TECHNICAL COMMITTEE ON AGRICULTURAL …...TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS Minutes of Meeting – NFPA 61 Second Draft Meeting March 31st - April 3, 2015, 2015 St. Petersburg,

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS

NFPA 61 CMD-AGR (A2016)

Second Draft Meeting

Kansas City Marriott Country Club Plaza

4445 Main Street

Kansas City, MO 64111

Tuesday through Thursday July 7th – July 9th from 8:00 am to 5:00 pm

1. Meeting is called to order at 8 AM each day.

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

3. Chair and Staff Liaison Remarks

4. Approve Minutes from the last meeting (attached)

5. Review of material from the April second draft meeting

o Response to Correlating Committee Notes

o Draft Second Revisions

o Pending task group items

6. Review of Public Comments

7. Old Business

8. New Business

9. Adjournment – Meeting will adjourn at 5 pm each day.

TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS

Minutes of Meeting – NFPA 61 Second Draft Meeting March 31st - April 3, 2015, 2015

St. Petersburg, Florida

Member Attending

Timothy Myers – chair yes Principal

Donald Ankele no Principal

Amy Brown yes Principal

Matt Bujewski yes Principal

Ashok Dastidar yes – by phone Principal

Brian Eklow yes Principal

Craig Froehling yes Principal

Dan Guaricci no Principal

Kevin Hudson no Principal

William Janz yes Principal

William Kearns yes Principal

William Kinslow no Principal

James Maness yes Principal

Jess McCluer yes Principal

Bruce McLelland yes Principal

Karl Nitsch no Principal

Jack Osborn yes Principal

Michael Peters yes Principal

Kent Quinney yes Principal

Jeffrey Rogers yes Principal

Mark Runyon yes Principal

Lee Sargent yes Principal

Robert Shafto yes Principal

Jeffrey Sutton yes Principal

P.D. (Nick) Thielen yes Principal

Erdem Ural Yes –by phone Principal

Clyde Waller No Principal

Stephen Wees Yes – by phone Principal

Anthony Yount Yes Principal

Chris Aiken Yes Alternate

Venkateswara Bhamidipati Yes Alternate

David Clayton No Alternate

Brian Deutsch Yes Alternate

Paul Kelley No Alternate

Steven McCoy Yes – by phone Alternate

Glen Mortensen No Alternate

Jim Norris Yes Alternate

Ronald Stein No Alternate

Peter Telthorst Yes Alternate

Matthew Chibbaro No Nonvoting

William Hamilton No Nonvoting

Robert Nelson No Member Emeritus

Susan Bershad Yes NFPA staff

Merrill Childs Yes Guest – Cargill

Robert Gombar Yes Guest – representing USBSA

Franz Albert Yes Guest – representing ATEX

Dean Heaning Yes Guest – representing Arden Mills

1.0 The meeting was called to order at 8 am by Tim Myers, chair. The attendees, guests,

and those attending via the web conference made self-introductions. 2.0 The minutes from the August 2014 first draft meeting were reviewed and approved. 3.0 Susan Bershad, NFPA staff, gave a brief presentation on the second draft process,

including the schedule for the A2016 cycle, membership, and the status of NFPA 652. This meeting is the first of two second draft meetings for NFPA 61. Since public comment for 61 does not close until May 15, the focus of this meeting was a review of the correlating committee notes for the first draft of 61, as well as a review of the work done by task groups.

4.0 The committee began with a review of the correlating notes for the first draft. The committee developed draft responses to the correlating committee on each of the notes. NFPA staff will circulate these responses to the committee for final review at the meeting in July.

5.0 The consensus of the committee is that 61 should be a stand-alone document that addresses all of the key requirements in 652, ratherthan referencing or relying on material in 652. This is for ease of use by a user of 61, who should not have to consult two separate documents. The committee will be working on aligning 61 with 652 in terms of structure and in terms of content as appropriate. This is in response to several of the correlating committee notes on the first draft. It is expected that this alignment may take more than one revision cycle.

6.0 The committee reviewed the work of several task groups, developing several proposed second revisions to the document. These include revisions to Chapter 3 to

align the definitions in 61 with the other dust documents, as well as new chapters on general requirements, hazard identification, performance based design and management systems to align with 652. NFPA staff will review and distribute all of the draft changes to the 61 technical committee prior to the meeting in August for review.

7.0 There were two new task groups set up at the meeting. 7.1 Checklist task group – Review checklist/examples for dust hazard analysis for

agricultural dust applications. This would be used as annex material. Members of this group are: Mark Runyon, Merrill Childs, Peter Telthorst, and Jeff Rodgers

7.2 Bucket/elevator speed/capacity exemption – Review the history of the speed/capacity exemptions in 5.4. This is in response to a correlating committee note. Based on the results of the research, the task group should consider a recommendation to the TC as to whether or not to keep the exemption. Members of this group are: Anthony Yount, Kent Quinney, Jim Manness, Peter Telthorst, Jack Osborn, and Amy Brown.

8.0 The public comment period for 61 closes on May 15th. Once this deadline has passed, NFPA staff will distribute public comments to the TC as soon as possible to enable the committee to review this material.

9.0 The meeting adjourned at 10:00 am on April 3rd. 10.0 The next meeting will be the continuation of the second draft meeting. It is

scheduled for July 7th through the 10th in Kansas City. Additional details, including the hotel block and RSVP link, are available on the document information page.

