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Public Input No. 12-NFPA 61-2018 [ Section No. 7.1.2.2 ]

7.1.2.2*
For existing processes and facility compartments that are not undergoing significant modification, the
owner/operator shall schedule and complete DHAs of bucket elevators, conveyors, grinding equipment,
spray dryer systems, centralized vacuum cleaning systems, and dust collection systems within a 5-year
period from the effective date of the standard.

Statement of Problem and Substantiation for Public Input

61 recognizes that centralized vacuum cleaning systems, like dust collection systems, represent a combustible
dust hazard. This is shown by the section 8.3.3 and the references to NFPA 654. 652 has additional system
requirements that would also be applicable (as per conflicts section). Thus, this is a recognized fire, flash-fire, and
explosion hazard that is often overlooked (per my experience). These systems should be included in the DHA for
existing facilities.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 10:07:10 EST 2018

Committee Statement

Resolution: The Technical Committee does not want to change the list of items until the 5-year period for
completing a DHA has elapsed. Many of these pieces of equipment are specifically addressed within
the body of NFPA 61.

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Public Input No. 14-NFPA 61-2018 [ Section No. 7.1.2.2 ]

7.1.2.2*
For existing processes and facility compartments that are not undergoing significant modification, the
owner/operator shall schedule and complete DHAs of bucket elevators, mechanical conveyors, pneumatic
conveying systems, grinding equipment, spray dryer systems, and dust collection systems within a 5-year
period from the effective date of the standard.

Statement of Problem and Substantiation for Public Input

61 recognizes that pneumatic conveying systems represent a combustible dust hazard by the requirements in
section 8.3.3. 652 also emphasizes additional requirements for these systems (via conflicts section). Pneumatic
conveying systems that utilize material handling fans, that are used to transfer after milling operations, etc.,
represent direct fire, flash-fire, and explosion hazards and risks that should be evaluated in the DHA. This should
be true for all new and existing systems.
Added "mechanical" to differentiate between the conveying systems.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 10:16:29 EST 2018

Committee Statement

Resolution: The Technical Committee does not want to change the list of items until the 5-year period for
completing a DHA has elapsed. Many of these pieces of equipment are specifically addressed within
the body of NFPA 61.

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Public Input No. 15-NFPA 61-2018 [ Section No. 7.1.2.2 ]

7.1.2.2*
For existing processes and facility compartments that are not undergoing significant modification, the
owner/operator shall schedule and complete DHAs of bucket elevators, conveyors, grinding equipment,
spray dryer drying systems, and dust collection systems within a 5-year period from the effective date of
the standard.

Statement of Problem and Substantiation for Public Input

61 recognizes that multiple types of Dyers (i.e. drying systems/methods), not just spray dryers, present combustible
dust hazards as per section 8.3.9. Having personally been involved with investigations involving multiple types of
dryer operations (fluid bed for example) that have either been involved in a major fire and/or an explosion which
could have been avoided had the user complied with the requirements. All dryer operations should be included in
the DHA, not just spray dryers.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 10:22:47 EST 2018

Committee Statement

Resolution: The Technical Committee does not want to change the list of items until the 5-year period for
completing a DHA has elapsed. Many of these pieces of equipment are specifically addressed within
the body of NFPA 61.

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Public Input No. 5-NFPA 61-2017 [ New Section after 7.3.1 ]

7.3.1.1 Alternative Method

(1) It shall be permitted to use a checklist to complete a DHA on an Agricultural Combustible Dust in luie of
the methodology described in section 7.3.1. See Annex F for a sample checklist.

Statement of Problem and Substantiation for Public Input

Annex F contains a sample DHA checklist, but the body of the standard does not state the checklist can be used.
The added lanuage clears up confusion that a checklist can be used instead of the DHA method that is in 7.3.1.

Submitter Information Verification

Submitter Full Name: Craig Froehling

Organization: Cargill, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Wed Feb 22 15:28:37 EST 2017

Committee Statement

Resolution: FR-1-NFPA 61-2018

Statement: Annex F contains a sample DHA checklist, but the body of the standard had not stated the checklist
could be used. The added language clarifies that a checklist can be used.

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Public Input No. 9-NFPA 61-2017 [ Section No. 8.3.2.4 ]

8.3.2.4 *
Bulk material conveyor belts and lagging shall have a surface resistivity not greater than 100 megohms
300 megohms per square and shall be fire resistant and oil resistant.
8.3.2.4.1
Belts shall be fire resistant by complying with the requirements of the Mine Safety and Health
Administration (MSHA) 2G flame test for conveyor belting in 30 CFR 18, Section 18.65.

Statement of Problem and Substantiation for Public Input

Due to our product being food for human consumption, we are required to use white food grade belting and
lagging. We have had an extremely difficult time finding a white, food grade, lagging and simply cannot find a
manufacturer that makes white, food grade belting that meets the 100 megohm per square specification. We have
been able to find belting that is less than 300 megohm per square.

Submitter Information Verification

Submitter Full Name: Steve Willcuts

Organization: Amalgamated Sugar
Street Address:
City:
State:
Zip:
Submittal Date: Fri Dec 22 10:35:53 EST 2017

Committee Statement

Resolution: FR-2-NFPA 61-2018

Statement: ISO, OSHA, and other testing shows that 300 megohms per square is adequate for dissipating static
electricity.

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Public Input No. 20-NFPA 61-2018 [ New Section after 8.3.3.1 ]

TITLE OF NEW CONTENT

Type your content here ...The systems shall be designed and maintained to ensure that the air-gas velocity
used shall meet or exceed the minimum required to keep the interior surfaces of all piping or ducting free of
accumulations under all normal operating modes.

