Technical Committee on Fundamentals of Combustible Dusts (CMD-FUN)

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 Fax: 617-770-0700 www.nfpa.org Technical Committee on Fundamentals of Combustible Dusts (CMD-FUN) NFPA Headquarters 1 Batterymarch Park Quincy, MA 02169-7471 August 8 th - 11 th (Meeting will convene at 12 pm on August 8 th and adjourn at 12 pm on August 11 th.) 1. Chair s welcome, call to order, and opening remarks at 12 pm (local time, EST) 2. Self-introduction of Committee Members and Guest 3. Approval of Minutes from the May 2015 Second Draft meeting (see Attachment A) 4. Staff liaison report: review of NFPA policies and procedures, committee membership, A2018 document schedule 5. Review of Public Input 6. Review of Correlating Committee Items, Reserved sections, New material on equipment (Chapter 8) 7. New business 8. Next meeting 9. Adjourn Page 1 of 87

Address List No Phone Fundamentals of Combustible Dusts Combustible Dusts Paul F. Hart Chair American International Group, Inc. (AIG) 18257 Martin Avenue Homewood, IL 60430-2107 I 8/9/2011 CMD-FUN Elizabeth C. Buc Principal Fire & Materials Research Laboratory, LLC 33025 Industrial Road Livonia, MI 48150-1619 07/11/2016 Susan Bershad CMD-FUN RT 8/9/2011 CMD-FUN Brad D. Burridge Principal Novelis, Inc. 639 Players Crossing Way Bowling Green, KY 42104 U 03/05/2012 CMD-FUN Brice Chastain Principal Georgia-Pacific LLC 133 Peachtree Street NE, 9th Floor Atlanta, GA 30303 Alternate: Richard F. Masta U 8/9/2011 CMD-FUN John M. Cholin Principal J. M. Cholin Consultants Inc. 101 Roosevelt Drive Oakland, NJ 07436 Alternate: Marc T. Hodapp SE 8/9/2011 CMD-FUN Tom Christman Principal 818 Brochardt Boulevard Knoxville, TN 37934 SE 8/9/2011 CMD-FUN Randal R. Davis Principal IEP Technologies 417-1 South Street Marlborough, MA 01752-3149 Alternate: David Grandaw M 03/05/2012 CMD-FUN Mark W. Drake Principal Liberty Mutual 14125 West 139th Street Olathe, KS 66062-5885 Alternate: Robert C. Berry I 8/9/2011 CMD-FUN Robert J. Feldkamp Principal Nordson Corporation 300 Nordson Drive Amherst, OH 44001 Alternate: Edward L. Jones M 03/05/2012 CMD-FUN Walter L. Frank Principal Frank Risk Solutions, Inc. 1110 Shallcross Avenue Wilmington, DE 19806 SE 8/9/2011 CMD-FUN Robert C. Gombar Principal Baker Engineering & Risk Consultants, Inc. 707 Hardwood Lane Annapolis, MD 21401-4570 US Beet Sugar Association Alternate: Philip J. Parsons U 8/9/2011 CMD-FUN Dale C. Hansen Principal Harrington Group, Inc. 2400 Meadowbrook Parkway, Suite 250 Duluth, GA 30096 SE 03/05/2012 CMD-FUN David M. House Principal I.C. Thomasson Associates, Inc. 2950 Kraft Drive, Suite 500 Nashville, TN 37204-3683 SE 03/05/2012 CMD-FUN James F. Koch Principal The Dow Chemical Company 1400 Building Midland, MI 48667 American Chemistry Council Alternate: Glenn W. Baldwin U 03/05/2012 CMD-FUN Page 2 of 87 1

Address List No Phone Fundamentals of Combustible Dusts Combustible Dusts Bruce McLelland Principal Fike Corporation 704 SW 10th Street Blue Springs, MO 64015-4263 Alternate: Jérôme R. Taveau M 10/18/2011 CMD-FUN Timothy J. Myers Principal Exponent, Inc. 9 Strathmore Road Natick, MA 01760-2418 07/11/2016 Susan Bershad CMD-FUN SE 8/9/2011 CMD-FUN Jim E. Norris Principal Bunge North America 11720 Borman Drive PO Box 28500 St. Louis, MO 63146-1000 International Oil Mill Superintendents Assn. U 03/05/2012 CMD-FUN Jack E. Osborn Principal Airdusco, Inc. 4739 Mendenhall Road South Memphis, TN 38141-8202 M 8/9/2011 CMD-FUN Niels H. Pedersen Principal Nederman LLC PO Box 429 Thomasville, NC 27361-0429 M 03/07/2013 CMD-FUN Jason P. Reason Principal Lewellyn Technology 2518 Thorium Drive, Apt 3 Greenwood, IN 46143 SE 8/9/2011 CMD-FUN Samuel A. Rodgers Principal Honeywell, Inc. 15801 Woods Edge Road Colonial Heights, VA 23834-6059 U 8/9/2011 CMD-FUN Steve Sallman Principal United Steelworkers Health, Safety & Environment 60 Boulevard of the Allies Pittsburgh, PA 15222 L 8/9/2011 CMD-FUN Thomas C. Scherpa Principal DuPont 71 Valley Road Sullivan, NH 03445 U 8/9/2011 CMD-FUN Denise N. Statham Principal VF Imagewear/Bulwark Protective Apparel 545 Marriott Drive Nashville, TN 37214 M 10/18/2011 CMD-FUN Bill Stevenson Principal CV Technology, Inc. 15852 Mercantile Court Jupiter, FL 33478 Alternate: Jason Krbec M 8/9/2011 CMD-FUN Robert D. Taylor Principal PRB Coal Users Group 4377 Sandra Kay Lane Newburgh, IN 47630-8596 U 8/9/2011 CMD-FUN Erdem A. Ural Principal Loss Prevention Science & Technologies, Inc. 2 Canton Street, Suite A2 Stoughton, MA 02072 SE 03/05/2012 CMD-FUN Robert G. Zalosh Principal Firexplo 20 Rockland Street Wellesley, MA 02481 SE 8/9/2011 CMD-FUN Page 3 of 87 2

