Our Statement is not a problem - we are encouraging continuation of the standard as it is written without substantive changes.

of 69 10/3/2016 2:09 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 Resolution: The technical committee appreciates the support of the submitter. Since the public input does not recommend any specific text changes, it is not actionable by the committee. Page 1 of 80

of 69 10/3/2016 2:09 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 Resolution: This issue is addressed by Section 8.4.1.2, which states, " the methods used for cleaning surfaces shall be selected based on the basis of reducing the potential for creating a combustible dust cloud." See FR -1, which added additional annex material to A.8.4.1.2 to address the concerns of the submitter. Page 2 of 80

of 69 10/3/2016 2:09 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 Resolution: See FR-6. Material was added as annex to 1.3.3 (4) Page 3 of 80

of 69 10/3/2016 2:09 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 Resolution: FR-2-NFPA 652-2016 Statement: Fixing typographical error. Page 4 of 80

of 69 10/3/2016 2:09 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 Resolution: FR-3-NFPA 652-2016 Statement: Date updates. Page 5 of 80

of 69 10/3/2016 2:09 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 Resolution: FR-4-NFPA 652-2016 Statement: The term explosible is used in this and other NFPA combustible dust standards and a uniform definition should be developed. The annex refers to NFPA 68. Page 6 of 80

of 69 10/3/2016 2:09 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 Resolution: Based on the committees action on the related PI, PI-66, this definition is not needed as it is not used in the standard. Page 7 of 80

of 69 10/3/2016 2:09 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 Resolution: Section 7.1 has been revised. The term "material modification" is no longer used and therefore, a definition is not needed. Page 8 of 80

of 69 10/3/2016 2:09 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 9 of 80

0 of 69 10/3/2016 2:09 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 10 of 80

1 of 69 10/3/2016 2:09 PM Submittal Date: Fri Jun 24 13:06:47 EDT 2016 Resolution: The technical committee believes that the proposed language was repetitive (e.g. 4.2.5 compliance options and 4.2.1.1). We believe that it basically recast our objectives and introduced a statement that objectives were not prescriptive requirements. The technical committee revised 4.2.4 to address the issue of users misinterpreting the objectives section as a prescriptive requirements. The objectives as stated in the current edition of 652 are organized to reflect the hazards that we seek to manage, i.e., fire, flash fire, and explosion. This organization would be lost in the proposed revision. Page 11 of 80

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 12 of 80

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 13 of 80

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 14 of 80

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 15 of 80

Submittal Date: 5 Page 16 of 80

2 of 69 10/3/2016 2:09 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 Resolution: The technical committee appreciates the support of the submitter. Since the public input does not recommend any specific text changes, it is not actionable by the committee. Page 17 of 80

3 of 69 10/3/2016 2:09 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 Resolution: The technical committee appreciates the support of the submitter. Since the public input does not recommend any specific text changes, it is not actionable by the committee. Page 18 of 80

4 of 69 10/3/2016 2:09 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 Resolution: The technical committee appreciates the support of the submitter. Since the public input does not recommend any specific text changes, it is not actionable by the committee. Page 19 of 80

5 of 69 10/3/2016 2:09 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 Resolution: FR-8-NFPA 652-2016 Statement: Some materials can oxidize or degrade in air changing their combustibility or explosibility characteristics and should be appropriately preserved between sampling and testing. Page 20 of 80

6 of 69 10/3/2016 2:09 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 Resolution: See FR-38 for the revision to Section 7.1 and the substantiation. Page 21 of 80

7 of 69 10/3/2016 2:09 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 Resolution: See FR-38 for the revision to Section 7.1 and the substantiation. Page 22 of 80

8 of 69 10/3/2016 2:09 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 Resolution: See FR-38 for the revision to Section 7.1 and the substantiation. Page 23 of 80

9 of 69 10/3/2016 2:09 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 Resolution: See FR-38 for the revision to Section 7.1 and the substantiation. Page 24 of 80