Statement of Problem and Substantiation for Public Input

adding the 652 general requirement for pneumatic conveying, dust collection and centralized vacuum cleaning
systems section 8.3.3.1.2. Would also include the appendix information from 652.
This requirement would be applicable even if not included in 61 via the conflicts section.
However, this is a basic and viable requirement for proper design and operation of such systems.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 10:51:18 EST 2018

Committee Statement

Resolution: FR-4-NFPA 61-2018

Statement: This is a basic and viable requirement for proper design and operation of such systems to avoid
product buildup and dust accumulation.

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Public Input No. 16-NFPA 61-2018 [ Section No. 8.3.3.1.1 ]

8.3.3.1.1
Pneumatic conveying, dust collection, and centralized vacuum cleaning systems shall be installed in
accordance with to section 8.5 3 .3 and Sections 7 . 5 through 7.9 of NFPA 654. of NFPA 652.

Statement of Problem and Substantiation for Public Input

section 8.53 of 654 does not exist. Sections 7.5 through 7.9 include factors that might or might not apply
depending upon use, etc. The fact that only pneumatic conveying systems are listed in 8.3.3.1.1 makes the use of
7.5 through 7.9 very questionable since a significant amount is for dust collection or certain types of pneumatic
transfer systems. Referring to 652 is significantly more applicable since there are requirements for each of the
three(3) types of systems that must be considered and some general information that is applicable (e.g. 8.3.3.1.3).
With or without this reference, 652's 8.3.3 (most of it) is still applicable via the conflicts section since there are no
conflicts involved and nothing in 61 about the requirements in 652. Have also provided other public inputs that can
be avoided by including this reference to 652 (would automatically include those public comments).

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 10:37:26 EST 2018

Committee Statement

Resolution: FR-5-NFPA 61-2018

Statement: Section 8.5.3 of 654 does not exist. These references are being updated to fix an error (going back to
the 2013 edition references). The Technical Committee will review these sections in NFPA 654 and
consider bringing the requirements over to NFPA 61 as extracts.

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Public Input No. 21-NFPA 61-2018 [ New Section after 8.3.3.5 ]

TITLE OF NEW CONTENT

Type your content here ...At each colection point, the sysetm shall be designed to achieve the minimum
velocity required for capture, control, and containment of the dust source.
The hood or pickup point for each dust source shall have a documented minimum flow based upon the
system design.
Branch lines shall not be disconnected, and unused portions of the system shall not be blanked off without
providing a means to maintain required and balanced airflow.
The addition of branch lines shall not be made to an existing system without first confirming that the entire
system will maintain the required and blanced airflow.

Statement of Problem and Substantiation for Public Input

Seeking to add the wording, requirements, and appendices, of sections 8.3.3.3.1, 8.3.3.3.2, 8.3.3.3.3, and 8.3.3.3.4
of 652. These are critical requirements for a successful dust collection system design and operation. Via the
conflicts section, if these requirements are not included in 61, these same requirements would be applicable since
they are contained in 652 and there is no conflict, etc.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 10:55:30 EST 2018

Committee Statement

Resolution: FR-5-NFPA 61-2018

Statement: Section 8.5.3 of 654 does not exist. These references are being updated to fix an error (going back to
the 2013 edition references). The Technical Committee will review these sections in NFPA 654 and
consider bringing the requirements over to NFPA 61 as extracts.

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Public Input No. 8-NFPA 61-2017 [ New Section after 8.3.4.1.1 ]

TITLE OF NEW CONTENT

Type your content here ...Add new sub section 8.3.4.1.1.3

If the dirty side volume of the air‐ material separator is greater than 8 3 (0.2m 3 ), it should be protected in
accorance with sec on 8.8.4.1.1.
(Reference- NFPA 652‐2016 (8.3.4.1.1)

Statement of Problem and Substantiation for Public Input

This addresses the minimum volume criterion for explosion protection requirement and inline with NFPA 652 -2016
and also inline with OSHA inspection check list
"" Appendix B- Inspection check list from OSHA NEP CPL-03-00-008 dated 03/11/08 lists one of sample inspector
question -Are dust collectors greater than 8 cuft volume located inside of the building?""

NFPA 652 (8.3.4.1.1) suggest that Air- material separators of dirty side volume less than 8 cuft would not require
explosion protection.

Submitter Information Verification

Submitter Full Name: Venkateswara Bhamidipati

Organization: Powder Process Solutions
Street Address:
City:
State:
Zip:
Submittal Date: Wed Dec 20 17:28:50 EST 2017

Committee Statement

Resolution: FR-9-NFPA 61-2018

Statement: It is not practicable to vent air material separators less than 8 ft3 and this is correlating with other dust
standards.

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Public Input No. 10-NFPA 61-2017 [ Section No. 8.3.7.1.9 ]

8.3.7.1.9
Where necessary to minimize slippage, Legs shall have lagging installed on the head pulley to minimize
slippage.

Additional Proposed Changes

File Name Description Approved

Elevator_Belting.pdf Elevator Belt

Statement of Problem and Substantiation for Public Input

We understand the thought behind lagging the head pulley is to minimize belt slippage, however with sugar, we
have no issues with the belt slipping on the head pulley and experience a greater safety hazard by having head
pulley lagging. Sugar is very abrasive and quickly wears the crown off of the lagging (within 3 - 5 months). Once
this happens, the belt is free to wander from side to side, and could potentially track far enough to rub the buckets
against the elevator housing. When the elevator is overloaded, the motor overloads trip as expected. We believe
speed monitors at the head and tail pulleys are an effective way to ensure no slippage is occurring. Even if there
was slippage, we believe the belt material will fail (pvc belting begins to fail at 180F) before the minimum ignition
temperature of sugar dust is reached (680F).

