TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS NFPA 61 … · 2016-04-04 · TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS NFPA 61 CMD-AGR (A2016) First Draft Meeting Sheraton Denver Downtown

TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS

NFPA 61 CMD-AGR (A2016) First Draft Meeting

Sheraton Denver Downtown

Denver, Colorado August 26-28, 2014

8 AM – 5 PM

AGENDA

1. Meeting is called to order at 8 AM

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

3. Chair and Staff Liaison Remarks

4. Approve Minutes of the Pre-First Draft Web/Teleconference Meeting held on February 6, 2014

5. Review of A2016 Revision Cycle and new NFPA process (Staff Liaison presentation on new process

and procedures, will include membership review and review of schedule)

6. Committee Correspondence

7. Review of Public Input to NFPA 61

8. Review of Committee Input to NFPA 61

9. Task Group Meeting

10. Old Business

11. New Business and determination of next meeting date and location

12. Adjournment – Meeting will adjourn at 5 pm on all three days

COMMITTEE ON AGRICULTURAL DUSTS TO: COMMITTEE ON AGRICULTURAL DUSTS FROM: G. R. Colonna, Staff Liaison DATE: February 12, 2014 SUBJ: Minutes of NFPA 61 Pre-First Draft Meeting (Conference Call),

February 6, 2014 ________________________________________________________________________ I. Attendance: (all by web and conference call) Members and Alternates: Timothy Myers, Exponent, Inc., Natick, MA Donald Ankele, UL LLC, Northbrook, IL Chris Aiken, Cargill, Inc., Wayzata, MN Venkateswara Sarma Bharmidipati, Powder Process Solutions, Chanhassen, MN Amy Brown, FM Global, Norwood, MA David Clayton, Exponent, Inc., Los Angeles, CA Ashok Dastidar, Fauske & Associates, LLC, Burr Ridge, IL Brian Eklow, Aon Risk Services, Chicago, IL Keith Epperson, American Feed Industry Association, Osage Beach, MO Craig Froehling, Cargill, Inc., Wayzata, MN William Kearns, Fred Pfening Company, Columbus, OH William Kinslow, Jr., Mondelēz International, East Hanover, NJ Bruce McLelland, Fike Corporation, Blue Springs, MO Jim Norris, Bunge North America, St. Louis, MO (NOPA) Jack E. Osborn, Airdusco, Inc., TN Jeffrey Rogers, Ag Processing Inc., Omaha, NE (NOPA) Lee Sargent, Todd & Sargent, Inc., Ames, IA Robert Shafto, Zurich Insurance, Milford, MI Ronald Stein, Aon Global Risk Consultants, Kansas City, MO Jeffrey Sutton, Global Risk Consultants Corporation, Excelsior, MN Peter Telthorst, FM Global, St. Louis, MO P.D. (Nick) Thielen, General Mills, Inc., Golden Valley, MN Stephen Wees, Hayes & Stolz Industrial Manufacturing, Ltd., Fort Worth, TX J. Anthony Yount, ConAgra Food Ingredients, Omaha, NE Guy R. Colonna, NFPA, Staff Liaison

CMD-AGR Meeting Minutes February 6, 2014 (Conference Call)

2

Guests: Brian Deutsch, Michigan Sugar Company, Bay City, MI (US Beet Sugar Association) Kent Quinney, The Amalgamated Sugar Company LLC, Boise, ID (US Beet Sugar Association) II. Minutes of Meeting 1. The Chair called the meeting to order at 11:05 a.m., Thursday, February 6, 2014. He welcomed the members and guests, outlined the agenda for the meeting, and requested Staff conduct a roll call of participants at the meeting. 2. Staff provided an update on the Committee membership, including pending appointments for the March meeting of the NFPA Standards Council. The Committee currently has 30 voting members (including one voting alternate member). In addition to moving the voting alternate to a principal voting member status, the Chair and Staff have also recommended appointment of the applicants from the US Beet Sugar Association (joining the meeting as guests). Staff also provided a review of the new NFPA Standards Process, demonstrating how Public Input is submitted, and reviewing the schedule for preparing the Annual 2016 revision cycle revision for NFPA 61 (see attached copy of the A2016 schedule). As part of this review, Staff also spoke about the role of the Combustible Dust Correlating Committee. In addition, the Chair and Staff reviewed the status of NFPA 652, which has requested a cycle change from F2014 to A2015 in order to finish all the Public Comments and the Second Draft. In order to make the "yet to be developed" second draft version of NFPA 652 available for review by the Agricultural Dust Committee, so that appropriate Public Input can be considered based on NFPA 652, Staff will prepare a Word draft of the proposed standard and distribute it to the Agricultural Dust Committee. A draft based on the recent Second Draft meeting (January 2014) will be made available by the end of February. Staff reported that there are already 4 Public Inputs on file for NFPA 61; the deadline for submittal of the proposed changes is July 7, 2014. 4. The Chair discussed how to approach this revision cycle, particularly the need to evaluate whether NFPA 652 impacts NFPA 61 in any way. He recommended forming several task groups - 6 specifically linked to chapters in the proposed NFPA 652. The guidance for the task groups would be to compare NFPA 61 with NFPA 652 and identify what topics covered by NFPA 652 are not currently in NFPA 61 and whether they should be. The task group listing is shown below; those members of the Committee not able to participate in this meeting but wishing to serve on one of the task groups should contact the Chair or Staff to be included. The goal for the task groups, where possible, is to develop any recommended changes to NFPA 61 prior to the closing date for submitting Public Input. The task group listing is as follows:


3

Ch 4 General

Ch 5 Hazard ID

Ch 6 Performance Based Design

Ch 7 PHA

Ch 8 Hazard management

Ch 9 Management Systems

Bob Shafto

Pete Telthorst

Ashok Dastidar Pete Telthorst

Bruce McLelland

Chris Aiken

Jeff Sutton

Keith Epperson

Venkat Bhamidipati

Nick Thielen

Craig Froehling

Jeff Sutton

Ashok Dastidar

Kent Quinney

Jack Osborn Amy Brown

Nick Thielen

Chris Aiken

Amy Brown

Bob Shafto

Anthony Yount

Bill Kearns

Bill Kinslow

Anthony Yount

Bill Kinslow 5. The Committee discussed two other items as possible considerations for the upcoming revision: whether specific provisions pertaining to the sugar industry (refining and processing) should be added to NFPA 61 and whether "fabric silos" should be included in the standard. The question surrounding requirements applicable for the sugar industry carried forward from the prior revision cycle when a draft chapter was considered by the Committee during the ROP phase. At this time, there were no specific recommendations made, so the Committee did not propose creating a separate task group to research whether requirements unique to operations and processes within the sugar industry are necessary. As for the discussion regarding fabric silos - several members of the Committee and Staff saw an online discussion asking questions about the use of these silos and wanted to raise the issue with the full Committee in case these storage silos should be included in the next edition of the standard. Again, general sense from the discussions at this meeting indicate there is no need identified to include requirements for use of fabric silos for the materials covered by NFPA 61. 6. Next Meeting. The Committee discussed date and location for its First Draft meeting based on the schedule outlined by the Staff. The Public Input closing date is July 7 and the last date for the Committee to hold its meeting is September 12. During this meeting, the Committee selected Denver as the location and a tentative date of August 12 - 14, with the meeting opening at 8:00 am on the 12th and the meeting adjourning by noon on the 14th. [Staff Note: Following the meeting, Staff reviewed the plans from the meeting for scheduling a First Draft meeting and realized that the dates proposed by the Committee conflict with the NFPA Standards Council meeting in Quincy. NFPA has established a policy for the purposes of staff, the Council, and committee members, not to schedule meetings that conflict with the August Council meeting so that NFPA staff can be available to meet with the Council as needed on agenda items, including appeals and


4

hearings related to the Annual cycle document approvals. Because the Council is scheduled to meet the same dates as was proposed for the NFPA 61 First Draft meeting, Staff has notified the Committee and the Chair and alternative dates are being selected. Based on the results of the poll, the week of August 25 is receiving the most support as the alternative, with the dates of 26 - 28 August being preferred (Tuesday - Thursday) over a Monday - Wednesday schedule. I will confirm with the Chair and send the final notice on rescheduling.] 7. There being no further business, the meeting was adjourned at 1:30 p.m., Thursday, February 6, 2014. Respectfully submitted, G. R. Colonna, Staff Liaison Attachment: Annual 2016 schedule

2016 ANNUAL 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 for Paper Submittal* 6/6/2014 6/6/2014

Public Input Closing Date for Online Submittal (e‐PI)* 7/7/2014 7/7/2014

Final Date for TC First Draft Meeting 12/12/2014 9/12/2014

Public Input Posting of First Draft and TC Ballot 1/30/2015 10/24/2014

Stage Final date for Receipt of TC First Draft ballot 2/20/2015 11/14/2014

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2/27/2015 11/21/2014

Posting of First Draft for CC Meeting 11/28/2014

Final date for CC First Draft Meeting 1/9/2015

Posting of First Draft and CC Ballot 1/30/2015

Final date for Receipt of CC First Draft ballot 2/20/2015

Final date for Receipt of CC First Draft ballot ‐ recirc 2/27/2015

Post First Draft Report for Public Comment 3/6/2015 3/6/2015

Public Comment Closing Date for Paper Submittal* 4/10/2015 4/10/2015

Public Comment Closing Date for Online Submittal (e‐PC)* 5/15/2015 5/15/2015

Final Date to Publish Notice of Consent Standards (Standards that received no Comments)

5/29/2015 5/29/2015

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

6/12/2015 6/12/2015

Final date for TC Second Draft Meeting 10/30/2015 7/24/2015

Comment Posting of Second Draft and TC Ballot 12/11/2015 9/4/2015

Stage Final date for Receipt of TC Second Draft ballot 1/4/2016 9/25/2015

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 1/11/2016 10/2/2015

Draft) Posting of Second Draft for CC Meeting 10/9/2015

Final date for CC Second Draft Meeting 11/20/2015

Posting of Second Draft for CC Ballot 12/11/2015

Final date for Receipt of CC Second Draft ballot 1/4/2016

Final date for Receipt of CC Second Draft ballot ‐ recirc 1/11/2016

Post Second Draft Report for NITMAM Review 1/18/2016 1/18/2016

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 2/19/2016 2/19/2016

Preparation Posting of Certified Amending Motions (CAMs) and Consent Standards

4/15/2016 4/15/2016

(& Issuance) Appeal Closing Date for Consent Standards 5/3/2016 5/3/2016

SC Issuance Date for Consent Standards 5/13/2016 5/13/2016

Tech Session Association Meeting for Standards with CAMs 6/6‐9/2016 6/6‐9/2016

Appeals and Appeal Closing Date for Standards with CAMs 6/29/2016 6/29/2016

Issuance SC Issuance Date for Standards with CAMs 8/4/2016 8/4/2016

Approved:__October 30, 2012 Revised___March 7, 2013_____________________

2016 ANNUAL 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 for Paper Submittal* 6/6/2014 6/6/2014

Public Input Closing Date for Online Submittal (e‐PI)* 7/7/2014 7/7/2014

Final Date for TC First Draft Meeting 12/12/2014 9/12/2014

Public Input Posting of First Draft and TC Ballot 1/30/2015 10/24/2014

Stage Final date for Receipt of TC First Draft ballot 2/20/2015 11/14/2014

(First Draft) Final date for Receipt of TC First Draft ballot ‐ recirc 2/27/2015 11/21/2014

