National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org
TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS
NFPA 61 CMD-AGR (A2016)
Second Draft Meeting
Kansas City Marriott Country Club Plaza
4445 Main Street
Kansas City, MO 64111
Tuesday through Thursday July 7th – July 9th from 8:00 am to 5:00 pm
1. Meeting is called to order at 8 AM each day.
2. Welcome and Self-Introduction of Committee Members and Guests
3. Chair and Staff Liaison Remarks
4. Approve Minutes from the last meeting (attached)
5. Review of material from the April second draft meeting
o Response to Correlating Committee Notes
o Draft Second Revisions
o Pending task group items
6. Review of Public Comments
7. Old Business
8. New Business
9. Adjournment – Meeting will adjourn at 5 pm each day.
TECHNICAL COMMITTEE ON AGRICULTURAL DUSTS
Minutes of Meeting – NFPA 61 Second Draft Meeting March 31st - April 3, 2015, 2015
St. Petersburg, Florida
Member Attending
Timothy Myers – chair yes Principal
Donald Ankele no Principal
Amy Brown yes Principal
Matt Bujewski yes Principal
Ashok Dastidar yes – by phone Principal
Brian Eklow yes Principal
Craig Froehling yes Principal
Dan Guaricci no Principal
Kevin Hudson no Principal
William Janz yes Principal
William Kearns yes Principal
William Kinslow no Principal
James Maness yes Principal
Jess McCluer yes Principal
Bruce McLelland yes Principal
Karl Nitsch no Principal
Jack Osborn yes Principal
Michael Peters yes Principal
Kent Quinney yes Principal
Jeffrey Rogers yes Principal
Mark Runyon yes Principal
Lee Sargent yes Principal
Robert Shafto yes Principal
Jeffrey Sutton yes Principal
P.D. (Nick) Thielen yes Principal
Erdem Ural Yes –by phone Principal
Clyde Waller No Principal
Stephen Wees Yes – by phone Principal
Anthony Yount Yes Principal
Chris Aiken Yes Alternate
Venkateswara Bhamidipati Yes Alternate
David Clayton No Alternate
Brian Deutsch Yes Alternate
Paul Kelley No Alternate
Steven McCoy Yes – by phone Alternate
Glen Mortensen No Alternate
Jim Norris Yes Alternate
Ronald Stein No Alternate
Peter Telthorst Yes Alternate
Matthew Chibbaro No Nonvoting
William Hamilton No Nonvoting
Robert Nelson No Member Emeritus
Susan Bershad Yes NFPA staff
Merrill Childs Yes Guest – Cargill
Robert Gombar Yes Guest – representing USBSA
Franz Albert Yes Guest – representing ATEX
Dean Heaning Yes Guest – representing Arden Mills
1.0 The meeting was called to order at 8 am by Tim Myers, chair. The attendees, guests,
and those attending via the web conference made self-introductions. 2.0 The minutes from the August 2014 first draft meeting were reviewed and approved. 3.0 Susan Bershad, NFPA staff, gave a brief presentation on the second draft process,
including the schedule for the A2016 cycle, membership, and the status of NFPA 652. This meeting is the first of two second draft meetings for NFPA 61. Since public comment for 61 does not close until May 15, the focus of this meeting was a review of the correlating committee notes for the first draft of 61, as well as a review of the work done by task groups.
4.0 The committee began with a review of the correlating notes for the first draft. The committee developed draft responses to the correlating committee on each of the notes. NFPA staff will circulate these responses to the committee for final review at the meeting in July.
5.0 The consensus of the committee is that 61 should be a stand-alone document that addresses all of the key requirements in 652, ratherthan referencing or relying on material in 652. This is for ease of use by a user of 61, who should not have to consult two separate documents. The committee will be working on aligning 61 with 652 in terms of structure and in terms of content as appropriate. This is in response to several of the correlating committee notes on the first draft. It is expected that this alignment may take more than one revision cycle.
6.0 The committee reviewed the work of several task groups, developing several proposed second revisions to the document. These include revisions to Chapter 3 to
align the definitions in 61 with the other dust documents, as well as new chapters on general requirements, hazard identification, performance based design and management systems to align with 652. NFPA staff will review and distribute all of the draft changes to the 61 technical committee prior to the meeting in August for review.
7.0 There were two new task groups set up at the meeting. 7.1 Checklist task group – Review checklist/examples for dust hazard analysis for
agricultural dust applications. This would be used as annex material. Members of this group are: Mark Runyon, Merrill Childs, Peter Telthorst, and Jeff Rodgers
7.2 Bucket/elevator speed/capacity exemption – Review the history of the speed/capacity exemptions in 5.4. This is in response to a correlating committee note. Based on the results of the research, the task group should consider a recommendation to the TC as to whether or not to keep the exemption. Members of this group are: Anthony Yount, Kent Quinney, Jim Manness, Peter Telthorst, Jack Osborn, and Amy Brown.
8.0 The public comment period for 61 closes on May 15th. Once this deadline has passed, NFPA staff will distribute public comments to the TC as soon as possible to enable the committee to review this material.
9.0 The meeting adjourned at 10:00 am on April 3rd. 10.0 The next meeting will be the continuation of the second draft meeting. It is
scheduled for July 7th through the 10th in Kansas City. Additional details, including the hotel block and RSVP link, are available on the document information page.