Submitter Information Verification

Submitter Full Name: Steve Willcuts

Organization: Amalgamated Sugar
Street Address:
City:
State:
Zip:
Submittal Date: Fri Dec 22 11:07:00 EST 2017

Committee Statement

Resolution: Lagging is a necessary requirement to keep belts and elevators from slipping, and to minimize the
possibility of ignition sources due to slippage.

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Public Input No. 2-NFPA 61-2017 [ Section No. 8.8.2.1.2.1 ]

8.8.2.1.2.1
The requirement in 8.8.2.1.2 shall not apply to existing tunnels and pits where explosion venting is not
practical due to confinement by soil, building constraints, or both.

Statement of Problem and Substantiation for Public Input

Permitting the exception to existing tunnels and pits only will eliminate new tunnels and pits from being built in
which a dust explosion hazard exist and explosion relief venting cannot be accomplished.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 1-NFPA 61-2017 [Section No. 8.8.2.1.2.2]

Submitter Information Verification

Submitter Full Name: Mark Drake

Organization: Liberty Mutual
Street Address:
City:
State:
Zip:
Submittal Date: Mon Feb 20 12:33:40 EST 2017

Committee Statement

Resolution: It is not practical to eliminate tunnels and pits. In new construction, an effort is made to minimize the
presence of fugitive dust in tunnels and pits.

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Public Input No. 1-NFPA 61-2017 [ Section No. 8.8.2.1.2.2 ]

8.8.2.1.2.2
The requirement in 8.8.2.1.2 shall not apply to existing bins and silos where explosion venting is not
practical due to bin or silo geometry, building constraints, or both.

Statement of Problem and Substantiation for Public Input

Permitting the exception to existing bins and silos only will eliminate new bins and silos from being built in which a
dust explosion hazard exist and explosion relief venting cannot be accomplished.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 2-NFPA 61-2017 [Section No. 8.8.2.1.2.1] same premise

Submitter Information Verification

Submitter Full Name: Mark Drake

Organization: Liberty Mutual
Street Address:
City:
State:
Zip:
Submittal Date: Mon Feb 20 12:22:59 EST 2017

Committee Statement

Resolution: It is not always practical to design explosion venting on new large bins and silos. As part of the DHA
of a new facility, it is required to document the appropriate explosion protection for the silo or bin.

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Public Input No. 22-NFPA 61-2018 [ Section No. 8.8.5.1.1 ]

8.8.5.1.1
Where the owner/operator determines that isolation is necessary an explosion hazard exists , isolation
devices shall be provided to prevent deflagration propagation between connected equipment in accordance
with NFPA 69.

Statement of Problem and Substantiation for Public Input

If an explosion hazard exists it is highly likely that isolation will be required. To leave it up to the owner/operator will
allow circumvention of situations where isolation would remove the hazard. The committee fully knows that there
are owner/operators which will choose to ignore the need for isolation (e.g. dust collection systems, bucket
elevators, etc.) due to the cost, difficulty, just because the want to, etc. None of the other standards allow this
exception and this is definitely a correlation issue, also. Explosion propagation is a real hazard and can represent
very high risks to personnel and property. Allowing a method to ignore such hazards is not consistent with the goal
of the standard.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 11:06:16 EST 2018

Committee Statement

Resolution: FR-10-NFPA 61-2018

Statement: This change clarifies how the owner/operator should determine if isolation is required. Isolation may
be accomplished in other ways besides a device.

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Public Input No. 3-NFPA 61-2017 [ Section No. 8.8.5.1.1 ]

8.8.5.1.1
Where the owner/operator determines that a DHA has determined that isolation is necessary, isolation
devices shall be provided to prevent deflagration propagation between connected equipment in accordance
with NFPA 69.

Statement of Problem and Substantiation for Public Input

Isolation protection should be determined by a DHA (one who is trained in the hazards of the existing operations)
rather than the owner/operator who may not be aware of all the hazards the operation(s) may present.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 4-NFPA 61-2017 [Section No. 8.8.5.2.1]

Submitter Information Verification

Submitter Full Name: Mark Drake

Organization: Liberty Mutual
Street Address:
City:
State:
Zip:
Submittal Date: Mon Feb 20 12:39:26 EST 2017

Committee Statement

Resolution: FR-10-NFPA 61-2018

Statement: This change clarifies how the owner/operator should determine if isolation is required. Isolation may
be accomplished in other ways besides a device.

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Public Input No. 23-NFPA 61-2018 [ Section No. 8.8.5.2.1 ]

8.8.5.2.1*
Where the owner/operator determines that isolation is required, isolation
Isolation devices shall be provided to prevent deflagration propagation from equipment through upstream
ductwork to the work areas in accordance with NFPA 69.

Statement of Problem and Substantiation for Public Input

Propagation through ductwork in dust collection systems or chutes between hazardous operations is a fully
documented and proven hazard and can represent high risks to personnel and property. To allow an
owner/operator the arbitrary option to not provide such protection (or provide proof the hazard is mitigated, etc.)
does not properly represent the goals of this or any other combustible dust commodity standard. This is also a
correlating issue as none of the other commodity-specific standards allow such an option or "out".

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 11:14:24 EST 2018

Committee Statement

Resolution: FR-11-NFPA 61-2018

Statement: This change clarifies how the owner/operator should determine if isolation is required. Isolation may
be accomplished in other ways besides a device.

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Public Input No. 4-NFPA 61-2017 [ Section No. 8.8.5.2.1 ]

8.8.5.2.1 *
Where the owner/operator determines a DHA has determined that isolation is required, isolation devices
shall be provided to prevent deflagration propagation from equipment through upstream ductwork to the
work areas in accordance with NFPA 69.