Posting of First Draft for CC Meeting 11/28/2014

Final date for CC First Draft Meeting 1/9/2015

Posting of First Draft and CC Ballot 1/30/2015

Final date for Receipt of CC First Draft ballot 2/20/2015

Final date for Receipt of CC First Draft ballot ‐ recirc 2/27/2015

Post First Draft Report for Public Comment 3/6/2015 3/6/2015

Public Comment Closing Date for Paper Submittal* 4/10/2015 4/10/2015

Public Comment Closing Date for Online Submittal (e‐PC)* 5/15/2015 5/15/2015

Final Date to Publish Notice of Consent Standards (Standards that received no Comments)

5/29/2015 5/29/2015

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

6/12/2015 6/12/2015

Final date for TC Second Draft Meeting 10/30/2015 7/24/2015

Comment Posting of Second Draft and TC Ballot 12/11/2015 9/4/2015

Stage Final date for Receipt of TC Second Draft ballot 1/4/2016 9/25/2015

(Second Final date for receipt of TC Second Draft ballot ‐ recirc 1/11/2016 10/2/2015

Draft) Posting of Second Draft for CC Meeting 10/9/2015

Final date for CC Second Draft Meeting 11/20/2015

Posting of Second Draft for CC Ballot 12/11/2015

Final date for Receipt of CC Second Draft ballot 1/4/2016

Final date for Receipt of CC Second Draft ballot ‐ recirc 1/11/2016

Post Second Draft Report for NITMAM Review 1/18/2016 1/18/2016

Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 2/19/2016 2/19/2016

Preparation Posting of Certified Amending Motions (CAMs) and Consent Standards

4/15/2016 4/15/2016

(& Issuance) Appeal Closing Date for Consent Standards 5/3/2016 5/3/2016

SC Issuance Date for Consent Standards 5/13/2016 5/13/2016

Tech Session Association Meeting for Standards with CAMs 6/6‐9/2016 6/6‐9/2016

Appeals and Appeal Closing Date for Standards with CAMs 6/29/2016 6/29/2016

Issuance SC Issuance Date for Standards with CAMs 8/4/2016 8/4/2016

Approved:__October 30, 2012 Revised___March 7, 2013_____________________

Address List No PhoneAgricultural Dusts CMD-AGR

Combustible Dusts

Susan Bershad07/29/2014

CMD-AGR

Timothy J. Myers

ChairExponent, Inc.9 Strathmore RoadNatick, MA 01760-2418

SE 10/27/2009CMD-AGR

Jason P. Allen

PrincipalGeorgia State Fire Marshal’s Office920 West Tower, Floyd Building2 Martin Luther King Jr. DriveAtlanta, GA 30334

E 08/09/2012

CMD-AGR

Donald W. Ankele

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

RT 10/20/2010CMD-AGR

Amy Brown

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

I 03/07/2013

CMD-AGR

Matthew J. Bujewski

PrincipalMJB Risk Consulting9650 Mill Hill LaneSt. Louis, MO 63127

SE 4/17/1998CMD-AGR

Ashok Ghose Dastidar

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

SE 07/29/2013

CMD-AGR

Brian L. Eklow

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

I 10/27/2005CMD-AGR

Keith Epperson

PrincipalAmerican Feed Industry Association5740 Parkview CourtOsage Beach, MO 65065-3432

U 3/21/2006

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

PrincipalCorn Products/National StarchPO Box 1084Indianapolis, IN 46206Alternate: Steven A. McCoy

U 10/18/2011CMD-AGR

William E. Janz

PrincipalXL Global Asset Protection Services301 Pine Ridge DriveWashington, IL 61571Alternate: Philip E. Griffin

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

1



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

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

2


Combustible Dusts


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

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 90066-7027

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

Philip E. Griffin

AlternateXL Global Asset Protection Services17823 County 27Spring Grove, MN 55974-2445Principal: William E. Janz

I 8/9/2011

CMD-AGR

Paul T. Kelly

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

RT 03/03/2014CMD-AGR

Steven A. McCoy

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

U 10/18/2011

CMD-AGR

Glen R. Mortensen

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

I 3/1/2011CMD-AGR

Jim E. Norris

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

U 10/20/2010

3


Combustible Dusts


CMD-AGR

Ronald A. Stein

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

I 07/29/2013CMD-AGR

Peter M. Telthorst

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

I 03/07/2013

CMD-AGR

Matthew I. Chibbaro

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

E 3/4/2009CMD-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 3/4/2009

CMD-AGR

Robert W. Nelson

Member Emeritus28 Wing RoadPO Box 418Pocasset, MA 02559

SE 1/1/1989CMD-AGR

Susan Bershad

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

04/16/2014

4

Public Input No. 30-NFPA 61-2014 [ Global Input ]

Please see the attached letter to USBSA Standards Council about NFPA 61. It reads in text form asfollows:

United States Beet Sugar Association

1156 FIFTEENTH STREET, N.W .

WASHINGTON, D.C. 20005

___(202) 296-4820

July 2, 2014

VIA ELECTRONIC MAIL TO [email protected]

Ms. Dawn Bellis, SecretaryStandards CouncilNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169

Re: NFPA 61

Dear Ms. Bellis:

This letter will both serve as a global public comment on the current version of NFPA 61, andas a request to the NFPA’s Standards Council.

As you are aware, there is a July 7, 2014, deadline for submitting public comments on thecurrent version of NFPA 61. We most respectfully make two requests: First, that that deadline bepostponed until at least three months after NFPA 652 is finalized. Second, that NFPA 61 be restoredto its previous 2017 revision cycle.

We request that the July 7, 2014, deadline be postponed until at least three months afterNFPA 652 is finalized because, as matters now stand, it is not possible for members of the publicaffected by NFPA 61 to intelligently comment on the most important question facing them: HowNFPA 61 should be revised to reflect provisions of the forthcoming NFPA 652. To take one example,it appears that NFPA 652 will likely permit the NFPA 61 standard to indicate which NFPA 61provisions would be permitted to be used instead of the corresponding NFPA 652 provision. In thatcase, the only way that the public could intelligently comment on which provisions of NFPA 61should so indicate their nature vis-à-vis NFPA 652 would be for the public to have a final version ofNFPA 652 before them for review.

But that is not the case. NFPA 652 is not final. It is still in the second draft stage, and hasnot yet been even voted on officially by the committee members. Although we understand that aversion of NFPA 652 was circulated in draft form to committee members on June 30, 2014, it is stillonly a draft (and apparently a partial draft at that) and has not been made available to members ofthe public. We are also informed that the draft in some important respects does not yet completelyreflect all of the unofficial votes of the NFPA 652 Committee. Moreover, the draft, as it goes throughthe official voting process, is subject to revision by the Committee and other bodies, not to mentionthe membership of the NFPA. That means that members of the public would have to expendconsiderable resources commenting on NFPA 61 with the aid of a draft of NFPA 652 that could wellbe later rendered inaccurate. Under these circumstances, the deadline for public comment shouldbe postponed until at least three months after NFPA 652 is finalized.

We also request that NFPA 61 be restored to its previous 2017 revision cycle. The shift to a2016 revision cycle means that the NFPA 61 Committee will be unable to revise NFPA 61 to timelyreflect the final text of NFPA 652. As a result, there will be a considerable period of time in whichusers of NFPA 61 will be literally required to comply with provisions in NFPA 652 that the NFPA 61Committee may well find inappropriate to agricultural products and thus will later prescribedifferent provisions addressing the same subject. Users of NFPA 61 will thus be needlessly

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

1 of 86 7/9/2014 2:34 PM

required at first to comply with a differing requirement in NFPA 652, and then will be required tocomply with yet another differing requirement once NFPA 61 is revised. This makes no sense, andwill produce confusion and waste. The best way to resolve these considerable difficulties would beto restore NFPA 61 to its 2017 revision cycle.

We look forward to a favorable response to our requests.

Respectfully,

James W. Johnson President, United States Beet Sugar Association

cc: Arthur G. Sapper, Esq. ([email protected]) Ms. Susan Bershad ([email protected])

Additional Proposed Changes

File Name Description Approved

Letter_to_Standards_Council_re_NFPA_61.pdf Letter to NFPA Standards Council

Statement of Problem and Substantiation for Public Input

(1) Inability of the public to intelligently comment on NFPA 61 by July 7, 2014, without an reliable, authoritative version of NFPA 652 available. Comments should therefore not be due until NFPA 652 is in final form. (2) Confusion caused by the 2016 development cycle assigned to NFPA 61, which will make the NFPA 61 committee unable to revise NFPA 61 to account for NFPA 652 and prevent conflicting and inconsistent requirements as the standards develop; the 2017 development cycle of NFPA 61 should therefore restored.

Submitter Information Verification

Submitter Full Name: ARTHUR SAPPER

Organization: MCDERMOTT WILL EMERY LLP

Affilliation: United States Beet Sugar Association

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jul 02 17:15:53 EDT 2014


2 of 86 7/9/2014 2:34 PM

U N I T E D S T A T E S B E E T S U G A R A S S O C I A T I O N

1156 FIFTEENTH STREET, N.W.

WASHIN GTON, D .C . 20005 ___

(202) 296-4820

July 2, 2014

VIA ELECTRONIC MAIL TO [email protected]

Ms. Dawn Bellis, Secretary Standards Council National Fire Protection Association 1 Batterymarch Park Quincy, MA 02169

Re: NFPA 61

Dear Ms. Bellis:

This letter will both serve as a global public comment on the current version of NFPA 61, and as a request to the NFPA’s Standards Council.

As you are aware, there is a July 7, 2014, deadline for submitting public comments on the current version of NFPA 61. We most respectfully make two requests: First, that that deadline be postponed until at least three months after NFPA 652 is finalized. Second, that NFPA 61 be restored to its previous 2017 revision cycle.

We request that the July 7, 2014, deadline be postponed until at least three months after NFPA 652 is finalized because, as matters now stand, it is not possible for members of the public affected by NFPA 61 to intelligently comment on the most important question facing them: How NFPA 61 should be revised to reflect provisions of the forthcoming NFPA 652. To take one example, it appears that NFPA 652 will likely permit the NFPA 61 standard to indicate which NFPA 61 provisions would be permitted to be used instead of the corresponding NFPA 652 provision. In that case, the only way that the public could intelligently comment on which provisions of NFPA 61 should so indicate their nature vis-à-vis NFPA 652 would be for the public to have a final version of NFPA 652 before them for review.