0 of 69 10/3/2016 2:09 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 Resolution: See FR-39. PI was made to the wrong station. FR is a change in the title of the section. The TC also added annex material. A task group was created to develop additional annex material for the second draft. Page 25 of 80

1 of 69 10/3/2016 2:09 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 Resolution: See FR-40 Page 26 of 80

2 of 69 10/3/2016 2:09 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 Resolution: This material was held from the last revision cycle and resubmitted this cycle as a new Public Input. The committee is not familiar enough with these devices and needs more information on the equipment. This was requested as a response to the public comment submitted at the last revision cycle but was not provided as part of the public input received this cycle. The committee requests that the submitter provide technical information to substantiate their request so that they can consider the addition of the text. Page 27 of 80

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3 of 69 10/3/2016 2:09 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 Resolution: This material was held from the last revision cycle and resubmitted this cycle as a new Public Input. The committee is not familiar enough with these devices and needs more information on the equipment. This was requested as a response to the public comment submitted at the last revision cycle but was not provided as part of the public input received this cycle. The committee requests that the submitter provide technical information to substantiate their request so that they can consider the addition of the text. Page 30 of 80

Page 500 of 898 Public Comment No. 400-NFPA 652-2013 [ New Section after 8.3.4.1.1.2 ] 8.3.4.1.1.3, New text 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 rotary drum filter shall be protected in accordance with Section 8.8. Statement of Problem and Substantiation for Public Comment 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: MARIE MARTINKO Organization: SPI Submittal Date: Fri Nov 15 09:40:05 EST 2013 http://submittals.nfpa.org/terraviewweb/contentfetcher?commentparams=%28comment... 9/8/2014 Page 31 of 80

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4 of 69 10/3/2016 2:09 PM Public Input No. 3-NFPA 652-2016 [ New Section after 8.3.4.1.1.2 ] 8.3.4.1.1.2.1 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 rotary drum filter shall be protected in accordance with Section 8.8. Additional Proposed Changes File Name Description Approved PublicCommentNo219.pdf NFPA 652 Public Comment 219 NOTE: The following Public Input appeared as "Reject but Hold" in Public Comment No. 219 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 asecondary (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 15:10:34 EST 2016 Resolution: This material was held from the last revision cycle and resubmitted this cycle as a new Public Input. The committee is not familiar enough with these devices and needs more information on the equipment. This was requested as a response to the public comment submitted at the last revision cycle but was not provided as part of the public input received this cycle. The committee requests that the submitter provide technical information to substantiate their request so that they can consider the addition of the text. Page 33 of 80

Page 498 of 898 Public Comment No. 219-NFPA 652-2013 [ New Section after 8.3.4.1.1.2 ] 8.3.4.1.1.3, New text Comment: Insert the following new section: 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 rotary drum filter shall be protected in accordance with Section 8.8. Statement of Problem and Substantiation for Public Comment 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 Richard Krock Name: Organization: The Vinyl Institute Affilliation: Street Address: Submittal Date: These materials were developed through a cooperative effort involving the Vinyl Institute's outside counsel, Lawrence P. Halprin of Keller and Heckman LLP, the Vinyl Institute staff and the Vinyl Institute member company representatives. These comments also reflect input we received from other trade associations. Tue Nov 12 14:47:57 EST 2013 http://submittals.nfpa.org/terraviewweb/contentfetcher?commentparams=%28comment... 9/8/2014 Page 34 of 80

Page499 of 898 Committee Rejected but held Action: Resolution: These comments propose addition of new text regarding rotary drum filters and where they are permitted to be located and with what protection features. The Committee is not familiar enough with these devices and needs more information to verify the type of equipment (does it have a housing or is it more like enclosureless AMS) and how does the design prevent the formation of a dust cloud? Since this type of information has not been provided in the substantiation for these comments, the Committee believes it is appropriate to act at this time to reject, but hold these comments for the next revision cycle. http://submittals.nfpa.org/terraviewweb/contentfetcher?commentparams=%28comment... 9/8/2014 Page 35 of 80