Correlating Committee Note No. 1-NFPA 61-2014 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: National Fire Protection Assoc
Street Address:
City:
State:
Zip:
Submittal Date: Tue Dec 16 16:16:30 EST 2014
Committee Statement
CommitteeStatement:
The Correlating Committee recommends that the 61 technical committee reconsider FR-52. Thestatement is considered to be broad and overreaching. The 61 committee is encouraged to review61 in more detail to determine how it aligns with NFPA 652. Please refer to CN # 3 for direction onaligning the layout and content of 61 with NFPA 652. It is understood by the correlating committeethat this alignment will be a process that may need to take place over several revision cycles.
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Correlating Committee Note No. 13-NFPA 61-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 20:24:54 EST 2015
Committee Statement
CommitteeStatement:
The Correlating Committee recommends that the 61 TC consider pointing the user in thedirection of NFPA 87 and NFPA 30 for guidance on heat transfer systems. This may be bestaccomplished through the addition of annex material.
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Correlating Committee Note No. 14-NFPA 61-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: National Fire Protection Assoc
Street Address:
City:
State:
Zip:
Submittal Date: Fri Jan 09 09:35:23 EST 2015
Committee Statement
CommitteeStatement:
The Correlating Committee recognizes the 61 technical committee for the significant progressthey have made in this first draft.
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Correlating Committee Note No. 15-NFPA 61-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: National Fire Protection Assoc
Street Address:
City:
State:
Zip:
Submittal Date: Fri Jan 09 10:42:50 EST 2015
Committee Statement
CommitteeStatement:
The 61 technical committee should consider including the language in Section 1.4.1 ofNFPA 654 -
1.4.1
This standard shall be used to supplement the requirements established by NFPA 652.
This clarifies the relationship between 652 and the commodity-specific standards.
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Correlating Committee Note No. 16-NFPA 61-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: National Fire Protection Assoc
Street Address:
City:
State:
Zip:
Submittal Date: Fri Jan 09 11:08:13 EST 2015
Committee Statement
CommitteeStatement:
The Correlating Committee recommends that the 61 technical committee consider adding thefollowing material to the proposed new chapter on general requirements. This material was addedto the first draft of 654 as well as 664. This recommendation is also being made to 484 and 655 asthey enter their revision cycles.
4.1.3 Owner's Obligation.
The facility owner/operator shall be responsible for ensuring that the facility and the systemshandling combustible particulate solids are designed, installed, and maintained in accordance withthe requirements of this standard and NFPA 652
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Correlating Committee Note No. 2-NFPA 61-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 19:25:43 EST 2015
Committee Statement
CommitteeStatement:
The 61 technical committee should review the definitions in Chapter 3 for consistency with 652. Thedefinitions in Chapter 3 of 652 should be considered a baseline for those in the other dustdocuments. In some cases, the occupancy specific document may elect to define a term differently.In those cases, the rationale for the differences should be documented. Note that this comment isalso being made to the 654 and the 664 technical committees, and will be made to the 655 and 484committees as they go through their next revision cycle.
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Correlating Committee Note No. 3-NFPA 61-2015 [ Global Input ]
Supplemental Information
File Name Description
652_outline.docx
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 19:28:09 EST 2015
Committee Statement
CommitteeStatement:
The 61 technical committee should review the layout of the document for consistency with NFPA652. The chapter layout for the commodity specific standards should align with the layout of NFPA652 in order to facilitate their use with NFPA 652 in accordance with section 1.4.2 of NFPA 652. Thiscomment is also being made to the 654 and 664 technical committees, and will be made to the 655and 484 technical committees as they go through the next revision cycle.
The Correlating Committee is providing an outline taken from 652 to assist the commodity specificcommittees with their expected alignment to 652 over the next revision cycles. In addition the outlineincludes the level of subsection that a user would use to compare 652 to an industry specificstandard. This is the minimum level of alignment expected, the committee is free to go beyond thislevel. Note that the unhighlighted sections are those that should be used. It is expected that this maynot be able to be completed in the current revision cycle, but this a goal that committees should worktoward.
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652 Chapter 1 Administration
