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Technical Committee on Fundamentals of Combustible Dusts

To: Technical Committee on Fundamentals of Combustible Dusts

From: Guy R. Colonna, Staff Liaison

Date: December 17, 2013

Subject: NFPA 652 Second Draft Meeting Agenda Package

Enclosed are the materials that will be required for the NFPA 652 Second Draft meeting being held January 15 – 17, 2014 at the Hilton St. Petersburg Carillon Park, St. Petersburg, FL. The primary purpose for this meeting will be the review of the Public Comments submitted to the NFPA 652 First Draft. To facilitate the conduct of the meeting and your participation in the discussions, please review the Public Comments prior to the meeting. These materials will also be available for access on‐line at www.nfpa.org/652next.

I have received preliminary notification from guests who plan to attend the meeting and have requested the opportunity to address the Committee on agenda items related to Public Comments they have authored.

Please let me know if you have any questions either phone (617‐984‐7435) or email ([email protected]).


Agenda

Hilton St. Petersburg Carillon Park 950 Lake Carillon Drive St. Petersburg, FL 33716

January 15 – 17, 2014

Starting at 8:00 am on Wednesday, January 15th (other days to be determined)

1. Call to order, Chair’s welcome, and opening remarks 2. Self‐introduction of members and guests 3. Review and approval of minutes for previous meeting (February 12 – 14, 2013)(Attachment A) 4. Staff Liaison Report

a. Review of policies and procedures b. Review of new process (Public Comment stage and Second Draft) c. Review of Committee membership (Attachment B) d. Review of F2014 Revision Cycle – timeline, milestones (Attachment C)

5. Second Draft process a. Review and act on Public Comments (Attachment D) b. Create Second Revisions as appropriate c. Guest input as previously notified

6. New Business 7. Next meeting – no meetings required

a. Review NITMAM process and amending motions b. Annual Technical Meeting – NFPA C&E, June 2015, Chicago

8. Adjournment – Friday, January 17, 2014 (scheduled for 4 pm)

ATTACHMENT A:

NFPA 652 FIRST DRAFT MEETING MINUTES

FEBRUARY 12 – 14, 2013, NFPA, QUINCY, MA


Date: April 19, 2013

To: Technical Committee on Fundamentals of Combustible Dusts

From: Derek Duval, Staff Liaison/Fire Protection Engineer

Re: NFPA 652 First Draft Meeting Minutes – February 2013

Enclosed are the meeting minutes from the February 12-15, 2013 NFPA 652 First Draft meeting at NFPA and the follow-up web-conference meetings on February 26-27, 2013, and March 4-5, 2013 to complete the First Draft. Please feel free to bring any substantive incorrect items to my attention. The next meeting will be held between November 15, 2013 and January 24, 2014. Details will follow as they become available. The Committee actions will be balloted before May 17, 2013. The Correlating Committee actions will be balloted no later than August 23, 2013. The First Draft Report will be posted no later than September 6, 2013. Public comments for must be submitted no later than November 15, 2013. If you have any questions or comments, please feel free to reach me at (617) 984-7434 or by e-mail at [email protected].

mailto:[email protected]

CMD-FUN Page 2 First Draft Minutes, NFPA 652 – February 2013


Minutes of Meeting NFPA Headquarters

1 Batterymarch Park, Quincy MA February 12-14, 2013

Web-Conferences February 26-27, 2013

March 4-5, 2013

I. Attendance: Principal Members/Staff: Paul Hart, Chair, XL Global Asset Protection Services Derek Duval, NFPA Elizabeth Buc, Fire & Materials Research Laboratory, LLC Brad Burridge, Novelis, Inc Brice Chastain, Georgia-Pacific, LLC John Cholin, J.M. Cholin Consultants, Inc Tom Christman, via web-conference Randal Davis, UTC/Kidde-Fenwal, Inc Lee DeVito, FIREPRO Inc Robert Feldkamp, Nordson Corporation, via web-conference Walter Frank, Frank Risk Solutions, Inc. via web-conference Robert Gombar, Baker Engineering & Risk Consultants, Inc, representing U.S. Beet Sugar Association David House, I.C. Thomasson Associates, Inc., via web-conference James Koch, The Dow Chemical Company, representing American Chemistry Council, via web-conference Bruce McLelland, Fike Corporation Timothy Myers, Exponent, Inc James Norris, Bunge North America, representing International Oil Mill Superintendents Association George Petino, Hazards Research Corporation, Inc., representing Mars Inc. Samuel Rodgers, Honeywell, Inc., via teleconference Steve Sallman, United Steelworkers Thomas Scherpa, The DuPont Company, Inc. Denise Statham, VF Imagewear/Bulwark Protective Apparel Bill Stevenson, CV Technology, Inc. Robert Taylor, American Electric Power, representing PRB Coal Users’ Group Erdem Ural, LPSTI Robert Zalosh, Firexplo Jason Reason, Indiana Department of Labor/IOSHA (nonvoting), via web-conference


Alternate Members and Guests: Robert Bitter, Honeywell, Inc. (Alternate) Dale Hansen, Harrington Group, Inc. (Alternate) Jason Krbec, CV Technology, Inc, via web-conference (Alternate) Richard Masta, Georgia-Pacific, LLC (Alternate) William Hamilton, U.S. Department of Labor, via web-conference (Alternate) Guy Colonna, NFPA (Guest) Niels Pedersen, Nederman LLC (Guest) Mark Saner, Workrite Uniform (Guest) Craig Froehling, Cargill (Guest) Anthony Yount, ConAgra (Guest) Chuck Durthler, Penford Corp (Guest) Jess McCluer, NGFA (Guest) Lawrence Halprin, Keller & Heckman (Guest)

II. Meeting Minutes: 1. Call to order. The meeting was called to order at 8:00 a.m. on February 28, 2013. The Chair,

Paul Hart, welcomed the Technical Committee (TC) members and guests to the meeting.

2. Self-Introductions. The TC members and guests introduced themselves and identified their affiliations.

3. Staff Liaison Report. The staff liaison made a brief presentation on NFPA policies and procedures, the new standards process, reviewed the document revision timeline (Attachment A, F2014 Revision Cycle), and updated the TC on membership changes.

4. New Business:

A. NFPA 652. The TC and guests split up into task groups to review and provide

recommendations on public input and first revisions. The TC reviewed and resolved all the public input (470). The TC created first revisions based on the public input and the task group recommendations. The first revisions, public inputs, and committee statements will be posted in the First Revision Report and Draft to be posted no later than September 6, 2013. The First Draft Report and Draft will be available via www.nfpa.org/652.

5. Next Meeting. The next meeting will take place between November 15, 2013 and January 2014,

more details to follow.

6. Adjournment. The meeting was adjourned at 1:30 p.m. March 5, 2013.

http://www.nfpa.org/652


ATTACHMENT A

NFPA 652 Revision Cycle Fall 2014

NFPA 652, Revision Cycle F2014 Important Dates for the Cycle:

Public Input Closing: January 4, 2013

Technical Committee First Draft Meeting: February 12-14, 2013

Correlating Committee First Draft Meeting: June 18-21, 2013*

Posting of First Draft: September 6, 2013

Public Comment Closing: November 15, 2013

Posting of Section Draft: July 18, 2014

Notice of Intent to Make a Motion (NITMAM): August 22, 2014

Issuance of Consent Standard: November 11, 2014

NFPA Annual Meeting with Certified Amending Motions (CAMs): June 8-11, 2015

Issuance of Standard – with CAMs: August 6, 2015 *Note: This is the date for the Correlating Committee, CMD-AAC; the TC CMD-FUN does not need to attend this meeting.

