NFPA 652: What the Woodworking Industry Needs to Know
In all situations, it is always dangerous if you don’t know what you don’t know. This is especially true of combustible dust. In this case, ignorance is not bliss. It’s expensive, and more importantly, deadly. The risks from fugitive combustible dust continue to remain high for the woodworking industry. Fugitive dust accumulates, forming a combustible cloud that results in explosions that destroy facilities and/or injure or kill employees. Fines from combustible sawdust buildup are also increasing as standards become more stringent. In April 2016, the Canadian paper Prince George Citizen reported that WorkSafeBC fined Brink Forest Products, Ltd over $137, 000 for hazardous levels of sawdust accumulation. Two other wood products manufacturers incurred large fines in March for similar safety concerns. C&C Wood Products located in British Columbia was fined $68,121, and Conifex sawmill also located in BC was fined $75,000 for sawdust buildup. These are just a few examples of high penalties, resulting from a lack of knowledge or lack of compliance – or both. However, it’s hard to remain compliant with changing and confusing standards. The National Fire Protection Association (NFPA) recently published a new standard on combustible dust - NFPA 652. The purpose was to clarify requirements; instead, in many sectors, it has caused more confusion than clarification. Woodworking industry professionals need the knowledge that best protects their businesses and employees from dangerous explosions and high fines for non-compliance. Below are highlighted the issues that matter within the NFPA 652 so those in the woodworking industry can take informed action. What is the NFPA 652? NFPA 652 defines its scope as the following: “This standard shall provide the basic principles of and requirements for identifying and managing the fire and explosion hazards of combustible dust and particulate solids.” In essence, it sets the standards that are fundamental requirements for all industries with combustible dust hazards. NFPA 654 was once considered the umbrella standard, but its focus emphasizes the chemical processing industry. (NFPA 654 contains additional requirements that go beyond those in NFPA 652.) The new NFPA 652 sets a baseline for all other industries. Together, these standards (general and industry-specific) provide a comprehensive framework for managing combustible dust hazards. During the development of NFPA 652, (Exponent, 8.11.15) there was debate over how to interact with existing commodity-specific combustible dust standards, when those standards contain differing requirements. To accommodate those differences, NFPA 652 contains a conflict section on which standards take precedence when there is a discrepancy in requirements. What’s new in the NFPA 652? Here are some of the changes in NFPA 652: • You cannot just look at the standards in NFPA 652 alone. Instead, you have to consider both the new 652 standard and NFPA 654. • All companies that generate, process, handle or store combustible dusts or particulate solids need to have a dust hazard analysis (DHA) for their operations. This is applied retroactively. • A DHA is permitted to be phased in no later than three years from the effective date of the standard. • Each plant must have its own threshold level of allowable dust accumulations, set by owner or management. From there, housekeeping methods will be developed, with appropriate documentation. • A management of change (MOC) plan is now required for certain changes made in any facility. • Operating equipment within an explosion hazard location must be isolated. • All buildings or areas with a dust deflagration hazard needs to be protected by either performance-based or prescriptive methods. • Overhead fans to limit dust accumulation have been identified specifically as a housekeeping solution What now? Now that you are better informed about the NFPA 652, you’re probably asking yourself how to move forward with your new knowledge. What’s the smartest action that woodworking professionals should take in light of the changes to NFPA 652? Clearly, the safest solution that makes most business sense must be implemented. And to do that, we need to know what is available, and evaluate the strengths and weaknesses of each option. Stay tuned for my next post as I discuss the merits of an engineered vs. managed approach to dealing with combustible sawdust.