NFPA 660 Q&A with Fike's Brian Edwards

Can you first provide a general overview of what's included in NFPA 660?

NFPA 660 is intended for any facility that manages and handles combustible particulates and dust, and covers both administrative and engineering requirements. The goal is to minimize fires and explosions at industrial sites that handle combustible dust.

• How do you know if you’re handling combustible dust or not? And how do you identify the hazards of your material? NFPA 660 covers the testing requirements you have to do and determines if a material is combustible, explosible or has special hazards such as water reactivity or the potential for self-heating.
  
• How do you determine where fire and explosion hazards exist? In general, you identify where combustible particulates are handled, you look at how they are handled to determine if they can create a dust cloud or not and you look for potential ignition sources, all of which may be achieved through a Dust Hazard Analysis.
  
• How do you know what type of administrative controls you need to have in place? NFPA 660 outlines the training and preventive maintenance required, and covers topics such as inspections, emergency preparedness, incident investigation, management of change and more.
  
• How do you minimize fugitive dust in the workplace? The standard covers dust leak prevention and housekeeping requirements and provides guidance for how to keep dust to manageable levels so that you don't have potential for secondary explosions.
  
• How do you segregate hazards? It details how to keep areas separated if one area of the process has dust explosion hazards and others do not. Segregation includes physical barriers between hazardous and non-hazardous areas, and separation includes the use of distance. This is all part of the building design, and is particularly important for new construction to prevent future issues.
  
• How do you ensure the equipment handling dust is safe? NFPA 660 provides instructions for the minimum safety requirements for dust-handling equipment: that they control ignition sources, that they don't release dust into the environment, and it describes protection options for when equipment has fire and/or explosion hazards.

NFPA 660 provides a high-level view of the fire and explosion protection options, but it does not cover the detailed design of the fire or explosion protection systems. Those will be covered in the sprinkler codes (NFPA 13, etc.) and in NFPA 68 and 69, for explosion protection.

Finally, the new standard goes into commodity specific guidelines, including ones on agriculture, metals, wood and a section on basically all other types of dust and materials.

Is it true that NFPA 660 absorbs some other NFPA standards, and if so what are those standards and are they now retired or are they still active?

NFPA 660 incorporates NFPA 61 which was for food and agricultural facilities, NFPA 484 which is for combustible metals, NFPA 652 which was fundamentals of combustible dust, NFPA 654 which was for combustible solids not covered by one of the other commodity standards, NFPA 655 for sulfur and NFPA 664 for wood dust. You can still visit nfpa.org and be able to access any of those legacy standards.

However, there are some fire codes that depending on what jurisdiction you're in might reference a 2018 international fire code, for example. And if you look in that international fire code, it's going to say the NFPA 61 2017 version is the local AHJ's code on record. So there are times where an older code might be what you have to design to, if that's the one referenced in your local fire code.

So, you can still access those on NFPA's website, but they have a note that these codes are no longer in the revision cycle. If you have any comments or want to make public input on any codes, you have to do that with NFPA 660, because they're not changing any of the old codes.

Can you speak to the general importance of NFPA 660, what it represents, and why this newly organized version of previous standards was necessary?

So that's actually an important point. In the past, you would have to look at the fundamentals which was the NFPA 652 standard that started in 2015 and covered everybody. Before that there were only commodity standards. So if you had agricultural dust, you only had to worry about the agricultural dust standard. You didn't necessarily care about metals, wood, etc.

In 2015 they came out with NFPA 652 which applied to everybody, and they had a caveat that said if there's something in NFPA 652 that contradicts what's in your commodity standard, the owner of the facility has the option to pick which one they want to follow. So if NFPA 61 says that you don't have to have explosion protection on an air material separator that's transporting ingredients, but NFPA 652 says all air material separators over eight cubic feet have to have explosion protection, you can say I'm picking NFPA 61. It says I don't have to so I'm going to go with that one. And honestly those things are still there.

The only difference is what was in 652 is now chapters 1 through nine of NFPA 660 and then the old commodity standards are a separate chapter in 660. So NFPA 61 is chapter 21, NFPA 484 is chapter 22 etc.

Who would you say is most affected by NFPA 660?

NFPA 660 covers any facility that handles solid materials and dust, so they are all affected. In general, the requirements that are in NFPA 660 already applied to all of these facilities; they were just spread out across six different standards. Anybody who regularly reviews and works with the standards will be most impacted. The actual requirements in the standards have not really had many significant changes, but I think they were just focused on consolidating and getting these standards together in a single document. So the actual requirements for this first revision have not changed a lot. There may be one or two changes such as the ingredient transport system now has an additional requirement to be exempt.

However, the biggest impact is that people don't have to jump between different standards, so you don't have to have multiple standards open when you're trying to review a file. You can just go to one document or the website and it’s all there.