ATTACHMENT B:

COMMITTEE MEMBERSHIP

Address List No PhoneFundamentals of Combustible Dusts CMD-FUNCombustible Dusts

Guy R. Colonna12/16/2013

CMD-FUNPaul F. HartChairAmerican International Group, Inc. (AIG)18257 Martin AvenueHomewood, IL 60430

I 8/9/2011CMD-FUN

Elizabeth C. BucPrincipalFire & Materials Research Laboratory, LLC33025 Industrial RoadLivonia, MI 48150

RT 8/9/2011

CMD-FUNBrad D. BurridgePrincipalNovelis, Inc.639 Players Crossing WayBowling Green, KY 42104Alternate: Van Mitchell

U 03/05/2012CMD-FUN

Cheryl B. CarbonePrincipalJELD-WEN, Inc.1500 SW First Avenue, Suite 1100Portland, OR 97201

U 03/07/2013

CMD-FUNBrice ChastainPrincipalGeorgia-Pacific LLC133 Peachtree Street NE, 9th FloorAtlanta, GA 30303Alternate: Richard F. Masta

U 8/9/2011CMD-FUN

John M. CholinPrincipalJ. M. Cholin Consultants Inc.101 Roosevelt DriveOakland, NJ 07436

SE 8/9/2011

CMD-FUNTom ChristmanPrincipal984 Foxridge LaneCaryville, TN 37714

SE 8/9/2011CMD-FUN

Randal R. DavisPrincipalUTC/Kidde-Fenwal, Inc.400 Main StreetAshland, MA 01721-2150Alternate: David Grandaw

M 03/05/2012

CMD-FUNLee C. DeVitoPrincipalFIREPRO Incorporated1600 Osgood Street, Suite 2082North Andover, MA 01845

SE 8/9/2011CMD-FUN

Mark W. DrakePrincipalLiberty Mutual11805 West 128th StreetOverland Park, KS 66213Alternate: Robert C. Berry

I 8/9/2011

CMD-FUNRobert J. FeldkampPrincipalNordson Corporation300 Nordson DriveAmherst, OH 44001Alternate: Edward L. Jones

M 03/05/2012CMD-FUN

Walter L. FrankPrincipalFrank Risk Solutions, Inc.1110 Shallcross AvenueWilmington, DE 19806

SE 8/9/2011

CMD-FUNRobert C. GombarPrincipalBaker Engineering & Risk Consultants, Inc.707 Hardwood LaneAnnapolis, MD 21401-4570US Beet Sugar Association

U 8/9/2011CMD-FUN

David M. HousePrincipalI.C. Thomasson Associates, Inc.2950 Kraft Drive, Suite 500Nashville, TN 37204

SE 03/05/2012

1



CMD-FUNJames F. KochPrincipalThe Dow Chemical Company1400 BuildingMidland, MI 48667American Chemistry CouncilAlternate: Glenn W. Baldwin

U 03/05/2012CMD-FUN

Bruce McLellandPrincipalFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263Alternate: Jerome R. Taveau

M 10/18/2011

CMD-FUNTimothy J. MyersPrincipalExponent, Inc.9 Strathmore RoadNatick, MA 01760

SE 8/9/2011CMD-FUN

Jim E. NorrisPrincipalBunge North America11720 Borman DrivePO Box 28500St. Louis, MO 63146-1000International Oil Mill Superintendents Assn.

U 03/05/2012

CMD-FUNJack E. OsbornPrincipalAirdusco, Inc.4739 Mendenhall Road SouthMemphis, TN 38141

M 8/9/2011CMD-FUN

Niels H. PedersenPrincipalNederman LLCPO Box 429Thomasville, NC 27361-0429

M 03/07/2013

CMD-FUNGeorge Petino, Jr.PrincipalHazards Research Corporation, Inc.200 Valley Road, Suite 104Mt. Arlington, NJ 07856Mars Inc.Alternate: Dale C. Hansen

U 8/9/2011CMD-FUN

Jason P. ReasonPrincipalLewellyn Technology321 North 18th AvenueBeech Grove, IN 46107

SE 8/9/2011

CMD-FUNSamuel A. RodgersPrincipalHoneywell, Inc.15801 Woods Edge RoadColonial Heights, VA 23834-6059Alternate: Robert F. Bitter

U 8/9/2011CMD-FUN

Steve SallmanPrincipalUnited SteelworkersFive Gateway Center, Room 902Pittsburgh, PA 15222

L 8/9/2011

CMD-FUNThomas C. ScherpaPrincipalThe DuPont Company, Inc.71 Valley RoadSullivan, NH 03445

U 8/9/2011CMD-FUN

Denise N. StathamPrincipalVF Imagewear/Bulwark Protective Apparel545 Marriott DriveNashville, TN 37214

M 10/18/2011

CMD-FUNBill StevensonPrincipalCV Technology, Inc.15852 Mercantile CourtJupiter, FL 33478Alternate: Jason Krbec

M 8/9/2011CMD-FUN

Robert D. TaylorPrincipalAmerican Electric Power4377 Sandra Kay LaneNewburgh, IN 47630PRB Coal Users’ Group

U 8/9/2011

2



CMD-FUNErdem A. UralPrincipalLoss Prevention Science & Technologies, Inc.2 Canton Street, Suite A2Stoughton, MA 02072

SE 03/05/2012CMD-FUN

Robert G. ZaloshPrincipalFirexplo20 Rockland StreetWellesley, MA 02481

SE 8/9/2011

CMD-FUNArthur P. Mattos, Jr.Voting AlternateXL Global Asset Protection Services3216 Tatting RoadMatthews, NC 28105-7181Voting Alt. to XLGAPS Rep.

I 03/07/2013CMD-FUN

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

U 03/07/2013

CMD-FUNRobert C. BerryAlternateLiberty Mutual Insurance Company1508 Beech CircleWilkesboro, NC 28697-2602Principal: Mark W. Drake

I 10/29/2012CMD-FUN

Robert F. BitterAlternateHoneywell, Inc.FM&T2000 East 95th StreetKansas City, MO 64141Principal: Samuel A. Rodgers

U 8/9/2011

CMD-FUNDavid GrandawAlternateFenwal IEP Technologies655 Grand Avenue, Suite 320Elmhurst, IL 60126Principal: Randal R. Davis

M 10/29/2012CMD-FUN

Dale C. HansenAlternateHarrington Group, Inc.2400 Meadowbrook Parkway, Suite 250Duluth, GA 30096Mars Inc.Principal: George Petino, Jr.

U 03/05/2012

CMD-FUNEdward L. JonesAlternateNordson Corporation300 Nordson Drive, M/S 44Amherst, OH 44001Principal: Robert J. Feldkamp

M 03/05/2012CMD-FUN

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

M 10/29/2012

CMD-FUNRichard F. MastaAlternateGeorgia-Pacific LLC133 Peachtree Street, 7th FloorAtlanta, GA 30303Principal: Brice Chastain

U 8/9/2011CMD-FUN

Van MitchellAlternateLogan Aluminum Inc.6920 Lewisburg RoadRussellville, KY 42276Principal: Brad D. Burridge

U 03/07/2013

CMD-FUNJerome R. TaveauAlternateFike Corporation704 South 10th StreetBlue Springs, MO 64015Principal: Bruce McLelland

M 03/07/2013

3



CMD-FUNMatthew I. ChibbaroNonvoting MemberUS Department of LaborOccupational Safety & Health Administration200 Constitution Ave. NW, Room N3609Washington, DC 20210Alternate: William R. Hamilton

E 10/18/2011CMD-FUN

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

E 10/18/2011

CMD-FUNGuy R. ColonnaStaff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

09/09/2013

4

ATTACHMENT C:

FALL 2014 REVISION CYCLE

2014 FALL 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* 1/4/2013 1/4/2013 Final Date for TC First Draft Meeting 6/14/2013 3/15/2013

Public Input Posting of First Draft and TC Ballot 8/2/2013 4/26/2013 Stage Final date for Receipt of TC First Draft ballot 8/23/2013 5/17/2013

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 8/30/2013 5/24/2013 Posting of First Draft for CC Meeting 5/31/2013 Final date for CC First Draft Meeting 7/21/2013 Posting of First Draft and CC Ballot 8/2/2013 Final date for Receipt of CC First Draft ballot 8/23/2013 Final date for Receipt of CC First Draft ballot ‐ recirc 8/30/2013 Post First Draft Report for Public Comment 9/6/2013 9/6/2013