Statement of Problem and Substantiation for Public Input

Isolation protection should be determined by a DHA (one who is trained in the hazards of the existing operations)
rather than the owner/operator who may not be aware of all the hazards the operation(s) may present.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 3-NFPA 61-2017 [Section No. 8.8.5.1.1] similar statements

Submitter Information Verification

Submitter Full Name: Mark Drake

Organization: Liberty Mutual
Street Address:
City:
State:
Zip:
Submittal Date: Mon Feb 20 12:44:53 EST 2017

Committee Statement

Resolution: FR-11-NFPA 61-2018

Statement: This change clarifies how the owner/operator should determine if isolation is required. Isolation may
be accomplished in other ways besides a device.

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Public Input No. 25-NFPA 61-2018 [ New Section after 9.9 ]

TITLE OF NEW CONTENT

Type your content here ...Written procedures shall be established and implemented to manage proposed
changes to process materials, staffing, job tasks, technology, equipment, procedures, and facilities.

Statement of Problem and Substantiation for Public Input

61's section on management of change does not have information that would assist the reader in understanding
the need and requirements for MOC. Also, via the conflicts section, the requirements in 652 would apply if this
information is not included in 61. This is also a correlation issue - to assure all commodity specific standards have
the same approach for MOC.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 11:26:08 EST 2018

Committee Statement

Resolution: FR-12-NFPA 61-2018

Statement: Annex material was added to clarify the management of change process. The 12 month period was
removed because that time period has passed. The exception for replacement-in-kind was moved to
a separate requirement for clarity.

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Public Input No. 26-NFPA 61-2018 [ New Section after 9.9 ]

TITLE OF NEW CONTENT

Type your content here ...The procedures shall ensure that the folowing are addressed prior to any change:
(1) The basis for the proposed change.
(2) Safety and health implications.
(3) Whether the change is permanent or temporary, including the authorized duration of temporary changes.
(4) Modifications to operating and maintenance procedures.
(5) Employee training requirements.
(6) Authorization requirements for the proposed change.
(7) Resuts of characterization tests ued to assess the hazard, if conducted.

Statement of Problem and Substantiation for Public Input

The purpose is to include section 9.9.2 (PI #25 was to include 9.9.1) to further explain what an MOC should cover.
The annex sections for all parts of the 652 sections should be included (same for 9.9.1) to assist the user. Via the
conflicts section, this requirement would still be necessary since it is in 652 and there is no exclusion, conflict, etc.
This is also a correlation issue.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 11:29:48 EST 2018

Committee Statement

Resolution: FR-12-NFPA 61-2018

Statement: Annex material was added to clarify the management of change process. The 12 month period was
removed because that time period has passed. The exception for replacement-in-kind was moved to
a separate requirement for clarity.

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Public Input No. 27-NFPA 61-2018 [ New Section after 9.9 ]

TITLE OF NEW CONTENT

Type your content here ...Implimentation of the management of change procedure shll not be required for
replacements-in-kind.

Statement of Problem and Substantiation for Public Input

This is in conjunction with PI's #25 and #26. This statement covers a typical situation for facilities and excludes the
necessity of MOC for replacement in kind. This is actually the requirement of section 9.9.3 from 652. The annex
information should also be included. This is automatically included even if the PI is not adopted via the conflicts
section.

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 11:35:25 EST 2018

Committee Statement

Resolution: FR-12-NFPA 61-2018

Statement: Annex material was added to clarify the management of change process. The 12 month period was
removed because that time period has passed. The exception for replacement-in-kind was moved to
a separate requirement for clarity.

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Public Input No. 24-NFPA 61-2018 [ Section No. 9.9.1 ]

9.9.1
Twelve months after the effective date of this standard, the The owner/operator shall require that a
qualified person knowledgeable in the fire and deflagration hazards of agricultural dust be informed of
changes (other than replacements-in-kind) to facilities, equipment, or processed materials before
implementation of the change.

Statement of Problem and Substantiation for Public Input

the time period is over

Submitter Information Verification

Submitter Full Name: Jack Osborn

Organization: Airdusco, Inc.
Street Address:
City:
State:
Zip:
Submittal Date: Tue Jan 02 11:19:34 EST 2018

Committee Statement

Resolution: FR-12-NFPA 61-2018

Statement: Annex material was added to clarify the management of change process. The 12 month period was
removed because that time period has passed. The exception for replacement-in-kind was moved to
a separate requirement for clarity.

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Public Input No. 31-NFPA 61-2018 [ New Section after A.1.3.1 ]

A.6.1.3.10
The SFPE Engineering Guide for Substantiating a Fire Model for a Given Application provides a framewrork
for determing and documenting the suitability of a fire model for use in a specific application.

Statement of Problem and Substantiation for Public Input

The SFPE provides guidance on how to document the selection of a fire modal that includes verification and
validation, model selection and user effects.

Submitter Information Verification

Submitter Full Name: Chris Jelenewicz

Organization: SFPE
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 04 14:02:05 EST 2018

Committee Statement

Resolution: These sections are extracted from NFPA 652, and NFPA 652 does not contain these proposed
annexes. They should be proposed to NFPA 652 first.

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Public Input No. 32-NFPA 61-2018 [ New Section after A.5.2.2 ]

A.6.2
The SFPE Engineering Guide to Fire Risk Assessment provides a framwork for the use of risk assessment
methodologies in the design and assessessment of buiding and/or process fire safety.

Statement of Problem and Substantiation for Public Input

The SFPE Guide provides guidance on how to perform the fire risk assessment identified in Section 6-2.

