National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 Fax: 617-770-0700 www.nfpa.org MEMORANDUM TO: FROM: Correlating Committee on Combustible Dusts Susan Bershad, Staff Liaison DATE: December 28, 2015 SUBJECT: NFPA 664 Proposed Tentative Interim Amendment (TIA) No. 1200 The Technical Committee on Wood and Cellulosic Materials Processing has been balloted on proposed TIA 1200, submitted by Brice Chastain of Georgia-Pacific LLC and endorsed by Randal Davis of IEP Technologies and Francois Tanguay of Louisiana Pacific Canada Ltd. A copy of the proposed TIA and the final results of the TC balloting are attached. This proposed TIA is being submitted to you for letter ballot. In accordance with Section 5 of the Regulations Governing the Development of NFPA Standards, you are being balloted on any correlating issues of the proposed TIA and whether this matter is of an emergency nature. A disagree vote is limited to subjects within the purview of the Correlating Committee. Opposition on a strictly technical basis is not sufficient grounds for substantiating a disagree vote. Please complete and return your ballot to Kelly Carey, Project Administrator either by e-mail to kcarey@nfpa.org or fax to 617-984-7110. Ballots are due on January 11, 2016. This proposed TIA 1200 has been published for public comment in the December 4, 2015 issue of NFPA News with a Public Comment Closing Date of January 15, 2016. Any public comments received will be circulated to the committee. The Standards Council will consider the issuance of this TIA at their April 5-6, 2016 meeting. Note: Please remember that the return of ballots and attendance at committee meetings are required in accordance with the Regulations Governing the Development of NFPA Standards. Enclosures
NFPA 664-Proposed 2017 Edition Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities TIA Log No.: 1200 Reference: 4.3 Comment Closing Date: January 15, 2016 Submitter: Brice Chastain, Georgia-Pacific LLC 1. Replace subsection 4.3 and associated Annex to read as follows: 4.3 Dust Hazards Analysis (DHA). 4.3.1* The requirements of Section 4.3 shall apply retroactively in accordance with 4.3.1.1 through 4.3.1.3. 4.3.1.1 For existing processes and facility compartments that are undergoing significant modification, the owner/operator shall complete DHAs as part of the project. [652: 7.1.2.1] 4.3.1.2 For existing processes and facility compartments that are not undergoing significant modification, the owner/operator shall schedule and complete DHAs of existing processes and facility compartments within a 5-year period from the effective date of the standard. The owner/operator shall demonstrate reasonable progress in each of the 5 years. 4.3.1.3 For the purposes of applying the provisions of 4.3.1, significant modification shall include modifications or maintenance and repair activities that exceed 25 percent of the replacement cost. 4.3.2 The design of the fire and explosion safety provisions shall be based on a DHA of the facility, the process, and the associated fire or explosion hazards. 4.3.2.1 The results of the DHA shall be documented and maintained for the life of the process. 4.3.2.2* The DHA shall be reviewed and updated at least every 5 years. A.4.3.1 A DHA is a careful review of the fire and explosion hazards to determine the consequences of what could go wrong and to determine what safeguards could be implemented to prevent or mitigate those consequences. DHA should be completed as soon as possible. For existing facilities, those processes with the greatest perceived risk should be evaluated first. [652: A.7.1.2] A.4.3.2.2 It is not the intent of this requirement to permit a delay in the completion of all DHA until the fifth year. [652: A.7.1.2.2] Substantiation: The NFPA 664 TC was remiss in not addressing the time requirement for performing and completing DHAs for combustible dust processes.
This TIA proposes a replacement section for the existing NFPA 664 paragraph 4.3 to be in consonance with NFPA 654 and NFPA 61 next edition s five year requirement for performing DHA of all combustible dust processes. Emergency Nature: NFPA 664 contains an error or omission that was overlooked during the 2017 edition revision process. This omission is the time period for completing Dust Hazard Analyses (DHA). Both NFPA 654 and NFPA 61 in the present revision cycle address the DHA performance time requirement. Both NFPA 654 and NFPA 61 require DHAs to be completed within 5 years from the date of each standards next revision issuance. If this omission is not addressed in the next revision, NFPA 664 will have a default DHA time completion period of three years as presently required for completing DHAs in the recent issuance of the new NFPA 652 standard. The attached TIA will resolve the NFPA 664 omission and ensure NFPA 664 is in consonance and consistent with both NFPA 654 and NFPA 61 requirements for performing DHAs within a five year time period.
National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 Fax: 617-770-0700 www.nfpa.org MEMORANDUM TO: FROM: Technical Committee on Wood and Cellulosic Materials Processing (CMD-WOO) Susan Bershad, Staff Liaison DATE: December 23, 2015 SUBJECT: NFPA 664 Proposed TIA No. 1200 PRELIMINARY TC BALLOT RESULTS According to 5.6(a) in the NFPA Regs, the preliminary results show this TIA HAS NOT achieved the ¾ majority vote needed on both Question No. 1 (Technical Merit) and Question No. 2 (Emergency Nature). 27 Eligible to Vote 3 Not Returned (S. Francis, T. Myers, B. Noe) Technical Merit: Emergency Nature: 0 Abstentions 0 Abstentions 21 Agree (w/comment: S. Dale, A. Mattos, Jr., J. 16 Agree (w/ comment: S. Dale) Reason) 3 Disagree (H. Eng, J. Nichols, E. Ural) 8 Disagree (H. Eng, J. Nichols, E. Ural, A. Dastidar, S. Dillon, A. Mattos, Jr., J. Reason, R. Reynolds) There are two criteria necessary to pass ballot [(1) simple majority (2) affirmative ¾ vote]. Both questions must pass ballot in order to recommend that the Standards Council issue this TIA. (1) In all cases, an affirmative vote of at least a simple majority of the total membership eligible to vote is required. [27 eligible 2 = 13.5 = (14)] (2) The number of affirmative votes needed to satisfy the ¾ requirement is 18. (27 eligible to vote - 3 not returned - 0 abstentions = 24 0.75 = 18) Ballot comments are attached for your review. This proposed TIA has been published for public comment in the December 4, 2015 issue of NFPA News with a Public Comment Closing Date of January 15, 2016. Any public comments received will be circulated to the committee. The Standards Council will consider the issuance of this TIA at their April 5-6, 2016 meeting. Attachment
CORRELATING COMMITTEE ON COMBUSTIBLE DUSTS LETTER BALLOT PROPOSED TENTATIVE INTERIM AMENDMENT LOG NO. 1200 To replace subsection 4.3 and associated Annex in NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities Question No. 1: I agree there are no CORRELATION ISSUES in accordance with 3.4.2 and 3.4.3 of the NFPA Regs. AGREE DISAGREE* ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagree or abstain vote. If disagreeing, cite relevant section(s)/paragraph(s) of the correlation issue and describe. Question No. 2: I agree the subject of this TIA is of an EMERGENCY NATURE. AGREE DISAGREE* ABSTAIN* EXPLANATION OF VOTE - Please type or print your comments: *An explanation must accompany a disagree or abstain vote. Signature Name (Please Print) Date Please return the ballot on or before January 11, 2016. PLEASE RETURN TO: Kelly Carey, Project Administrator NFPA 1 Batterymarch Park Quincy, MA 02169 FAX: (617) 984-7110 E-mail: kcarey@nfpa.org