Correlating Committee Note No. 1-NFPA 61-2014 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Susan Bershad

Organization: National Fire Protection Assoc

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Submittal Date: Tue Dec 16 16:16:30 EST 2014

Committee Statement

CommitteeStatement:

The Correlating Committee recommends that the 61 technical committee reconsider FR-52. Thestatement is considered to be broad and overreaching. The 61 committee is encouraged to review61 in more detail to determine how it aligns with NFPA 652. Please refer to CN # 3 for direction onaligning the layout and content of 61 with NFPA 652. It is understood by the correlating committeethat this alignment will be a process that may need to take place over several revision cycles.

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

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Organization: [ Not Specified ]

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Submittal Date: Thu Jan 08 20:24:54 EST 2015

Committee Statement

CommitteeStatement:

The Correlating Committee recommends that the 61 TC consider pointing the user in thedirection of NFPA 87 and NFPA 30 for guidance on heat transfer systems. This may be bestaccomplished through the addition of annex material.


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Submittal Date: Fri Jan 09 09:35:23 EST 2015

Committee Statement

CommitteeStatement:

The Correlating Committee recognizes the 61 technical committee for the significant progressthey have made in this first draft.


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Committee Statement

CommitteeStatement:

The 61 technical committee should consider including the language in Section 1.4.1 ofNFPA 654 -

1.4.1

This standard shall be used to supplement the requirements established by NFPA 652.

This clarifies the relationship between 652 and the commodity-specific standards.


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Committee Statement

CommitteeStatement:

The Correlating Committee recommends that the 61 technical committee consider adding thefollowing material to the proposed new chapter on general requirements. This material was addedto the first draft of 654 as well as 664. This recommendation is also being made to 484 and 655 asthey enter their revision cycles.

4.1.3 Owner's Obligation.

The facility owner/operator shall be responsible for ensuring that the facility and the systemshandling combustible particulate solids are designed, installed, and maintained in accordance withthe requirements of this standard and NFPA 652


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Committee Statement

CommitteeStatement:

The 61 technical committee should review the definitions in Chapter 3 for consistency with 652. Thedefinitions in Chapter 3 of 652 should be considered a baseline for those in the other dustdocuments. In some cases, the occupancy specific document may elect to define a term differently.In those cases, the rationale for the differences should be documented. Note that this comment isalso being made to the 654 and the 664 technical committees, and will be made to the 655 and 484committees as they go through their next revision cycle.


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Supplemental Information

File Name Description

652_outline.docx




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Committee Statement

CommitteeStatement:

The 61 technical committee should review the layout of the document for consistency with NFPA652. The chapter layout for the commodity specific standards should align with the layout of NFPA652 in order to facilitate their use with NFPA 652 in accordance with section 1.4.2 of NFPA 652. Thiscomment is also being made to the 654 and 664 technical committees, and will be made to the 655and 484 technical committees as they go through the next revision cycle.

The Correlating Committee is providing an outline taken from 652 to assist the commodity specificcommittees with their expected alignment to 652 over the next revision cycles. In addition the outlineincludes the level of subsection that a user would use to compare 652 to an industry specificstandard. This is the minimum level of alignment expected, the committee is free to go beyond thislevel. Note that the unhighlighted sections are those that should be used. It is expected that this maynot be able to be completed in the current revision cycle, but this a goal that committees should worktoward.


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652 Chapter 1 Administration

1.1 Scope

1.2 Purpose

1.3 Application

1.4 Conflicts

1.5 Retroactivity

1.6 Equivalency

1.7 Units and Formulas

Chapter 2 Referenced Publications

2.1 General

2.2 NFPA Publications.

2.3 Other Publications

2.4 References for Extracts in Mandatory Sections

Chapter 3 Definitions

Committees should align with 652 definitons

Chapter 4 General Requirements

4.1* General

4.2 Objectives

4.2.1 Life Safety

4.2.2* Mission Continuity

4.2.3 Mitigation of Fire Spread and Explosions

Chapter 5 Hazard Identification

5.1* Responsibility

5.2 Overview Screening for Combustibility and Explosibility

5.3* Self-Heating and Reactivity Hazards (Reserved)

5.4 Combustibility and Explosibility Tests

5.4.1* Determination of Combustibility

5.4.2 Determination of Flash Fire Hazard (Reserved)

5.4.3 Determination of Explosibility

5.4.4 Quantification of Combustibility and Explosibility Characteristics

5.5 Sampling

5.5.1 Sampling Plan

5.5.2 Mixtures

5.5.3 Representative Samples

Chapter 6 Performance-Based Design Option

6.1* General Requirements

6.1.12 Approved Qualifications

6.1.2* Document Requirements

6.1.4 Sources of Data

6.1.5* Maintenance of the Design Features

6.2 Risk Component and Acceptability (Reserved)

6.3 Performance Criteria

6.3.1 Life Safety

6.3.2 Structural Integrity

6.3.3 Mission Continuity

6.3.4 Mitigation of Fire Spread and Explosions

6.3.5 Effects of Explosions

6.4* Design Scenarios

6.4.1 Fire Scenarios

6.4.2 Explosion Scenarios

6.5 Evaluation of Proposed Design

Chapter 7 Dust Hazard Analysis

7.1* General Requirements

7.1.1 Responsibility

7.2 Criteria

7.2.1* Overview

7.2.2* Qualifications

7.2.4 Documentation

7.3 Methodology

7.3.1 General

7.3.2 Material Evaluation

7.3.3 Process Systems

7.3.4 Facility Compartments

Chapter 8 Hazard Management: Mitigation and Prevention

8.1 Inherently Safe Designs (Reserved)

8.2 Building Design

8.2.1* Construction

8.2.2 Building/Room Protection

8.2.3 Life Safety

8.2.5 Separation of Hazard Areas from Other Hazard Areas and from Other Occupancies

8.3 Equipment Design

8.3.1* Risk Assessment

8.3.2* Design for Dust Containment

8.3.3* Pneumatic Conveying, Dust Collection, and Centralized Vacuum Cleaning Systems