Address List No Phone Fundamentals of Combustible Dusts Combustible Dusts Glenn W. Baldwin Alternate The Dow Chemical Company PO Box 8361 South Charleston, WV 25303 American Chemistry Council Principal: James F. Koch U 03/07/2013 CMD-FUN Robert C. Berry Alternate Liberty Mutual Insurance Company 1508 Beech Circle Wilkesboro, NC 28697-2602 Principal: Mark W. Drake 07/11/2016 Susan Bershad CMD-FUN I 10/29/2012 CMD-FUN David Grandaw Alternate IEP Technologies 2015 Bluemist Drive Aurora, IL 60504 Principal: Randal R. Davis M 10/29/2012 CMD-FUN Marc T. Hodapp Alternate JENSEN HUGHES 703 South Milton Avenue Baltimore, MD 21224-3755 JENSEN HUGHES Principal: John M. Cholin SE 08/17/2015 CMD-FUN Edward L. Jones Alternate Nordson Corporation 300 Nordson Drive, M/S 42 Amherst, OH 44001 Principal: Robert J. Feldkamp M 03/05/2012 CMD-FUN Jason Krbec Alternate CV Technology, Inc. 15852 Mercantile Court Jupiter, FL 33478 Principal: Bill Stevenson M 10/29/2012 CMD-FUN Richard F. Masta Alternate Georgia-Pacific LLC 133 Peachtree Street, 7th Floor Atlanta, GA 30303 Principal: Brice Chastain U 8/9/2011 CMD-FUN Philip J. Parsons Alternate Baker Engineering & Risk Consultants, Inc. 319 Stieren Street San Antonio, TX 78210-1154 US Beet Sugar Association Principal: Robert C. Gombar U 08/17/2015 CMD-FUN Jérôme R. Taveau Alternate Fike Corporation 704 SW 10th Street Blue Springs, MO 64015-4263 Principal: Bruce McLelland M 03/07/2013 CMD-FUN William R. Hamilton Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3609 Washington, DC 20210 E 10/18/2011 CMD-FUN Susan Bershad Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA 02169-7471 04/16/2014 CMD-FUN Page 4 of 87 3

COMMITTEE ON FUNDAMENTALS OF COMBUSTIBLE DUSTS TO: FROM: COMMITTEE ON FUNDAMENTALS OF COMBUSTIBLE DUSTS G. R. Colonna, Staff Liaison DATE: October 7, 2014 SUBJ: Minutes of NFPA 652 Second Draft Meeting (Continuation), May 12 16, 2014 I. Attendance: (remote attendance noted) Members and Alternates: Paul Hart, Chair, AIG, IL Glenn Baldwin, The Dow Chemical Company, WV (representing ACC) Robert Bitter, Honeywell, Inc., MO (remote attendance) Elizabeth Buc, Fire & Materials Research Laboratory, LLC, MI (remote attendance) Brad Burridge, Novelis, Inc., KY John M. Cholin, J.M. Cholin Consultants Inc., NJ Randall Davis, Fenwal-IEP Technologies, MA Lee DeVito, FIREPRO Incorporated, MA Mark Drake, Liberty Mutual, KS Robert Gombar, Baker Engineering & Risk Consultants, Inc., MD (representing US Beet Sugar Association) (remote attendance) Dale Hansen, Harrington Group, Inc., GA (representing Mars Inc.) David House, I.C. Thomasson Associates, Inc., TN Edward Jones, Nordson Corporation, OH James Koch, The Dow Chemical Company, MI (representing ACC) Richard Masta, Georgia-Pacific LLC, GA (remote attendance) Arthur Mattos, XL Global Asset Protection Services, NC Timothy Myers, Exponent, Inc., Natick, MA (remote attendance) Jim Norris, Bunge North America, MO (International Oil Mill Superintendents Assn.) Jack E. Osborn, Airdusco, Inc., TN Niels Pedersen, Nederman LLC, NC Jason Reason, Lewellyn Technology, IN (remote attendance) Samuel Rodgers, Honeywell, Inc., VA (remote attendance) Steve Sallman, United Steelworkers, PA Thomas Scherpa, DuPont, NH (remote attendance) Denise Statham, VF Imagewear/Bulwark Protective Apparel, TN (remote attendance) Bill Stevenson, CV Technology, Inc., FL Robert Taylor, PRB Coal Users' Group, IN Page 5 of 87

