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February 9, 2018 Previous day Next day

Photo: U.S. Chemical Safety Board


This week marks 10 years since the fatal event on February 7, 2008, at the Imperial Sugar Company manufacturing facility in Port Wentworth, Georgia. Fourteen workers were killed and 36 others were treated for serious burns and injuries after a series of sugar dust explosions. 


In its investigation report released in September 2009, the U.S. Chemical Safety Board (CSB) found that an initial dust explosion originated in the enclosed steel belt conveyor located below the sugar silos where high concentrations of sugar dust had accumulated inside the enclosure. The initial explosion stirred up sugar dust that had built up on the floors and other surfaces, causing a chain reaction of additional dust explosions through the buildings. Fires resulting from the explosions destroyed the packing buildings, silos, and palletizer building and severely damaged parts of the refinery and sugar loading area. The investigation conducted by the CSB highlighted many safety concerns regarding buildings where dust explosions are a risk and resulted in providing a list of recommendations to ensure that buildings at risk for dust explosions reduce that risk and even prevent such explosions from occurring.


But, what does this have to do with the Fire Code?


Chapter 40 of NFPA 1 addresses dust explosion and fire prevention provisions. In past editions of the code, a majority of the requirements found in Chapter 40 were extracted from NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, the then main document for dust hazards. After several investigation reports and studies, the CSB recommended that the Occupational Safety and Health Administration (OSHA) develop a comprehensive federal standard to address the numerous workplace hazards found in facilities where combustible solids are handled, used, or stored in a manner that has the potential to generate and release combustible dusts. It was the tragic event at the Imperial Sugar refinery that pushed this recommendation into action. OSHA later announced that they would initiate the rulemaking process in order to develop a federal standard addressing these needs. 


Fast forward a few years, and a new committee structure was put in place at NFPA to oversee the standards-making process for these documents related to dust hazards. As a result, NFPA 652, Standard on the Fundamentals of Dust, was born. This document provides the basic principles of and requirements for identifying and managing the fire and explosion hazards of combustible dusts and particulate solids.


The first edition of NFPA 652 was issued in the summer of 2015 with a 2016 edition date. The latest edition of NFPA 1, 2018, is first referencing this document as the source for extracted requirements in Chapter 40. During the 2018 revision cycle for NFPA 1, a majority of requirements, previously extracted from NFPA 654 as noted above, were deleted and replaced with the appropriate requirements from NFPA 652. NFPA 652 is now considered the fundamental document for combustible dust. It establishes minimum requirements for managing combustible dust hazards and it directs the user to other NFPA standards for industry- and commodity-specific requirements, including:


  • NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities
  • NFPA 484, Standard for Combustible Metals
  • NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids.
  • NFPA 655, Standard for the Prevention of Sulfur Fires and Explosions
  • NFPA 664, Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities

So how does Chapter 40 impact fire inspectors using NFPA 1? It outlines operating procedures and practices;  inspection, testing and maintenance of equipment; maintenance programs and procedures; training and hazard awareness; qualifications and training for contractors; emergency planning and response; management of change; documentation; and management of systems.  An inspector/AHJ must be aware of the provisions related to these facilities and confirm that these protection strategies and procedures are in place and that facilities are maintaining safe conditions for the protection of the building and workers.  


For more detailed information on the history and development of NFPA 652 check out the NFPA Journal article, “Credible Risk”.


Get free access to the 2018 edition of the code and check out the updates to Chapter 40.


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Do you know that there are three chapters in NFPA 70E®, Standard for Electrical Safety in the Workplace®? Although Chapter 1 is the most well-known there are two other chapters applicable to the users of the standard. Chapter 2 applies to any facility that conducts maintenance. Chapter 3 addresses specific equipment and may not be applicable to all users of the standard.

Chapter 2: Article 205 contains basic information that is critical to maintenance. Without proper maintenance, not only are workers put a risk when performing energized work or establishing an electrically safe work condition, but the production line worker doing their job is also put at risk. Everyone knows that someone conducting energized work must be a qualified person but that person must also be qualified to conduct those maintenance tasks and tests. For example, special knowledge is necessary to maintain a motor and its protection technique in hazardous locations. A single-line diagram is crucial to conducting a risk assessment and but the document is of no use unless it is legible and current. Maintenance must follow the manufacturer’s instructions and industry standards but 205.3 points out who is responsible for making sure maintenance is conducted and documented.

Clear and ample working space around electrical equipment is necessary to safely conduct maintenance whether an electrically safe work condition is established or justified energized work is conducted. Enclosures need to be maintained and safety equipment must be functional to provide the designed protection. Cables and cords need to be free from damage to provide insulation and appropriate grounding. Many people associate personal protective equipment (PPE) with arc-rated clothing and voltage rated gloves. Article 250 points out that personal safety and protective equipment is not limited to protective clothing. Other Chapter 2 articles address the maintenance of several types of electrical equipment also in general terms. Although Chapter 2 does not provide information on how to conduct the inspections, tests or maintenance, without thee requirements to do so many would not perform these tasks.

Chapter 3: The special equipment addressed in Chapter 3 lends to it being the least used among the three chapters. Electrolytic cells, battery and battery rooms, power electronic equipment, lasers, and research and development laboratories all present unique electrical hazards. If your facility includes any of these locations or equipment, the general safety requirements from Chapter 1 may not adequately protect your employees. It is possible to place employees at additional risk of injury without using the modified or additional requirements from Chapter 3 to address these unique hazards.

For more information on 70E, read my entire 70E blog series on Xchange.

Next time: Increasing electrical safety for all employees.

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