Public Comment Closing Date for Paper Submittal* 10/11/2013 10/11/2013 Public Comment Closing Date for Online Submittal (e‐PC)* 11/15/2013 11/15/2013 Final Date to Publish Notice of Consent Standards (Standards that

received no Comments) 11/29/2013 11/29/2013

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

12/13/2013 12/13/2013

Final date for TC Second Draft Meeting 5/2/2014 1/24/2014 Comment Posting of Second Draft and TC Ballot 6/13/2014 3/7/2014 Stage Final date for Receipt of TC Second Draft ballot 7/7/2014 3/28/2014

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 7/14/2014 4/4/2014 Draft) Posting of Second Draft for CC Meeting 4/11/2014

Final date for CC Second Draft Meeting 5/23/2014 Posting of Second Draft for CC Ballot 6/13/2014 Final date for Receipt of CC Second Draft ballot 7/3/2014 Final date for Receipt of CC Second Draft ballot ‐ recirc 7/11/2014 Post Second Draft Report for NITMAM Review 7/18/2014 7/18/2014

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 8/22/2014 8/22/2014 Preparation Posting of Certified Amending Motions (CAMs) and Consent

Standards 10/17/2014 10/17/2014

(& Issuance) Appeal Closing Date for Consent Standards 11/1/2014 11/1/2014 SC Issuance Date for Consent Standards 11/11/2014 11/11/2014

Tech Session Association Meeting for Standards with CAMs 6/22‐25/2015 6/22‐25/2015 Appeals and Appeal Closing Date for Standards with CAMs 7/15/2015 7/15/2015 Issuance SC Issuance Date for Standards with CAMs 8/20/2015 8/20/2015

Approved___ October 18, 2011 _ Revised____March 7, 2013____________

ATTACHMENT D:

PUBLIC COMMENTS TO NFPA 652 FIRST DRAFT

NFPA 652 Standard on Combustible Dusts

Public Comments Submitted For Review

Second Draft Meeting January 15‐17, 2014

Public Comment No. 11-NFPA 652-2013 [ Global Input ]

Texas Cotton Ginners’ Association supports the concept of using a stepped approach to determinecombustibility. Specifically, we support the use in section 4.5.1.1 of the UN Recommended testmethod as a screening test to determine combustibility. We are also in support of section 5.2.3,which allows for published data to be used in determining whether a dust is combustible orexplosible.

Our main concern with this standard is mentioned in Appendix A, Section A.3.3.2, which is thepossibility for a sample to return a false positive caused when a high energy ignition sourceoverdrives a test. The use of this stepwise determination should help to reduce the incidences offalse positives by eliminating some dusts in the first step.

For dusts containing a significant amount of inert (i.e. non-combustible) material, such as soil, thenon-combustible material prevents flame propagation beyond the ignition source. If there is nopropagation, there can be no MEC. Without an MEC, there can be no explosion. If a dust with alarge percentage of inert (i.e. non-combustible) material, for example 60% or more, passes the UNtest it should not be considered a combustible dust and no further testing should be required.

In summary, we believe the allowance of a stepped approach for determining combustibility orexplosivity, combined with the ability to use published industry data on this subject will allow for amuch more accurate classification of a wide variety of dusts.

J Kelley Green

Texas Cotton Ginners’ Association

[email protected]

Statement of Problem and Substantiation for Public Comment

We are not proposing any changes, but are supporting the stepped approach this version of the standard contemplates. The main concern we have with the issue of classifying combustible dusts is the ability to address over-driven false positives that some test methods can produce.

Submitter Information Verification

Submitter Full Name: Kelley GreenOrganization: Texas Cotton Ginners' AssociationStreet Address:City:State:Zip:Submittal Date: Fri Sep 20 15:35:44 EDT 2013

Copyright Assignment

I, Kelley Green, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Kelley Green, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature

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

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Type your content here ...

The National Cotton Ginners’ Association (NCGA) supports the concept of using a stepped approach todetermine combustibility. The NCGA supports the use in section 4.5.1.1 of the UN Recommended testmethod as a screening test to determine combustibility. We also support section 5.2.3 that allows forpublished data to be used in determining whether a dust is combustible or explosible.

NCGA’s main concern with this standard (Appendix A, Section A.3.3.2) is the possibility for a sample toproduce a false positive that is caused when a high energy ignition source overdrives the test. The use ofthis stepwise determination should help to reduce the incidences of false positives by eliminating somedusts in the first step.

Additionally, dusts containing a significant amount of inert (i.e. non-combustible) material, such as soil,prevent flame propagation beyond the ignition source. If there is no propagation, there can be no MEC, andwithout an MEC, there can be no explosion. If dust with a large percentage of inert (i.e. non-combustible)material, for example 60% or more, passes the UN test, it should not be considered a combustible dust andno further testing should be required.

In summary, NCGA believes the allowance of a stepped approach for determining combustibility orexplosivity, combined with the ability to use published industry data on this subject, will allow for a muchmore accurate classification of a wide variety of dusts.


The National Cotton Ginners’ Association is not proposing changes, but is supporting the stepped approach of this standard. The NCGA’s main concern with the issue of classifying combustible dusts, is the ability to address over-driven false positives that some test methods can produce.


Submitter Full Name: Harrison AshleyOrganization: National Cotton Ginners' AssociationStreet Address:City:State:Zip:Submittal Date: Fri Oct 04 14:05:18 EDT 2013


I, Harrison Ashley, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright inthis Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend thatI acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similaror derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Harrison Ashley, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature


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Additional Proposed Changes

File Name Description ApprovedNFPA_652_Comments_in_Response_to_First_Draft.pdf Supporting and explanatory comments


These are general comments on the process and the standard.


Submitter Full Name: MARC FLEISCHAKEROrganization: ARENT FOX LLPAffilliation: NOPA, NGFA, IOMSAStreet Address:City:State:Zip:Submittal Date: Sun Nov 10 14:21:18 EST 2013


I, MARC FLEISCHAKER, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights incopyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understandand intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this oranother similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power andauthority to enter into this copyright assignment.

By checking this box I affirm that I am MARC FLEISCHAKER, and I agree to be legally bound by the above Copyright Assignment andthe terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature thatwill, upon my submission of this form, have the same legal force and effect as a handwritten signature


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Preliminary Draft of NFPA 652 Standard on Combustible Dusts

Proposed 2015 Edition

Comments by the Non-Ferrous Founders’ Society

Park Ridge, Illinois

Introduction

The Non-Ferrous Founders’ Society (NFFS, or hereinafter the Society) is a 70 year old not-for-profittrade association representing aluminum and copper-based foundries and ingot manufacturers.The Society has a documented history of successfully developing and distributing regulatorycompliance assistance services both to our member foundries and the metal casting industry.

Industry Background

Foundries are included under NAICS Code 331000, Primary Metal Manufacturing industry. There aretwenty-six distinct sub-categorizations of facilities within this industry designation. Three specificsub-categories describe Non-Ferrous Foundries: 331524, Aluminum Foundries (exceptDie-Casting); 331529, Copper Foundries (except Die-Casting); and 331528, Other NonferrousFoundries (except Die-Casting).

By industry estimates, there are still more than 2,000 non-ferrous foundries in operation in theUnited States. Most nonferrous foundries and Ingotmakers in the United States are classified assmall businesses under U.S. Small Business Administration definitions (less than 500 employees).More than ninety percent (90%) of these facilities employ fewer than 100 people. The majority ofthese companies are privately held - many are family-run businesses, some actually owned andoperated by the same family for several generations. Although many of these companies lack thepersonnel and resources to employ a full-time safety & health expert or industrial hygienist,non-ferrous foundries do invest heavily in workplace safety.

Comments specific to the preliminary draft of NFPA 652

Foundries are inherently dusty, and much of the dust is not combustible as it consists ofoxides, non-combustible metals, and silica (sand) dust that is co-mingled with other metaldusts;

Not all facilities will have conditions conducive to a secondary deflagration even whenfugitive dust may be determined to be combustible (e.g. the facility may utilize an open airdesign or have a large volume, preventing the airborne concentrations of combustible dustnecessary to support a secondary deflagration).

