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.
Thanks for reading, stay safe!