But that is not the case. NFPA 652 is not final. It is still in the second draft stage, and has not yet been even voted on officially by the committee members. Although we understand that a version of NFPA 652 was circulated in draft form to committee members on June 30, 2014, it is still only a draft (and apparently a partial draft at that) and has not been made available to members of the public. We are also informed that the draft in some important respects does not yet completely reflect all of the unofficial votes of the NFPA 652 Committee. Moreover, the draft, as it goes through the official voting process, is subject to revision by the Committee and other bodies, not to mention the membership of the NFPA. That means that members of the public would have to expend considerable resources commenting on NFPA 61 with the aid of a draft of NFPA 652 that could well be later rendered inaccurate. Under these circumstances, the deadline for public comment should be postponed until at least three months after NFPA 652 is finalized.

mailto:[email protected]

Ms. Dawn Bellis, Secretary July 2, 2014 Page 2 We also request that NFPA 61 be restored to its previous 2017 revision cycle. The shift to a 2016 revision cycle means that the NFPA 61 Committee will be unable to revise NFPA 61 to timely reflect the final text of NFPA 652. As a result, there will be a considerable period of time in which users of NFPA 61 will be literally required to comply with provisions in NFPA 652 that the NFPA 61 Committee may well find inappropriate to agricultural products and thus will later prescribe different provisions addressing the same subject. Users of NFPA 61 will thus be needlessly required at first to comply with a differing requirement in NFPA 652, and then will be required to comply with yet another differing requirement once NFPA 61 is revised. This makes no sense, and will produce confusion and waste. The best way to resolve these considerable difficulties would be to restore NFPA 61 to its 2017 revision cycle.

We look forward to a favorable response to our requests.

Respectfully,

James W. Johnson President, United States Beet Sugar Association cc: Arthur G. Sapper, Esq. ([email protected]) Ms. Susan Bershad ([email protected])

Public Input No. 1-NFPA 61-2013 [ Section No. 1.1.1 ]

1.1.1 *

This standard shall apply to all of the following:

(1) All facilities that receive, handle, process, dry, blend, use, mill, package, store, or ship dryagricultural bulk materials, their by-products, or dusts that include grains, oilseeds, agricultural seeds,legumes, sugar, flour, spices, feeds, and other related materials " such as dairy/food powders eg.milk powder, lactose, whey, maltodextrine and other dry food ingredients"

(2) All facilities designed for manufacturing and handling starch, including drying, grinding, conveying,processing, packaging, and storing dry or modified starch, and dry products and dusts generated fromthese processes

(3) Those seed preparation and meal-handling systems of oilseed processing plants not covered byNFPA 36, Standard for Solvent Extraction Plants


The facilities that use dairy/food products are not indicated in this standard


Submitter Full Name: Venkateswara Bhamidipati

Organization: Powder Process Solutions

Street Address:

City:

State:

Zip:

Submittal Date: Tue Jun 18 11:04:44 EDT 2013


3 of 86 7/9/2014 2:34 PM

Public Input No. 20-NFPA 61-2014 [ New Section after 1.4.1 ]

1.4.1.1 When major replacement or renovation of existing facilities is planned, provisions of thisstandard shall apply.


The current standard has language that addresses new construction and existing construction, but not renovation work. (The proposed language is used in NFPA 654:1.5.5)


Submitter Full Name: Bill Galloway

Organization: Southern Regional Fire Code De

Street Address:

City:

State:

Zip:

Submittal Date: Thu Apr 17 16:44:43 EDT 2014


4 of 86 7/9/2014 2:34 PM


2.3.3 MSHA Publications

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

MSHA CFR Part 18 - MSHA 2G Test - Flame-resistant conveyor belt


The 2G Flame Test is mentioned in section 3.3.10 but no reference is given.


Submitter Full Name: Amy Brown

Organization: FM Global

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 06 12:35:09 EDT 2014


5 of 86 7/9/2014 2:34 PM


3.3.1 * Agricultural Dust.

Any finely divided solid agricultural material 420 microns or smaller in diameter (material passing a U.S.No. 40 Standard Sieve) that presents a flash fire or hazard or explosion hazard when dispersedsuspended and ignited in air.


Removed the specific reference to a particle size to make the definition more consistent with NFPA 654 [Section 3.3.5 Combustible Dust - 2013 Edition] and NFPA 652 [Section 3.3.4 - Draft 2015 Edition].

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 34-NFPA 61-2014 [Section No. A.3.3.1]




Street Address:

City:

State:

Zip:



6 of 86 7/9/2014 2:34 PM


3.3.8 * Explosion.

The bursting or rupture of an enclosure or container due to the development of internal pressure from adeflagration. [ 654 , 2013]


Suggested adding the reference to NFPA 654 since the definition is exactly the same.




Street Address:

City:

State:

Zip:



7 of 86 7/9/2014 2:34 PM


3.3.11 add a definition of Headhouse


The definition of Headhouse is not in Chapter 3 or in the Merriam-Webster’s Collegiate dictionary 11th edition. In Googling this term, it is defined as an accessory structure pertaining to railway station operations. Delete the term if by the definition established, a “headhouse” does not pose the same explosion risk as does a silo. The definitiin is needed for those not familiar with the terms within the document but need to apply it.


Submitter Full Name: Kelly Nicolello

Organization: Western Regional Fire Code Dev

Street Address:

City:

State:

Zip:

Submittal Date: Tue Apr 01 19:01:34 EDT 2014


8 of 86 7/9/2014 2:34 PM


3.3.10 Fire-Resistant Belting Materials.

Belts that meet Mine Safety and Health Administration (MSHA) 2G flame test for conveyor belting.

(see 7.2.2)


This just moves the requirements into section 7.2.2 (new) to comply with the Manual of Style which does not allow requirements or references to codes, standards or regulations in defintions.



Public Input No. 31-NFPA 61-2014 [Section No. 7.2]


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 04 17:26:42 EDT 2014


9 of 86 7/9/2014 2:34 PM


3.3.15 add a definition of personnel-intensive area.


Once defined, the examples given in the exception may not be described as personnel-intensive areas, therefore may be deleted. Also note that the exception references small control rooms, which does not pose similar safety issues as would personnel-intensive areas.

The definition is needed for those not familiar with the terms within the document but need to apply it.




Street Address:

City:

State:

Zip:



10 of 86 7/9/2014 2:34 PM


4.1.3 Use of Separation.

4.1.3.1*

Separation shall be permitted to be used to limit the dust explosion hazard or deflagration hazard

area within a building when it is supported by a documented engineering evaluation acceptable

to the authority having jurisdiction.

A.4.1.3.1

A building could be considered as a single combustible dust hazard area, or as a collection of

smaller, separated combustible dust hazard areas. When the owner/operator chooses to consider

the building as a single area, then the hazard analysis should consider the entire building floor

area, and the considerations for mitigation apply to the entire building. Where the combustible

dust hazard areas are sufficiently distant to assert separation and the owner/operator chooses to

consider each hazard area separately, the hazard analysis should consider each separated area,

and the considerations for mitigation should be applied to each area independently. Due

consideration should be given to overhead dust accumulations, such as on beams or ductwork,

which would negate the use of separation to limit combustible dust hazard areas. If the

separation option is chosen, a building floor plan, showing the boundaries considered, should be

maintained to support housekeeping plans.

4.1.3.2*

The required separation distance between the dust explosion hazard or deflagration hazard area

and surrounding exposures shall be determined by an engineering evaluation that addresses the

following:

(1) Properties of the materials

(2) Type of operation

(3) Amount of material likely to be present outside the process equipment

(4) Building and equipment design

(5) Nature of surrounding exposures

A.4.1.3.2

Separation distance is the distance between the outer perimeter of a primary dust accumulation

area and the outer perimeter of a second dust accumulation area. Separation distance

evaluations should include the area and volume of the primary dust accumulation area as well

as the building or room configuration.

4.1.3.3

The separation area shall be free of dust, or where dust accumulations exist on any surface, the surface colors belowshall be readily discernible.

4.1.3.4

When separation is used to limit the dust explosion or deflagration hazard area determined in

Chapter 7, the minimum separation distance shall not be less than 35 ft (11 m).

4.1.3.5*

When separation is used, housekeeping, fixed dust collection systems employed at points of

release, and the use of physical barriers shall be permitted to be used to limit the extent of the

dust explosion hazard or flash-fire hazard area.


11 of 86 7/9/2014 2:34 PM

A.4.1.3.5

The assertion of separation must recognize the dust accumulation on all surfaces in the

intervening distance, including floors, beam flanges, piping, ductwork, equipment, suspended

ceilings, light fixtures, and walls. Process equipment or ductwork containing dust can also

provide a connecting conduit for propagation between accumulation areas. In order to prevent

flame propagation across the separation distance, the dust accumulation should be very low. The

National Grain and Feed Association study, Dust Explosion Propagation in Simulated Grain

Conveyor Galleries, has shown that a layer as thin as 1/100 in. is sufficient to propagate flame

in a limited expansion connection, such as an exhaust duct or a hallway. In the subject study, the

flame propagated for at least 80 ft (24.4 m) in an 8 ft (2.4 m) tall by 8 ft (2.4 m) wide gallery.


Suggested addition based on NFPA 652 - 2015 Edition section 8.2.5.3.




Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 07 16:50:57 EDT 2014


12 of 86 7/9/2014 2:34 PM


4.1.4 *

Masonry shall not be used for the construction of exterior walls or roofs of areas classified as Class II,Group G, Division 1 in NFPA 70, National Electrical Code.

Exception: Masonry 4.1.4.1 This requirement shall not apply to masonry walls that are designed forexplosion resistance to preclude failure of these walls before the explosion pressure can be vented safelyto the outside.


Exception to 4.1.4 moved to section 4.1.4.1 to confirm with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



13 of 86 7/9/2014 2:34 PM

Public Input No. 39-NFPA 61-2014 [ Section No. 4.1.5.1 ]

4.1.5.1

Structures housing personnel-intensive areas not directly involved in operations such as, but not limited to,those involved exclusively in administrative or clerical personnel groups, grain inspection and weighingsupervision, or operations from control rooms shall be constructed in a location remote from storage silosand headhouse structures as specified in 4.1.5.2 through 4.1.5.4.Exception: Small

4.1.5.1.1 This requirement shall not apply to small control rooms contiguous to specific operations such asrailcar and truck discharging or loading or to control rooms such as those used in feed mills for mixingoperations.


Exception to 4.1.5.1 moved to section 4.1.5.1.1 to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



14 of 86 7/9/2014 2:34 PM


4.1.5.2

Structures housing personnel-intensive areas shall not be constructed directly over subterranean tunnelsthrough which grain-handling equipment or dust control system ductwork passes or over other tunnels thathave direct openings into grain-handling areas.

Exception: Small 4.1.5.2.1 This section shall not apply to small control room structures contiguous tospecific operations such as railcar and truck discharging or loading.






Street Address:

City:

State:

Zip:



15 of 86 7/9/2014 2:34 PM


4.1.5.3

Where reinforced concrete is used in silos and headhouses, the separation distance from personnel-intensive areas shall be at least 30 m (100 ft).

Exception: Distances less than 30 m (100 ft) but in no case less than 15 m (50 ft) shall be permitted if anyof the following conditions exist:

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

Structures do not have inside legs.

Structures have inside legs that if the

(1) Structures have inside legs and are equipped with explosion suppression systems in accordancewith NFPA 69, Standard on Explosion Prevention Systems .


Having inadequate distance or permanent constraints to your property boundary or having a structure without “inside legs” should not warrant the distance from a potentially explosive silo to "structures housing personnel-intensive areas" to be cut in half. We cannot seem to grasp the idea of a structure having “inside legs” would cause it to be less hazardous, thus allowing the reduction in distance as exampled in exception (2).




Street Address:

City:

State:

Zip:



16 of 86 7/9/2014 2:34 PM


4.1.5.3

Where reinforced concrete is used in silos and headhouses, the separation distance from personnel-intensive areas shall be at least 30 m (100 ft).