1.1 Scope
1.2 Purpose
1.3 Application
1.4 Conflicts
1.5 Retroactivity
1.6 Equivalency
1.7 Units and Formulas
Chapter 2 Referenced Publications
2.1 General
2.2 NFPA Publications.
2.3 Other Publications
2.4 References for Extracts in Mandatory Sections
Chapter 3 Definitions
Committees should align with 652 definitons
Chapter 4 General Requirements
4.1* General
4.2 Objectives
4.2.1 Life Safety
4.2.2* Mission Continuity
4.2.3 Mitigation of Fire Spread and Explosions
Chapter 5 Hazard Identification
5.1* Responsibility
5.2 Overview Screening for Combustibility and Explosibility
5.3* Self-Heating and Reactivity Hazards (Reserved)
5.4 Combustibility and Explosibility Tests
5.4.1* Determination of Combustibility
5.4.2 Determination of Flash Fire Hazard (Reserved)
5.4.3 Determination of Explosibility
5.4.4 Quantification of Combustibility and Explosibility Characteristics
5.5 Sampling
5.5.1 Sampling Plan
5.5.2 Mixtures
5.5.3 Representative Samples
Chapter 6 Performance-Based Design Option
6.1* General Requirements
6.1.12 Approved Qualifications
6.1.2* Document Requirements
6.1.4 Sources of Data
6.1.5* Maintenance of the Design Features
6.2 Risk Component and Acceptability (Reserved)
6.3 Performance Criteria
6.3.1 Life Safety
6.3.2 Structural Integrity
6.3.3 Mission Continuity
6.3.4 Mitigation of Fire Spread and Explosions
6.3.5 Effects of Explosions
6.4* Design Scenarios
6.4.1 Fire Scenarios
6.4.2 Explosion Scenarios
6.5 Evaluation of Proposed Design
Chapter 7 Dust Hazard Analysis
7.1* General Requirements
7.1.1 Responsibility
7.2 Criteria
7.2.1* Overview
7.2.2* Qualifications
7.2.4 Documentation
7.3 Methodology
7.3.1 General
7.3.2 Material Evaluation
7.3.3 Process Systems
7.3.4 Facility Compartments
Chapter 8 Hazard Management: Mitigation and Prevention
8.1 Inherently Safe Designs (Reserved)
8.2 Building Design
8.2.1* Construction
8.2.2 Building/Room Protection
8.2.3 Life Safety
8.2.5 Separation of Hazard Areas from Other Hazard Areas and from Other Occupancies
8.3 Equipment Design
8.3.1* Risk Assessment
8.3.2* Design for Dust Containment
8.3.3* Pneumatic Conveying, Dust Collection, and Centralized Vacuum Cleaning Systems
8.3.4 AMS Locations
8.3.5 Recycle of AMS Clean Air Exhaust AMS
8.3.6 Transfer Points (Reserved)
8.4 Housekeeping
8.4.1 General
8.4.2* Methodology
8.4.3 Training
8.4.4 Equipment (Reserved)
8.4.5 Vacuum Trucks
8.4.6 Frequency and Goal
8.4.7 Auditing and Documentation
8.5 Ignition Source Control
8.5.1* General
8.5.2* Risk Assessment
8.5.3 Hot Work
8.5.5 Bearings
8.5.6 Electrical Equipment and Wiring
8.5.7 Electrostatic Discharges
8.5.8 Open Flames and Fuel Fired Equipment
8.5.9 Industrial Trucks
8.5.10 Process Air and Media Temperatures
8.5.11 Self-Heating
8.5.12 Friction and Impact Sparks
8.6 Personal Protective Equipment
8.6.1 Workplace Hazard Assessment
8.6.2 Limitations of PPE Application (Flame-Resistant Garments)
8.6.3 Limitations of PPE to Combustible Dust Flash-Fires (Reserved)
8.6.4 Face, Hands, and Footwear Protection (Reserved)
8.x Pyrophoric Dusts (Reserved)
8.7 Dust Control
8.7.2* Liquid Dust Suppression Methods for Dust Control
8.7.3 Fans to Limit Accumulation (Reserved)
8.8 Explosion Prevention/Protection
8.8.1 General
8.8.2 Risk Assessment
8.8.3 Equipment Protection
8.8.4 Equipment Isolation
8.9 Fire Protection
8.9.1 General
8.9.3 Fire Extinguishers
8.9.4 Hose, Standpipes, Hydrants, and Water Supply
8.9.5 Automatic Sprinklers
8.9.6 Spark/Ember Detection and Extinguishing Systems
8.9.7 Special Fire Protection Systems
Chapter 9 Management Systems
9.1 Retroactivity
9.2* General
9.3 Operating Procedures and Practices
9.4 Inspection, Testing, and Maintenance
9.5 Training and Hazard Awareness
9.6 Contractors
9.6.3* Contractor Training
9.7 Emergency Planning and Response
9.8* Incident Investigation
9.9 Management of Change
9.10* Documentation Retention
9.11 Management Systems Review
9.12* Employee Participation
Correlating Committee Note No. 4-NFPA 61-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 19:30:29 EST 2015
Committee Statement
CommitteeStatement:
The 61 technical committee should review the document to ensure that retroactivity is handledconsistently with the other combustible dust documents. Those sections that are to be appliedretroactively should be explicitly designated in the document section. Typically, management systemelements that do not require capital improvements, such as training and housekeeping, areretroactive. This comment is also being made to the 654 and 664 technical committees and will bemade to the 655 and the 484 technical committees as they go through their next revision cycle.
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Correlating Committee Note No. 5-NFPA 61-2015 [ Global Input ]
Supplemental Information
File Name Description
Draft_Objectives_for_CC_review.docx
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 19:31:48 EST 2015
Committee Statement
CommitteeStatement:
The 61 committee should consider aligning their objectives with those presented in attacheddocument developed by the correlating committee task group on objectives. The correlatingcommittee would like to work towards having all of the dust documents have similar objectives. Thisdocument is a product of a task group with representation from all of the combustible dustcommittees and represents the direction the correlating committee would like to head in. Thisrecommendation is also being made to the 654 and the 664 technical committees, and will be madeto the 484, 655, and 652 technical committees as they enter the next revision cycle.
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NFPA 652 – Draft Objectives for CC review (product of the objectives task group) 4.2 Objectives. 4.2.1 The design of the facility, processes and equipment shall be based upon the goal of providing a reasonable level of safety and property protection by meeting the following objectives:
1.) Life Safety 2.) Mission Continuity 3.) Mitigation of Fire Spread and Explosions
4.2.1.1 The objectives stated in Section 4.2 shall be interpreted as intended outcomes of this standard and not as prescriptive requirements.
4.2.1.2 The objectives stated in Section 4.2 shall be deemed to be met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6,
1.) the facility, processes and equipment are designed, constructed and maintained in accordance with the prescriptive criteria set forth in this standard, and
2.) The management systems set forth in this standard are implemented.