CMD-FUN Meeting Minutes May 12-16, 2014; Rosemont, IL Erdem Ural, Loss Prevention Science & Technologies, Inc., MA (remote attendance) Robert Zalosh, Firexplo, MA Susan Bershad, NFPA, Staff Liaison Guests: Chris Aiken, Cargill, Inc., MN Merrill Childs, Cargill, Inc. Guy Colonna, NFPA, MA Ryan Essex, HDR Inc., IL/WI Henry Febo, FM Global, MA (remote attendance) Vincent Giordano, General Electric (remote attendance) Sheila Glesmann, ADA Carbon Solutions, (representing ICAC) (remote attendance) Steve Kroon, Kroon LLC, IN II. Minutes of Meeting 1. The Chair called the meeting to order at 12:22 p.m., Monday, May 12, 2014. He welcomed the members and guests and asked staff to conduct a roll-call of attendees. He then outlined the agenda for the meeting, which is to serve as a continuation of the April conference call meetings, with the work on the agenda to begin with Public Comment 596 related to Chapter 8 content, as Chapter 7, Chapter 9 and some Annex A items were addressed during the conference call meetings. Prior to starting on the Public Comments and Second Revisions, the Committee was asked to consider the minutes from the prior meetings (face-to-face March 12 14 and conference call/web meetings April 15 and 28. A motion was made and approved to accept the minutes for those meetings as written. 2. The Committee worked through all items pertaining to Chapter 8, Annex A and other annex items, before returning to items that were tabled for review by Task Groups. Task Groups on the following shared their recommendations with the Committee: use of the terms enclosure and compartment ; use of term dust deflagration hazard ; Figure 1.3.1; and A.4.2.1.1. At the close of the April 28 remote meeting, members of the task group responsible for developing annex language for A.4.2.1.1 recommended discussing their proposed text. As a reminder, their work stems from action at the initial First Draft meeting related to several Public Comments and remains an open item in terms of creating a Second Revision. However, in discussion at the April 28 th meeting, it was requested that the text be included with the meeting minutes so that in preparation for the May 12 16 meeting in Chicago, the full Committee could be prepared to take any appropriate action on this task group language. The proposed text included in the minutes is as follows: Related to Annex A.4.2.1.1; PC 165, 103, 203, 205, 393, 394 [Possible SR] A.4.2.1.1 Given the fast acting nature of flash fire, deflagration, and explosions the stated Life Safety Objective recognizes the difficulty if not the impossibility of protecting occupants in the immediate proximity of the ignition and thus the stated objective is to protect occupants not in the immediate proximity of ignition. 2 Page 6 of 87

CMD-FUN Meeting Minutes May 12-16, 2014; Rosemont, IL However, all available practices should be employed to ensure the safety of all persons both near and far from the ignition. An example of this might be the standard s prescriptive exception relative to the less than 8 cu. ft. air-material separator not requiring protection; however the intent of the Objective is to consider the effect of deflagration to occupants in the immediate area of the small air-material separator and mitigate this hazard if possible. Likewise the standard has not defined immediate proximity in that this could mean within just feet of the hazard or within the same building or structure and leaves that judgment to the AHJ. The intent of the Objective is to employ all available and reasonable protection, techniques, and practices to protect all occupants understanding that it might not always be achievable. As a reminder, the Chair formed the four task groups as listed below during the January meeting; the tasks and task group members are listed in the table below: Chapter 3, enclosure, compartment, and similar, various PC Chapter 3, Dust Deflagration Hazard, PC 17 Chapter 3, dilute phase conveying, PC 175 and 243 Chapter 4, Annex for 4.2.1.1 Sam Rodgers Dale Hansen Jim Koch Bob Bitter Tim Myers Walt Frank Todd Baker Tom Scherpa Paul Hart Tom Scherpa Bill Stevenson Dale Hansen Dave House Chuck Duthler Jack Osborn Bob Taylor The task group working on a definition for dilute phase conveying proposed revised text for Chapter 8 instead; the Committee acted on the proposed text as part of a Second Revision action. Completion by the task groups on the remaining Chapter 3 items enclosure/compartment and dust deflagration hazard enabled the Committee to address the related open agenda items. 3. Staff agreed to update the Word draft of the standard to show the Second Revisions based on the completion of action on all Public Comments. 4. Next Meeting. As this meeting completed the Second Draft stage of the development process for NFPA 652, there are no more scheduled meetings of the Fundamentals Committee at this stage. The next step in the process will be preparation of the letter ballot and its distribution to the Committee. 5. There being no further business, the meeting was adjourned at 4:45 p.m., Friday, May 16, 2014. Respectfully submitted, G. R. Colonna, Staff Liaison Page 7 of 87 3

Process Stage Comment Stage (Second Draft) 2018 ANNUAL REVISION CYCLE * Public Input Closing 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 Next Edition tab. Public Input Stage (First Draft) Process Step Dates for TC Dates for TC with CC Public Input Closing Date 6/29/2016 6/29/2016 Final date for TC First Draft Meeting 12/7/2016 9/7/2016 Posting of First Draft and TC Ballot 1/25/2017 10/19/2016 Final date for Receipt of TC First Draft ballot 2/15/2017 11/9/2016 Final date for Receipt of TC First Draft ballot recirc 2/22/2017 11/16/2016 Posting of First Draft for CC Meeting 11/23/2016 Final date for CC First Draft Meeting 1/4/2017 Posting of First Draft and CC Ballot 1/25/2017 Final date for Receipt of CC First Draft ballot 2/15/2017 Final date for Receipt of CC First Draft ballot recirc 2/22/2017 Post First Draft Report for Public Comment 3/1/2017 3/1/2017 Public Comment closing date 5/10/2017 5/10/2017 Notice published on Consent Standards (Standards that receive No Comments). Note: Date varies and determined via TC ballot. Appeal Closing Date for Consent Standards (15 Days) (Standards That Received No Comments) Final date for TC Second Draft Meeting 11/8/2017 8/2/2017 Posting of Second Draft and TC Ballot 12/20/2017 9/13/2017 Final date for Receipt of TC Second Draft Ballot 1/10/2018 10/4/2017 Final date for receipt of TC Second Draft ballot recirc 1/17/2018 10/11/2017 Posting of Second Draft for CC Mtg 10/18/2017 Final date for CC Second Draft Meeting 11/29/2017 Posting of Second Draft for CC Ballot 12/20/2017 Final date for Receipt of CC Second Draft ballot 1/10/2018 Final date for Receipt of CC Second Draft ballot recirc 1/17/2018 Post Second Draft Report for NITMAM Review 1/24/2018 1/24/2018 Tech Session Preparation (& Issuance) Notice of Intent to Make a Motion (NITMAM) Closing Date 2/21/2018 2/21/2018 Posting of Certified Amending Motions (CAMs) and Consent Standards 4/4/2018 4/4/2018 Appeal Closing Date for Consent Standards (15 Days after posting) 4/19/2018 4/19/2018 SC Issuance Date for Consent Standards (10 Days) 4/29/2018 4/29/2018 Tech Session Association Meeting for Standards with CAMs 6/4 7/2018 6/4 7/2018 Appeals and Issuance Appeal Closing Date for Standards with CAMs (20 Days after ATM) 6/27/2018 6/27/2018 Council Issuance Date for Standards with CAMs* 8/14/2018 8/14/2018 Page 8 of 87