5 of 69 10/3/2016 2:09 PM Public Input No. 33-NFPA 652-2016 [ New Section after 8.3.4.1.2 ] 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 rotary drum filter shall be protected in accordance with Section 8.8. 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: Marie Gargas Organization: SPI: The Plastics Industry Trade Association Affilliation: SPI: The Plastics Industry Trade Association Submittal Date: Mon Jun 27 14:59:08 EDT 2016 Resolution: This material was held from the last revision cycle and resubmitted this cycle as a new Public Input. The committee is not familiar enough with these devices and needs more information on the equipment. This was requested as a response to the public comment submitted at the last revision cycle but was not provided as part of the public input received this cycle. The committee requests that the submitter provide technical information to substantiate their request so that they can consider the addition of the text. Page 36 of 80

6 of 69 10/3/2016 2:09 PM Public Input No. 56-NFPA 652-2016 [ Section No. 8.3.4.1.2.1 ] 8.3.4.1.2.1 Wet air material separators shall be permitted to be located inside when all of the following criteria are met: (1) Interlocks are provided to shutdown the system if the flow rate of the scrubbing medium is less than the designed minimum flow rate. (2) The scrubbing medium is not a flammable or combustible liquid. (3) The separator is designed to prevent the formation of a combustible dust cloud within the air-material separator. (4) The design of the separator addresses any reaction between the separated material and the scrubbing medium. NOTE: Because many supplier offer immersion seperators, might consider including, excluding or distiguishing an immesion seperator from a wet knockdown air scrubber, when discussing wet AMS Better definitions & distinctions of product types & offerings, clarify equipment definitions Submitter Full Name: Norman Nowosinski Organization: Nilfisk Industrial Vacuums Submittal Date: Tue Jun 28 15:01:13 EDT 2016 Resolution: This PI is not actionable as written as it as there are no proposed revisions to the text. The technical committee is putting together a task group to possibly add annex material on types of wet air material separators. Page 37 of 80

7 of 69 10/3/2016 2:09 PM Public Input No. 66-NFPA 652-2016 [ New Section after 8.3.5.3 ] Point of Use Dust Collectors From Section 8.7.2.4 of NFPA 61 (Note the annex material appears to be missing from NFPA 61) X.X* A point-of-use dust collector shall be permitted to be mounted directly to conveying equipment in both indoor and outdoor locations, provided all of the following conditions are met: (1) When the point-of-use dust collector is mounted to an enclosure, such as a bucket elevator leg, the enclosure shall have explosion protection per the provisions of this standard. The volume of the dirty air side and of the transition shall be included in the determination of explosion protection design. (2) The point-of-use dust collector shall be mounted directly to the conveying equipment housing via a transition duct without an airlock (3) The transition between the point-of-use dust collector and the vented equipment shall be designed such that dust will release from the filter media and return to the equipment product stream and the transition is not a collection point for dust accumulation under normal operations. (4) The cross-sectional area of the transition connection shall be equal to or greater than the cross-sectional area of the point-of-use dust collector. (5) The point-of-use dust collector shall include an integral air-moving device on the clean side of the dust collector to maintain negative pressure. (6) The point-of-use dust collector shall not be connected to any other pieces of equipment. (7) Point-of-use dust collectors that return air to the inside of buildings shall be capable of a minimum filtering efficiency of 0.02 g per dry standard cubic meter of airflow (0.008 grains per dry standard cubic feet of airflow). A.X.X The purpose of this dust control method is to remove displaced air from the equipment so that it operates under a slight negative pressure in order to reduce fugitive dust emissions from the equipment; to keep the dust generated (from the material being conveyed) with the material; and eliminate the propagation hazard of interconnecting the conveying equipment through a central dust collection system. The dust is not removed from the equipment nor does this approach lower the risk of a dust deflagration within the Page 38 of 80