4.2.1.3 Where a performance-based alternative design is used, it shall be documented to meet the same objectives as the prescriptive design it replaces, in accordance with Chapter 6 of this standard.
4.2.2 Life Safety. The life safety objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the occupants not in the immediate proximity of the ignition are protected from the effects of fires, flash-fires, and explosions for the time needed to evacuate, relocate, or take refuge in order to prevent serious injury. 4.2.3* Mission Continuity. The mission continuity objective shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the protection features for the facility, processes and equipment limit damage to levels that ensure the ongoing mission, production, or operating capability of the facility to a degree acceptable to the owner/operator. A.4.2.3 Other stakeholders could also have mission continuity goals that will necessitate more stringent objectives as well as more specific and demanding performance criteria. The protection of property beyond maintaining structural integrity long enough to escape is actually a mission continuity objective.
The mission continuity objective encompasses the survival of both real property, such as the building, and the production equipment and inventory beyond the extinguishment of the fire. Traditionally, property protection objectives have addressed the impact of the fire on structural elements of a building as well as the equipment and contents inside a building. Mission continuity is concerned with the ability of a structure to perform its intended functions and with how that affects the structure's tenants. It often addresses post-fire smoke contamination, cleanup, and replacement of damaged equipment or raw materials. 4.2.4* Mitigation of Fire Spread and Explosions. The mitigation of fire spread and explosions shall be deemed to have been met when, consistent with the goal in Section 4.2.1 and the provisions in Sections 1.4 and 1.6, the prescribed or performance based alternative design features are incorporated into the facility and processes to prevent or mitigate fires and explosions that can cause failure of adjacent buildings or building compartments, or other enclosures, emergency life safety systems, adjacent properties, adjacent storage, or the facility's structural elements. A.4.2.4 Adjacent compartments share a common enclosure surface (wall, ceiling, floor) with the compartment of fire or explosion origin. The intent is to prevent the collapse of the structure during the fire or explosion. 4.2.5 Where a dust fire, deflagration, or explosion hazard exists within a process system, the hazards shall be managed in accordance with this standard. 4.2.6 Where a dust fire, deflagration, or explosion hazard exists with a facility compartment, the effects of the fire, deflagration, or explosion shall be managed in accordance with this standard. 4.2.7* Compliance Options. The objectives in Section 4.2 shall be achieved by either of the following means:
1. A prescriptive approach in accordance with Chapters 5, 7, 8, and 9 in conjunction with any additional prescriptive provisions of applicable commodity-specific NFPA standards.
2. A performance-based approach in accordance with Chapter 6.
A.4.2.7
Usually a facility or process system is designed using the prescriptive criteria until a prescribed solution is found to be infeasible or impracticable. Then the designer can use the performance-based option to develop a design, addressing the full range of fire and explosion scenarios and the impact on other prescribed design features. Consequently, facilities are usually designed not by using performance-based design methods for all facets of the facility but rather by using a mixture of both design approaches as needed.
Correlating Committee Note No. 6-NFPA 61-2015 [ Global Input ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 19:51:07 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends that the 61 technical committee review the exceptions forbucket elevators with capacities less than 106 m3/hr (3750 ft3/hr) found in sections 7.5.1.10.4,7.5.2.1, and 7.5.3.3.1. The 61 committee should provide technical justification for these exceptionsor remove them. Note that these exceptions have been removed from NFPA 654.
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Correlating Committee Note No. 11-NFPA 61-2015 [ New Section after 4.1.3 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 20:15:11 EST 2015
Committee Statement
CommitteeStatement:
The Correlating Committee recommends that the 61 technical committee consider includingsegregation and detachment as management strategies for consistency with the other combustibledust documents. In addition to including the other two management strategies, the 61 technicalcommittee should include the definitions for these terms, as extracted from NFPA 652, in Chapter 3of NFPA 61.
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Correlating Committee Note No. 9-NFPA 61-2015 [ Section No. 4.4.3.1 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 20:08:30 EST 2015
Committee Statement
CommitteeStatement:
The correlating committee recommends that the 61 technical committee review the use of the termfire-resistance in this section. 654 made several first revisions changing the term fire-resistancerating to fire-protection rating for doors. The 61 committee should review the changes in 654 andensure that it used the proper term throughout the document. This is a correlating issue between thedocuments.
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Correlating Committee Note No. 10-NFPA 61-2015 [ Section No. 6.2 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 20:11:57 EST 2015
Committee Statement
CommitteeStatement:
The Correlating Committee recommends that the 61 technical committee review the use of theterm "combustion explosion" in this section. This terminology is not consistent with those usedthroughout the other combustible dust standards.
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Correlating Committee Note No. 7-NFPA 61-2015 [ Section No. 7.4.2 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 19:58:21 EST 2015
Committee Statement
CommitteeStatement:
The 61 technical committee should review FR-18 in light of the negative comments, specificallythose that suggest that the provisions conflict with those in NFPA 68.
First Revision No. 18-NFPA 61-2014 [Section No. 7.4.2]
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Correlating Committee Note No. 8-NFPA 61-2015 [ New Section after 13.11 ]
Submitter Information Verification
Submitter Full Name: Susan Bershad
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 08 20:00:22 EST 2015
Committee Statement
CommitteeStatement:
The Correlating Committee recommends that the 61 technical committee review its action relatingto FR-50. The proposed text does not meet the standard of care established by the othercombustible dust documents such as NFPA 652 and 654 with regards to dust hazard analysis(DHA).