Submitter Information Verification

Submitter Full Name: Chris Jelenewicz

Organization: SFPE
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 04 14:12:47 EST 2018

Committee Statement

Resolution: These sections are extracted from NFPA 652, and NFPA 652 does not contain these proposed
annexes. They should be proposed to NFPA 652 first.

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Public Input No. 34-NFPA 61-2018 [ Section No. A.5.2.2 ]

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A.5.2.2

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Data can be from samples within the facility that have been tested or data can be based on whether the
material is known to be combustible or not. There are some published data of commonly known materials,
and the use of these data is adequate to determine whether the dust is a combustible dust. For well-known
commodities, published data are usually acceptable. A perusal of published data illuminates that there is
often a significant spread in values. It is useful, therefore, to compare attributes (such as particle distribution
and moisture content) in published data with the actual material being handled in the system whenever
possible. Doing so would help to verify that the data are pertinent to the hazard under assessment. Even
test data of material can be different from the actual conditions. Users should review the conditions of the
test method as well to ensure that it is representative of the conditions of the facility. Where that is not
possible, the use of worst-case values should be selected. Composition and particle size are two
parameters that are useful to identify the number and location of representative samples to be collected
and tested. (See Section 5.5 for information on sampling.)
These are locations in which combustible dust is in the air in quantities sufficient to produce explosive or
ignitible mixtures under normal operating conditions, or locations where mechanical failure or abnormal
operation of machinery or equipment could cause explosive or ignitible mixtures to be produced, and
combustible dust in the air could provide a source of ignition through simultaneous failure of electrical
equipment, operation of protection devices, or other causes.
Situations can occur in which it is not possible to provide calculated deflagration venting as described in
NFPA 68. Such situations do not justify the exclusion of all venting. The maximum practical amount of
venting should be provided, since some venting should reduce the damage potential. In addition,
consideration should be given to other protection and prevention methods.
Table A.5.2.2 contains examples of test data for selected agricultural dusts with known explosion data
parameters. Other databases, such as the IFA (Institute for Occupational Safety and Health of the German
Social Accident Insurance), GESTIS-DUST-EX Database Combustion, are available for data on explosion
characteristics of dusts.
Please note that the information provided in the table is for the specific agricultural dust sample tested.
Explosion severity and ignition sensitivity parameters are greatly influenced by many factors, including
particle size distribution, particle morphology, and moisture content. Differences in specific material
composition and possible contamination will also affect explosibility parameters. Thus, the information in
Table A.5.2.2 will not apply in all cases.
If dealing with an agricultural dust with unknown explosion or ignition sensitivity when designing explosion
protection or developing risk mitigation strategies, consider testing the dust in accordance with the relevant
ASTM, ISO, or CEN standards so the data being used is as applicable as possible.
Table A.5.2.2 20-L Sphere Test Data — Agricultural Dusts

Percent (1)
P max
Median Minimum Explosive Minimum
Dust Percent < 200 K St
Concentration
Particle Ignition
Name Moisture Mesh
Size (μm) (bar (g/m 3 ) Energy (mJ)
g)
(bar
(%) m/sec)
Alfalfa 2.1 36 83 6.7 94

Angel food cake mix 4.1 41

7.5 132

Apple

155 9 6.7 34 125

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Beet root

108 26 6.1 30 125

Carrageen 3.8

98 8.5 140

Carrot 4.0 29 76 6.9 65

Cereal dust (mixed) 4.4 121

6.7 74 265

Cheesy pasta sauce mix (corn starch and spices) 7.9 <45 68 7.2 99

45
Chili sauce mix (corn starch and spices) 7.0 79 70 6.6 60

74
Cocoa bean dust 2.3 45 100 7.1 133

Cocoa powder 3.9 194 14 8.0 162 65 100–180*

Coconut shell dust 6.5

51 6.8 111

Coffee dust – coarse particles 4.8 321 0.4 6.9 55

160*
Coffee dust – fine particles 4 40 100 7.7 158
Corn (maize) 9.0 165

Corn 8.
7
5
117
192
30
60-75
>10
10<MIE<30
Corn meal
8

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7.
2
15
403 0.6 6.2 47
48 80-100 300-1000
Cornstarch – coarse particles 2.2 217 0.1 7.9 186

30–60*
Cornstarch – fine particles

11 100 9.5 141 60

Cotton

44 72 7.2 24 100

Cottonseed

245 10 7.7 35 125

Fudge brownie mix 4.8 221

5.8 43

Garlic powder

8.6 164

Gluten

150 33 7.7 110 125

Grass dust

200

8.0 47 125

Green coffee 5.0 45 81 7.8 116

Hops (malted)

490 9 8.2 90

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Lemon peel dust 9.5 38 73 6.8 125

Lemon pulp 2.8 180 17 6.7 74

Linseed

300

6.0 17

Locust bean gum 1.7

53 7.8 78

Malt 10.5 72 54 7.5 170

Milk powder 3.1 41 88 7.5 145

Oat flour 4.3 180 0.2 6.8 64

Oat grain dust

295 6.0 14 750

8.03 176 75-100 10<MIE<30

Olive pellets

10.4 74 125

Onion powder

9.0 157

Parmesan sauce mix (corn starch and spices) 6.7 66 60 6.1 45

62
Parsley (dehydrated) 5.4

26 7.5 110

Peach

140 17 8.4 81 60

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Peanut meal and skins 3.8

6.4 45

Peat

74 48 8.3 51 125

Potato

82 30 6 20 250

Potato flakes 8.0 249 7.0 6.2 33

Potato flour

65 53 9.1 69 125

Potato starch

32 100 9.4 89

>3200
Raw yucca seed dust 12.7 403 5 6.2 65

Rice dust
2.5 4
7.
7
07
11840–120*
98

125-150 100-300
Rice flour 12.2 45 100 7.7 140 65 >500
Rice starch

18 90 10 190

Rye flour

29 76 8.9 79

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Semolina 13.6 57 100 7.0 109

