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NFPA 654- Proposed 2010 Edition Standard for the Prevention of Fire and Dust Explosions from the

Manufacturing, Processing, and Handling of Combustible Particulate Solids TIA Log No.: 991 Reference: 3.3.4 Combustible Dust Comment Closing Date: June 18, 2010 Submitter: David Wechsler, The Dow Chemical Company 1. Revise 3.3.4 definition as follows: 3.3.4* Combustible Dust. A combustible solid material composed of distinct particles or pieces, regardless of shape or chemical composition, which due to its small particle size presents a flash-fire or explosion hazard as a result of its ability to propagate combustion when dispersed in air or the process-specific oxidizing medium. Submitter’s Substantiation: Ignition controls to prevent deflagrations for materials defined as “Combustible dusts” are addressed in NFPA 499 Hazardous Area Classification and are the same materials addressed in NFPA 654 as having a potential flash fire or explosion hazards. As such the definitions need to be the same. Emergency Nature: It has been almost three years since OSHA published the “Combustible Dust National Emphasis Program” (NEP); document CPL 03-00-006 describing policies and procedures regarding inspection of facilities that handle combustible dust. All segments of the US, including but not limited to, industry, inspectors, emergency responders, and the general public have been made increasing aware of the potential serious hazards associated with combustible dusts. The March/April 2010 issue of the NFPA Journal contained the headline summary statement: “Two years ago, an Imperial Sugar refinery was destroyed by a dust explosion that was described as “entirely preventable”.” The volunteer committee members comprising many of the NFPA Standards, codes and practices dealing with dusts have also been working hard to properly identify the mitigations and appropriate procedures to address dusts. What is most evident is that the issues associated with dusts are complex and cannot be addressed with a single all inclusive statement. However it is clear that there are two distinct hazard potentials associated with combustible particulate solids or dusts. Combustible particulate solids present only ordinary fire hazards while the subset of “combustible dusts” also present flash-fire or explosion hazards. Improved understanding and need for controls to address potential combustible dust hazards depends upon a portion of NFPA 654 which addresses the dust flash-fire and explosion potential hazards as well as NFPA 499 dealing with hazardous classified locations which also addresses the dust flash-fire and explosion potential hazards by controlling potential ignition sources. If these NFPA documents are to be effective in reducing property damage and in helping control loss of life from the adverse effects of dust flash-fires and dust explosion hazards, both of these NFPA documents must have a common definition for the material dust flashfire and dust explosion hazard defined by the term “combustible dust”. For almost 25 years both NFPA 654 and NFPA 499 did in fact use the same definition for combustible dust. This has all changed and it has become increasing obvious that this is now creating a serious safety concern. NFPA 654 is likely to be published following the NFPA June, 2010 meeting. NFPA 499 is not yet in cycle. Unless prompt action is taken these two documents will continue to be published following different document cycles and each document will contain its own definition for ‘combustible dust’ for what should be the same materials. To permit this condition to continue is inexcusable. An NFPA 499 task group, having representatives who also having memberships on NFPA 654, NFPA 68 and NFPA 70 have been working on this dust issue. Having the advantage over NFPA 654 by being able to continue work on this problem after NFPA 654 concluded its cycle work, this task group has developed a definition which appropriately addresses potential dust explosible materials as combustible dusts. Unlike the NFPA 654

This TIA is expected to result in prompt correction of this important issue by applying a definition developed by the NFPA 499 task group within NFPA 654 as well as within NFPA 499. this NFPA 499 definition clearly identifies the important aspects of a potential combustible dust flash-fire and explosion hazards. Quincy. . and the variability with shape and chemical composition. please identify the number of the TIA and forward to the Secretary. this definition includes salient aspects considered by the NFPA 654 Committee such as propagating combustion. To submit a comment (on company letterhead). If successful. MA 02169-7471. dispersion in air or the process specific oxidizing medium.definition. 1 Batterymarch Park. this action will immediately result in a common definition for combustible dust when 654 is published following the June. Standards Council. Lastly. Anyone may submit a comment by the closing date indicated above. 2010 NFPA meeting. as well as the important effect that distinct small particle sizes of a combustible dust have.