The Correlating Committee recognizes the work of the 61 technical committee. It is aware that thecommittee has a task group that is working on this issue for the second draft. The CorrelatingCommittee encourages the 61 technical committee to review the material in NFPA 652 and strive towork towards the goals and objectives addressed in chapters 5 and 7 of NFPA 652.
First Revision No. 50-NFPA 61-2014 [New Section after 13.11]
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Public Comment No. 8-NFPA 61-2015 [ Section No. 1.5.4 ]
1.5.4
The requirements of Chapter 13 shall apply to all facilities, both new and existing.
Statement of Problem and Substantiation for Public Comment
This language should be moved from Chapter 1 into a new Section 13.1 in Chapter 13, as suggested there. Reason: The Correlating Committee Note suggested moving retroactivity provisions into the specific chapters and sections where they apply.
Related Item
Correlating Committee Note No. 4-NFPA 61-2015 [Global Input]
Submitter Information Verification
Submitter Full Name: ARTHUR SAPPER
Organization: McDermott Will & Emery
Affilliation: United States Beet Sugar Association
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 14 09:35:30 EDT 2015
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Public Comment No. 9-NFPA 61-2015 [ Section No. 1.5.5 ]
1.5.5
When renovation of existing facilities is planned, provisions or a substantial renovation is made to anexisting facility or process, the provisions of this standard shall apply to that the renovated portion of thefacility or process.
1.5.5.1 For purposes of applying 1.5.5, a substantial renovation is one that exceeds 25 percent of the totalreplacement cost of the facility or process.
Statement of Problem and Substantiation for Public Comment
As currently written, Sec. 1.5.5 is overbroad in two respects. It will make the provisions of NFPA 61 apply to an existing facility or process if any renovation, regardless of its size and scope, is merely planned, even if the renovation is never actually made. As so written, Sec. 1.5.5 substantially undercuts the grandfather provision in Sec. 1.5.1 of NFPA 61. The 25 percent figure in the new Sec. 1.5.5.1 is based on Sec. 7.1.2.3 of NFPA 652, Second Draft.
Related Item
First Revision No. 10-NFPA 61-2014 [Chapter 1]
Submitter Information Verification
Submitter Full Name: ARTHUR SAPPER
Organization: MCDERMOTT WILL EMERY LLP
Affilliation: United States Beet Sugar Association
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 14 09:46:47 EDT 2015
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Public Comment No. 1-NFPA 61-2015 [ Section No. 2.3 ]
2.3 Other Publications.
2.3.1 AMCA Publications.
Air Movement and Control Association International, Inc., 30 West University Drive, Arlington Heights, IL60004-1893.
ANSI/ AMCA Standard 99, Standards Handbook, Standard 99-0401-86, Classifications for SparkResistant Construction , 2010 .
2.3.2 ASME Publications.
American Society of Mechanical Engineers ASME International , Two Park Avenue, New York, NY10016-5990.
ASME Unfired ASME Boiler and Pressure Vessel Code, Section VIII, “Rules Division I, “Rules forConstruction of Pressure Vessels,” 2013 2015 .
2.3.3 ISA Publications.
International Society of Automation, 67 T.W. Alexander Drive, P.O. Box 12277, Research Triangle Park, NC27709.
ANSI/ISA 84.00.01, Functional Safety: Safety Instrumented Systems for the Process Industry Sector, 2004.
2.3.4 MSHA Publications.
Mine Safety and Health Administration (MSHA), 1100 Wilson Boulevard, 21st Floor, Arlington VA22209-3939.
MSHA Title 30 Code of Federal Regulations, Part 18, Section 18.65, "2G Test".
2.3.5 Other Publications.
Merriam-Webster's Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.
Statement of Problem and Substantiation for Public Comment
Referenced current edition of AMCA Standard 99, and updated ASME name.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 10-NFPA 61-2015 [Section No. F.1.2]
Related Item
First Revision No. 57-NFPA 61-2014 [Section No. 2.3]
Submitter Information Verification
Submitter Full Name: Aaron Adamczyk
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Sun Mar 01 23:40:38 EST 2015
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Public Comment No. 2-NFPA 61-2015 [ Section No. 4.2.4.1 ]
4.2.4.1 *
Separation shall be permitted allowed to be used to limit the dust explosion hazard or deflagration hazardarea within a building if the separation is supported by a documented evaluation and approved .
Statement of Problem and Substantiation for Public Comment
Using the word “allowed” is more descriptive. The word “permitted” seems like there is a permit attached to the requirement. Adding “and approved” at the end of the requirement will require it to be acceptable to the AHJ as defined. We agree with the original Public Input and the Negative with Comment that suggests the AHJ must approve such separations.
Related Item
First Revision No. 3-NFPA 61-2014 [New Section after 4.1.3]
Submitter Information Verification
Submitter Full Name: Jim Muir
Organization: Building Safety Division, Clark County, WA
Affilliation: NFPA's Building Code Development Committee (BCDC)
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 05 14:12:23 EDT 2015
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Public Comment No. 3-NFPA 61-2015 [ Section No. 4.2.6.3.1 ]
4.2.6.3.1
For existing facilities, Distances less than 30 m (100 ft) but in no case less than 15 m (50 ft) shall bepermitted where any of the following conditions exist:
(1) The property boundaries or other permanent constraints preclude 30 m (100 ft).
(2) Structures do not have inside legs.
(3) Structures have inside legs that are equipped with explosion protection equipment in accordance withChapter 7.