Snack mix spices 8.3 85

Soybean dust 2.1 59 7.5 125
6.8 73

Soybean (Dust, Meal, Hulls) 6.73 98 150-200 100-300

Spice dust 10.0

2 6.9 65

Spice powder 10.0

7.8 172

Sugar, fine 1.3 45 100 7.6 117 135 38

Sugar, granulated 2 152 13 6.2 66

Sugar, powdered 13 45 100 7.0 122

30*
Sunflower

420 10 7.9 44 125

Tea 6.3 77 53 7.6 102 125

Tobacco blend 1.0 120

8.0 124

Tomato

200

100

Walnut dust 6.0

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31 8.4 174

Wheat/rice cereal base 2.8 187

5.7 28 150

Wheat/rice cereal base regrinds 6.4 217

6.4 29
Wheat grain dust 80 48 9.3 112 60

Wheat flour 12.9 57 60 8.3 87 60

Wheat (Winter and Spring) 8.41 170 75-100 30-100

Wheat starch

20

9.8 132 60 25–60*

Xanthan gum 8.6 45 91 7.5 61

Yellow cake mix 6.1 219

6.3 73

*The SFPE Handbook of Fire Protection Engineering, 4th Edition, Table 3-18.2
Notes:

(1) Normalized to 1 m3 test vessel pressures, per ASTM E1226, Standard Test Method for Explosibility of
Dust Clouds.
(2) See also Table F.1(a) in NFPA 68 for additional information on agricultural dusts with known explosion
hazards.
(3) For those agricultural dusts without known explosion data, the dust should be tested in accordance with
established standardized test methods.
Source: FM Global, © 2015. Reprinted with permission. All rights reserved.

Additional Proposed Changes

File Name Description Approved

Attached is a file that includes data to add
Proposed_Data_to_Add_to_NFPA_Annex_A.5.2.2.xlsx
to Annex A.5.2.2

Statement of Problem and Substantiation for Public Input

In 2015, the National Grain and Feed Foundation approved funding of a project, at the recommendation of the
National Grain and Feed Association’s Safety, Health and Environmental Quality (SHEQ) Committee, to update
data that measures the combustibility value of various grains and oilseeds.

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The study was designed to provide updated data on the explosibility of particular types of grain dust to assist grain,
feed, processing and milling facilities to identify specific operational and procedural steps that can be used to
mitigate the risk of fire and explosion hazards. Information gained from the study also is designed to be useful to
the industry in complying with the Occupational Safety and Health Administration’s (OSHA) new requirements in
the revised Hazard Communication Standard (HCS) and the National Fire Protection Association’s (NFPA) revised
combustible dust voluntary consensus standards.

The research was conducted because current data referenced in both the OSHA standards and the NFPA
combustible dust voluntary consensus standards are nearly 50 years old and outdated. Further, many current
products in the grain supply chain, such as dried distillers dried grains with solubles (DDGS), canola and sorghum
do not have recognized Kst values.

Therefore, the test data in Table A.5.2.2 should be updated to reflect the results of the study that was conducted by
FIKE.

Submitter Information Verification

Submitter Full Name: Jess McCluer

Organization: National Grain and Feed Association
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 04 16:17:43 EST 2018

Committee Statement

Resolution: CI-13-NFPA 61-2018

Statement: The data that has been submitted (attached) is missing some parameters such as moisture content
and particle size, as well as whether there was inductance in the MIE testing. A task group will be
established to review this data before the Second Draft.

The existing dusts in Table 5.2.2 that have missing data will also be reviewed.

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 Summary of Test Results on Grain Ground and Seived

Kst (bar m/sec) Pmax (bar g) Minimum Explosive Concentration (MEC) (g/m3) Minimum Ignition Energy (MIE) (mJ)
Canola Dust 40 6.15 60-75 10 <MIE<30

Canola Meal 91 7.12 100-125 100-300

DDGS 135 7.64 75-100 10 <MIE<30

Sorghum 124 8.14 100-125 10 <MIE<30

Barley 192 8.74 75-100 10 <MIE<30

Mixed Grain Dust 170 8.27 60-75 10 <MIE<30

Corn Meal 48 7.15 80-100 300-1000

Oat Grain Dust 176 8.03 75-100 10 <MIE<30

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Public Input No. 7-NFPA 61-2017 [ Section No. A.5.2.2 ]