8.3.4 AMS Locations

8.3.5 Recycle of AMS Clean Air Exhaust AMS

8.3.6 Transfer Points (Reserved)

8.4 Housekeeping

8.4.1 General

8.4.2* Methodology

8.4.3 Training

8.4.4 Equipment (Reserved)

8.4.5 Vacuum Trucks

8.4.6 Frequency and Goal

8.4.7 Auditing and Documentation

8.5 Ignition Source Control

8.5.1* General

8.5.2* Risk Assessment

8.5.3 Hot Work

8.5.5 Bearings

8.5.6 Electrical Equipment and Wiring

8.5.7 Electrostatic Discharges

8.5.8 Open Flames and Fuel Fired Equipment

8.5.9 Industrial Trucks

8.5.10 Process Air and Media Temperatures

8.5.11 Self-Heating

8.5.12 Friction and Impact Sparks

8.6 Personal Protective Equipment

8.6.1 Workplace Hazard Assessment

8.6.2 Limitations of PPE Application (Flame-Resistant Garments)

8.6.3 Limitations of PPE to Combustible Dust Flash-Fires (Reserved)

8.6.4 Face, Hands, and Footwear Protection (Reserved)

8.x Pyrophoric Dusts (Reserved)

8.7 Dust Control

8.7.2* Liquid Dust Suppression Methods for Dust Control

8.7.3 Fans to Limit Accumulation (Reserved)

8.8 Explosion Prevention/Protection

8.8.1 General

8.8.2 Risk Assessment

8.8.3 Equipment Protection

8.8.4 Equipment Isolation

8.9 Fire Protection

8.9.1 General

8.9.3 Fire Extinguishers

8.9.4 Hose, Standpipes, Hydrants, and Water Supply

8.9.5 Automatic Sprinklers

8.9.6 Spark/Ember Detection and Extinguishing Systems

8.9.7 Special Fire Protection Systems

Chapter 9 Management Systems

9.1 Retroactivity

9.2* General

9.3 Operating Procedures and Practices

9.4 Inspection, Testing, and Maintenance

9.5 Training and Hazard Awareness

9.6 Contractors

9.6.3* Contractor Training

9.7 Emergency Planning and Response

9.8* Incident Investigation

9.9 Management of Change

9.10* Documentation Retention

9.11 Management Systems Review

9.12* Employee Participation





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Committee Statement

CommitteeStatement:

The 61 technical committee should review the document to ensure that retroactivity is handledconsistently with the other combustible dust documents. Those sections that are to be appliedretroactively should be explicitly designated in the document section. Typically, management systemelements that do not require capital improvements, such as training and housekeeping, areretroactive. This comment is also being made to the 654 and 664 technical committees and will bemade to the 655 and the 484 technical committees as they go through their next revision cycle.


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Supplemental Information

File Name Description

Draft_Objectives_for_CC_review.docx




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Committee Statement

CommitteeStatement:

The 61 committee should consider aligning their objectives with those presented in attacheddocument developed by the correlating committee task group on objectives. The correlatingcommittee would like to work towards having all of the dust documents have similar objectives. Thisdocument is a product of a task group with representation from all of the combustible dustcommittees and represents the direction the correlating committee would like to head in. Thisrecommendation is also being made to the 654 and the 664 technical committees, and will be madeto the 484, 655, and 652 technical committees as they enter the next revision cycle.


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NFPA 652 – Draft Objectives for CC review (product of the objectives task group) 4.2 Objectives. 4.2.1 The design of the facility, processes and equipment shall be based upon the goal of providing a reasonable level of safety and property protection by meeting the following objectives:

1.) Life Safety 2.) Mission Continuity 3.) Mitigation of Fire Spread and Explosions

4.2.1.1 The objectives stated in Section 4.2 shall be interpreted as intended outcomes of this standard and not as prescriptive requirements.

4.2.1.2 The objectives stated in Section 4.2 shall be deemed to be met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6,

1.) the facility, processes and equipment are designed, constructed and maintained in accordance with the prescriptive criteria set forth in this standard, and

2.) The management systems set forth in this standard are implemented.

4.2.1.3 Where a performance-based alternative design is used, it shall be documented to meet the same objectives as the prescriptive design it replaces, in accordance with Chapter 6 of this standard.

4.2.2 Life Safety. The life safety objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the occupants not in the immediate proximity of the ignition are protected from the effects of fires, flash-fires, and explosions for the time needed to evacuate, relocate, or take refuge in order to prevent serious injury. 4.2.3* Mission Continuity. The mission continuity objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the protection features for the facility, processes and equipment limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. A.4.2.3 Other stakeholders could also have mission continuity goals that will necessitate more stringent objectives as well as more specific and demanding performance criteria. The protection of property beyond maintaining structural integrity long enough to escape is actually a mission continuity objective.