Statement of Problem and Substantiation for Public Comment
NFPA Today indicates that there were 50 combustible dust accidents resulting in 29 fatalities and 161 injuries between 2008 and 2012. Recent agricultural dust explosions have shown that separations are necessary. The BCDC agrees with the negative comment. If the TC is going to allow this exception, it should only apply to existing facilities. This should not encourage new facilities to be built near property boundaries or other permanent constraints. As pointed out, even a 30 m distance does not preclude all hazards.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 4-NFPA 61-2015 [Section No. 4.2.6.4.1]
Related Item
First Revision No. 7-NFPA 61-2014 [Section No. 4.1.5.3]
Submitter Information Verification
Submitter Full Name: Jim Muir
Organization: Building Safety Division, Clark County, WA
Affilliation: NFPA's Building Code Development Committee (BCDC)
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 05 14:16:50 EDT 2015
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Public Comment No. 4-NFPA 61-2015 [ Section No. 4.2.6.4.1 ]
4.2.6.4.1
For existing facilities, Distances less than 15 m (50 ft) shall be permitted if the property boundaries or otherpermanent constraints preclude 15 m (50 ft), but in no case shall distances less than 9 m (30 ft) bepermitted.
Statement of Problem and Substantiation for Public Comment
NFPA Today indicates that there were 50 combustible dust accidents resulting in 29 fatalities and 161 injuries between 2008 and 2012. Recent agricultural dust explosions have shown that separations are necessary. The BCDC agrees with the negative comment. If the TC is going to allow this exception, it should only apply to existing facilities. This should not encourage new facilities to be built near property boundaries or other permanent constraints.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 3-NFPA 61-2015 [Section No. 4.2.6.3.1] similar
Related Item
First Revision No. 8-NFPA 61-2014 [Section No. 4.1.5.4]
Submitter Information Verification
Submitter Full Name: Jim Muir
Organization: Building Safety Division, Clark County, WA
Affilliation: NFPA's Building Code Development Committee (BCDC)
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 05 14:19:29 EDT 2015
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Public Comment No. 11-NFPA 61-2015 [ New Section after 13.1 ]
TITLE OF NEW CONTENT
Add a new Section 13.1:
13.1 The requirements of Chapter 13 shall apply to all facilities, both new and existing.
Statement of Problem and Substantiation for Public Comment
This text was just moved from Sec. 1.5.4. See the comment there about the reason for moving it, that is, that the Correlating Committee Note suggested moving retroactivity provisions into the specific chapters and sections where they apply.
Related Item
Correlating Committee Note No. 4-NFPA 61-2015 [Global Input]
Submitter Information Verification
Submitter Full Name: ARTHUR SAPPER
Organization: MCDERMOTT WILL EMERY LLP
Affilliation: United States Beet Sugar Association
Street Address:
City:
State:
Zip:
Submittal Date: Fri May 15 09:57:21 EDT 2015
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Public Comment No. 12-NFPA 61-2015 [ Section No. 13.12 ]
Move all of Section 13.12 (Management Practices) into one or more new chapters and re-numberaccordingly.
13.12 Management Practices.
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13.12.1 Determination of Hazards of Agricultural Dust .
The requirements of 13.12.1.1 through 13.12.1.3 shall be permitted to be used instead of those in Section4.2 and in Chapter 5 of NFPA 652.
13.12.1.1
It shall be permitted to assume that an agricultural dust or mixture is explosible and combustible and toassume worst-case characteristics as a basis for actions, such as design or housekeeping, and as a basisupon which to meet requirements under this standard, such as an agricultural dust hazard survey.
13.12.1.2
The user shall be permitted to rely upon existing historical facility data and published data for explosiveproperties of dust to evaluate dust hazards.
13.12.1.3*
Test results, historical data, and published data shall be documented and, when requested, provided to theauthority having jurisdiction (AHJ). [652:5.2.2]
13.12.2 Agricultural Dust Hazard Survey.
The requirements of 13.12.2.1 through 13.12.2.4 shall be permitted to be used instead of those inChapter 7 of NFPA 652.
13.12.2.1 Scope.
The requirements in 13.12.2.2 through 13.12.2.4 apply to facilities that have agricultural or food dust.
13.12.2.2*
The owner/operator shall, within 5 years of the effective date of this standard, determine whether the facilityis in compliance and, if not, how the facility will be brought into compliance with this standard, and shallinclude a list of compliance steps.
13.12.2.3*
The survey shall include consideration of the following:
(1) Which persons, if any, are required to wear flame-resistant garments. It shall be permitted to consultNFPA 2113 in such consideration. The requirements of 13.12.2.3(1) shall be permitted to be usedinstead of those of 8.6.1.1 of NFPA 652.
(2) Whether separation shall be permitted to be used to limit the dust explosion or deflagration hazardarea within a building and whether detachment shall be permitted to limit the dust explosion hazard ordeflagration hazard area to a building physically separated from adjacent or surrounding exposures.The requirements of 13.12.2.3(2) shall be permitted to be used instead of those of 8.2.5.3 and 8.2.5.4of NFPA 652.
13.12.2.4
Further changes to facilities, equipment, and dusts shall be made in accordance with the management ofchange provision in 13.12.3.
13.12.3 Management of Change.
The requirements of 13.12.3.1 through 13.12.3.2.1 shall be permitted to be used instead of those ofSection 9.9 of NFPA 652.
13.12.3.1 Scope.
The requirements in 13.12.3.1 through 13.12.3.2.1 shall apply to facilities that have agricultural dust orfood dust.