It is not economically feasible for many foundries to:

Conduct the number of tests required by the standard, which could cost manythousands of dollars in testing costs, with very little, if any, improvement in workersafety;

Redesign and retrofit existing ventilation systems to avoid combustible dustdeflagrations which are not likely to occur.

The actual number of incidents within the metal casting industry NAICS codes does notsupport the need for a combustible dust standard:

The explosion at Jahn Foundry, located in Springfield, MA, on February 25, 1999 isoften presented as evidence supporting the need for combustible dust standardsaffecting the foundry industry, even though this incident is not representative of amajority of the US domestic foundry industry. Jahn Foundry operated a shell moldoperation, and they were coating their own silica sand with phenol formaldehyde resinto allow the sand to bind during the curing process. Very few foundries coat their ownsand in this fashion in present day. The explosion was found to be due to theaccumulation of phenol formaldehyde resin dust (not metal dust) within the ventilation


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ducts, poor ventilation design, poor maintenance practices and equipment in poorcondition. Combustible metals dusts were never determined to be a contributingfactor in this incident.

The fire and fatality at the Hayes Lemmerz International Huntington Facility onOctober 29, 2003 is also cited when discussing the need for combustible dustregulations. The US Chemical Safety and Hazard Investigation Board identified theroot causes of the incident as:

The company not preforming a review to address why the chip system wasreleasing excess dust;

Not ensuring the proper design of the dust collector system;

The company having no formal documented program to investigate andimplement corrective action for incidents involving fires in the foundry area,especially those (potentially) fueled by aluminum dust;

Employees were not wearing flame-retardant clothing when performing routinework near the melt furnace;

Housekeeping and maintenance in the chip processing and dust collector areaswas inadequate;

Personnel received no formal training for operating and maintaining thechip-processing and dust collection systems

There have been no known documented incidents of explosions or deflagrationsprimarily attributed to combustible metal dusts in non-ferrous casting facilities (NAICS331524, 331525 and 331528)

The standard is too generic to be applicable to all industries, and the definition ofcombustible dust is too broad. Industry sector specific standards, such as the standard forgrain handling (NFPA 61) and wood products (NFPA 664), are the preferred approach tomanaging industry-specific hazards.

The burden of determining hazards is placed on the company via randomized samplingrather than being defined in terms specific to the industry being regulated;

The abatement methods employed to control combustible dust hazards are best determinedby facility engineers with industry specific expertise, rather than being prescribed by ageneric standard, or by individuals not familiar with the design of facilities in the industryand/or their related hazards;

NFPA standards are not available for comment by individuals in regulated industries, ratherthe right it is reserved solely for NFPA members. Small companies, such as most non-ferrousfoundries, typically do not have employees who are NFPA members and therefore do nothave the opportunity to enter comments on proposed standards or standard revisions. Itmust be understood that consensus standards such as NFPA 652 are often used/adopted byregulatory agencies (such as OSHA) as part of their enforcement activities. This magnifiesthe necessity to allow open dialogue on the requirements found within NFPA standards bythe regulated community. Without open dialogue and peer review, the inclusion of guidancedocuments from non-governmental organizations, such as NFPA, is inappropriate for use byregulatory agencies

For these reasons, we do not believe that the NFPA 652 Standard on Combustible Dusts (or itspreliminary 2015 draft) to be an effective approach in managing combustible dust hazards in thenon-ferrous casting industry. Rather, a more appropriate approach would be to update the otherindustry specific standards, such as NFPA 61 and NFPA 664, and to develop an industry specificstandard that properly categorizes the hazards of specific metal dusts in the non-ferrous metalcasting industry.



the problem is that this standard is not in the interests of the nonferrous casting industry


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Submitter Full Name: JERROD WEAVEROrganization: NON FERROUS FOUNDERS SOCIETYStreet Address:City:State:Zip:Submittal Date: Thu Nov 14 16:12:28 EST 2013


I, JERROD WEAVER, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

By checking this box I affirm that I am JERROD WEAVER, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature


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These comments are submitted by and on behalf of the General Electric Company [GE]. GE is aglobal manufacturing and services company with a significant manufacturing presence in theUnited States.

GE recognizes the hazards posed by combustible dusts and supports the development of acombustible dust standard. In fact, this year GE has developed a uniform standard to identify andaddress combustible dusts and the GE standard will apply globally to facilities owned and operatedby GE. Although GE and its insurer has had a long-standing program to identify and addresscombustible dusts, the program had not been well articulated, nor promulgated.

Although GE agrees that there is a need for a combustible dust standard, we object to a number ofprovisions proposed in the NFPA 652 standard.

We will discuss each major objection in the body of the comments but for convenience have listedthem below:

(1) NFPA 652 works to essentially require that the owner or operator test every dust forcombustibility or assume that the dust is combustible. There are no exceptions for thisextremely costly approach to addressing dusts of “unknown” combustibility.

(2) NFPA 652 does not recognize existing company programs which are implemented andsupported by a knowledgeable third party entity, such as an insurance company withcombustible dust expertise;

(3) NFPA 652 goes beyond its remit by requiring a significant amount of test data that is notpertinent to the primary of objective of the standard; and by incorporating objectives which gobeyond the protection of human health and structures;

(4) The definition of dust is too complex and broad, and therefore will act as a multiplier for thepotentially unnecessary costs that may be imposed by this standard.

(5) NFPA 652 does not tier its expectations to the test results. A “hard to ignite” dust is treated inthe same manner as a dust with an MIE < 25 mj.

GE’s major objections to the proposed standard:

(1) NFPA 652 proposes to adopt the most expensive and ineffective method for addressing dustsof “unknown” combustibility. NFPA 652 essentially requires that owners or operators testevery dust for combustibility or assume that the dust is combustible. There are no exceptions(e.g. de minimus quantities, experience or manner of use) for this extremely costly approach. Appendix A appears to provide some flexibility on the testing requirement, but the discussionis neither explicit, nor is Appendix A part of the requirement of the NFPA document. “Appendix A is included for informational purposes only.” See Annex A explanatory Material

In developing our own combustible dust standard, GE also wrestled with the issue of dusts of“unknown” combustibility. To phrase the issue in another way, under what circumstances wouldwe require our facilities to sample and test dusts for combustibility? We considered, and rejected,the NFPA 652 approach of requiring testing of all dusts and powders or assuming that they arecombustible. In our view this is not an effective use of resources to require the testing of all dustsand powders. In fact, it is the most expensive approach for addressing the issues of unknownsand ignores loss experience, chemistry, manner of use, and a perspective on the potential hazards(e.g., de minimus amounts of dust).

We approached this issue by asking FM Global, our insurance carrier, the circumstances underwhich they have experienced losses due to combustible dust. FM Global’s loss experienceincludes GE’s experience as well as the loss experience of many other companies. In this way, wetook a broader view rather than limiting this decision to solely our experience. FM Global’s lossPrevention Data Sheet provides a number of illustrative tables. Table 6 (provided below) depictslosses by Equipment type.

***See Table 6 that has been uploaded***


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We decided that instead of testing every dust and powder, we would require the testing of dustsand powders which are used in certain equipment or managed in certain ways. For example, onewould be required to test dusts or powers which are:

Managed in a dust collector or dust conveyance system;

Stored in a silo;

Added to a vessel in excess of 55 gallons; etc.

The purpose of the use descriptor is to ensure that the combustibility testing requirement is appliedto, and prioritized to address, the types of situations which have been known to cause losses. Inthis way, we are using the loss experience to focus efforts on those dusts which may present ahazard.

(1) NFPA 652 does not recognize existing company programs which are implemented andsupported by a knowledgeable third party entity, such as an insurance company.

The proposed NFPA 652 has two compliance options. Section 4.2.5 of the proposal requires thatthe goal in Section 1.5 and the objectives in Section 4.2 shall be achieved by either: the prescriptiveprovision in Chapters 5, 7, 8 and 9; or the performance based provisions in Chapter 6. GE has anumber of comments about this approach.