The mission continuity objective encompasses the survival of both real property, such as the building, and the production equipment and inventory beyond the extinguishment of the fire. Traditionally, property protection objectives have addressed the impact of the fire on structural elements of a building as well as the equipment and contents inside a building. Mission continuity is concerned with the ability of a structure to perform its intended functions and with how that affects the structure's tenants. It often addresses post-fire smoke contamination, cleanup, and replacement of damaged equipment or raw materials. 4.2.4* Mitigation of Fire Spread and Explosions. The mitigation of fire spread and explosions shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the prescribed or performance based alternative design features are incorporated into the facility and processes to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments, or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility's structural elements. A.4.2.4 Adjacent compartments share a common enclosure surface (wall, ceiling, floor) with the compartment of fire or explosion origin. The intent is to prevent the collapse of the structure during the fire or explosion. 4.2.5 Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard. 4.2.6 Where a dust fire, deflagration, or explosion hazard exists with a facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard. 4.2.7* Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means:

1. A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any additional prescriptive provisions of applicable commodity-specific NFPA standards.

2. A performance-based approach in accordance with Chapter 6.

A.4.2.7

Usually a facility or process system is designed using the prescriptive criteria until a prescribed solution is found to be infeasible or impracticable. Then the designer can use the performance-based option to develop a design, addressing the full range of fire and explosion scenarios and the impact on other prescribed design features. Consequently, facilities are usually designed not by using performance-based design methods for all facets of the facility but rather by using a mixture of both design approaches as needed.





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Committee Statement

CommitteeStatement:

The correlating committee recommends that the 61 technical committee review the exceptions forbucket elevators with capacities less than 106 m3/hr (3750 ft3/hr) found in sections 7.5.1.10.4,7.5.2.1, and 7.5.3.3.1. The 61 committee should provide technical justification for these exceptionsor remove them. Note that these exceptions have been removed from NFPA 654.


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Correlating Committee Note No. 11-NFPA 61-2015 [ New Section after 4.1.3 ]




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Committee Statement

CommitteeStatement:

The Correlating Committee recommends that the 61 technical committee consider includingsegregation and detachment as management strategies for consistency with the other combustibledust documents. In addition to including the other two management strategies, the 61 technicalcommittee should include the definitions for these terms, as extracted from NFPA 652, in Chapter 3of NFPA 61.


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Correlating Committee Note No. 9-NFPA 61-2015 [ Section No. 4.4.3.1 ]




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Committee Statement

CommitteeStatement:

The correlating committee recommends that the 61 technical committee review the use of the termfire-resistance in this section. 654 made several first revisions changing the term fire-resistancerating to fire-protection rating for doors. The 61 committee should review the changes in 654 andensure that it used the proper term throughout the document. This is a correlating issue between thedocuments.


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Correlating Committee Note No. 10-NFPA 61-2015 [ Section No. 6.2 ]




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Committee Statement

CommitteeStatement:

The Correlating Committee recommends that the 61 technical committee review the use of theterm "combustion explosion" in this section. This terminology is not consistent with those usedthroughout the other combustible dust standards.


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Correlating Committee Note No. 7-NFPA 61-2015 [ Section No. 7.4.2 ]




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Committee Statement

CommitteeStatement:

The 61 technical committee should review FR-18 in light of the negative comments, specificallythose that suggest that the provisions conflict with those in NFPA 68.

First Revision No. 18-NFPA 61-2014 [Section No. 7.4.2]


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Correlating Committee Note No. 8-NFPA 61-2015 [ New Section after 13.11 ]




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Committee Statement

CommitteeStatement:

The Correlating Committee recommends that the 61 technical committee review its action relatingto FR-50. The proposed text does not meet the standard of care established by the othercombustible dust documents such as NFPA 652 and 654 with regards to dust hazard analysis(DHA).

The Correlating Committee recognizes the work of the 61 technical committee. It is aware that thecommittee has a task group that is working on this issue for the second draft. The CorrelatingCommittee encourages the 61 technical committee to review the material in NFPA 652 and strive towork towards the goals and objectives addressed in chapters 5 and 7 of NFPA 652.

First Revision No. 50-NFPA 61-2014 [New Section after 13.11]


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Public Comment No. 8-NFPA 61-2015 [ Section No. 1.5.4 ]

1.5.4

The requirements of Chapter 13 shall apply to all facilities, both new and existing.

Statement of Problem and Substantiation for Public Comment

This language should be moved from Chapter 1 into a new Section 13.1 in Chapter 13, as suggested there. Reason: The Correlating Committee Note suggested moving retroactivity provisions into the specific chapters and sections where they apply.

Related Item

Correlating Committee Note No. 4-NFPA 61-2015 [Global Input]


Submitter Full Name: ARTHUR SAPPER

Organization: McDermott Will & Emery

Affilliation: United States Beet Sugar Association

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Submittal Date: Thu May 14 09:35:30 EDT 2015


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1.5.5

When renovation of existing facilities is planned, provisions or a substantial renovation is made to anexisting facility or process, the provisions of this standard shall apply to that the renovated portion of thefacility or process.