of 68 7/11/2016 3:16 PM Public Input No. 25-NFPA 652-2016 [ Global Input ] This standard was approved on September 7, 2015, less than one year ago. We believe this standard as written generally provides useful procedures for evaluating the combustibility and explosibility of a dust, and would discourage any substantive changes to the existing language at this time. Our Statement is not a problem - we are encouraging continuation of the standard as it is written without substantive changes. Submitter Full Name: Kelley Green Organization: Texas Cotton Ginners' Association Submittal Date: Wed Jun 22 10:22:40 EDT 2016 Page 9 of 87

of 68 7/11/2016 3:16 PM Public Input No. 9-NFPA 652-2016 [ Global Input ] When referring to the housekeeping of dust-layers that have accumulated on surfaces, replace all references to "cleaning surfaces" with "removal of dust from surfaces". The use of "cleaning" does not clearly identify that the dust-layer on a surface should not just be dispersed into the air to settle and accumulate elsewhere within the local area. Submitter Full Name: Joe Aiken Organization: Safety Solutions Ltd. Submittal Date: Wed May 04 19:46:39 EDT 2016 Page 10 of 87

of 68 7/11/2016 3:16 PM Public Input No. 29-NFPA 652-2016 [ New Section after 1.3.3 ] A.1.3.3(4) Warehousing includes the storage of bags, super-sacks, or other containers of combustible dusts where no processing or handling of the dusts is performed, except for moving closed containers or loaded pallets. If the business activity of the facility or specific areas of the facility are confined to strictly warehousing, then the standard does not apply. However, if the facility is processing or handling the dusts outside of the closed containers (e.g. opening containers and dispensing dusts), then the facility is required to meet all of all of the applicable requirements of this standard. The term "warehousing" in Section 1.3.3(4) is somewhat confusing and is not clear when storage areas are or are not covered under NFPA 652. Thus, annex material is needed to further explain the committee's intent of which facilities or areas of the facility are not covered under the scope and application of NFPA 652. Submitter Full Name: Jason Reason Organization: Lewellyn Technology Submittal Date: Fri Jun 24 18:49:15 EDT 2016 Page 11 of 87

of 68 7/11/2016 3:16 PM Public Input No. 62-NFPA 652-2016 [ Section No. 1.4.1 ] 1.4.1* For the purposes of this standard, the industry- or commodity-specific NFPA standards shall include the following: (1) NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities (2) NFPA 484, Standard for Combustible Metals (3) NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids (4) NFPA 655, Standard for Prevention of Sulfure Sulfur Fires and Explosions (5) NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities Fixing typographical error. Submitter Full Name: Timothy Myers Organization: Exponent Inc Submittal Date: Wed Jun 29 18:40:43 EDT 2016 Page 12 of 87

of 68 7/11/2016 3:16 PM Public Input No. 4-NFPA 652-2016 [ Section No. 2.3.2 ] 2.3.2 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM E1226, Standard Test Method for Explosibility of Dust Clouds, 2012a. ASTM E1515, Standard Test Method for Minimum Explosible Concentration of Combustible Dusts, 2007 2014. Date updates. Submitter Full Name: Timothy Earl Organization: GBH International Submittal Date: Tue Jan 05 10:02:43 EST 2016 Page 13 of 87

of 68 7/11/2016 3:16 PM Public Input No. 63-NFPA 652-2016 [ New Section after 3.1 ] Explosible Definition 3.3.X Explosible. A finely-divided combustible particulate solid that can propagate a deflagration when dispersed in air or the processspecific oxidizing media as determined in the screening tests described in Section 5.4.3 The term explosible is used in this and other NFPA combustible dust standards and a uniform definition should be developed. NFPA 68 includes an alternative definition and another definition is being proposed by the NFPA 484 technical committee. Submitter Full Name: Timothy Myers Organization: Exponent Inc Submittal Date: Wed Jun 29 18:48:03 EDT 2016 Page 14 of 87

of 68 7/11/2016 3:16 PM Public Input No. 67-NFPA 652-2016 [ New Section after 3.3 ] Extracted from section 3.3.29 of NFPA 61 3.3.X Point-of-Use Dust Collector. A bin vent type of dust collector with an integral AMD used to create negative pressure on enclosed conveying equipment. Point of use dust collectors are seeing increased use in a variety of industries. This definition is complimentary to the proposed section on these collectors. Related Public Inputs for This Document Related Input Public Input No. 66-NFPA 652-2016 [New Section after 8.3.5.3] Relationship The defined term is used in this requirement. Submitter Full Name: Timothy Myers Organization: Exponent Inc Submittal Date: Wed Jun 29 19:20:08 EDT 2016 Page 15 of 87

of 68 7/11/2016 3:16 PM Public Input No. 30-NFPA 652-2016 [ New Section after 3.3.28 ] 3.3.x Material modification. A modification that changes the original design of the equipment or process, or that changes the explosibility properties of the contents of the equipment. Section 7.1.2.1 of the standard is unclear as to what constitutes a material modification. This definition will add clarity. Submitter Full Name: Marie Gargas Organization: SPI: The Plastics Industry Trade Association Affilliation: SPI: The Plastics Industry Trade Association Submittal Date: Mon Jun 27 11:04:01 EDT 2016 Page 16 of 87