Our first comment is that NFPA 652 should allow for a third option. Any company program thataddresses the goal in Section 1.5 and the objectives in Section 4.2, and which is implemented inconjunction with a knowledgeable third party entity should be recognized by the NFPA. As statedabove GE is implementing its combustible dust program in conjunction with our insurer, FMGlobal. FM Global is quite knowledgeable about the hazards posed by combustible dust, has acombustible dust testing laboratory, and has engineering capacity to advise on ignition control andexplosion mitigation measures. We believe that the NFPA should support those companies whichhave been proactive in addressing the hazards of combustible dust, by allowing those companiesto continue to implement their programs.

(1) The Chapter 7 process hazard analysis should be simplified and allow for informal,non-quantitative approaches.

In addition to recognizing pre-existing company programs, we agree with providing a baselineprescriptive approach with the alternative of a more flexible approach. However, the flexibleapproach should be based on a simplified Chapter 7’s process hazard analysis. Once a dust isknown to be combustible, the simplified, non-quantitative PHA should be used to develop areasonable and practicable program.

As currently described in Chapter 7 the PHA is too formal in its approach requiring far too muchdocumentation which goes beyond its objective.

(1) NFPA 652 goes beyond its remit by requiring test data that is not pertinent to the primaryobjective of the standard; and by incorporating objectives which go beyond the protection ofhuman health and structures;

The Terraview version of the NFPA 652 proposed standard had a section 4.4.2 intermingled withinanother section. Section 4.4.2 required that the “hazard identification, assessment, and mitigationshall address all known hazards, which include …. Personal hygiene issues, … environmentalhazards … and reactivity hazards …” emphasis added. These tests go well beyond the issue ofcombustibility hazards and control. Any testing required by this standard should be limited tocombustion and explosion potential and force. Further the testing should be tiered, such that dustswhich are “hard to ignite” are not subjected to the full suite of combustibility testing.

The proposed NFPA has an unnecessarily expanded suite of testing requirements, which may betied to the unnecessarily expanded set of objectives set forth in section 4.2. GE supports theobjective of life safety and structural integrity, but objects to the NFPA including “missioncontinuity” as an objective. The level of control and investment needed to “ensure the ongoingmission, production, or operating capability of the facility” should be left solely to theowner/operator and their respective stakeholders and insurers. This objective should be strickenfrom the proposed standard and all testing and expectations associated with this objectiveremoved.

(1) The definition of dust is too complex and broad, and therefore will act as a multiplier for thecosts imposed by this standard.


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The proposed definition of dust is dependent on particle shape. However, the definition does notincorporate the means by which one can determine whether their particulate material is a “dust”under this standard. GE proposes a simpler approach. Dust should be defined as follows: particulates less than 500 um.

(1) NFPA 652 does not tier its expectations to the test results. A “hard to ignite” dust is treated inthe same manner as a dust with an MIE < 25 mj.

The proposed standard’s prescriptive approach should recognize that there are degrees ofcombustible dusts such that expectations for controlling the hazard are tiered to the hazard. Forexample, the prescriptive approach could establish a minimum set of measures that would applyfor every combustible dust (e.g. housekeeping, warning signs, employee training, etc.). As thehazard posed by the dust increases (e.g. MIE < 25 mj) additional expectations would be imposed.

As an FM Global client we are familiar with the term “hard to ignite” dusts.

***See the Hard to Ignite paragraph that has been uploaded***

Under the GE program, a “hard to ignite” dust must meet the basic level of combustible dustexpectations to address: hazard communication; dust control; ignition control; fire and explosionmitigation and auditing. A dust that does not meet the “hard to ignite” testing criteria, hasadditional expectations; and a dust that has an MIE < 25 mj has more expectations. In this way, wehave tailored the risk mitigation approach to the combustibility test results.


File Name Description Approved652_Giordano_Uploaded.docx Table 6 & Hard to Ignite paragraph


Conclusion

We encourage the NFPA to continue its efforts to prepare a standard on combustible dust. However, we also encourage the NFPA to focus its efforts by adopting the following suggestions:

•Simplify and narrow the definition of “dust”;•Require testing dusts of unknown combustibility only when those dusts are used in certain equipment or in specific ways (use loss experience to focus your efforts);•Limit testing to only those tests pertaining to combustibility and allow one to tier the testing (e.g., testing in excess of basic tests should be limited to dusts of certain combustibility);•Recognize existing company programs implemented in conjunction with a knowledgeable third-party entity (such as an insurer) as a third option;•Tier prescriptive expectations to test results. A “hard to ignite” dust should not be treated in the same manner as a dust with an MIE < 25 mj.


Submitter Full Name: V GiordanoOrganization: General ElectricStreet Address:City:State:Zip:Submittal Date: Fri Nov 15 13:16:00 EST 2013


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I, V Giordano, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am V Giordano, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature


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Change the title of the document to: “Standard on Fundamentals of Combustible Dust."


A more accurate title — one that better reflects the scope of the committee — would be “Standard on Fundamentals of Combustible Dust.” From reviewing documents available on the NFPA web site, we thought that the Committee had already voted to implement just such a change. The title should therefore be corrected to reflect the Committee’s vote. (We found several other instances where the draft fails to reflect the Committee’s vote, and we recommend that the Committee examine the draft with this in mind.)


Submitter Full Name: ARTHUR SAPPEROrganization: for United States Beet Sugar AssociationStreet Address:City:State:Zip:Submittal Date: Fri Nov 15 13:33:59 EST 2013


I, ARTHUR SAPPER, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

By checking this box I affirm that I am ARTHUR SAPPER, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature


12 of 784 12/11/2013 11:51 AM


ICAC NFPA 652 First Draft Comments [Redlines are suggested edits to the proposedlanguage] DRAFT

A.7.5.11.1 Tabulations of materials prone to self-heating can be found in the following references:National Fire Protection Agency, Fire Protection Handbook, , DOE Handbook, Primer onSpontaneous Heating and Pyrophoricity, and V. Babrauskas, Ignition Handbook Database. Testmethods to assess the propensity for self-heating, critical storage pile sizes, and time toself-heating are also described in the Babrauskas reference. Methods of self-heating detectioninclude temperature monitors within the pile or silo and carbon dioxide monitors in the silo. Self-heating management can be accomplished, for example, through timely processing of theaffected particulate through the storage system before self-heating can become an issue.

Self-heating can be controlled through control of the temperature of the materials as it is added tothe storage and by controlling the residence time in storage. The permissible temperature andresidence time can be determined based on the characteristics of the material, the size of the pile,and the environment around the pile.

Statement of Problem and Substantiation for Public Input

(1) Listing five materials rather than sending the reader directly to the more comprehensive,expert documents on self-heating undermines the critical message that familiarity with thematerial and specific storage conditions are keys to good system design and materialsmanagement that can mitigate or eliminate the conditions under which self-heating may occur.

(a) The intent of this standard does not appear to be to specify the complex conditionsincluding composition, temperature, pile size, exposure to contaminants, etc that wouldlead a given material to self-heat to a critical temperature. Rather the intent seems to beto indicate where to obtain good reference information, and to outline an approach usingPHA that accomplishes good design.

(b) This list goes beyond the general approach of the standard, and yet is not a complete list. The lists are better left to the reference works.

(1) Activated carbon, which has been demonstrated to be unreactive and non-hazardous at thestated conditions, should not be on this list.

(a) Under most circumstances activated carbon is not self-heating, including extended bulkstorage conditions. Many activated carbons have been evaluated for self-heatingcharacteristics. Various test methods have been developed and applied, anddemonstrated to be effective for modeling bulk storage conditions. These results supportthe safe bulk storage of activated carbon. In particular, steam-activated carbons havebeen demonstrated by Cameron and MacDowall (see reference below) to have criticaltemperatures well in excess of ambient temperatures. Wirling also reports self-ignitiontemperature of 250 C for HOK, a specific activated carbon. Two references are providedin support:

i. “The Self Heating of Commercial Powdered Activated Carbons” by A. Cameron andJ.D. MacDowall, J. appl. Chem. Biotechnol., 1972, 22, 1007-1018

ii. “Safety Aspects in the Use of Carbonaceous Sorbents during Waste Gas Treatment,”by J. Wirling and J. Jablonski, Metallurgical Plant and Technology, 3 (2007), pages144–152

(b) The NFPA’s Fire Protection Handbook has a tabulation of self-heating materials, whichdoes not include activated carbon.