1.5.5.1 For purposes of applying 1.5.5, a substantial renovation is one that exceeds 25 percent of the totalreplacement cost of the facility or process.


As currently written, Sec. 1.5.5 is overbroad in two respects. It will make the provisions of NFPA 61 apply to an existing facility or process if any renovation, regardless of its size and scope, is merely planned, even if the renovation is never actually made. As so written, Sec. 1.5.5 substantially undercuts the grandfather provision in Sec. 1.5.1 of NFPA 61. The 25 percent figure in the new Sec. 1.5.5.1 is based on Sec. 7.1.2.3 of NFPA 652, Second Draft.

Related Item

First Revision No. 10-NFPA 61-2014 [Chapter 1]



Organization: MCDERMOTT WILL EMERY LLP


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Public Comment No. 1-NFPA 61-2015 [ Section No. 2.3 ]

2.3 Other Publications.

2.3.1 AMCA Publications.

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

ANSI/ AMCA Standard 99, Standards Handbook, Standard 99-0401-86, Classifications for SparkResistant Construction , 2010 .

2.3.2 ASME Publications.

American Society of Mechanical Engineers ASME International , Two Park Avenue, New York, NY10016-5990.

ASME Unfired ASME Boiler and Pressure Vessel Code, Section VIII, “Rules Division I, “Rules forConstruction of Pressure Vessels,” 2013 2015 .

2.3.3 ISA Publications.

International Society of Automation, 67 T.W. Alexander Drive, P.O. Box 12277, Research Triangle Park, NC27709.

ANSI/ISA 84.00.01, Functional Safety: Safety Instrumented Systems for the Process Industry Sector, 2004.

2.3.4 MSHA Publications.

Mine Safety and Health Administration (MSHA), 1100 Wilson Boulevard, 21st Floor, Arlington VA22209-3939.

MSHA Title 30 Code of Federal Regulations, Part 18, Section 18.65, "2G Test".

2.3.5 Other Publications.

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


Referenced current edition of AMCA Standard 99, and updated ASME name.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 10-NFPA 61-2015 [Section No. F.1.2]

Related Item

First Revision No. 57-NFPA 61-2014 [Section No. 2.3]


Submitter Full Name: Aaron Adamczyk


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Submittal Date: Sun Mar 01 23:40:38 EST 2015


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Public Comment No. 2-NFPA 61-2015 [ Section No. 4.2.4.1 ]

4.2.4.1 *

Separation shall be permitted allowed to be used to limit the dust explosion hazard or deflagration hazardarea within a building if the separation is supported by a documented evaluation and approved .


Using the word “allowed” is more descriptive. The word “permitted” seems like there is a permit attached to the requirement. Adding “and approved” at the end of the requirement will require it to be acceptable to the AHJ as defined. We agree with the original Public Input and the Negative with Comment that suggests the AHJ must approve such separations.

Related Item

First Revision No. 3-NFPA 61-2014 [New Section after 4.1.3]


Submitter Full Name: Jim Muir

Organization: Building Safety Division, Clark County, WA

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

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Submittal Date: Tue May 05 14:12:23 EDT 2015


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Public Comment No. 3-NFPA 61-2015 [ Section No. 4.2.6.3.1 ]

4.2.6.3.1

For existing facilities, Distances less than 30 m (100 ft) but in no case less than 15 m (50 ft) shall bepermitted where any of the following conditions exist:

(1) The property boundaries or other permanent constraints preclude 30 m (100 ft).

(2) Structures do not have inside legs.

(3) Structures have inside legs that are equipped with explosion protection equipment in accordance withChapter 7.


NFPA Today indicates that there were 50 combustible dust accidents resulting in 29 fatalities and 161 injuries between 2008 and 2012. Recent agricultural dust explosions have shown that separations are necessary. The BCDC agrees with the negative comment. If the TC is going to allow this exception, it should only apply to existing facilities. This should not encourage new facilities to be built near property boundaries or other permanent constraints. As pointed out, even a 30 m distance does not preclude all hazards.



Public Comment No. 4-NFPA 61-2015 [Section No. 4.2.6.4.1]

Related Item

First Revision No. 7-NFPA 61-2014 [Section No. 4.1.5.3]





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Public Comment No. 4-NFPA 61-2015 [ Section No. 4.2.6.4.1 ]

4.2.6.4.1

For existing facilities, Distances less than 15 m (50 ft) shall be permitted if the property boundaries or otherpermanent constraints preclude 15 m (50 ft), but in no case shall distances less than 9 m (30 ft) bepermitted.


NFPA Today indicates that there were 50 combustible dust accidents resulting in 29 fatalities and 161 injuries between 2008 and 2012. Recent agricultural dust explosions have shown that separations are necessary. The BCDC agrees with the negative comment. If the TC is going to allow this exception, it should only apply to existing facilities. This should not encourage new facilities to be built near property boundaries or other permanent constraints.



Public Comment No. 3-NFPA 61-2015 [Section No. 4.2.6.3.1] similar

Related Item

First Revision No. 8-NFPA 61-2014 [Section No. 4.1.5.4]





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Public Comment No. 11-NFPA 61-2015 [ New Section after 13.1 ]

TITLE OF NEW CONTENT

Add a new Section 13.1:

13.1 The requirements of Chapter 13 shall apply to all facilities, both new and existing.


This text was just moved from Sec. 1.5.4. See the comment there about the reason for moving it, that is, that the Correlating Committee Note suggested moving retroactivity provisions into the specific chapters and sections where they apply.