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A.5.2.2

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Data can be from samples within the facility that have been tested or data can be based on whether the
material is known to be combustible or not. There are some published data of commonly known materials,
and the use of these data is adequate to determine whether the dust is a combustible dust. For well-known
commodities, published data are usually acceptable. A perusal of published data illuminates that there is
often a significant spread in values. It is useful, therefore, to compare attributes (such as particle distribution
and moisture content) in published data with the actual material being handled in the system whenever
possible. Doing so would help to verify that the data are pertinent to the hazard under assessment. Even
test data of material can be different from the actual conditions. Users should review the conditions of the
test method as well to ensure that it is representative of the conditions of the facility. Where that is not
possible, the use of worst-case values should be selected. Composition and particle size are two
parameters that are useful to identify the number and location of representative samples to be collected
and tested. (See Section 5.5 for information on sampling.)
These are locations in which combustible dust is in the air in quantities sufficient to produce explosive or
ignitible mixtures under normal operating conditions, or locations where mechanical failure or abnormal
operation of machinery or equipment could cause explosive or ignitible mixtures to be produced, and
combustible dust in the air could provide a source of ignition through simultaneous failure of electrical
equipment, operation of protection devices, or other causes.
Situations can occur in which it is not possible to provide calculated deflagration venting as described in
NFPA 68. Such situations do not justify the exclusion of all venting. The maximum practical amount of
venting should be provided, since some venting should reduce the damage potential. In addition,
consideration should be given to other protection and prevention methods.
Table A.5.2.2 contains examples of test data for selected agricultural dusts with known explosion data
parameters. Other databases, such as the IFA (Institute for Occupational Safety and Health of the German
Social Accident Insurance), GESTIS-DUST-EX Database Combustion, are available for data on explosion
characteristics of dusts.
Please note that the information provided in the table is for the specific agricultural dust sample tested.
Explosion severity and ignition sensitivity parameters are greatly influenced by many factors, including
particle size distribution, particle morphology, and moisture content. Differences in specific material
composition and possible contamination will also affect explosibility parameters. Thus, the information in
Table A.5.2.2 will not apply in all cases.
If dealing with an agricultural dust with unknown explosion or ignition sensitivity when designing explosion
protection or developing risk mitigation strategies, consider testing the dust in accordance with the relevant
ASTM, ISO, or CEN standards so the data being used is as applicable as possible.
Table A.5.2.2 20-L Sphere Test Data — Agricultural Dusts

Percent (1)
P max
Median Minimum Explosive Minimum
Dust Percent < 200 K St
Concentration
Particle Ignition
Name Moisture Mesh
Size (μm) (bar (g/m 3 ) Energy (mJ)
g)
(bar
(%) m/sec)
Alfalfa 2.1 36 83 6.7 94

Angel food cake mix 4.1 41

7.5 132

Apple

155 9 6.7 34 125

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Beet root

108 26 6.1 30 125

Carrageen 3.8

98 8.5 140

Carrot 4.0 29 76 6.9 65

Cereal dust (mixed) 4.4 121

6.7 74 265

Cheesy pasta sauce mix (corn starch and spices) 7.9 <45 68 7.2 99

45
Chili sauce mix (corn starch and spices) 7.0 79 70 6.6 60

74
Cocoa bean dust 2.3 45 100 7.1 133

Cocoa powder 3.9 194 14 8.0 162 65 100–180*

Coconut shell dust 6.5

51 6.8 111

Coffee dust – coarse particles 4.8 321 0.4 6.9 55

160*
Coffee dust – fine particles 4 40 100 7.7 158

Corn (maize) 9.0 165

8.7 117 30 >10

Corn meal 8.2 403 0.6 6.2 47

Cornstarch – coarse particles 2.2 217 0.1 7.9 186

30–60*
Cornstarch – fine particles

11 100 9.5

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141
194 60

Cotton

44 72 7.2 24 100

Cottonseed

245 10 7.7 35 125

Fudge brownie mix 4.8 221

5.8 43

Garlic powder

8.6 164

Gluten

150 33 7.7 110 125

Grass dust

200

8.0 47 125

Green coffee 5.0 45 81 7.8 116

Hops (malted)

490 9 8.2 90

Lemon peel dust 9.5 38 73 6.8 125

Lemon pulp 2.8 180 17 6.7 74

Linseed

300

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6.0 17

Locust bean gum 1.7

53 7.8 78

Malt 10.5 72 54 7.5 170

Milk powder 3.1 41 88 7.5 145

Oat flour 4.3 180 0.2 6.8 64

Oat grain dust

295

6.0 14 750

Olive pellets

10.4 74 125

Onion powder

9.0 157

Parmesan sauce mix (corn starch and spices) 6.7 66 60 6.1 45

62
Parsley (dehydrated) 5.4

26 7.5 110

Peach

140 17 8.4 81 60

Peanut meal and skins 3.8

6.4 45

Peat

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74 48 8.3 51 125

Potato

82 30 6 20 250

Potato flakes 8.0 249 7.0 6.2 33

Potato flour

65 53 9.1 69 125

Potato starch

32 100 9.4 89

>3200
Raw yucca seed dust 12.7 403 5 6.2 65

Rice dust 2.5

4 7.7 118

40–120*
Rice flour 12.2 45 100 7.7 140 65 >500
Rice starch

18 90 10 190

Rye flour

29 76 8.9 79

Semolina 13.6 57 100 7.0 109

Snack mix spices 8.3 85

6.8 73

Soybean dust 2.1

59 7.5 125

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Spice dust 10.0

2 6.9 65

Spice powder 10.0

7.8 172

Sugar, fine 1.3 45 100 7.6 117 135 38

Sugar, granulated 2 152 13 6.2 66

Sugar, powdered 13 45 100 7.0 122

30*
Sunflower

420 10 7.9 44 125

Tea 6.3 77 53 7.6 102 125

Tobacco blend 1.0 120

8.0 124

Tomato

200

100

Walnut dust 6.0

31 8.4 174

Wheat/rice cereal base 2.8 187

5.7 28 150

Wheat/rice cereal base regrinds 6.4 217

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6.4 29

Wheat flour 12.9 57 60 8.3 87 60

Wheat grain dust

80 48 9.3 112 60

Wheat starch

20

9.8 132 60 25–60*

Xanthan gum 8.6 45 91 7.5 61

Yellow cake mix 6.1 219

6.3 73

*The SFPE Handbook of Fire Protection Engineering, 4th Edition, Table 3-18.2
Notes:

(1) Normalized to 1 m3 test vessel pressures, per ASTM E1226, Standard Test Method for Explosibility of
Dust Clouds.
(2) See also Table F.1(a) in NFPA 68 for additional information on agricultural dusts with known explosion
hazards.
(3) For those agricultural dusts without known explosion data, the dust should be tested in accordance with
established standardized test methods.
Source: FM Global, © 2015. Reprinted with permission. All rights reserved.