of 68 7/11/2016 3:16 PM Public Input No. 28-NFPA 652-2016 [ Section No. 4.2 ] 4. 2 Objectives 2 Objectives. * 4.2.1 Life Safety. The design of the facility, processes and equipment shall be based upon the goal of providing a reasonable level of safety and property protection by meeting the following objectives: (1) Life safety (2) Mission continuity (3) Mitigation of fire spread and explosions 4.2.1.1 The facility, processes, and equipment shall be designed, constructed, equipped, and maintained and management systems shall be implemented to reasonably protect occupants not in the immediate proximity of the ignition from the effects of fire for the time needed to evacuate, relocate, or take refuge. The objectives stated in Section 4.2 shall be interpreted as intended outcomes of this standard and not as prescriptive requirements. 4.2.1.2 The objectives stated in Section 4.2 shall be deemed to be met when, consistent with the goal in Section 4.2.1.2 The and the provisions in Sections 1.4 and 1.5, the following has been achieved:, (1) T he facility, processes and equipment shall be are designed, constructed, equipped, and maintained and management systems shall be implemented to reasonably prevent serious injury from flash fires and maintained in accordance with the prescriptive criteria set forth in this standard. (2) The management systems set forth in this standard are implemented. 4.2.1.3 The facility, processes, and equipment shall be designed, constructed, equipped, and maintained and management systems shall be implemented to reasonably prevent injury from explosions Where a performance-based alternative design is used, it shall be documented to meet the same objectives as the prescriptive design it replaces, in accordance with Chapter 6 of this standard. 4.2. 1.4 The structure shall be located, designed, constructed, and maintained to reasonably protect adjacent properties and the public from the effects of fire, flash fire, or explosion 2 Life Safety. The life safety objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.5, the occupants not in the immediate proximity of the ignition are protected from the effects of fires, flash-fires, and explosions for the time needed to evacuate, relocate, or take refuge in order to prevent serious injury. 2 4.2. 3 * Mission Mission Continuity. The facility, processes, and equipment shall be designed, constructed, equipped, and maintained and management systems shall be implemented to The mission continuity objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.5, the protection features for the facility, processes and equipment limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. A. 4.2. 3 * Mitigation 3 Other stakeholders could also have mission continuity goals that will necessitate more stringent objectives as well as more specific and demanding performance criteria. The protection of property beyond maintaining structural integrity long enough to escape is actually a mission continuity objective. Page 17 of 87

0 of 68 7/11/2016 3:16 PM The mission continuity objective encompasses the survival of both real property, such as the building, and the production equipment and inventory beyond the extinguishment of the fire. Traditionally, property protection objectives have addressed the impact of the fire on structural elements of a building as well as the equipment and contents inside a building. Mission continuity is concerned with the ability of a structure to perform its intended functions and with how that affects the structure's tenants. It often addresses post-fire smoke contamination, cleanup, and replacement of damaged equipment or raw materials. 4.2.4* Mitigation of Fire Spread and Explosions. The facility and processes The mitigation of fire spread and explosions shall be designed to deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.5, the prescribed or performance based alternative design features are incorporated into the facility and processes to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments, or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility s facility's structural elements. A. 4.2.4 * Compliance Options. The objectives in Section Adjacent compartments share a common enclosure surface (wall, ceiling, floor) with the compartment of fire or explosion origin. The intent is to prevent the collapse of the structure during the fire or explosion. 4.2.5* Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means: (1) A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any prescriptive provisions of applicable commodity-specific NFPA standards. Chapter 6 Chapter 6. 5 6 A. 4.2. (2) A performance-based approach in accordance with 5 Usually a facility or process system is designed using the prescriptive criteria until a prescribed solution is found to be infeasible or impracticable. Then the designer can use the performance-based option to develop a design, addressing the full range of fire and explosion scenarios and the impact on other prescribed design features. Consequently, facilities are usually designed not by using performance-based design methods for all facets of the facility but rather by using a mixture of both design approaches as needed. 4.2.6 Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard. 4.2. 7 Where a dust fire, deflagration, or explosion hazard exists within a building or building facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard. Additional Proposed Changes File Name Description Approved USBSA_4.2_changes.docx Attached word file of the complete public input to assist. This revision would implement a decision by the Correlating Committee on Combustible Dusts. In November 2014, the Correlating Committee set up an Objectives Task Group to examine aligning the Objectives provisions for all of the combustible dust standards. The Objectives Task Group had members representing the following NFPA combustible dust standards: 61, 484, 652, 654, and 664. In January 2015, the Correlating Committee reviewed the work product of the Objectives Task Group and created a Correlating Committee Note containing a document with the Objectives language developed by the Objectives Task Group. The Objectives language being recommended in this public comment is the language developed by the Objectives Task Group, and is being submitted solely to implement the intent of the Correlating Committee and the work of its Task Group. Submitter Full Name: Arthur Sapper Organization: McDermott Will Emery Llp Page 18 of 87

1 of 68 7/11/2016 3:16 PM Submittal Date: Fri Jun 24 13:06:47 EDT 2016 Page 19 of 87