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Correlating Committee Note No. 4-NFPA 61-2015 [Global Input]





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Submittal Date: Fri May 15 09:57:21 EDT 2015


7 of 14 5/18/2015 12:43 PM

Public Comment No. 12-NFPA 61-2015 [ Section No. 13.12 ]

Move all of Section 13.12 (Management Practices) into one or more new chapters and re-numberaccordingly.

13.12 Management Practices.


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13.12.1 Determination of Hazards of Agricultural Dust .

The requirements of 13.12.1.1 through 13.12.1.3 shall be permitted to be used instead of those in Section4.2 and in Chapter 5 of NFPA 652.

13.12.1.1

It shall be permitted to assume that an agricultural dust or mixture is explosible and combustible and toassume worst-case characteristics as a basis for actions, such as design or housekeeping, and as a basisupon which to meet requirements under this standard, such as an agricultural dust hazard survey.

13.12.1.2

The user shall be permitted to rely upon existing historical facility data and published data for explosiveproperties of dust to evaluate dust hazards.

13.12.1.3*

Test results, historical data, and published data shall be documented and, when requested, provided to theauthority having jurisdiction (AHJ). [652:5.2.2]

13.12.2 Agricultural Dust Hazard Survey.

The requirements of 13.12.2.1 through 13.12.2.4 shall be permitted to be used instead of those inChapter 7 of NFPA 652.

13.12.2.1 Scope.

The requirements in 13.12.2.2 through 13.12.2.4 apply to facilities that have agricultural or food dust.

13.12.2.2*

The owner/operator shall, within 5 years of the effective date of this standard, determine whether the facilityis in compliance and, if not, how the facility will be brought into compliance with this standard, and shallinclude a list of compliance steps.

13.12.2.3*

The survey shall include consideration of the following:

(1) Which persons, if any, are required to wear flame-resistant garments. It shall be permitted to consultNFPA 2113 in such consideration. The requirements of 13.12.2.3(1) shall be permitted to be usedinstead of those of 8.6.1.1 of NFPA 652.

(2) Whether separation shall be permitted to be used to limit the dust explosion or deflagration hazardarea within a building and whether detachment shall be permitted to limit the dust explosion hazard ordeflagration hazard area to a building physically separated from adjacent or surrounding exposures.The requirements of 13.12.2.3(2) shall be permitted to be used instead of those of 8.2.5.3 and 8.2.5.4of NFPA 652.

13.12.2.4

Further changes to facilities, equipment, and dusts shall be made in accordance with the management ofchange provision in 13.12.3.

13.12.3 Management of Change.

The requirements of 13.12.3.1 through 13.12.3.2.1 shall be permitted to be used instead of those ofSection 9.9 of NFPA 652.

13.12.3.1 Scope.

The requirements in 13.12.3.1 through 13.12.3.2.1 shall apply to facilities that have agricultural dust orfood dust.

13.12.3.2

After 3 months of the effective date of this standard, the owner/operator shall require that a personknowledgeable in the fire and deflagration hazards of agricultural dust be informed of changes (other thanreplacements in kind) to facilities, equipment, or processed materials before implementation of the change,if feasible, or if not, immediately after implementation.

13.12.3.2.1

The knowledgeable person shall consider whether or not the change would comply with NFPA 61. If thechange does not comply, then a method of compliance shall be determined.


The Management Practices provisions are substantially different from the other provisions in Chapter 13 and should be set out separately to facilitate a comparison with the chapters and sections in NFPA 652 that cover the same issues.


9 of 14 5/18/2015 12:43 PM

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10 of 14 5/18/2015 12:43 PM


13.12.1 Determination of Hazards of Agricultural Dust .

The requirements of 13.12.1.1 through 13.12.1.3 shall apply to both new and existing facilities andprocesses and shall be permitted to be used instead of those in Section 4.2 and in the requirements inChapter 5 of NFPA 652.

13.12.1.1

It shall be permitted to assume that an agricultural dust or mixture is explosible and combustible and toassume worst-case characteristics as a basis for actions, such as design or housekeeping, and as a basisupon which to meet requirements under this standard, such as an agricultural dust hazard survey.

13.12.1.2

The user shall be permitted to rely upon existing historical facility data and published data for explosiveproperties of dust to evaluate dust hazards.

13.12.1.3*

Test results, historical data, and published data shall be documented and, when requested, provided to theauthority having jurisdiction (AHJ). [652:5.2.2]


The change is related to and made necessary because of the move of Section 1.5.4 to be a new Section 13.1, which was done in response to the Correlating Committee Note about retroactivity provisions.

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13.12.2 Agricultural Dust Hazard Survey.

The requirements of 13.12.2.1 through 13.12.2.4 shall not be applied retroactively to facilities existingprior to the effective date of the standard. The requirements of 13.12.2.1 through 13.12.2.4 shall bepermitted to be used instead of those in Chapter 7 of NFPA 652.

13.12.2.1 Scope.

The requirements in 13.12.2.2 through 13.12.2.4 apply to facilities that have agricultural or food dust.

13.12.2.2*

The owner/operator shall, within 5 years of the effective date of this standard, determine whether the facilityis in compliance and, if not, how the facility will be brought into compliance with this standard, and shallinclude a list of compliance steps.