(c) The current language’s reference books (Bowes, Babrauskas) that go into much moredetail, including case studies on the characteristics, conditions, storage size, etc,describe certain conditions that have resulted in self-heating of certain activated carbons. On a close read of Bowes, the activated carbons mentioned as self-heating are


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chemically-activated. This is a subcategory of activated carbons and as indicated inBowes, packaging solutions have been applied to correct the problem. A designer or enduser referring to NFPA 652 can go to these references that provide the supportinginformation and conclude what criteria are applicable. Activated carbon should not becalled out as a categorically problematic material in this context. Activated carbon canself-heat under known circumstances. But these are not “extended bulk storage”conditions.

(d) The requirements already embedded within NFPA 652 for Process Hazard Analysissufficiently address activated carbon without labeling all activated carbon as self-heatingin ambient conditions (which they are not).

(e) It should also be noted that in the process of activated carbon manufacture, oxygenpassivation steps are included to minimize and/or eliminate the activated carbon’s abilityto self heat regardless of whether the carbon is made by thermal steam or chemicalactivation and whether the carbon is coal or cellulosic based.

(2) The reference work by Bowes is not readily available or in current print, therefore we suggestto include the NFPA’s Fire Protection Handbook as an available and routinely updated resourceinstead.


About the Institute of Clean Air Companies (ICAC) - ICAC is the national non-profit trade associationof companies that supply air pollution control and monitoring systems, equipment, reagents, andservices for stationary sources. ICAC has promoted the air pollution control industry andencouraged the improvement of engineering and technical standards since 1960. Our membersinclude nearly 100 companies who are leading manufacturers of equipment to control and monitoremissions of particulate matter (PM), volatile organic compounds (VOC), sulfur dioxide (SO2),nitrogen oxides (NOx), hazardous air pollutants (HAP), and greenhouse gases (GHG).Type your content here ...


File Name Description ApprovedICAC_NFPA_652_Comments_FINAL_111513.docx


ICAC believes activated carbon is not a combustible hazard in lomg-term storage and should be removed from the list.


Submitter Full Name: Doug AustinOrganization: ICACStreet Address:City:State:Zip:Submittal Date: Fri Nov 15 14:07:52 EST 2013


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I, Doug Austin, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Doug Austin, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature


15 of 784 12/11/2013 11:51 AM

ICAC NFPA 652 First Draft Comments [Redlines are suggested edits to the proposed language] DRAFT

A.87.5.11.1 Particulate materials that are notorious self‐heaters during extended bulk storage conditions include, but are not limited to, sawdust, sub‐bituminous coal, activated carbon and charcoal, and bagasse. Tabulations of materials prone to self‐heating can be found in the following references: National Fire Protection Agency, Fire Protection Handbook, P.C. Bowes, Self‐heating: Evaluating and Controlling the Hazards, DOE Handbook, Primer on Spontaneous Heating and Pyrophoricity, and V. Babrauskas, Ignition Handbook Database. Test methods to assess the propensity for self‐heating, critical storage pile sizes, and time to self‐heating are also described in the Bowes and Babrauskas references. Methods of self‐heating detection include temperature monitors within the pile or silo and carbon dioxide monitors in the silo. Self‐heating management can be accomplished, for example, through timely processing of the affected particulate through the storage system before self‐heating can become an issue.

Self‐heating can be controlled through control of the temperature of the materials as it is added to the storage and by controlling the residence time in storage. The permissible temperature and residence time can be determined based on the characteristics of the material, the size of the pile, and the environment around the pile.

StatementofProblemandSubstantiationforPublicInput

1. Listingfivematerialsratherthansendingthereaderdirectlytothemorecomprehensive,expertdocumentsonself‐heatingunderminesthecriticalmessagethatfamiliaritywiththematerialandspecificstorageconditionsarekeystogoodsystemdesignandmaterialsmanagementthatcanmitigateoreliminatetheconditionsunderwhichself‐heatingmayoccur.

a. Theintentofthisstandarddoesnotappeartobetospecifythecomplexconditionsincludingcomposition,temperature,pilesize,exposuretocontaminants,etcthatwouldleadagivenmaterialtoself‐heattoacriticaltemperature.Rathertheintentseemstobetoindicatewheretoobtaingoodreferenceinformation,andtooutlineanapproachusingPHAthataccomplishesgooddesign.

b. Thislistgoesbeyondthegeneralapproachofthestandard,andyetisnotacompletelist.Thelistsarebetterlefttothereferenceworks.

2. Activatedcarbon,whichhasbeendemonstratedtobeunreactiveandnon‐hazardousatthestatedconditions,shouldnotbeonthislist.

a. Undermostcircumstancesactivatedcarbonisnotself‐heating,includingextendedbulkstorageconditions.Manyactivatedcarbonshavebeenevaluatedforself‐heatingcharacteristics.Varioustestmethodshavebeendevelopedandapplied,anddemonstratedtobeeffectiveformodelingbulkstorageconditions.Theseresultssupportthesafebulkstorageofactivatedcarbon.Inparticular,steam‐activatedcarbonshavebeendemonstratedbyCameronandMacDowall(seereferencebelow)tohavecriticaltemperatureswellinexcessofambienttemperatures.Wirlingalsoreportsself‐ignitiontemperatureof250CforHOK,aspecificactivatedcarbon.Tworeferencesareprovidedinsupport:

i. “TheSelfHeatingofCommercialPowderedActivatedCarbons”byA.CameronandJ.D.MacDowall,J.appl.Chem.Biotechnol.,1972,22,1007‐1018

ii. “SafetyAspectsintheUseofCarbonaceousSorbentsduringWasteGasTreatment,”byJ.WirlingandJ.Jablonski,MetallurgicalPlantandTechnology,3(2007),pages144–152

b. TheNFPA’sFireProtectionHandbookhasatabulationofself‐heatingmaterials,whichdoesnotincludeactivatedcarbon.

Formatted: Font: Italic

c. Thecurrentlanguage’sreferencebooks(Bowes,Babrauskas)thatgointomuchmoredetail,includingcasestudiesonthecharacteristics,conditions,storagesize,etc,describecertainconditionsthathaveresultedinself‐heatingofcertainactivatedcarbons.OnaclosereadofBowes,theactivatedcarbonsmentionedasself‐heatingarechemically‐activated.ThisisasubcategoryofactivatedcarbonsandasindicatedinBowes,packagingsolutionshavebeenappliedtocorrecttheproblem.AdesignerorenduserreferringtoNFPA652cangotothesereferencesthatprovidethesupportinginformationandconcludewhatcriteriaareapplicable.Activatedcarbonshouldnotbecalledoutasacategoricallyproblematicmaterialinthiscontext.Activatedcarboncanself‐heatunderknowncircumstances.Butthesearenot“extendedbulkstorage”conditions.

d. TherequirementsalreadyembeddedwithinNFPA652forProcessHazardAnalysissufficientlyaddressactivatedcarbonwithoutlabelingallactivatedcarbonasself‐heatinginambientconditions(whichtheyarenot).

e. Itshouldalsobenotedthatintheprocessofactivatedcarbonmanufacture,oxygenpassivationstepsareincludedtominimizeand/oreliminatetheactivatedcarbon’sabilitytoselfheatregardlessofwhetherthecarbonismadebythermalsteamorchemicalactivationandwhetherthecarboniscoalorcellulosicbased.

3. ThereferenceworkbyBowesisnotreadilyavailableorincurrentprint,thereforewesuggesttoincludetheNFPA’sFireProtectionHandbookasanavailableandroutinelyupdatedresourceinstead.

SubmitterInformationVerification

About the Institute of Clean Air Companies (ICAC) ‐ ICAC is the national non‐profit trade association of companies that supply air pollution control and monitoring systems, equipment, reagents, and services for stationary sources. ICAC has promoted the air pollution control industry and encouraged the improvement of engineering and technical standards since 1960. Our members include nearly 100 companies who are leading manufacturers of equipment to control and monitor emissions of particulate matter (PM), volatile organic compounds (VOC), sulfur dioxide (SO2), nitrogen oxides (NOx), hazardous air pollutants (HAP), and greenhouse gases (GHG).




