NFPA 652 Compliance
Combustible Dust Hazards have been understood as a hazard for many years, with NFPA Guidelines for protection in the grain and coal industries dating back to the 1920s. However, a published report by the Chemical Safety Board (CSB) released in 2006 created highlighted the shortcomings of the many employers’ awareness of the hazards related to combustible dust. This prompted OSHA to issue a Combustible Dust National Emphasis Program (NEP) in 2007 and later re-issued the NEP in 2008 following the Imperial Sugar disaster in Port Wentworth GA where 14 died and 38 were injured as a result of Dust Explosion. Feedback from responses to this NEP uncovered that many users of combustible dust found the existing NFPA Standards to be inconsistent and confusing.
Following these events, the National Fire Protection Association (NFPA) decided to create a new Fundamentals Standard for Combustible which was later called NFPA 652 and initially released on September 7th, 2015. Additionally, the NFPA created a new Correlating Committee specifically tasked with ensuring that all NFPA Combustible Dust Standards align and that inconsistencies be minimized. This new NFPA Document is meant to be the starting point for compliance for all users of combustible dust and directs users to industry-specific documents as appropriate.
Beyond the NFPA 652 Document, there are several other documents that are important for understanding the risks and protection methods related to combustible dust:
- NFPA 61 - Food and Agriculture
- NFPA 484 - Combustible Metals
- NFPA 654 - General Industry
- NFPA 655 - Sulfur
- NFPA 664 - Wood Processing
- NFPA 68 - Explosion Venting
- NFPA 69 - Explosion Prevention Systems
- NFPA 77 - Static Electricity
- NFPA 91 - Exhaust Systems
- NFPA 499 - Electrical Classification
Additional Compliance With NFPA 652 Information
In order to comply with the NFPA 652 Document, the first step for all facilities producing or handling dust is to determine if it is explosible. NFPA 652 Outlines two acceptable methods for determining combustibility:
- Industry Published Values – For well documented materials such as agricultural products, there are published data in the NFPA Documents, Safety Data Sheets, and other Databanks. It is acceptable to use these published values to characterize your dust only if the published data is representative of your material.
- Dust Testing of Material Sample – This method will give a more reliable result to understanding of the explosibility of your dust. Both moisture content and particle size have a large impact on the combustibility of your material, so it is important to ensure that a representative sample is taken. Samples may be tested “As-Received” or “per ASTM Protocol”.
After determining whether a sample is combustible, the next step in the process of NFPA Compliance is to Identify and Evaluate the Dust Hazards in your facility or process. This is done by completing a Dust Hazard Analysis (DHA) which will systematically assess the fire and explosion hazards in your facility. The goals of a DHA are (1) Identify where hazards exist, (2) Identify existing safeguards, and (3) Identify where additional safeguards are needed. The Dust Hazard Analysis report should become the guiding document for process safety moving forward and the recommendations act as a roadmap for compliance. An example and detailed guidance on how to conduct a DHA can be found in the appendix sections of NFPA 652.
After the DHA has identified the hazards and the recommendations are put forth within the report, those recommendations should be implemented in accordance with the applicable NFPA requirements to manage the hazards. More information on what Explosion Mitigation techniques are acceptable can be found in the Dust Explosion Mitigation section of our website. The implementation of recommended safeguards should be tracked to completion.
The final requirement for facilities to remain compliant with NFPA 652 is to communicate the hazards of combustible dust to affected personnel and to provide training on both the hazards and on the safeguards related to combustible dust. These and other Administrative Controls are vital to managing and preventing combustible dust Fires and Explosions.