13.12.2.3*

The survey shall include consideration of the following:

(1) Which persons, if any, are required to wear flame-resistant garments. It shall be permitted to consultNFPA 2113 in such consideration. The requirements of 13.12.2.3(1) shall be permitted to be usedinstead of those of 8.6.1.1 of NFPA 652.

(2) Whether separation shall be permitted to be used to limit the dust explosion or deflagration hazardarea within a building and whether detachment shall be permitted to limit the dust explosion hazard ordeflagration hazard area to a building physically separated from adjacent or surrounding exposures.The requirements of 13.12.2.3(2) shall be permitted to be used instead of those of 8.2.5.3 and 8.2.5.4of NFPA 652.

13.12.2.4

Further changes to facilities, equipment, and dusts shall be made in accordance with the management ofchange provision in 13.12.3.


To require such a survey for every facility, even given a five year period, is an unnecessary burden on companies with many facilities that have been operating safely in the same manner for many years.

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Public Comment No. 15-NFPA 61-2015 [ Section No. 13.12.3.2 ]

13.12.3.2

After 3 6 months of the effective date of this standard, the owner/operator shall require that a personknowledgeable in the fire and deflagration hazards of agricultural dust be informed of changes (other thanreplacements in kind) to facilities, equipment, or processed materials before implementation of the change,if feasible, or if not, immediately after implementation.

13.12.3.2.1

The knowledgeable person shall consider whether or not the change would comply with NFPA 61. If thechange does not comply, then a method of compliance shall be determined.


This requirement will apply to existing facilities, and companies with many facilities will need more time to designate “a person knowledgeable” and put an MOC system in place in each facility.

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13 of 14 5/18/2015 12:43 PM

Public Comment No. 10-NFPA 61-2015 [ Section No. F.1.2 ]

F.1.2 Other Publications.

F.1.2.1 ANSI Publications.

American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.

ANSI/ITSDF B56.1, Safety Standard for Low Lift and High Lift Trucks, 2012 2014 .

F.1.2.2 ASTM Publications.

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

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

F.1.2.3 National Grain and Feed Association Publications.

National Grain and Feed Association, 1201 New York Avenue, N.W., Suite 830, Washington, DC 20005.

Emergency Preplanning and Fire Fighting Manual — A Guide for Grain Elevator Operators and FireDepartment Officials, 1987.

F.1.2.4 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

ANSI/ UL 558, Standard for Internal Combustion Engine-Powered Industrial Trucks, 1996, revised 2014.

ANSI/ UL 583, Standard for Electric-Battery-Powered Industrial Trucks, 1996, revised 2014.

F.1.2.5 U.S. Government Publications.

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

OSHA Title 29, Code of Federal Regulations, Part 1910.272.


Updated editions.



Public Comment No. 1-NFPA 61-2015 [Section No. 2.3] Updated editions.

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First Revision No. 45-NFPA 61-2014 [Section No. F.1.2.2]

First Revision No. 59-NFPA 61-2014 [Section No. F.1.2.4]

First Revision No. 60-NFPA 61-2014 [Section No. F.3]


Submitter Full Name: Aaron Adamczyk


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Address List No PhoneAgricultural Dusts CMD-AGR

Combustible Dusts

Susan Bershad06/09/2015

CMD-AGR

Timothy J. Myers

ChairExponent, Inc.9 Strathmore RoadNatick, MA 01760-2418Alternate: David B. Clayton

SE 10/27/2009CMD-AGR

Donald W. Ankele

PrincipalUL LLC333 Pfingsten RoadNorthbrook, IL 60062-2096Alternate: Paul T. Kelly

RT 10/20/2010

CMD-AGR

Amy Brown

PrincipalFM Global1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Alternate: Peter M. Telthorst

I 03/07/2013CMD-AGR

Matthew J. Bujewski

PrincipalMJB Risk Consulting9650 Mill Hill LaneSt. Louis, MO 63127

SE 4/17/1998

CMD-AGR

Ashok Ghose Dastidar

PrincipalFauske & Associates, LLC16W070 83rd StreetBurr Ridge, IL 60527-5802

SE 07/29/2013CMD-AGR

Brian L. Eklow

PrincipalAon Risk Services200 East Randolph StreetChicago, IL 60601Alternate: Ronald A. Stein

I 10/27/2005

CMD-AGR

Craig Froehling

PrincipalCargill, Inc.15407 McGinty Road West, MS 63Wayzata, MN 55391Alternate: Chris Aiken

U 03/05/2012CMD-AGR

Dan A. Guaricci

PrincipalATEX Explosion Protection, L.P.2629 Waverly Barn Road, Suite 121Davenport, FL 33897

M 7/20/2000

CMD-AGR

Kevin M. Hudson

PrincipalIngredionPO Box 1084Indianapolis, IN 46206Alternate: Steven A. McCoy

U 10/18/2011CMD-AGR

William E. Janz

PrincipalXL Global Asset Protection Services301 Pine Ridge DriveWashington, IL 61571

I 4/4/1997

CMD-AGR

William F. Kearns

PrincipalFred D. Pfening Company1075 West Fifth AvenueColumbus, OH 43212

M 8/5/2009CMD-AGR

William F. Kinslow, Jr.