Exception: Distances4.1.5.3.1 Distances less than 30 m (100 ft) but in no case less than 15 m (50 ft) shall be permitted if anyof 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 suppression systems in accordancewith NFPA 69, Standard on Explosion Prevention Systems.


Exception to 4.1.5.3 moved to 4.1.5.3.1 to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



17 of 86 7/9/2014 2:34 PM


4.1.5.4

Where the headhouse is constructed of structural steel or reinforced concrete framework with lightweight,explosion-relieving wall panels, or does not contain inside or unprotected bucket elevators, the separationdistance from personnel-intensive areas shall be at least 15 m (50 ft).

Exception: 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.


Having limited or inadequate distance to your property boundary should not warrant the distance to "structures housing personnel-intensive areas" to be reduced.




Street Address:

City:

State:

Zip:



18 of 86 7/9/2014 2:34 PM


4.1.5.4

Where the headhouse is constructed of structural steel or reinforced concrete framework with lightweight,explosion-relieving wall panels, or does not contain inside or unprotected bucket elevators, the separationdistance from personnel-intensive areas shall be at least 15 m (50 ft).

Exception: Distances 4.1.5.4.1 Distances less than 15 m (50 ft) shall be permitted if the propertyboundaries or other permanent constraints preclude 15 m (50 ft), but in no case shall distances less than9 m (30 ft) be permitted.






Street Address:

City:

State:

Zip:



19 of 86 7/9/2014 2:34 PM

Public Input No. 6-NFPA 61-2013 [ Section No. 4.2 ]

4.2 * Interior Surfaces.

Horizontal surfaces shall be minimized to prevent accumulations of dust in all interior structural areaswhere significant where dust accumulations could occur.


This is a subjective word and allows for uneven enforcement. Either remove or replace with a specific amount such as ½ inch.


Submitter Full Name: Doug Hohbein

Organization: Northcentral Fire Code Develop

Street Address:

City:

State:

Zip:

Submittal Date: Tue Oct 15 16:59:24 EDT 2013


20 of 86 7/9/2014 2:34 PM

Public Input No. 7-NFPA 61-2013 [ Section No. 4.3.3 [Excluding any Sub-Sections] ]

Necessary openings in fire walls and fire barrier walls shall be kept to a minimum and be as small aspracticable. Such openings shall be protected with listed self-closing fire doors, fire shutters, fire dampers,or penetration seals installed in accordance with NFPA 5000, Building Construction and Safety Code,Chapter 8, Fire-Resistive Materials and Construction.


If the openings are properly protected by listed protectives meeting code, should they be limited?




Street Address:

City:

State:

Zip:



21 of 86 7/9/2014 2:34 PM


4.4.1.1 Normally occupied spaces/rooms where hazardous dust accumulation may occur shall bedesigned according to ‘Special Provisions for Occupancies with High Hazard Contents’ in NFPA101.


Prescribed housekeeping measures to prevent or reduce dust generation and dispersal can do much to lessen the hazards of combustible dust, but cannot eliminate them. LSC 101:7.11 addresses exit egress provisions specific to this type hazard.


Submitter Full Name: Bill Galloway

Organization: Southern Regional Fire Code De

Street Address:

City:

State:

Zip:

Submittal Date: Thu Apr 17 16:45:44 EDT 2014


22 of 86 7/9/2014 2:34 PM


4.4.3

Bin decks shall , with travel distances to the means of egress of 15 m (50 ft) or greater, shall have twomeans of egress that are remote from each other such that a single fire or explosion event will not likelyblock both means of egress.

Exception: Only one means of egress shall be required for bin deck areas where travel distance to themeans of egress is less than 15 m (50 ft).


Reworded the section to remove the expcetion without changing the intent of the section. This change helps the section conform with the NFPA Manual for Style.




Street Address:

City:

State:

Zip:



23 of 86 7/9/2014 2:34 PM


4.4.3

Bin decks shall have two means of egress that are remote from each other such that a single fire orexplosion event will not likely block both means of egress.

Exception: Only one one means of egress shall be required for bin deck areas where travel distance tothe means of egress is less than 15 m (50 ft).


Only is not needed.




Street Address:

City:

State:

Zip:



24 of 86 7/9/2014 2:34 PM

Public Input No. 44-NFPA 61-2014 [ Chapter 5 ]

Chapter 5 Ventilation and Venting

5.1 General.

5.1.1

In this chapter, ventilation shall refer to natural or mechanical movement of air necessary for normaloperation and personnel comfort and safety.

5.1.2

Recirculating or recycling exhaust air ventilation systems for dust explosion hazard areas, if used, shall beequipped with filter systems capable of removing dust from the air.

5.1.3

Dust collection systems used in conjunction with ventilation systems shall comply with the provisions ofChapter 10 of this standard.

5.2

Dust collection systems used in conjunction with ventilation systems shall comply with the provisions ofChapter 10 of this standard.

5.2 Exhaust Air

5.2.1 Exhaust air from the final air-material separator shall be discharged outside to a restricted area andaway from air intakes.

5.2.2 Air from air-material separators shall be permitted to be re-circulated directly back to the pneumaticconveying system.

5.2.3 Recycling of air-material separator exhaust to buildings or rooms shall be permitted when all of thefollowing requirements are met:

(1) Combustible or flammable gases or vapors are not present either in the intake or the recycled air inconcentrations above applicable industrial hygiene exposure limits or 1 percent of the LFL, whicheveris lower.

(2) *Combustible particulate solids are not present in the recycled air in concentrations above applicableindustrial hygiene exposure limits or 1 percent of the MEC, whichever is lower.

(3) *The oxygen concentration of the recycled air stream is between 19.5 percent and 23.5 percent byvolume.

(4) Provisions are incorporated to prevent transmission of flame and pressure effects from a deflagrationin an air-material separator back to the facility unless a process hazard analysis indicates that thoseeffects do not pose a threat to the facility or the occupants.

(5) Provisions are incorporated to prevent transmission of smoke and flame from a fire in an air-materialseparator back to the facility unless a process hazard analysis indicates that those effects do notpose a threat to the facility or the occupants.

(6) The system includes a method for detecting air-material separator malfunctions that would reducecollection efficiency and allow increases in the amount of combustible particulate solids returned tothe building.

(7) The building or room to which the recycled air is returned meets the fugitive dust control andhousekeeping requirements of this standard (Chapter 10).

(8) Recycled-air ducts are inspected and cleaned at least annually.

5.3 Venting of Bins, Tanks, and Silos.

5. 2 3 .1

The requirements for air displacement shall be as follows:

(1) Each bin, tank, or silo shall be provided with means for air displacement during filling or emptying.

(2) Displaced air shall not be discharged to the building atmosphere unless it is cleaned with a filterhaving a minimum efficiency of 0.02 g per dry standard cubic meter of airflow (0.008 grains per drystandard cubic foot of airflow).


25 of 86 7/9/2014 2:34 PM

5. 2 3 .2 *

Vents shall be designed to prevent plugging due to accumulations of dust.

5. 2 3 .3

Inclined vent stacks shall have clean-out doors or panels.

5. 2 3 .4

All vents shall be fitted with weather hoods.

5. 2 3 .5

Bin vents shall be sized to handle the air displaced by either filling or emptying.


Suggest we replace the existing 5.1.2 guidance on air recirculation with the guidance in NFPA 654 (Section 7.13.1.6.3 - 2013 Edition). Also suggest we include the annex material (PI 45).Renumbered the existing section on venting of bins, tanks and silos to accomodate the proposed new section.



Public Input No. 45-NFPA 61-2014 [New Section after A.5.2.2]





Street Address:

City:

State:

Zip:



26 of 86 7/9/2014 2:34 PM

Public Input No. 2-NFPA 61-2013 [ Chapter 6 [Title Only] ]

Explosion Prevention , Relief, and Venting Protection Systems


The Explosion Prevention and Protection systems would be a better title




Street Address:

City:

State:

Zip:



27 of 86 7/9/2014 2:34 PM

Public Input No. 47-NFPA 61-2014 [ Section No. 6.2.1 [Excluding any Sub-Sections] ]

If a dust explosion hazard exists in rooms, buildings, or other enclosures under normal operatingconditions or upset conditions , such areas shall be provided with explosion relief venting distributed overthe exterior walls (and roof, if applicable) in accordance with NFPA 68, Standard on Explosion Protection byDeflagration Venting.


The potential for a dust explosion during an upset condition should not be overlooked. Most other standard on dust explosion hazards (NFPA 68, NFPA 654, FM Global Data Sheet 7-76, and FM Global Data Sheet 7-76) do not make the distinction between normal operating conditions and upset conditions.




Street Address:

City:

State:

Zip:



28 of 86 7/9/2014 2:34 PM


6.2.1.2

The design shall offer the least possible resistance to explosion pressures.

Exception No 6 . 1: Tunnels 2.1.2.1 This requirement does not apply to tunnels and pits where explosionventing is not practical due to confinement by soil, building constraints, or both.

Exception No 6 .2: Bins .1.2.2 This requirement does not apply to bins and silos where explosion ventingis not practical due to bin or silo geometry, building constraints, or both.


Exceptions to 6.2.1.2 have been moved to subsections to conform with NFPA Mannual of Style.




Street Address:

City:

State:

Zip:



29 of 86 7/9/2014 2:34 PM

Public Input No. 80-NFPA 61-2014 [ New Section after 6.3.3.1 ]

6.3.3.2

Venting shall be located to relieve pressure through an outside wall or roof.

6.3.3.3

The fireball, blast hazards, and missile hazards that are created by deflagration venting shall not expose additionalpersonnel or property assets.


Suggested additional information based on NFPA 652 - 2015 Edition - Section 8.2.2.2.1 and 8.2.2.2.2.




Street Address:

City:

State:

Zip:



30 of 86 7/9/2014 2:34 PM


7.1.1

Antifriction bearings shall be used on all machinery, conveyors, legs, and processing equipment.

Exception: Sleeve 7.1.1.1 Sleeve and friction-type bearings, plastic bearings, or oil-impregnated woodbearings shall be permitted for equipment operating at 150 rpm or less.


Exception to 7.1.1 moved to section 7.1.1.1 to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



31 of 86 7/9/2014 2:34 PM


7.1.3 *

All bearings on legs and conveyors shall be located outside of machinery enclosures and isolated from theproduct stream to minimize exposure to dust and to be more accessible for inspection and service.

Exception: Antifriction 7.1.3.1 Antifriction support bearings on screw conveyors and similar equipmentrequiring bearings to be within the product stream shall be of the sealed type.

7.1.3.2 Sleeve and friction-type bearings shall be permitted for equipment operating at 150 rpm or less.


Moved the exceptions to 7.1.3 to sub-sections to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



32 of 86 7/9/2014 2:34 PM


7.2 Drive Belts.

7.2.1

Where drive assemblies involve the use of belts, such as V-belts, timing belts, flat belts, and so forth, theyshall be electrically conductive at 1 megohm or less and shall be fire resistant and oil resistant.

7.2.2

Belts shall be fire resistant by complying with the requirements of the Mine Safety and HealthAdministration (MSHA) 2G flame test for conveyor belting.