File Name Description ApprovedICAC_NFPA_652_Comments_FINAL_111513.docx


ICAC believes activated carbon is not a combustible hazard in lomg-term storage and should be removed from the list.


Submitter Full Name: Doug AustinOrganization: ICACStreet Address:City:State:Zip:Submittal Date: Fri Nov 15 14:12:01 EST 2013


I, Doug Austin, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Doug Austin, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature


16 of 784 12/11/2013 11:51 AM

ICAC NFPA 652 First Draft Comments [Redlines are suggested edits to the proposed language] DRAFT

A.87.5.11.1 Particulate materials that are notorious self‐heaters during extended bulk storage conditions include, but are not limited to, sawdust, sub‐bituminous coal, activated carbon and charcoal, and bagasse. Tabulations of materials prone to self‐heating can be found in the following references: National Fire Protection Agency, Fire Protection Handbook, P.C. Bowes, Self‐heating: Evaluating and Controlling the Hazards, DOE Handbook, Primer on Spontaneous Heating and Pyrophoricity, and V. Babrauskas, Ignition Handbook Database. Test methods to assess the propensity for self‐heating, critical storage pile sizes, and time to self‐heating are also described in the Bowes and Babrauskas references. Methods of self‐heating detection include temperature monitors within the pile or silo and carbon dioxide monitors in the silo. Self‐heating management can be accomplished, for example, through timely processing of the affected particulate through the storage system before self‐heating can become an issue.

Self‐heating can be controlled through control of the temperature of the materials as it is added to the storage and by controlling the residence time in storage. The permissible temperature and residence time can be determined based on the characteristics of the material, the size of the pile, and the environment around the pile.

StatementofProblemandSubstantiationforPublicInput

1. Listingfivematerialsratherthansendingthereaderdirectlytothemorecomprehensive,expertdocumentsonself‐heatingunderminesthecriticalmessagethatfamiliaritywiththematerialandspecificstorageconditionsarekeystogoodsystemdesignandmaterialsmanagementthatcanmitigateoreliminatetheconditionsunderwhichself‐heatingmayoccur.

a. Theintentofthisstandarddoesnotappeartobetospecifythecomplexconditionsincludingcomposition,temperature,pilesize,exposuretocontaminants,etcthatwouldleadagivenmaterialtoself‐heattoacriticaltemperature.Rathertheintentseemstobetoindicatewheretoobtaingoodreferenceinformation,andtooutlineanapproachusingPHAthataccomplishesgooddesign.

b. Thislistgoesbeyondthegeneralapproachofthestandard,andyetisnotacompletelist.Thelistsarebetterlefttothereferenceworks.

2. Activatedcarbon,whichhasbeendemonstratedtobeunreactiveandnon‐hazardousatthestatedconditions,shouldnotbeonthislist.

a. Undermostcircumstancesactivatedcarbonisnotself‐heating,includingextendedbulkstorageconditions.Manyactivatedcarbonshavebeenevaluatedforself‐heatingcharacteristics.Varioustestmethodshavebeendevelopedandapplied,anddemonstratedtobeeffectiveformodelingbulkstorageconditions.Theseresultssupportthesafebulkstorageofactivatedcarbon.Inparticular,steam‐activatedcarbonshavebeendemonstratedbyCameronandMacDowall(seereferencebelow)tohavecriticaltemperatureswellinexcessofambienttemperatures.Wirlingalsoreportsself‐ignitiontemperatureof250CforHOK,aspecificactivatedcarbon.Tworeferencesareprovidedinsupport:

i. “TheSelfHeatingofCommercialPowderedActivatedCarbons”byA.CameronandJ.D.MacDowall,J.appl.Chem.Biotechnol.,1972,22,1007‐1018

ii. “SafetyAspectsintheUseofCarbonaceousSorbentsduringWasteGasTreatment,”byJ.WirlingandJ.Jablonski,MetallurgicalPlantandTechnology,3(2007),pages144–152

b. TheNFPA’sFireProtectionHandbookhasatabulationofself‐heatingmaterials,whichdoesnotincludeactivatedcarbon.

Formatted: Font: Italic

c. Thecurrentlanguage’sreferencebooks(Bowes,Babrauskas)thatgointomuchmoredetail,includingcasestudiesonthecharacteristics,conditions,storagesize,etc,describecertainconditionsthathaveresultedinself‐heatingofcertainactivatedcarbons.OnaclosereadofBowes,theactivatedcarbonsmentionedasself‐heatingarechemically‐activated.ThisisasubcategoryofactivatedcarbonsandasindicatedinBowes,packagingsolutionshavebeenappliedtocorrecttheproblem.AdesignerorenduserreferringtoNFPA652cangotothesereferencesthatprovidethesupportinginformationandconcludewhatcriteriaareapplicable.Activatedcarbonshouldnotbecalledoutasacategoricallyproblematicmaterialinthiscontext.Activatedcarboncanself‐heatunderknowncircumstances.Butthesearenot“extendedbulkstorage”conditions.

d. TherequirementsalreadyembeddedwithinNFPA652forProcessHazardAnalysissufficientlyaddressactivatedcarbonwithoutlabelingallactivatedcarbonasself‐heatinginambientconditions(whichtheyarenot).

e. Itshouldalsobenotedthatintheprocessofactivatedcarbonmanufacture,oxygenpassivationstepsareincludedtominimizeand/oreliminatetheactivatedcarbon’sabilitytoselfheatregardlessofwhetherthecarbonismadebythermalsteamorchemicalactivationandwhetherthecarboniscoalorcellulosicbased.

3. ThereferenceworkbyBowesisnotreadilyavailableorincurrentprint,thereforewesuggesttoincludetheNFPA’sFireProtectionHandbookasanavailableandroutinelyupdatedresourceinstead.

SubmitterInformationVerification

About the Institute of Clean Air Companies (ICAC) ‐ ICAC is the national non‐profit trade association of companies that supply air pollution control and monitoring systems, equipment, reagents, and services for stationary sources. ICAC has promoted the air pollution control industry and encouraged the improvement of engineering and technical standards since 1960. Our members include nearly 100 companies who are leading manufacturers of equipment to control and monitor emissions of particulate matter (PM), volatile organic compounds (VOC), sulfur dioxide (SO2), nitrogen oxides (NOx), hazardous air pollutants (HAP), and greenhouse gases (GHG).


This document is overly scientific and pedantic and while it could be a part of a text on combustibledust hazards, as a useful tool on fundamental dust control it comes up short. I recommend thepublication of the document be delayed at least one cycle to give the committee a chance to goback through the whole document and simplify it and provide material this is useful to ordinaryusers, not college professors.


I believe the justification is in the statement and the numerous Public Comments submitted by me and others.


Submitter Full Name: Henry FeboOrganization: FM GlobalStreet Address:City:State:Zip:Submittal Date: Fri Nov 15 14:30:16 EST 2013


I, Henry Febo, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am Henry Febo, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature


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Recommend that the draft be withdrawn.