Public Comment No. -NFPA 652-2016 [Section 4.2] 4.2 Objectives. 4.2.1 Life Safety. 4.2.1.1* The facility, processes and equipment, shall be designed, constructed, equipped, and maintained and management systems shall be implemented to reasonably protect occupants not in the immediate proximity of the ignition from the effects of fire for the time needed to evacuate, relocate, or take refuge. 4.2.1.2 The facility, processes and equipment shall be designed, constructed, equipped, and maintained and management systems shall be implemented to reasonably prevent serious injury from flash fires. 4.2.1.3 The facility, processes and equipment shall be designed, constructed, equipped, and maintained and management systems shall be implemented to reasonably prevent serious injury from explosions. 4.2.1.4 The structure shall be located, designed, constructed, and maintained to reasonably protect adjacent properties and the public from the effects of fire, flash fire, or explosion. 4.2.2* Mission Continuity. The facility, processes and equipment shall be designed, constructed, equipped, and maintained and management systems shall be implemented to limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. 4.2.3* Mitigation of Fire Spread and Explosions. The facility and processes shall be designed to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility's structural elements. 4.2.4* Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means: (1) A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any prescriptive provisions of applicable commodity-specific NFPA standards. (2) A performance-based approach in accordance with Chapter 6. 4.2.5 Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard. 1 Page 20 of 87

4.2.6 Where a dust fire, deflagration, or explosion hazard exists within a building or building compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard. 4.2 Objectives. 4.2.1 The design of the facility, processes and equipment shall be based upon the goal of providing a reasonable level of safety and property protection by meeting the following objectives: (1) Life safety (2) Mission continuity (3) Mitigation of fire spread and explosions 4.2.1.1 The objectives stated in Section 4.2 shall be interpreted as intended outcomes of this standard and not as prescriptive requirements. 4.2.1.2 The objectives stated in Section 4.2 shall be deemed to be met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.5, the following has been achieved: (1) The facility, processes and equipment are designed, constructed and maintained in accordance with the prescriptive criteria set forth in this standard. (2) The management systems set forth in this standard are implemented. 4.2.1.3 Where a performance-based alternative design is used, it shall be documented to meet the same objectives as the prescriptive design it replaces, in accordance with Chapter 6 of this standard. 4.2.2 Life Safety. The life safety objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.5, the occupants not in the immediate proximity of the ignition are protected from the effects of fires, flash-fires, and explosions for the time needed to evacuate, relocate, or take refuge in order to prevent serious injury. 4.2.3* Mission Continuity. The mission continuity objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.5, the protection features for the facility, processes and equipment limit damage 2 Page 21 of 87

to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. A.4.2.3 Other stakeholders could also have mission continuity goals that will necessitate more stringent objectives as well as more specific and demanding performance criteria. The protection of property beyond maintaining structural integrity long enough to escape is actually a mission continuity objective. The mission continuity objective encompasses the survival of both real property, such as the building, and the production equipment and inventory beyond the extinguishment of the fire. Traditionally, property protection objectives have addressed the impact of the fire on structural elements of a building as well as the equipment and contents inside a building. Mission continuity is concerned with the ability of a structure to perform its intended functions and with how that affects the structure's tenants. It often addresses post-fire smoke contamination, cleanup, and replacement of damaged equipment or raw materials. 4.2.4* Mitigation of Fire Spread and Explosions. The mitigation of fire spread and explosions shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.5, the prescribed or performance based alternative design features are incorporated into the facility and processes to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments, or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility's structural elements. A.4.2.4 Adjacent compartments share a common enclosure surface (wall, ceiling, floor) with the compartment of fire or explosion origin. The intent is to prevent the collapse of the structure during the fire or explosion. 4.2.5* Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means: (1) A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any prescriptive provisions of applicable commodity-specific NFPA standards. (2) A performance-based approach in accordance with Chapter 6. 3 Page 22 of 87

A.4.2.5 Usually a facility or process system is designed using the prescriptive criteria until a prescribed solution is found to be infeasible or impracticable. Then the designer can use the performance-based option to develop a design, addressing the full range of fire and explosion scenarios and the impact on other prescribed design features. Consequently, facilities are usually designed not by using performance-based design methods for all facets of the facility but rather by using a mixture of both design approaches as needed. 4.2.6 Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard. 4.2.7 Where a dust fire, deflagration, or explosion hazard exists within a facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard. Statement of Problem and Substantiation for Public Comment This revision would implement a decision by the Correlating Committee on Combustible Dusts. In November 2014, the Correlating Committee set up an Objectives Task Group to examine aligning the Objectives provisions for all of the combustible dust standards. The Objectives Task Group had members representing the following NFPA combustible dust standards: 61, 484, 652, 654, and 664. In January 2015, the Correlating Committee reviewed the work product of the Objectives Task Group and created a Correlating Committee Note containing a document with the Objectives language developed by the Objectives Task Group. The Objectives language being recommended in this public comment is the language developed by the Objectives Task Group, and is being submitted solely to implement the intent of the Correlating Committee and the work of its Task Group. Submitter Full Name: ARTHUR SAPPER Organization: for the United States Beet Sugar Association 4 Page 23 of 87

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2 of 68 7/11/2016 3:16 PM Public Input No. 21-NFPA 652-2016 [ Section No. 5.2.1 ] 5.2.1 The determination of combustibility or explosibility shall be permitted to be based upon either of the following: (1) Historical facility data or published data that are deemed to be representative of current materials and process conditions (2) Analysis of representative samples in accordance with the requirements of 5.4.1 and 5.4.3 This section is very important for industries with dusts that are essentially identical, and should be maintained as written. There is no problem with this section - we are supporting the section as written. Submitter Full Name: Kelley Green Organization: Texas Cotton Ginners' Association Submittal Date: Wed Jun 22 09:57:45 EDT 2016 Page 25 of 87

3 of 68 7/11/2016 3:16 PM Public Input No. 22-NFPA 652-2016 [ Section No. 5.4.1.1 ] 5.4.1.1 Where the combustibility is not known, determination of combustibility shall be determined by one of the following tests: (1) A screening test based on the UN Recommendations on the Transport of Dangerous Goods: Model Regulations Manual of Tests and Criteria, Part III, Subsection 33.2.1, Test N.1, Test Method for Readily Combustible Solids (2) Other equivalent fire exposure test methods There is no problem with this section - we are supporting the section as written. Submitter Full Name: Kelley Green Organization: Texas Cotton Ginners' Association Submittal Date: Wed Jun 22 09:58:40 EDT 2016 Page 26 of 87