13.12.3.2
After 3 months of the effective date of this standard, the owner/operator shall require that a personknowledgeable in the fire and deflagration hazards of agricultural dust be informed of changes (other thanreplacements in kind) to facilities, equipment, or processed materials before implementation of the change,if feasible, or if not, immediately after implementation.
13.12.3.2.1
The knowledgeable person shall consider whether or not the change would comply with NFPA 61. If thechange does not comply, then a method of compliance shall be determined.
Statement of Problem and Substantiation for Public Comment
The Management Practices provisions are substantially different from the other provisions in Chapter 13 and should be set out separately to facilitate a comparison with the chapters and sections in NFPA 652 that cover the same issues.
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Related Item
First Revision No. 50-NFPA 61-2014 [New Section after 13.11]
Submitter Information Verification
Submitter Full Name: ARTHUR SAPPER
Organization: MCDERMOTT WILL EMERY LLP
Affilliation: United States Beet Sugar Association
Street Address:
City:
State:
Zip:
Submittal Date: Fri May 15 10:01:26 EDT 2015
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10 of 14 5/18/2015 12:43 PM
Public Comment No. 13-NFPA 61-2015 [ Section No. 13.12.1 ]
13.12.1 Determination of Hazards of Agricultural Dust .
The requirements of 13.12.1.1 through 13.12.1.3 shall apply to both new and existing facilities andprocesses and shall be permitted to be used instead of those in Section 4.2 and in the requirements inChapter 5 of NFPA 652.
13.12.1.1
It shall be permitted to assume that an agricultural dust or mixture is explosible and combustible and toassume worst-case characteristics as a basis for actions, such as design or housekeeping, and as a basisupon which to meet requirements under this standard, such as an agricultural dust hazard survey.
13.12.1.2
The user shall be permitted to rely upon existing historical facility data and published data for explosiveproperties of dust to evaluate dust hazards.
13.12.1.3*
Test results, historical data, and published data shall be documented and, when requested, provided to theauthority having jurisdiction (AHJ). [652:5.2.2]
Statement of Problem and Substantiation for Public Comment
The change is related to and made necessary because of the move of Section 1.5.4 to be a new Section 13.1, which was done in response to the Correlating Committee Note about retroactivity provisions.
Related Item
First Revision No. 50-NFPA 61-2014 [New Section after 13.11]
Submitter Information Verification
Submitter Full Name: ARTHUR SAPPER
Organization: MCDERMOTT WILL EMERY LLP
Affilliation: United States Beet Sugar Association
Street Address:
City:
State:
Zip:
Submittal Date: Fri May 15 10:03:08 EDT 2015
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Public Comment No. 14-NFPA 61-2015 [ Section No. 13.12.2 ]
13.12.2 Agricultural Dust Hazard Survey.
The requirements of 13.12.2.1 through 13.12.2.4 shall not be applied retroactively to facilities existingprior to the effective date of the standard. The requirements of 13.12.2.1 through 13.12.2.4 shall bepermitted to be used instead of those in Chapter 7 of NFPA 652.
13.12.2.1 Scope.
The requirements in 13.12.2.2 through 13.12.2.4 apply to facilities that have agricultural or food dust.
13.12.2.2*
The owner/operator shall, within 5 years of the effective date of this standard, determine whether the facilityis in compliance and, if not, how the facility will be brought into compliance with this standard, and shallinclude a list of compliance steps.
13.12.2.3*
The survey shall include consideration of the following:
(1) Which persons, if any, are required to wear flame-resistant garments. It shall be permitted to consultNFPA 2113 in such consideration. The requirements of 13.12.2.3(1) shall be permitted to be usedinstead of those of 8.6.1.1 of NFPA 652.
(2) Whether separation shall be permitted to be used to limit the dust explosion or deflagration hazardarea within a building and whether detachment shall be permitted to limit the dust explosion hazard ordeflagration hazard area to a building physically separated from adjacent or surrounding exposures.The requirements of 13.12.2.3(2) shall be permitted to be used instead of those of 8.2.5.3 and 8.2.5.4of NFPA 652.
13.12.2.4
Further changes to facilities, equipment, and dusts shall be made in accordance with the management ofchange provision in 13.12.3.
Statement of Problem and Substantiation for Public Comment
To require such a survey for every facility, even given a five year period, is an unnecessary burden on companies with many facilities that have been operating safely in the same manner for many years.
Related Item
First Revision No. 50-NFPA 61-2014 [New Section after 13.11]
Submitter Information Verification
Submitter Full Name: ARTHUR SAPPER
Organization: MCDERMOTT WILL EMERY LLP
Affilliation: United States Beet Sugar Association
Street Address:
City:
State:
Zip:
Submittal Date: Fri May 15 10:06:55 EDT 2015
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Public Comment No. 15-NFPA 61-2015 [ Section No. 13.12.3.2 ]
13.12.3.2
After 3 6 months of the effective date of this standard, the owner/operator shall require that a personknowledgeable in the fire and deflagration hazards of agricultural dust be informed of changes (other thanreplacements in kind) to facilities, equipment, or processed materials before implementation of the change,if feasible, or if not, immediately after implementation.
13.12.3.2.1
The knowledgeable person shall consider whether or not the change would comply with NFPA 61. If thechange does not comply, then a method of compliance shall be determined.
Statement of Problem and Substantiation for Public Comment
This requirement will apply to existing facilities, and companies with many facilities will need more time to designate “a person knowledgeable” and put an MOC system in place in each facility.