7.2.3

Where a drive belt is used, the drive train shall be designed with a minimum service factor of 1.5 or higher ifthe manufacturer of the drive components recommends a higher service factor for continuous service forthe type of equipment to be driven.

Exception: Line shaft drives as used in the milling industry.


This just moves the requirements for fire resistant belts from Chapter 3 (definitions) into Chapter 7, in compliance with the Manual of Style, that prohibits requirements in definitions.



Public Input No. 32-NFPA 61-2014 [Section No. 3.3.10]


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 04 17:23:38 EDT 2014


33 of 86 7/9/2014 2:34 PM


7.2.3

Drive belts shall be designed to stall without the belt slipping, or a safety device shall be provided to shutdown the equipment if slippage occurs. [654, 2013]


Suggested additional precaution to avoid overheating that could be a potential ignition source.




Street Address:

City:

State:

Zip:



34 of 86 7/9/2014 2:34 PM


7.2.2

Where a drive belt is used, the drive train shall be designed with a minimum service factor of 1.5 or higher ifthe manufacturer of the drive components recommends a higher service factor for continuous service forthe type of equipment to be driven.

Exception: Line 7.2.2.1 This requirement shall not apply to line shaft drives as used in the millingindustry.


Moved the exception to 7.2.2 to 7.2.2.1 to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



35 of 86 7/9/2014 2:34 PM


7.3.2

Bulk material conveyor belts shall have belt alignment and hot bearing sensors at the head and tail or tailmotion sensors that will cut power to the drive in the event the belt slows to 80 percent of the normaloperating speed .

Exception: Open belt conveyors operating below 250 ft/min


The addition of tail motion sensors would stop the process and notify operating personnel that a problem exists. Open belt conveyors have a low probability of having a combustible dust atmosphere


Submitter Full Name: JAMES FUHRMAN

Organization: Monsanto Company

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jun 04 16:10:19 EDT 2014


36 of 86 7/9/2014 2:34 PM


7.3.6 * Interior linings

7.3.6.1 Interior linings shall be noncombustible.

7.3.6.2 Where noncombustible linings are not pratical, provide fire protection. Automatic sprinklers, whereprovided, shall be installed in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems.

7.3.6.3

Use of combustible lining shall be permitted in spouts and other handling equipment at impact points andon wear surfaces.


Suggested changes to better align the mandatory language with the annex material. The existing annex material states that the use of non-combustible linings are preferred.




Street Address:

City:

State:

Zip:



37 of 86 7/9/2014 2:34 PM


7.4.1.4 *

Each leg shall be independently driven by motor(s) and drive train(s) capable of handling the full-ratedcapacity of the elevator leg without overloading.

Exception: Line 7.4.1.4.1

Line shaft drives shall be acceptable for legs used in the milling industry as long as they are capable ofhandling the full-rated capacity of all connected equipment without overloading.

7.4.1.4. 1 2

Multiple motor drives shall be interlocked to prevent operation of the leg upon failure of any single motor.

7.4.1.4.2

The drive shall be capable of starting the unchoked leg under full (100 percent) load.


Exception made into a subsection and existing subsections renumbered to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



38 of 86 7/9/2014 2:34 PM


7.4.1.9

Legs Where necessary to minimize slippage, legs shall have lagging installed on the head pulley tominimize slippage .

7.4.1.9.1 *

Leg belts and lagging shall have a surface resistivity not greater than 100 megohms per square.

7.4.1.9.2

Leg belts and lagging shall be fire resistant and oil resistant.

Exception No. 1: Oil-resistant lagging or belting shall not be required for bucket elevators used in flourmills or for handling inert materials.

Exception No. 2: Line shaft drives as used in the milling industry shall be exempt from the laggingrequirement.


We have experienced belt tracking as well as product contamination issues due to head pulley lagging; our product tends to be abrasive and rapidly wears lagging off, causing product contamination problems. Therefore, we have removed all head pulley lagging and have not had any belt slipping issues. Our elevators have enough tension on them to prevent any slippage, in fact, when our elevators are extremely loaded, we find the motor overloads will 'kick out' or we'll break a chain before any slippage occurs. We see no evidence of slippage (no signs of heat or belt discoloration) due to slippage.


Submitter Full Name: AL WHITBY

Organization: AMALGAMATED SUGAR CO LLC

Street Address:

City:

State:

Zip:



39 of 86 7/9/2014 2:34 PM

Public Input No. 28-NFPA 61-2014 [ Section No. 7.4.1.9 [Excluding any Sub-Sections] ]

Legs Where necessary to minimize slippage, legs shall have lagging installed on the head pulley tominimize slippage .


As it is now written, section 7.4.1.9 requires lagging installed on the head pulley in all cases, even when it is not needed to minimize slippage. The original intent of the provision was probably to require lagging only where slippage is a problem. Not all head pulleys need lagging to minimize slippage. Some do and some do not. The requested revision would make the likely original intent clear; that is, it would make clear that lagging is required where necessary to minimize slippage. It does this by just moving the reference to slippage from the back of the provision to its beginning, so that it would read, "“7.4.1.9 Where necessary to minimize slippage, legs shall have lagging installed on the head pulley.”


Submitter Full Name: ARTHUR SAPPER

Organization: MCDERMOTT WILL EMERY LLP

Affilliation: United States Beet Sugar Association

Street Address:

City:

State:

Zip:



40 of 86 7/9/2014 2:34 PM

Public Input No. 55-NFPA 61-2014 [ Section No. 7.4.1.9.2 ]

7.4.1.9.2

Leg belts and lagging shall be fire resistant and oil resistant.Exception No

7 .

1: Oil

4.1.9.2.1 Oil -resistant lagging or belting shall not be required for bucket elevators used in flour mills or forhandling inert materials.

Exception No. 2: Line 7.4.1.9.2.2 Oil-resistant lagging or belting shall not be required for line shaft drivesas used in the milling industry shall be exempt from the lagging requirement .


Exceptions to 7.4.1.9.2 have been moved to subsections to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



41 of 86 7/9/2014 2:34 PM


7.4.1.10 *

Inside legs shall have bearing temperature or vibration detection, head pulley alignment, and belt alignmentmonitors at head and tail pulleys.

Exception: Legs that have capacities less than 106 m3/hr (3750 ft3/hr) or have belt speeds below2 .5m/sec (500 ft/mi)


The last revision requires a motion detector to stop the leg in the event the belt speed drops to 80% of normal. 7.4.1.5 had the speed exception removed. Slow belt speeds and the tail motion sensor provide adequate indication of problems with slow speed elevators. The standard should encourage designers and engineers to use slower speeds. Slower speeds will have slower heat build up during a problem. As is stands now a bucket elevator could be increased in capacity to very high belt speeds but stay below the 3750 ft3/hr limit. A slower belt speed will decrease the likelihood of dust being extracted from the grain as it moves up the elevator.Work by Jaeger indicated a relationship between speed and heat for mechanical rubbing. Remain consistent with NFPA 654 (500 ft/min or 3750 ft3/hr) (7.10.9.4)




Street Address:

City:

State:

Zip:



42 of 86 7/9/2014 2:34 PM


7.4.1. 10 *

Inside legs shall have bearing temperature or

10 Monitors

7.4.1.10.1 Elevators shall have monitors at head and tail pulleys that indicate high bearing temperature,vibration detection, head pulley alignment, and belt alignment

monitors at head and tail pulleys. Exception: Legs that have capacities less than 106 m 3 /hr (3750 ft 3

.

7.4.1.10.2 Abnormal conditions shall actuate an alarm requiring corrective action.

7.4.1.10.3 The alarm shall sound at the operator control station.

7.4.1.10.4* The requirement of 7.4.1.10.1 shall not apply to elevators that have belt speeds below 500ft/min (150 m/min) or capacities less than 3750 ft3/hr (106 m3 /hr).


Suggested change to align better with NFPA 654 (Section 7.10.9 - 2013 Edition). The changes also remove the exception conforming with the NFPA Manual of Style. Relocated the * for the annex material so the reference is still relevant.



Public Input No. 57-NFPA 61-2014 [Section No. A.7.4.1.10]




Street Address:

City:

State:

Zip:



43 of 86 7/9/2014 2:34 PM


7.4.2 Legs Handling Bulk Raw Grain.

7.4.2.1 *

Legs handling bulk raw grain shall be installed either as an outside leg or as an inside

leg withleg with compliance with one of the following cases:

(1) Legs are located within 3 m (10 ft) of an exterior wall and are vented as outlined in 7.4.2.2 to theoutside of the building and designed so that the explosion pressures will not rupture the ductwork orthe leg. Explosion relief panels shall be provided on the leg housing so the ducts will not be acollection point for dust during normal operations.

(2) Legs are vented in accordance with NFPA 68, Standard on Explosion Protection by DeflagrationVenting.

(3) Legs are provided with explosion suppression in accordance with NFPA 69, Standard on ExplosionPrevention Systems.

(4)

7.4.2.2 *

* Legs that have capacities less than 106 m3/hr (3750 ft3/hr).


44 of 86 7/9/2014 2:34 PM

All newly installed outside legs shall be provided with explosion relief panels located at intervals no greaterthan 6 m (20 ft) along the casings as shown in Figure 7.4.2.2(a) and Figure 7.4.2.2(b) .

7.4.2.2.1 To minimize personnel exposure, explosion venting for outside legs shall start between 2.5 m to3.5 m (8 ft to 12 ft) above grade, or the bottom of the explosion vent shall be within 0.3 m to 1 m (1 ft to 4 ft)after the leg penetrates the building roof.

7.4.2.2.2 Head section explosion venting shall be located in the top surface of the head or on the sidesusing a method to deflect the explosion upward.

Figure 7.4.2.2(a) Typical Elevator Explosion Venting for a Single Casing Leg.

Figure 7.4.2.2(b) Typical Elevator Explosion Venting for a Double Casing Leg.


45 of 86 7/9/2014 2:34 PM

Exception No. 1: Legs that have capacities less than 106 m 3 /hr (3750 ft 3 /hr).

Exception No. 2: Those 7.4.2.2.3 Venting shall not be required on portions of outside legs, as defined indefined in this standard, located below grade or passing through ground-level buildings.

7.4.2.2. 1 4

Each side vent shall have a minimum area equivalent to two-thirds of the cross-sectional area of the legcasing.

7.4.2.2. 2 5

A single face vent shall be permitted to replace a pair of opposing side vents in those portions of a double-casing leg where either of the following situations exists:

(1) Side venting could expose personnel on access ladders or platforms.

(2) Structural interferences are present that would interfere with vent operation.

7.4.2.2. 3 6

Single face vents shall be equal to the area of two side vents [4/3 of the cross-sectional area of the legcasing as indicated in Figure 7.4.2.2(b) ].

7.4.2.2. 4 7

The head section of bucket elevators shall be provided with explosion vents in the top surface or on the

sides using a method to deflect the explosion upward. The vent area shall be a minimum of 0.14 m2 (5 ft2)

of vent area per 2.9 m3 (100 ft3) of head section volume. The largest vent area as practicable shall be usedin the head section to help minimize the development of explosive pressure. Vents shall deploy when aninternal pressure of 3.5 kPa to 6.9 kPa (0.5 psi to 1.0 psi) occurs.

7.4.2.2.8

Explosion relief panels shall be provided on the leg housing so the ducts will not be a collection point fordust during normal operations.


