide little guidance on the “how” part of the requirements
- Impact to small businesses
There are other concerns about the adoption of NFPA dust documents, but I believe these to be the key factors that started NFPA to consider a restructure of the current Dust committees.
NFPA Dust Technical Committee Restructure:
Currently, NFPA develops five major dust standards that target specific dust types:
- NFPA 61, Standard for the prevention of fires and dust explosions in agricultural and food processing facilities
- NFPA 484, Standard for Combustible Metals
- NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids
- NFPA 655, Standard for Preventing Sulfur Fires and Explosions
- NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities
These five documents are the responsibility of four technical committees:
- CMD-AGR: TC on Agricultural Dusts (NFPA 61)
- CMD-CMM: TC on Combustible Metals and Metal Dusts (NFPA 484)
- CMD-HAP: TC on Handling and Conveying of Dusts, Vapors, and Gases (NFPA 91, 654, and 655)
- CMD-WOO: TC on Wood and Cellulosic Materials Processing (NFPA 664)
Following the OSHA stakeholder meetings, NFPA staff made a request to restructure the current NFPA dust committees and documents. The Standards Council in the March 2010 Standards Council Meeitng (Minute Item 10-3-19) voted to publish the notice to solicit comments from the public regarding the restructing of the NFPA dust committees and documents.
The following Standards Council meeting in August 2010 (Minute Item 10-8-36), the Standards Council reviewed the public input of the request to restructure the NFPA dust committees and documents, and established a task group to consider the issues and determine the best option for NFPA dust committee and documents.
The task group consisted of the current chairs of the four dust committees, four additional representatives from the four dust committees, NFPA staff and a Standards Council member. They met in early 2011 and from that meeting came up with recommendations and sent them to the Standards Council. The following was the Standards Council's decision at the March 2011 Meeting (Minute Item 11-3-24):
- Establish a Technical Correlating Committee (CMD-AAC) to oversee the work of the 4 dust committees and the proposed new committee
- Establish a Technical Committee on the fundamentals of combustible dusts (CMD-FUN)
- Task CMD-FUN with development of a new document that contains general requirements used to prevent and protect users of combustible dust from fires and explosions AND directed users to the appropriate industry or commodity-specific standard
For all NFPA technical committees, each committee member is assigned a classification based on their principle interest in the activity of the Committee. The interest classifications that NFPA uses to categorize the committee members are:
- Applied Research/Testing Laboratory
- Enforcing Authority
- Special Expert
No more than 1/3 from any interest category can make up a committee. This is the key to keeping the balance of the NFPA technical committees. There was one other element when establishing the Technical Committee on the Fundamentals of Combustible Dusts, ensuring proper representation from the different industries that deal with combustible dusts.
From all the applications and over the course of the year (2011), the Standards Council appointed 28 voting members, 6 alternates, and 2 representatives from OSHA. From these members, the representation from the different industries are as follows:
Again, balance is the key in this technical committee that has been tasked with the development of a standard to develop the general requirements for all combustible dusts and then direct the users to the industry and commodity-specific standard.
What's going on now?
Both CMD-AAC and CMD-FUN have submitted their scope for approval from the Standards Council at the August 2012 Meeting. Additionally, the fundamentals committee has been working over this past year on a draft document to present to the Standards Council.