Statement of Problem and Substantiation for Public Input

An incorrect Kst value for coarse starch was placed in the table last edition. This was confirmed by a previous task
group member.

Submitter Information Verification

Submitter Full Name: Timothy Myers

Organization: Exponent Inc
Street Address:
City:
State:
Zip:
Submittal Date: Tue Nov 07 13:59:00 EST 2017

Committee Statement

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Resolution: FR-14-NFPA 61-2018

Statement: An incorrect Kst value for fine cornstarch was placed in the table last edition. This was confirmed by a
previous task group member.

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Public Input No. 28-NFPA 61-2018 [ Section No. A.6.1.2.1 ]

A.6.1.2.1
The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings
describes , 2nd edition describes the documentation that will be provided for a performance-based design.
[652:A.6.1.2.1]
Proper documentation of a performance-based design is critical to design acceptance and construction.
Proper documentation will ensure that all parties involved understand the factors necessary for the
implementation, maintenance, and continuity of the fire protection design. If attention to detail is maintained
in the documentation, there should be little dispute during approval, construction, startup, and use.
[652:A.6.1.2.1]
Poor documentation could result in rejection of an otherwise good design, poor implementation of the
design, inadequate system maintenance and reliability, and an incomplete record for future changes or for
testing the design forensically. [652:A.6.1.2.1]

Statement of Problem and Substantiation for Public Input

Edit to provide correct title of the SFPE Guide.

Submitter Information Verification

Submitter Full Name: Chris Jelenewicz

Organization: SFPE
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 04 13:40:02 EST 2018

Committee Statement

Resolution: FR-15-NFPA 61-2018

Statement: Edit to provide correct title of the SFPE Guide and update extracted material.

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Public Input No. 29-NFPA 61-2018 [ Section No. A.6.1.3 ]

A.6.1.3
Chapter 5 of NFPA 101 provides a more complete description of the performance-based design process
and requirements. In addition, the SFPE Engineering Guide to Performance-Based Fire Protection
Analysis and Design of Buildings outlines , 2nd edition outlines a process for developing, evaluating, and
documenting performance-based designs. [652:A.6.1.3]

Statement of Problem and Substantiation for Public Input

Edits needed to provide correct title of the SFPE guide.

Submitter Information Verification

Submitter Full Name: Chris Jelenewicz

Organization: SFPE
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 04 13:50:20 EST 2018

Committee Statement

Resolution: FR-16-NFPA 61-2018

Statement: Edits needed to provide correct title of the SFPE guide and update extracted material.

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Public Input No. 30-NFPA 61-2018 [ Section No. A.6.5.1 ]

A.6.5.1
The SFPE Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings ,
2nd edition outlines a process for evaluating whether trial designs meet the performance criteria.
[652:A.6.5.1]

Statement of Problem and Substantiation for Public Input

Edits need to provide correct title of the SFPE Guide

Submitter Information Verification

Submitter Full Name: Chris Jelenewicz

Organization: SFPE
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 04 13:57:04 EST 2018

Committee Statement

Resolution: FR-17-NFPA 61-2018

Statement: Edits need to provide correct title of the SFPE Guide and updates extracted material.

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Public Input No. 6-NFPA 61-2017 [ Section No. B.6 ]

B.6 Manual Fire Suppression.

Those individuals responsible for manual fire suppression at these types of facilities should have a fire
protection plan. This plan should meet the recommendations contained in the National Grain and Feed
Association Research Report, Emergency Preplanning and Fire Fighting Manual — A Guide for Grain
Elevator Operators and Fire Department Officials.
This section should be deleted, as obtaining a copy was very difficult and I was advised by the National Feed
and Grain Association that this information was "dated".
The following is an email from the NGFA VP of Safety and Regulatory Affairs:
Travis –
Probably the main reason that you haven’t heard back from anyone is that we have been tied up with our
annual convention in New Orleans over the past 5 days.
I’ll have a copy mailed to you shortly. Please send me your mailing address.
The document was created in 1987 and was last updated in 1998 so it is a bit dated.
Regards,
Jess
Jess McCluer , Vice President, Safety and Regulatory Affairs
National Grain and Feed Association
[email protected] | (202) 289-0873 | (202) 289-5388 (f)

Statement of Problem and Substantiation for Public Input

Locating the National Grain and Feed Association Research Report Titled: Emergency Planning and Fire Fighting
Manual- A Guide for Grain Elevator Operators and Fire Department Official was very difficult (2 months to receive)
and the information was dated. Please provide a more recent suggestion on how to handle manual fire fighting
operations at Grain Elevators and/or Dryers.

Submitter Information Verification

Submitter Full Name: Travis Moore

Organization: Tate and Lyle
Street Address:
City:
State:
Zip:
Submittal Date: Sat May 20 06:13:54 EDT 2017

Committee Statement

Resolution: The information in the report is still relevant and, while only available in hard copy form, copies can be
requested from the National Grain and Feed Association.

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National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...

Public Input No. 33-NFPA 61-2018 [ Section No. G.1.2.6 ]

G.1.2.6 Other Publications.

FM Global Data Sheet 10-3, Hot Work Management.
SFPE, Engineering Guide to Performance-Based Fire Protection Analysis and Design of Buildings, 2000. ,
2006
SFPE, Handbook of Fire Protection Engineering, 2008 2016 ..

Statement of Problem and Substantiation for Public Input

Update correct versions of identified references.

Submitter Information Verification

Submitter Full Name: Chris Jelenewicz

Organization: SFPE
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 04 14:25:20 EST 2018

Committee Statement

Resolution: FR-18-NFPA 61-2018

Statement: Update correct versions of identified references.

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