Reordered the section to improve clarity. I relocated the last sentance in the existing section 7.4.2.1(1) to its own subsection as it applies to all cases discussed. Removed exception 1 in the existing section 7.4.2.2 as it is redundant based on the guidnace provided in section 7.4.2.1(4). Relocated exception 2 in the existing section 7.4.2.2 to its own subsection to confirm with the NPFA Manual of Style.



Public Input No. 59-NFPA 61-2014 [Section No. 7.4.3]




Street Address:

City:

State:

Zip:



46 of 86 7/9/2014 2:34 PM


7.4.2.1 *

Legs handling bulk raw grain shall be installed either as an outside leg or as an inside leg with compliancewith one of the following cases:

(1) Legs are located within 3 m (10 ft) of an exterior wall and are vented as outlined in 7.4.2.2 to theoutside of the building and designed so that the explosion pressures will not rupture the ductwork orthe leg. Explosion relief panels shall be provided on the leg housing so the ducts will not be acollection point for dust during normal operations.

(2) Legs are vented in accordance with NFPA 68, Standard on Explosion Protection by DeflagrationVenting.

(3) Legs are provided with explosion suppression in accordance with NFPA 69, Standard on ExplosionPrevention Systems.

(4)


The standard should encourage designers and engineers to use slower speeds. Slower speeds will have slower heat build up during a problem. As is stands now a bucket elevator could be increased in capacity to very high belt speeds but stay below the 3750 ft3/hr limit. A slower belt speed will decrease the likelihood of dust being extracted from the grain as it moves up the elevator.




Street Address:

City:

State:

Zip:


* Legs that have capacities less than 106 m3/hr (3750 ft3/hr) or belt speeds less than 2 .5 m/sec(500 ft/min)


47 of 86 7/9/2014 2:34 PM

Public Input No. 26-NFPA 61-2014 [ Section No. 7.4.2.2 [Excluding any Sub-Sections] ]


48 of 86 7/9/2014 2:34 PM

All If and explosion hazard exists, all newly installed outside legs shall be provided with explosion reliefpanels located at intervals no greater than 6 m (20 ft) along the casings as shown in Figure 7.4.2.2(a) andFigure 7.4.2.2(b) . To minimize personnel exposure, explosion venting for outside legs shall start between2.5 m to 3.5 m (8 ft to 12 ft) above grade, or the bottom of the explosion vent shall be within 0.3 m to 1 m (1ft to 4 ft) after the leg penetrates the building roof. Head section explosion venting shall be located in the topsurface of the head or on the sides using a method to deflect the explosion upward.

Figure 7.4.2.2(a) Typical Elevator Explosion Venting for a Single Casing Leg.

Figure 7.4.2.2(b) Typical Elevator Explosion Venting for a Double Casing Leg.

Exception No. 1: Legs that have capacities less than 106 m3/hr (3750 ft3/hr).


49 of 86 7/9/2014 2:34 PM

Exception No. 2: Those portions of outside legs, as defined in this standard, below grade or passingthrough ground-level buildings.


The new design may be completed in such a way that an explosion hazard does not exist inside the elevator. eg dust aspiration on the leg




Street Address:

City:

State:

Zip:



50 of 86 7/9/2014 2:34 PM


7.4.3 Legs Handling Materials Other Than Bulk Raw Grain That Present an Explosion Hazard.

7.4.3.1

Explosion venting of legs into buildings shall not be permitted.

7.4.3.2 *

Newly installed outside legs shall be equipped with explosion venting in accordance with 7.4.2.2.

Exception: Those portions of outside legs, as defined in this standard, below grade or passing throughground-level buildings.

7.4.3.3 *

Legs or portions of legs that are located inside shall have the maximum practicable explosion relief areathrough the roof directly to the outside.Exception: Legs

7.4.3.3.1 This requirement shall not apply to legs that have capacities less than 106 m 3 /hr (3750 ft 3 /hr).


Exception 1 was removed. Assuming the way the exception in PI58 is handled is accepted, exception 1 is redundant. Exception 2 was moved to its own subsection to conform with the NFPA Manual of Style.



Public Input No. 58-NFPA 61-2014 [SectionNo. 7.4.2]

Exception 1 can be removed from this section is PI58 isaccepted.




Street Address:

City:

State:

Zip:



51 of 86 7/9/2014 2:34 PM


7.5 Processing Machinery and Equipment.

"Any other process equipment that is not indicated, one should refer to NFPA 654. (eg. blenders, screensetc.)"

7.5.1 * General.

7.5.1.1

Receiving systems prior to the leg shall be equipped with one or more devices such as grating, wire meshscreens, permanent magnets, listed electromagnets, pneumatic separators, or specific gravity separators,to minimize or eliminate tramp material from the product stream.

Exception: Barge and ship receiving systems using legs as the primary reclaiming systems shall beallowed to have the tramp material protection after the unloading leg but prior to being handled in anotherleg or processing equipment.

7.5.1.2 *

Where tributary spouts or conveyors feed whole grain or grain products for size reduction into grinders,pulverizers, or rolling mills, they shall be equipped with properly installed permanent magnets or listedelectromagnets, pneumatic separators, specific gravity separators, scalpers, or screens to exclude metal orforeign matter of a size larger than the grain being processed as far as practicable.

7.5.1.3 *

Equipment shall be bonded and grounded to dissipate static electricity.

7.5.1.4

All processing machinery and components, such as magnets, shall be mounted to facilitate access forcleaning.

Exception: Where processing machinery is mounted on a tight-fitting base that prevents material fromreaching inaccessible places beneath the machine.

7.5.1.5

Screw, drag, or en-masse conveyors shall be fully enclosed in metal housings and shall be designed toeither relieve or stop if the discharge end becomes plugged.

7.5.2 Starch Processing Machinery and Equipment.

7.5.2.1

Carbon steel shall be avoided in the grinding chambers and moving parts of grinding mills in favor ofbrass, bronze, stainless steel, and other metals with lower sparking potential.

7.5.2.2

The reels or sieves of screens, scalpers, and similar devices shall be in dusttight enclosures.

7.5.2.3

Connecting ducts shall be metal.

Exception No. 1: Electrically conductive nonmetallic flexible connecting ducts having an electricalresistance not greater than 1 megohm.

Exception No. 2: Plastic tubing used for sample delivery systems.

7.5.2.4

Where more than one material source is connected to a common conveyor, air-material separator, orsimilar device, each source that is connected shall be equipped with a method to prevent propagation of adeflagration in accordance with NFPA 69, Standard on Explosion Prevention Systems .

7.5.2.5

Dry milling or grinding of starch shall be performed in a separate building with explosion relief or in aseparate room isolated from other areas by interior walls designed according to 4.1.2 .

Exception No. 1: This requirement shall not apply if the equipment can be designed to be protectedin accordance with NFPA 69, Standard on Explosion Prevention Systems , by deflagration containment,by explosion suppression, or by inerting the volume to reduce oxygen such that combustion is notsupported.

Exception No. 2: This requirement shall not apply if mills are provided with explosion venting to asafe outside location. If explosion vent ducts longer than 3 m (10 ft) are to be used, the milling equipmentand explosion vent duct shall be designed to withstand the increased vented explosion pressure.


52 of 86 7/9/2014 2:34 PM


Many dairy and food processing systems have equipment such as blenders/sifters/ etc. but not mentioned in NFPA 61. Hence a guidance to refer to NFPA 654 will be useful




Street Address:

City:

State:

Zip:



53 of 86 7/9/2014 2:34 PM


7.5 Processing Machinery and Equipment.

7.5.1 * General.

7.5.1.1 *

Receiving systems prior to the leg shall be equipped with one or more devices such as grating, wire meshscreens, permanent magnets, listed electromagnets, pneumatic separators, or specific gravity separators,to minimize or eliminate tramp material from the product stream.Exception: Barge7.5.1.1.1 Barge and ship receiving systems using legs as the primary reclaiming systems shall be allowedto have the tramp material protection after the unloading leg but prior to being handled in another leg orprocessing equipment.

7.5.1.2 *

Where tributary spouts or conveyors feed whole grain or grain products for size reduction into grinders,pulverizers, or rolling mills, they shall be equipped with properly installed permanent magnets or listedelectromagnets, pneumatic separators, specific gravity separators, scalpers, or screens to exclude metal orforeign matter of a size larger than the grain being processed as far as practicable.

7.5.1.3 *

Equipment shall be bonded and grounded to dissipate static electricity.

7.5.1.4

All processing machinery and components, such as magnets, shall be mounted to facilitate access forcleaning.Exception: Where7.5.1.4.1 This requirement shall not apply where processing machinery is mounted on a tight-fitting basethat prevents material from reaching inaccessible places beneath the machine.

7.5.1.5

Screw, drag, or en-masse conveyors shall be fully enclosed in metal housings and shall be designed toeither relieve or stop if the discharge end becomes plugged.

7.5.2 Starch Processing Machinery and Equipment.


54 of 86 7/9/2014 2:34 PM

7.5.2.1

Carbon steel shall be avoided in the grinding chambers and moving parts of grinding mills in favor of brass,bronze, stainless steel, and other metals with lower sparking potential.

7.5.2.2

The reels or sieves of screens, scalpers, and similar devices shall be in dusttight enclosures.

7.5.2.3

Connecting ducts shall be metal. Exception No. 1: Electrically

one of the following:

(1) Metal.

(2) Electrically conductive nonmetallic flexible connecting ducts having an electrical resistance not greaterthan 1 megohm.

Exception No 7 . 2: Plastic 5.2.3.1 This requirement shall not apply to plastic tubing used for sampledelivery systems.

7.5.2.4

Where more than one material source is connected to a common conveyor, air-material separator, orsimilar device, each source that is connected shall be equipped with a method to prevent propagation of adeflagration in accordance with NFPA 69, Standard on Explosion Prevention Systems.

7.5.2.5

Dry milling or grinding of starch shall be performed in a separate building with explosion relief or in aseparate room isolated from other areas by interior walls designed according to 4.1.2.Exception No.1: This requirement shall7.5.2.5.1 The requirement in section 7.5.2.5 shall not apply if the equipment can be designed to beprotected in accordance with NFPA 69, Standard on Explosion Prevention Systems , by deflagrationcontainment, by explosion suppression, or by inerting the volume to reduce oxygen such that combustionis not supported.

Exception No 7 . 2: This requirement 5.2.5.2 The requirement in section 7.5.2.5 shall not apply if millsare provided with explosion venting to a safe outside location. If explosion vent ducts longer than 3 m (10ft) are to be used, the milling equipment and explosion vent duct shall be designed to withstand theincreased vented explosion pressure.


Relocated exceptions to subsections to conform with the NFPA Manual of Style.Relocated the * indicating annex material from 7.5.1 to 7.5.1.1 as it suited that section better.







Street Address:

City:

State:

Zip:



55 of 86 7/9/2014 2:34 PM


8.2.2.1

Dryers shall be constructed of noncombustible materials.


Is it possible for a dryer to be completely noncombustible? Enforcement is difficult.




Street Address:

City:

State:

Zip:



56 of 86 7/9/2014 2:34 PM

Public Input No. 62-NFPA 61-2014 [ Section No. 8.2.4.3.1 ]

8.2.4.3.1

The automatic shutdown shall accomplish all of the following:

(1) Shut off the fuel or heat to the burners.