4 of 68 7/11/2016 3:16 PM Public Input No. 23-NFPA 652-2016 [ Section No. 5.4.3.1 ] 5.4.3.1 Where the explosibility is not known, determination of explosibility of dusts shall be determined according to one of the following tests: (1) The Go/No-Go screening test methodology described in ASTM E1226, Standard Test Method for Explosibility of Dust Clouds (2) ASTM E1515, Standard Test Method for Minimum Explosible Concentration of Combustible Dusts (3) An equivalent test methodology This section should be maintained as written. It provides important information for determination of explosbility. The issue of over-driven results when the 20 L sphere is used is further discussed in published peer reviewed papers by B. Ganesan et al and AnnMarie Fauske. (Ganesan, B., Parnell Jr., C. B., McGee, R. O., & Faulkner, W.B (2015); A critical evaluation of explosible dust testing methods: Part II. Applied Engineering in Agriculture, Vol 31(2) 203-209. http://elibrary.asabe.org/abstract.asp?aid=45458&t=1&redir=aid=45458&confalias=&redir= [volume=31&issue=2&conf=aeaj&orgconf=aeaj2015]&redirtype=toc_journals.asp&redirtype=toc_journals.asp), and (Fauske, A (2014) Combustible Dust Basics, Part 3: What is Overdriving? http://blog.fauske.com/blog/bid/381834/combustible-dust-basics-part-3-what-is- Overdriving). Submitter Full Name: Kelley Green Organization: Texas Cotton Ginners' Association Submittal Date: Wed Jun 22 09:59:28 EDT 2016 Page 27 of 87

5 of 68 7/11/2016 3:16 PM Public Input No. 64-NFPA 652-2016 [ New Section after 5.5.3 ] Sample preservation 5.X.X Samples that may oxidize or degrade in the presence of air shall be maintained in suitable inert gas or vacuum packaging until tested. Some materials can oxidize or degrade in air changing their combustibility or explosibility characteristics and should be appropriately preserved between sampling and testing. Submitter Full Name: Timothy Myers Organization: Exponent Inc Submittal Date: Wed Jun 29 19:00:44 EDT 2016 Page 28 of 87

6 of 68 7/11/2016 3:16 PM Public Input No. 38-NFPA 652-2016 [ Section No. 7.1.2 ] 7.1.2 (new 7.1. 2 * and move existing 7.1.2, etc., accordingly) A DHA shall be completed for all new processes and facility compartments. 7.1.3* The requirements of Chapter 7 shall apply retroactively in accordance with 7.1.2.1 through 7.1.2.3. 7.1.2 3.1 For existing processes and facility compartments that are undergoing material modification, the owner/operator shall complete DHAs as part of the project. 7.1.2 3.2* For existing processes and facility compartments that are not undergoing material modification, the owner/operator shall schedule and complete DHAs of existing processes and facility compartments within a 3-year period from the effective date of the standard. The owner/operator shall demonstrate reasonable progress in each of the 3 years. 7.1.2 3.3 For the purposes of applying the provisions of 7.1.2, material modification shall include modifications or maintenance and repair activities that exceed 25 percent of the original cost. Although the requirement for a DHA for new processes and facility compartments are "implied" by 5.1 and 5.1.1, it is not specifically required in chapter 7. Such a requirement should not be implied but specifically stated to assure there is no doubt as to the necessity of the DHA for new processes, etc. Submitter Full Name: Jack Osborn Organization: Airdusco, Inc. Submittal Date: Tue Jun 28 07:45:44 EDT 2016 Page 29 of 87

7 of 68 7/11/2016 3:16 PM Public Input No. 58-NFPA 652-2016 [ New Section after 7.1.2.3 ] 7.1.2.4. The absence of previous incidents shall not be used as the basis for not performing a DHA. This requirement is needed because all too often facilities will incorrectly use the fact that no incidents have occurred as basis for not assessing and mitigating potential combustible dust hazards. These facilities have no idea what hazards are present at their facilities and incorrectly use the lack of an incident as justification for not performing a DHA. This requirement clarifies the need to perform a DHA, regardless of whether incidents have occurred or not, at each facility covered under NFPA 652. Submitter Full Name: Jason Reason Organization: Lewellyn Technology Submittal Date: Tue Jun 28 17:04:17 EDT 2016 Page 30 of 87

8 of 68 7/11/2016 3:16 PM Public Input No. 39-NFPA 652-2016 [ Section No. 7.1.2.3 ] 7.1.2.3 For the purposes of applying the provisions of 7.1.2, material modification shall include modifications or maintenance and repair activities that exceed 25 percent of the original replacement cost. The original cost of a system and/or equipment 20 or more years old can be a very small fraction of the actual present costs (in comparison). Thus, small changes in a system can result in a requirement for a DHA. Such small changes (e.g. duct changes in a dust collection system, or changes in the discharge of the collected material in the dust collector) are adequately covered by Management of Change requirements. A full DHA should be required for significant changes only and the use of the 25% of replacement cost is more representative of that type of change. Submitter Full Name: Jack Osborn Organization: Airdusco, Inc. Submittal Date: Tue Jun 28 07:54:11 EDT 2016 Page 31 of 87