PrincipalMondelēz International100 DeForest AvenueEast Hanover, NJ 07936

U 3/1/2011

CMD-AGR

James E. Maness

PrincipalJEM Safety Consulting5 Eagle DriveRehoboth, DE 19971Grain Elevator and Processing Society

U 1/1/1986CMD-AGR

Jess P. McCluer

PrincipalNational Grain and Feed Association1250 Eye Street, NW, Suite 1003Washington, DC 20005-3922

U 1/10/2008

1



CMD-AGR

Bruce McLelland

PrincipalFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263

M 3/2/2010CMD-AGR

Karl Nitsch

PrincipalKN Associates Corporation1995 Weston RoadPO Box 783Toronto, ON M9N 3W9 Canada

SE 4/17/1998

CMD-AGR

Jack E. Osborn

PrincipalAirdusco, Inc.4739 Mendenhall Road SouthMemphis, TN 38141

M 7/23/2008CMD-AGR

Michael Peters

PrincipalNebraska State Fire Marshal1205 South V RoadHampton, NE 68843

E 08/09/2012

CMD-AGR

Kent C. Quinney

PrincipalThe Amalgamated Sugar Company LLC1951 South Saturn Way, Suite 100Boise, ID 83709-2924US Beet Sugar AssociationAlternate: Brian G. Deutsch

U 03/03/2014CMD-AGR

Jeffrey K. Rogers

PrincipalAg Processing Inc.PO Box 2047Omaha, NE 68103-2047National Oilseed Processors AssociationAlternate: Jim E. Norris

U 7/26/2007

CMD-AGR

Mark L. Runyon

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

I 10/23/2013CMD-AGR

Lee M. Sargent

PrincipalTodd & Sargent, Inc.2905 SE 5th StreetAmes, IA 50010-7716

SE 7/1/1993

CMD-AGR

Robert D. Shafto

PrincipalZurich Insurance1093 Tall Pines TrailHighland, MI 48356Alternate: Glen R. Mortensen

I 3/1/2011CMD-AGR

Jeffery W. Sutton

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

SE 4/3/2003

CMD-AGR

P. D. (Nick) Thielen

PrincipalGeneral Mills, Inc.9000 Plymouth Avenue, NorthGolden Valley, MN 55427

U 3/2/2010CMD-AGR

Erdem A. Ural

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

SE 3/2/2010

CMD-AGR

Clyde Waller

PrincipalPowder Process Solutions1610 Lake Drive WestChanhassen, MN 55317Alternate: Venkateswara Sarma Bhamidipati

IM 8/9/2011CMD-AGR

Stephen L. Wees

PrincipalHayes & Stolz Industrial Manufacturing, Ltd.3521 Hemphill StreetFort Worth, TX 76110

M 3/21/2006

2



CMD-AGR

J. Anthony Yount

PrincipalConAgra Food Ingredients11 ConAgra DriveOmaha, NE 68103

U 3/21/2006CMD-AGR

Chris Aiken

AlternateCargill, Inc.15407 McGinty Road West, MS 63Wayzata, MN 55391Principal: Craig Froehling

U 07/29/2013

CMD-AGR

Venkateswara Sarma Bhamidipati

AlternatePowder Process Solutions1620 Lake Drive WestChanhassen, MN 55317Principal: Clyde Waller

IM 10/29/2012CMD-AGR

David B. Clayton

AlternateExponent, Inc.5401 McConnell AvenueLos Angeles, CA 90066-7027Principal: Timothy J. Myers

SE 10/20/2010

CMD-AGR

Brian G. Deutsch

AlternateMichigan Sugar Company2600 South Euclid AvenueBay City, MI 48706US Beet Sugar AssociationPrincipal: Kent C. Quinney

U 03/03/2014CMD-AGR

Paul T. Kelly

AlternateUnderwriters Laboratories Inc.333 Pfingsten Road60062-2096Northbrook, IL 60062-2096Principal: Donald W. Ankele

RT 03/03/2014

CMD-AGR

Steven A. McCoy

AlternateIngredionPO Box 1084Indianapolis, IN 46206Principal: Kevin M. Hudson

U 10/18/2011CMD-AGR

Glen R. Mortensen

AlternateZurich Services CorporationRisk Engineering21337 West Crescent DriveMundelein, IL 60060-3399Principal: Robert D. Shafto

I 3/1/2011

CMD-AGR

Jim E. Norris

AlternateBunge North America11720 Borman DrivePO Box 28500St. Louis, MO 63146-1000National Oilseed Processors AssociationPrincipal: Jeffrey K. Rogers

U 10/20/2010CMD-AGR

Ronald A. Stein

AlternateAon Global Risk Consultants4801 Main Street, Suite 350Kansas City, MO 64112Principal: Brian L. Eklow

I 07/29/2013

CMD-AGR

Peter M. Telthorst

AlternateFM Global540 Maryville Center Drive, Suite 400St Louis, MO 63141Principal: Amy Brown

I 03/07/2013CMD-AGR

Matthew I. Chibbaro

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

E 3/4/2009

3



CMD-AGR

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-AGR

Robert W. Nelson

Member Emeritus28 Wing RoadPO Box 418Pocasset, MA 02559

SE 1/1/1989

CMD-AGR

Susan Bershad

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

04/16/2014

4

Documents

TECHNICAL COMMITTEE ON AGRICULTURAL …...TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS Minutes of Meeting – NFPA 61 Second Draft Meeting March 31st - April 3, 2015, 2015 St. Petersburg,