(2) Stop the flow of product out of into the dryer.

(3) Stop all airflow from fans into the dryer.

(4) Sound an alarm at a constantly attended location or for the operator, or both, to prompt an emergencyresponse.


The existing language conflicts with section 8.2.2.6 which requires an emergency dump of product in the event of a fire. This is one of the conditions that would activate the high temperature alarm.




Street Address:

City:

State:

Zip:



57 of 86 7/9/2014 2:34 PM


8.2.5.1

Operating controls shall be designed, constructed, and installed so that required conditions of safety forsafe operation of the air heater, the dryer, and the ventilation equipment are maintained.


Editorial change to improve clarity.




Street Address:

City:

State:

Zip:



58 of 86 7/9/2014 2:34 PM


8.2.7 Explosion Protection

8.2.7.1 Where an explosion hazard exists, protection shall be in accordance with Section 6.3.


The introduction to Chapter 8 talks about fire and explosion hazards but the explosion hazards associated with dryers is not addressed in this section.




Street Address:

City:

State:

Zip:



59 of 86 7/9/2014 2:34 PM


9.1.1

Heat transfer devices utilizing air, steam, or vapors of heat transfer fluids shall be provided with pressure-relief valves where necessary.

9.1.1.1 Relief valves on systems employing combustible heat transfer media shall be vented to a safeoutside location.


Separated the two requirements to improve clarity.




Street Address:

City:

State:

Zip:



60 of 86 7/9/2014 2:34 PM


9.1.2

Heaters and pumps for combustible heat transfer fluids shall be located in a separate, dustfree room orbuilding of noncombustible construction.

9.1.2.1 Buildings or rooms that contain heaters and shall be protected pumps for combustible heattransfer fluids shall be protected by automatic sprinklers designed in accordance with NFPA 13, Standardfor the Installation of Sprinkler Systems, to control a fire involving the combustible heat transfer fluid.

9.1.2.2 Air for combustion shall be taken from a clean outside source.

9.1.2. 1 3 *

Buildings or rooms that contain heat transfer equipment and boilers that use combustible heat transferfluids shall be located in separate areas such that they do not communicate directly with areas that containa dust explosion hazard.

9.1.2. 2 4

Where combustible heat transfer fluids are used, doorways shall be curbed or ramped and floor drains shallbe provided to direct spills of the heat transfer fluid to a safe location.

9.1.2.4.1 Automatic sprinkler protection designed to control these fluid fires shall be provided in areascontaining equipment that uses these fluids and in areas containing storage tanks for these fluids.


Separated criteria to help improve clarity.







Street Address:

City:

State:

Zip:



61 of 86 7/9/2014 2:34 PM


10.2.2

The use of compressed air or other means that cause dust to be suspended in air during removal fromledges, walls, and other surfaces shall be permitted only after all machinery in the area has been shut downand all sources of ignition controlled.

Exception: Areas10.2.2.1 Areas in processing facilities shall be permitted to be cleaned with compressed air, providedthat both of the following conditions are met:

(1) Airborne material will not envelop adjacent operating equipment.

(2) Prior to blowdown, areas and adjacent equipment are checked to ensure that no ignition sourcesare present.


Exception to 10.2.2 moved to section 10.2.2.1 to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



62 of 86 7/9/2014 2:34 PM


10.2.4

Where flammable vapors or gases are present, vacuum cleaners shall be listed for Class I and Class II hazardouslocations.


Suggested addition based on NFPA 652 - 2015 Edition section 8.4.2.2.4.




Street Address:

City:

State:

Zip:



63 of 86 7/9/2014 2:34 PM


10.4.3 * Location.

Dust collectors shall be located outside of buildings and shall be protected in accordance with Section 6.3.

Exception No. 1: Dust 10.4.3.1 Dust collectors shall be permitted inside of buildings if any of thefollowing apply:

(1) If deflagration venting is provided in accordance with the requirements of NFPA 68.

Exception No. 2: Dust collectors shall be permitted to be located inside of buildings if (2) If equipped withan explosion suppression system designed according to NFPA 69, Standard on Explosion PreventionSystems.

Exception No 10 . 3: Centrifugal separators 4.3.2 Dust collector is a centrifugal separator , without bags,used for removing moisture from coolers that handle pelleted, extruded, or flaked grain and feed productsshall be permitted inside or outside of buildings without explosion protection.

Exception No 10 .4: Bin .3.3 Bin vent dust collectors directly mounted without a hopper on a tank or bin,whose primary function is to filter air displaced during filling or blending operations and return dust directlyto the bin, shall be permitted inside or outside of buildings without explosion protection. Filters that returnair to inside of buildings shall be capable of a minimum efficiency of 0.02 g per dry standard cubic meterof airflow (0.008 grains per dry standard cubic feet of airflow).

Exception No. 5: Filters 10.4.3.4 Filters used for classifying food products with air (product purifiers) shallbe permitted to be located inside or outside of buildings without explosion protection.


Exceptions to 10.4.3 have been moved to subsection 10.4.3.X to conform with the NFPA Manual of Style.







Street Address:

City:

State:

Zip:



64 of 86 7/9/2014 2:34 PM


10.4.4.1 *At each collection point, the system shall be designed to achieve the minimum required face

velocity for dust capture over the entire opening of the hood or pickup point.

A.10.4.4.1

Proper dust collection design requires that a minimum air volume flow be maintained for each

dust collection source point (hood). This value must be determined as part of the design process.

This value should be documented to allow for field-testing to determine if the system is providing

that flow and operating properly.

This design also requires that the hood be constructed to assure that a continuous airflow is

provided at all times.

The ACGIH, Industrial Ventilation: A Manual of Recommended Practice has extensive

information on the design basis for dust collection hoods and the necessary minimum air

volumes and velocities to assure the containment, capture (i.e., collection), and control of the

aerated dusts being generated.

10.4.4.2*

The hood or pickup point for each dust source shall have a documented minimum air volume

flow based upon the system design.

A.10.4.4.2

Proper dust collection design requires that a minimum air volume flow be maintained for each

dust collection source point (e.g., hood). This value must be determined as part of the design

process. This value should be documented to allow for field-testing to determine if the system is

providing that flow and operating properly.

10.4.4.3*

Branch lines shall not be disconnected, and unused portions of the system shall not be blankedc off without providinga means to maintain required and balanced airflow.

A.10.4.4.3

Proper system design requires that airflows in the various branch lines be balanced to assure

minimum air volume flow at each dust source collection point. When a branch line is

disconnected, blanked off, or otherwise modified it changes the airflows in all the other branches

of the system. This can lead to an imbalance of air flows that result in flows below the minimum

required to keep the dust from accumulating in the ducts.

Use of manual slide or “blast” gates is not recommended. Use of such gates can lead to

uncontrolled modification of the flow volumes for both a single line and the system as a whole.

The results often lead to improper balance of the system airflows and material accumulations in

the ducts. Proper design methods inherently assure minimum airflows and duct velocities

without the use of manual slide or “blast” gates.

10.4.4.4*

The addition of branch lines shall not be made to an existing system without first confirming that

the entire system will maintain the required and balanced airflow.

A.10.4.4.4

Installation of branch lines for additional dust sources to an existing dust collection system will


65 of 86 7/9/2014 2:34 PM

result in lower air volumes and duct velocities for the existing portions of the system. Without

providing for additional system performance this can result in a system performing below the

minimum required for keeping the ducts free from material accumulations.

10.4.4.5*

Dust collection systems that remove material from operations that generate flames, sparks, or hot

material under normal operating conditions shall not be interconnected with dust collection

systems without isolation that transport combustible particulate solids or hybrid mixtures. ( See

8.8.4. )

A.10.4.4.5

Examples of operations that under normal operating conditions could generate flames, sparks,

or hot material can include grinding, saws, etc. This section is intended to segregate the

equipment and operations that are recognized ignition sources from those that are not.

10.4.4.6*

The air-material separator selected for the system shall be designed to allow for the

characteristics of the combustible dust being separated from the air or gas flow.

A.10.4.4.6

Combustible dusts vary considerably in their characteristics and the type of equipment necessary

to separate them from the conveying air or gas stream. While the typical bag or cartridge dust

collector (AMS) can be used with most combustible dusts, an exception would be most metal

dusts, which can require a scrubber or wet collector. Refer to NFPA 484, Standard for

Combustible Metals, for metal dust collection.

10.4.4.7*

Air-moving devices (AMD) shall be of appropriate type and sufficient capacity to maintain the required rate of airflow in all parts of the system.

A.10.4.4.7

The majority of dust collection systems use centrifugal fans for inducing the air flow through the

system. Various models are available that will provide the performance characteristics required.

Care must be taken to consider the worst-case situation, when the filters are nearly blinded or

the scrubber is at maximum differential, as well as the situation where the system is new during

start-up.


Suggested new sesction based on NFPA 652 - 2015 Edition - Section 8.3.3.3




Street Address:

City:

State:

Zip:



66 of 86 7/9/2014 2:34 PM


10.4.4 Construction.

All components of the dust collection system shall be constructed of noncombustible materials.

Exception: Filter 10.4.4.1 This requirement does not apply to filter bags, filter media, liners, drive belts,wear parts, and flexible connector ducts.


Exception to 10.4.4 was moved to subsection 10.4.4.1 to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



67 of 86 7/9/2014 2:34 PM


10.4.5 Manifolding.

Dust collection systems for one or more hammermills or pulverizer mills shall not be manifolded with othertypes of machinery.

Exception: Conveyors 10.4.5.1 Conveyors , sifters, and hammermills used for the sizing of oilseed mealsand hulls shall be permitted to have a common dust collection system.






Street Address:

City:

State:

Zip:



68 of 86 7/9/2014 2:34 PM


10.4.11 *

If provided, floor sweeps shall be on a separate, dedicated vacuum or dust collection system, provided thefan is located downstream of the filter.

10.4.11.1 Floor sweeps, if provided, shall be designed in accordance with NFPA 654, Standard for thePrevention of Fire and Dust Explosions form the Manufacturing, Processing and Handling of CombustibleParticulate Solids.


Suggest moving the annex material to the main body of the document as it sounds like a requirement rather than explanatory text.







Street Address:

City:

State:

Zip:



69 of 86 7/9/2014 2:34 PM


10.6.8*

The hose length and diameter shall be sized for the application and operation.

A.10.6.8

It is recommended that 1.5 in. (38.1 mm) and/or 2.0 in. (50.8 mm) I.D. hoses be used for

housekeeping purposes. It is also recommended that 25 ft (7.6 m) maximum hose length be used.

In most systems the pressure losses (i.e., energy losses) through the hose represent more than 50

percent of the overall system differential pressure requirements. Shorter hose lengths can be

used to improve system performance.

I.D. hoses of 1.5 in. (38.1 mm) are most commonly used for cleaning around equipment and for

lighter duty requirements, while 2 in. (50.8 mm) I.D. hoses are used for larger dust

accumulations and for cleaning large open areas.

10.6.9

Where ignition-sensitive materials are collected, vacuum tools shall be constructed of metal or

static dissipative materials and provide proper grounding to the hose.

A.10.6.9

Ignition-sensitive materials typically have an MIE of 30 mJ or less.


Suggested new language based on NFPA652 - 2015 Edition section 8.3.3.4.2 and 8.3.3.4.3.