For the information of the NFPA 652 Committee and of the public, the United States Beet Sugar Association (the “USBSA”) represents nine beet sugar companies, which operate twenty-two processing factories in nine states. These firms produce refined sugar from sugar beets grown by about 10,000 family farmers on about 1.2 million acres in eleven states. All member firms are farmer cooperatives. A senior executive from each member-firm comprises the Board of Trustees, which sets policy and oversees the USBSA’s activities. The USBSA represents the industry before the legislative and executive branches of the Federal Government and monitors related activities in Washington, D.C. The Association has participated in the development of NFPA 652, and several of its comments on the previous drafts were adopted. We have also examined the comments filed by the National Oilseed Processors Association, the Corn Refiners Association, the National Grain and Feed Association and the International Oil Mill Superintendants Association, and we commend them to the Committee.With the greatest respect for the Committee members and their work on this project, we most respectfully recommend that the draft be withdrawn. We do not make this recommendation lightly, nor without appreciation for the hard work that went it. Instead, we believe that, as OSHA concluded last year, that the subject of combustible dust is too broad, too technically complex and difficult, and too varied to be easily covered in a single standard. E.g., OSHA Regulatory Agenda (http://www.reginfo.gov) (moving dust standard moved to long term action, i.e., from proposed rule stage to prerule stage); U. S. Chemical Safety and Hazard Investigation Board, Recommendations Status Change Summary pp. 4-5 (July 25, 2013). This can be seen in the way that that the standard was drafted.• Many key terms are either undefined or lack a definition that resolves key technical questions.• Many key provisions impose unqualified duties that are literally infeasible as stated.• Many key provisions state a broad, unqualified general duty but then—evidently out of a recognition that the provision is infeasible or overbroad in many cases—state that the owner-operator may instead perform a hazard analysis or engineering study to justify a departure. The alternative is so open-ended and vague in its criteria, however, that it provides no useful guidance and indicates that the general rule was not drafted to be literally applied. As a result, many key provisions of the draft state aspirational general principles rather than rules intended for literal compliance.• Many key provisions state a broad, unqualified duty but then state that the Authority Having Jurisdiction (AHJ) may authorize a departure from the duty, without stating what criteria the AHJ is to apply.


Submitter Full Name: ARTHUR SAPPEROrganization: for United States Beet Sugar AssociationStreet Address:City:State:Zip:Submittal Date: Tue Nov 19 07:04:42 EST 2013


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I, ARTHUR SAPPER, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyrightin this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intendthat I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or anothersimilar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority toenter into this copyright assignment.

By checking this box I affirm that I am ARTHUR SAPPER, and I agree to be legally bound by the above Copyright Assignment and theterms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will,upon my submission of this form, have the same legal force and effect as a handwritten signature


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Public Comment No. 456-NFPA 652-2013 [ New Section after 1.1 ]

TITLE OF NEW CONTENTsee attached document for GE comments.


File Name Description ApprovedGE_comments_on_Draft_NFPA_652.doc


please read the attached document.

thank you for your consideration.


Submitter Full Name: V GiordanoOrganization: General ElectricStreet Address:City:State:Zip:Submittal Date: Fri Nov 15 13:35:42 EST 2013


I, V Giordano, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in thisPublic Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that Iacquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar orderivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter intothis copyright assignment.

By checking this box I affirm that I am V Giordano, and I agree to be legally bound by the above Copyright Assignment and the termsand conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon mysubmission of this form, have the same legal force and effect as a handwritten signature


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g

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From: Vincent Giordano General Electric Company Counsel/Manager High Hazard Operations & Auditing Programs Date: November 15, 2013 Re: Draft NFPA 652 ________________________________________________________________ These comments are submitted by and on behalf of the General Electric Company [GE]. GE is a global manufacturing and services company with a significant manufacturing presence in the United States. GE recognizes the hazards posed by combustible dusts and supports the development of a combustible dust standard. In fact, this year GE has developed a uniform standard to identify and address combustible dusts and the GE standard will apply globally to facilities owned and operated by GE. Although GE and its insurer has had a long-standing program to identify and address combustible dusts, the program had not been well articulated, nor promulgated. Although GE agrees that there is a need for a combustible dust standard, we object to a number of provisions proposed in the NFPA 652 standard. We will discuss each major objection in the body of the comments but for convenience have listed them below:

1. NFPA 652 works to essentially require that the owner or operator test every dust for combustibility or assume that the dust is combustible. There are no exceptions for this extremely costly approach to addressing dusts of “unknown” combustibility.

2. NFPA 652 does not recognize existing company programs which are implemented and supported by a knowledgeable third party entity, such as an insurance company with combustible dust expertise;

3. NFPA 652 goes beyond its remit by requiring a significant amount of test data that is not pertinent to the primary of objective of the standard; and by incorporating objectives which go beyond the protection of human health and structures;

4. The definition of dust is too complex and broad, and therefore will act as a multiplier for the potentially unnecessary costs that may be imposed by this standard.

5. NFPA 652 does not tier its expectations to the test results. A “hard to ignite” dust is treated in the same manner as a dust with an MIE < 25 mj.

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GE’s major objections to the proposed standard:

1. NFPA 652 proposes to adopt the most expensive and ineffective method for addressing dusts of “unknown” combustibility. NFPA 652 essentially requires that owners or operators test every dust for combustibility or assume that the dust is combustible. There are no exceptions (e.g. de minimus quantities, experience or manner of use) for this extremely costly approach. Appendix A appears to provide some flexibility on the testing requirement, but the discussion is neither explicit, nor is Appendix A part of the requirement of the NFPA document. “Appendix A is included for informational purposes only.” See Annex A explanatory Material

In developing our own combustible dust standard, GE also wrestled with the issue of dusts of “unknown” combustibility. To phrase the issue in another way, under what circumstances would we require our facilities to sample and test dusts for combustibility? We considered, and rejected, the NFPA 652 approach of requiring testing of all dusts and powders or assuming that they are combustible. In our view this is not an effective use of resources to require the testing of all dusts and powders. In fact, it is the most expensive approach for addressing the issues of unknowns and ignores loss experience, chemistry, manner of use, and a perspective on the potential hazards (e.g., de minimus amounts of dust). We approached this issue by asking FM Global, our insurance carrier, the circumstances under which they have experienced losses due to combustible dust. FM Global’s loss experience includes GE’s experience as well as the loss experience of many other companies. In this way, we took a broader view rather than limiting this decision to solely our experience. FM Global’s loss Prevention Data Sheet provides a number of illustrative tables. Table 6 (provided below) depicts losses by Equipment type.

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We decided that instead of testing every dust and powder, we would require the testing of dusts and powders which are used in certain equipment or managed in certain ways. For example, one would be required to test dusts or powers which are:

Managed in a dust collector or dust conveyance system; Stored in a silo; Added to a vessel in excess of 55 gallons; etc.

The purpose of the use descriptor is to ensure that the combustibility testing requirement is applied to, and prioritized to address, the types of situations which have been known to cause losses. In this way, we are using the loss experience to focus efforts on those dusts which may present a hazard.

2. NFPA 652 does not recognize existing company programs which are implemented and supported by a knowledgeable third party entity, such as an insurance company.

The proposed NFPA 652 has two compliance options. Section 4.2.5 of the proposal requires that the goal in Section 1.5 and the objectives in Section 4.2 shall be achieved by either: the prescriptive provision in Chapters 5, 7, 8 and 9; or the performance based provisions in Chapter 6. GE has a number of comments about this approach.

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Our first comment is that NFPA 652 should allow for a third option. Any company program that addresses the goal in Section 1.5 and the objectives in Section 4.2, and which is implemented in conjunction with a knowledgeable third party entity should be recognized by the NFPA. As stated above GE is implementing its combustible dust program in conjunction with our insurer, FM Global. FM Global is quite knowledgeable about the hazards posed by combustible dust, has a combustible dust testing laboratory, and has engineering capacity to advise on ignition control and explosion mitigation measures. We believe that the NFPA should support those companies which have been proactive in addressing the hazards of combustible dust, by allowing those companies to continue to implement their programs.

3. The Chapter 7 process hazard analysis should be simplified and allow for informal, non-quantitative approaches.

In addition to recognizing pre-existing company programs, we agree with providing a baseline prescriptive approach with the alternative of a more flexible approach. However, the flexible approach should be based on a simplified Chapter 7’s process hazard analysis. Once a dust is known to be combustible, the simplified, non-quantitative PHA should be used to develop a reasonable and practicable program. As currently described in Chapter 7 the PHA is too formal in its approach requiring far too much documentation which goes beyond its objective.

4. NFPA 652 goes beyond its remit by requiring test data that is not pertinent to the primary objective of the standard; and by incorporating objectives which go beyond the protection of human health and structures;

The Terraview version of the NFPA 652 proposed standard had a section 4.4.2 intermingled within another section. Section 4.4.2 required that the “hazard identification, assessment, and mitigation shall address all known hazards, which include …. Personal

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