9 of 68 7/11/2016 3:16 PM Public Input No. 57-NFPA 652-2016 [ New Section after 7.2.3 ] 7.2.4 Review. The DHA shall be reviewed and updated at least every 5 years. The DHA should always be reviewed at a predetermined interval to ensure that the hazard assessment and mitigation techniques used during the DHA are still correct and valid. Both NFPA 654 and NFPA 484 both have this 5 year review requirement for DHAs (hazard analyses). Submitter Full Name: Jason Reason Organization: Lewellyn Technology Submittal Date: Tue Jun 28 16:57:18 EDT 2016 Page 32 of 87

0 of 68 7/11/2016 3:16 PM Public Input No. 65-NFPA 652-2016 [ New Section after 8.1 ] X.X.Y Where practical, facilities shall consider alternative processes or raw materials that reduce the need to handle combustible dusts. Inherent safety is currently designated as a reserved section. The technical committee should begin to describe the concepts of inherent safety either through prescriptive requirements or annex material. Submitter Full Name: Timothy Myers Organization: Exponent Inc Submittal Date: Wed Jun 29 19:04:30 EDT 2016 Page 33 of 87

1 of 68 7/11/2016 3:16 PM Public Input No. 61-NFPA 652-2016 [ New Section after 8.3.3.3 ] Insert new 8.3.3.3.5 and renumber following sections 8.3.3.3.5* It shall be permitted to use an engineered system managed by a control system together with a variable frequency driveoperated fan. The control system ensures maintaining minimum design air volume flow in main ducts and open branch ducts at all operating conditions. A.8.3.3.3.5 In a single main system with multiple drops the main duct is optimized based on the maximum and average workstation utilization to allow system to be operated from minimum air volume flow up to the maximum air volume flow. The control system maintains the minimum design air volume flow in the main duct and open branch ducts. In a system with sub-main ducts the control system must measure air volume flow at hood (or drops), at branches and sub-branches and automatically adjust minimum design air volume flow in each branch. The controller must ensure that minimum air volume flow is maintained at each open branch and sub-branch and that minimum design air volume flow is maintained at all open hoods or pickup Energy requirement for dust systems are significant and often the single largest power consumer in a facility. Multiple tests has shown that the actual demand for vacuum is often in the 20 to 30% of full open design flows. With new technology it is now possible via a control system to manage where vacuum is needed and at the same time assure that minimum design velocities are maintained to prevent accumulation of dust in the ducting and also maintain minimum design flows at each drop. Submitter Full Name: Niels Pedersen Organization: Nederman LLC Submittal Date: Wed Jun 29 14:45:44 EDT 2016 Page 34 of 87

2 of 68 7/11/2016 3:16 PM Public Input No. 1-NFPA 652-2016 [ New Section after 8.3.4.1.1.2 ] 8.3.4.1.1.3 Rotary drum filters shall be permitted to be located indoors without protection from combustible dust hazards when all of the following criteria are met: (1) The drum filter is designed to prevent the formation of a combustible dust cloud with the air-material separator enclosure housing the drum filter; (2) The drum filter has sprinkler protection; and (3) AMS downstream from the rotary drum filter shall be protected in accordance with Section 8.8. Additional Proposed Changes File Name Description Approved PublicCommentNo91.pdf NFPA 652 Public Comment No. 91 NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 91 of the A2015 Second Draft Report for NFPA 652 and per the Regs. at 4.4.8.3.1. Substantiation :Rotary drum filters have long been used in the textile and cellulosic industries, and have proven to be inherently safe from deflagration. The rotating media drum's filter media contains only a minimal amount of dust at any time during use which is never suspended in air-in contrast to baghouse operation. It is only vacuumed off a felt on the rotating drum with vacuum nozzles similar to home vacuum cleaner nozzles and conveyed to a secondary (conventional) AMS (e.g., cyclone) which should be protected in accordance with this standard. As it is written, it appears that this document would disallow interior rotary drum filters by taking away the qualifying requirement of "where an explosion hazard exists" arbitrarily requiring protection on equipment that (i) does not require protection and (ii) is impossible to protect with chemical suppression or relief venting. Submitter Full Name: TC ON CMD-FUN Organization: NFPA TC ON FUNDAMENTALS OF COMBUSTIBLE DUSTS Submittal Date: Mon Jan 04 14:22:59 EST 2016 Page 35 of 87

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3 of 68 7/11/2016 3:16 PM Public Input No. 2-NFPA 652-2016 [ New Section after 8.3.4.1.1.2 ] 8.3.4.1.1.3 Rotary drum filters shall be permitted to be located indoors without protection from combustible dust hazards when all of the following criteria are met. (1) The drum filter is designed to prevent the formation of a combustible dust cloud within the air-material separator enclosure housing the drum filter; (2) The drum filter has sprinkler protection; and (3) AMS downstream from the torary drum filter shall be protected in accordance with Section 8.8. Additional Proposed Changes File Name Description Approved PublicCommentNo400.pdf NFPA 652 Public Comment No. 400 NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 400 of the A2015 Second Draft Report for NFPA 652 and per the Regs. at 4.4.8.3.1. Rotary drum filters have long been used in the textile and cellulosic industries, and have proven to be inherently safe from deflagration. The rotating media drum s filter media contains only a minimal amount of dust at any time during use which is never suspended in air in contrast to baghouse operation. It is only vacuumed off a felt on the rotating drum with vacuum nozzles similar to home vacuum cleaner nozzles and conveyed to a secondary (conventional) AMS (e.g., cyclone) which should be protected in accordance with this standard. As it is written, it appears that this document would disallow interior rotary drum filters by taking away the qualifying requirement of where an explosion hazard exists arbitrarily requiring protection on equipment that (i) does not require protection and (ii) is impossible to protect with chemical suppression or relief venting. Submitter Full Name: TC ON CMD-FUN Organization: NFPA TC ON FUNDAMENTALS OF COMBUSTIBLE DUSTS Submittal Date: Mon Jan 04 14:45:42 EST 2016 Page 38 of 87