Street Address:

City:

State:

Zip:



70 of 86 7/9/2014 2:34 PM


11.5.1 *

All transport modes such as railcars (hopper cars, boxcars, or tank cars) and trucks (both receiving andshipping in bulk), into which or from which commodities or products are pneumatically conveyed, shall beelectrically bonded to the plant ground system or earth grounded.

Exception: Materials 11.5.1.1 This requirement shall not apply to materials of processes involving inertmaterials, such as limestone at feed mills.






Street Address:

City:

State:

Zip:



71 of 86 7/9/2014 2:34 PM


12.4.3 *

Wet or dry standpipes shall be installed in warehouses and packing areas with combustible contents.

Exception: Bulk storage warehouses or warehouses used for other than agricultural or food productstorage.


Suggest removing this exception since warehouses storing things other than agricultural or food products is beyond the scope of NFPA 61.




Street Address:

City:

State:

Zip:



72 of 86 7/9/2014 2:34 PM


13.2.2 *

Electrical wiring and equipment in areas meeting the definition of Class II, Group G, Division 1 or 2according to Article 500 of NFPA 70, National Electrical Code, shall comply with Article 502 of that code.

Exception No. 1: Electrical 13.2.2.1 The requirements in 13.2.2 shall not apply to electrical equipmentthat has been listed and installed as intrinsically safe according to Article 504 of NFPA 70.

Exception No. 2: Electrical 13.2.2.2 The requirements in 13.2.2 shall not apply to electrical equipmentthat is housed in an enclosure that meets the applicable requirements of NFPA 496, Standard for Purgedand Pressurized Enclosures for Electrical Equipment.


Exceptions to 13.2.2 moved to separate subsections to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



73 of 86 7/9/2014 2:34 PM


13.5.3

Spark arresters shall be used on the exhaust stacks of all diesel-powered units.

Exception No. 1: Engines 13.5.3.1 The requirements in 13.5.3 shall not apply to engines equipped withturbo-chargers.

Exception No. 2: Road 13.5.3.2 The requirements in 13.5.3 shall not apply to road vehicles, such asgrain delivery vehicles, locomotives, and other vehicles that do not operate in combustible dust-producingareas.


Exceptions to 13.5.3 have been moved to separate subsections to conform with the NFPA Manual of Style.




Street Address:

City:

State:

Zip:



74 of 86 7/9/2014 2:34 PM

Public Input No. 34-NFPA 61-2014 [ Section No. A.3.3.1 ]

A.3.3.1 Agricultural Dust.

Dusts traditionally have been defined as a material 420 µm or smaller (capable of passing through a U.S.No. 40 standard sieve). Other standards have adopted the For consistancy with other standards, 500 µm(capable of passing through a U.S. No. 35 standard sieve) as the appropriate is now consideredan appropriate size criterion. For the purposes of this standard, the Committee believes that 420 µmshould be retained because of the historical data that exist. In some cases, material smaller than 420than 500 µm might not be explosible, and in some cases material larger 420 larger 500 µm might beexplosible. Explosibility can ultimately be determined by testing such as using the go/no-go explosibilityscreening test described in ASTM E 1226, Standard Test Method for Explosibility of Dust Clouds.

Any time a combustible dust is processed or handled, a potential for an explosion exists. The degreeseverity of the explosion hazard will vary depending on the type of agricultural dust and processingmethods used.

A dust explosion has the following five conditions, all of which must be met:

(1) The dust is combustible.

(2) The dust particles are in suspension.

(3) The dust particles exceed the minimum explosive concentration in air.

(4) The dust is confined within a piece of equipment, a building, or a structure.

(5) A source of ignition is present.

Evaluation of a combustible dust explosion hazard and the prevention techniques employed should bedetermined by means of actual test data. All combustible dusts that can produce a dust explosion should betested so as to determine the following data:

(1) Particle size distribution

(2) Moisture content as received and dried

(3) Minimum dust concentration to ignite

(4) Minimum energy required for ignition (joules)

(5) Maximum rate of pressure rise at various concentrations

(6) Layer ignition temperature

(7) Maximum explosion pressure at optimum concentration

Optional testing includes the following:

(1) Dust cloud ignition temperature

(2) Maximum permissible oxygen content to prevent ignition

(3) Electrical resistivity measurement


Suggested changes to annex language to be consistent with PI 33. These changes would also most the annex material consistent with NFPA 654 [Section A.3.3.5 - 2013 Edition].



Public Input No. 33-NFPA 61-2014 [Section No.3.3.1]

Changes needed to annex material if PI33 isaccepted.


75 of 86 7/9/2014 2:34 PM




Street Address:

City:

State:

Zip:



76 of 86 7/9/2014 2:34 PM


A.3.3.7 Dust Collection System.

A typical dust collection system consists of the following:

(1) Hoods — devices designed to contain, capture, and control the airborne dusts by

directing the

(1) using an induced air flow

through the fugitive dust

(1) in close proximity to the point of dust generation (local exhaust zone) to entrain fugitive airbornedusts .

(2) Ducting — piping, tubing, fabricated duct,

and so forth

(1) etc. , used to provide the controlled pathway from the hoods to the dust collector (

i.e., air-material separator

(1) AMS ). Maintaining

proper

(1) adequate duct velocity

is

(1) (usually 4000 fpm or higher) is a key factor in the proper functioning of the system.

(2) Dust collector — an AMS designed to filter the conveyed dusts from the conveying air stream.

Typically

(1) Usually these devices have automatic methods for cleaning the

filters to

(1) filter media to allow extended use without blinding. In some systems, a scrubber or similar device isused in place of the filter unit.

(2) Fan package — an

air-moving device

(1) AMD designed to induce air flow through the entire system.

The system is designed to collect only suspended dusts at the point of generation and not dusts at rest onsurfaces. The system is also not designed to convey large amounts of dusts as they system design doesnot include friction loss due to solids loading in the pressure drop calculation. Thus, material loading mustbe minimal compared to the volume or mass of air flow. [ 654 , 2013]


Suggested changes to make the annex material consistent with NFPA 654 [Section A.3.3.12 - 2013 Edition].




Street Address:


77 of 86 7/9/2014 2:34 PM

City:

State:

Zip:



78 of 86 7/9/2014 2:34 PM

Public Input No. 45-NFPA 61-2014 [ New Section after A.5.2.2 ]

A.5.2.3 (2) The system should be designed, maintained, and operated according to acceptedengineering practice, and the air-material separator efficiency should be sufficient to prevent dustin the recycled air from causing hazardous accumulations of combustible dust in any area of thebuilding.

A.5.2.3 (3) OSHA has established limits on oxygen concentration in the workplace. Permissiblelimits range from no lower than 19.5 percent by volume to no higher than 23.5 percent by volume inair. See 29 CFR, Part 1910.146.


New annex material from NFPA 654 (Section A.7.13.1.6.3 - 2013 Edition) to accompany the new proposed language for section 5.2. Associated with PI44.



Public Input No. 44-NFPA 61-2014 [Chapter 5] Associated annex material.




Street Address:

City:

State:

Zip:



79 of 86 7/9/2014 2:34 PM


A.5. 2 3 .2

If a vertical vent stack cannot be installed because of structural conditions, the vent should be permitted tobe located in the side of the bin, below its top, or should be permitted to be installed at an angle of up to 30degrees from vertical.


Renumbered the annex material to accomdate a proposed new section 5.2.



Public Input No. 44-NFPA 61-2014 [Chapter 5] Renumbering to accomdate proposed new section.




Street Address:

City:

State:

Zip:



80 of 86 7/9/2014 2:34 PM

Public Input No. 57-NFPA 61-2014 [ Section No. A.7.4.1.10 ]

A.7.4.1.10 .4

This requirement is also desirable for outside legs. The exemption for 106 m3/hr (3750 ft3/hr) represents aprocessing rate of 3000 bushels/hr. This exemption is based on reports that low belt speeds with largebuckets substantially reduce dust concentrations.


If the changes in PI56 are accepted then the reference to the annex material needed to be updated.



Public Input No. 56-NFPA 61-2014 [Section No. 7.4.1.10] Update of reference section.




Street Address:

City:

State:

Zip:



81 of 86 7/9/2014 2:34 PM


A.7.5.1 .1

Openings of 64 mm × 64 mm (2 1⁄2 in. × 2 1⁄2 in.) should be used on grating for receiving pits, to limit entry offoreign objects. Larger openings could be needed to accommodate some materials, such as wholecorncobs and hay cubes.


This language appears to be related to 7.5.1.1 rather than the whole of section 7.5.1.



Public Input No. 60-NFPA 61-2014 [Section No. 7.5] Relocated the * to align with the suggeted change.




Street Address:

City:

State:

Zip:



82 of 86 7/9/2014 2:34 PM


A.9.1.2. 1 3

Communication between hazardous and heat-producing areas should be arranged so that a fire partition,fire wall, and so forth, with all openings closed is always between the hazard and the heat-producing area.The firebreak could be a nonhazardous room, entryway, airlock, and so forth, arranged so that thecommunicating opening between the room and the hazardous area will not be open when thecommunicating opening between the room and heat-producing area is open, and vice versa.

A communicating opening such as machinery doors is permitted, provided that these doors are kept lockedand are only opened when either the hazardous area or the heat-producing area is shut down and will notcause a fire or explosion with the machinery door open.


If the rearrangement of 9.1.2 is accepted (PI66) then the reference number of the annex matrerial also needs to be changed.



Public Input No. 66-NFPA 61-2014 [Section No. 9.1.2] Change of section number.




Street Address:

City:

State:

Zip:



83 of 86 7/9/2014 2:34 PM


A.10.4.11

Floor sweeps, if used, should be designed and operated according to the provisions of Section 8.2 in NFPA654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, andHandling of Combustible Particulate Solids .


Suggest moving to main body of the document as 10.4.11.1 (see PI72).



Public Input No. 72-NFPA 61-2014 [Section No. 10.4.11] Relocated the 10.4.11.1




Street Address:

City:

State:

Zip:



84 of 86 7/9/2014 2:34 PM


A.10.4.12.1

For bin vents, see 10.4.3, Exception No . 4 3 . Return air ducts should have a method to preventexcessive dust from returning to the plant in the case of filter failure. Methods include, but are not limited to,use of a diverter valve that exhausts return air outside, or a series of secondary filters in the return air linedesigned to collect the material if part of the filter medium fails.


If the suggested changes in PI69 are accepted then the reference to exception 4 needs to be removed.



Public Input No. 69-NFPA 61-2014 [Section No. 10.4.3] Removal of Exception 4 in 10.4.3




Street Address:

City:

State:

Zip:



85 of 86 7/9/2014 2:34 PM

Public Input No. 79-NFPA 61-2014 [ Section No. F.1.2.2 ]

F.1.2.2 ASTM Publications.

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

ASTM E 1226, Standard Test Method for Explosibility of Dust Clouds, 2010 2012a .


Update the year date for standard(s)


Submitter Full Name: Steve Mawn

Organization: ASTM International

Street Address:

City:

State:

Zip:



86 of 86 7/9/2014 2:34 PM

Documents

TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS NFPA 61 … · 2016-04-04 · TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS NFPA 61 CMD-AGR (A2016) First Draft Meeting Sheraton Denver Downtown