NFPA Combustible Dust Standard Now in Place
An NFPA staff member provided an update on the new NFPA 652 standard during the AIHce 2016 meeting and said the association is moving toward a single combustible dust standard.
BALTIMORE -- The National Fire Protection Association's new combustible dust standard, NFPA 652, Standard on the Fundamentals of Combustible Dust, is now in effect. While it is the latest in a series of NFPA standards that apply to combustible dusts -- 61, 484, 654, 655, and 664 -- this one, issued in August 2015, includes the important new requirement of dust hazard analysis, Susan Berhad, the association's staff liaison for the combustible dust project, said during a May 25 presentation on the standard at the AIHce 2016 meeting here.
She said 2017 editions of the 61, 652, and 664 standards have recently been issued, and the 652 standard includes a provision that points to the explosion prevention standards -- 67, 68, and 69. The 652 standard sets out three fundamental principles, which are controlling the fuel, controlling the ignition sources, and limiting the spread of any combustion event, she explained.
Redesigning facilities is not retroactive under the standard, Berhad said. But management of change, employee training, and housekeeping requirements all do apply retroactively. There are two compliance options, a prescriptive one and a performance-based one. A dust hazard analysis (DHA) is mandatory for existing processes and facilities within three years, she said, adding that there should be documentation for each of these required elements: responsible party, due date, tracking of redesign activities, date action items are closed out, how they were closed out, and recommendations rejected for cause (if any) and why they were rejected. "You keep your documentation for the life of the process -- you should do it," she added.
Common techniques that are useful in the DHA process include HAZOP (Hazard Operability Analysis), checklist analysis, what if/checklist analysis, FMEA (Failure Mode Effects Analysis), and layers of protection analysis.
And, while the 654 standard requires revalidation of a DHA every five years, that probably will be added to the other standards, including 652, for consistency, Berhad said.
Berhad said in the long term, NFPA envisions a single combustible dust standard. "The short answer is yes, someday. . . . It's going to take some time," she said.