Related Item
First Revision No. 50-NFPA 61-2014 [New Section after 13.11]
Submitter Information Verification
Submitter Full Name: ARTHUR SAPPER
Organization: MCDERMOTT WILL EMERY LLP
Affilliation: United States Beet Sugar Association
Street Address:
City:
State:
Zip:
Submittal Date: Fri May 15 10:10:41 EDT 2015
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13 of 14 5/18/2015 12:43 PM
Public Comment No. 10-NFPA 61-2015 [ Section No. F.1.2 ]
F.1.2 Other Publications.
F.1.2.1 ANSI Publications.
American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036.
ANSI/ITSDF B56.1, Safety Standard for Low Lift and High Lift Trucks, 2012 2014 .
F.1.2.2 ASTM Publications.
ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.
ASTM E1226, Standard Test Method for Explosibility of Dust Clouds, 2012a.
F.1.2.3 National Grain and Feed Association Publications.
National Grain and Feed Association, 1201 New York Avenue, N.W., Suite 830, Washington, DC 20005.
Emergency Preplanning and Fire Fighting Manual — A Guide for Grain Elevator Operators and FireDepartment Officials, 1987.
F.1.2.4 UL Publications.
Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.
ANSI/ UL 558, Standard for Internal Combustion Engine-Powered Industrial Trucks, 1996, revised 2014.
ANSI/ UL 583, Standard for Electric-Battery-Powered Industrial Trucks, 1996, revised 2014.
F.1.2.5 U.S. Government Publications.
U.S. Government Printing Office, Washington, DC 20402.
OSHA Title 29, Code of Federal Regulations, Part 1910.272.
Statement of Problem and Substantiation for Public Comment
Updated editions.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 1-NFPA 61-2015 [Section No. 2.3] Updated editions.
Related Item
First Revision No. 45-NFPA 61-2014 [Section No. F.1.2.2]
First Revision No. 59-NFPA 61-2014 [Section No. F.1.2.4]
First Revision No. 60-NFPA 61-2014 [Section No. F.3]
Submitter Information Verification
Submitter Full Name: Aaron Adamczyk
Organization: [ Not Specified ]
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 14 21:14:27 EDT 2015
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Address List No PhoneAgricultural Dusts CMD-AGR
Combustible Dusts
Susan Bershad06/09/2015
CMD-AGR
Timothy J. Myers
ChairExponent, Inc.9 Strathmore RoadNatick, MA 01760-2418Alternate: David B. Clayton
SE 10/27/2009CMD-AGR
Donald W. Ankele
PrincipalUL LLC333 Pfingsten RoadNorthbrook, IL 60062-2096Alternate: Paul T. Kelly
RT 10/20/2010
CMD-AGR
Amy Brown
PrincipalFM Global1151 Boston-Providence TurnpikePO Box 9102Norwood, MA 02062-9102Alternate: Peter M. Telthorst
I 03/07/2013CMD-AGR
Matthew J. Bujewski
PrincipalMJB Risk Consulting9650 Mill Hill LaneSt. Louis, MO 63127
SE 4/17/1998
CMD-AGR
Ashok Ghose Dastidar
PrincipalFauske & Associates, LLC16W070 83rd StreetBurr Ridge, IL 60527-5802
SE 07/29/2013CMD-AGR
Brian L. Eklow
PrincipalAon Risk Services200 East Randolph StreetChicago, IL 60601Alternate: Ronald A. Stein
I 10/27/2005
CMD-AGR
Craig Froehling
PrincipalCargill, Inc.15407 McGinty Road West, MS 63Wayzata, MN 55391Alternate: Chris Aiken
U 03/05/2012CMD-AGR
Dan A. Guaricci
PrincipalATEX Explosion Protection, L.P.2629 Waverly Barn Road, Suite 121Davenport, FL 33897
M 7/20/2000
CMD-AGR
Kevin M. Hudson
PrincipalIngredionPO Box 1084Indianapolis, IN 46206Alternate: Steven A. McCoy
U 10/18/2011CMD-AGR
William E. Janz
PrincipalXL Global Asset Protection Services301 Pine Ridge DriveWashington, IL 61571
I 4/4/1997
CMD-AGR
William F. Kearns
PrincipalFred D. Pfening Company1075 West Fifth AvenueColumbus, OH 43212
M 8/5/2009CMD-AGR
William F. Kinslow, Jr.
PrincipalMondelēz International100 DeForest AvenueEast Hanover, NJ 07936
U 3/1/2011
CMD-AGR
James E. Maness
PrincipalJEM Safety Consulting5 Eagle DriveRehoboth, DE 19971Grain Elevator and Processing Society
U 1/1/1986CMD-AGR
Jess P. McCluer
PrincipalNational Grain and Feed Association1250 Eye Street, NW, Suite 1003Washington, DC 20005-3922
U 1/10/2008
1
Address List No PhoneAgricultural Dusts CMD-AGR
Susan Bershad06/09/2015
CMD-AGR
Bruce McLelland
PrincipalFike Corporation704 SW 10th StreetBlue Springs, MO 64015-4263
M 3/2/2010CMD-AGR
Karl Nitsch
PrincipalKN Associates Corporation1995 Weston RoadPO Box 783Toronto, ON M9N 3W9 Canada
SE 4/17/1998
CMD-AGR
Jack E. Osborn
PrincipalAirdusco, Inc.4739 Mendenhall Road SouthMemphis, TN 38141
M 7/23/2008CMD-AGR
Michael Peters
PrincipalNebraska State Fire Marshal1205 South V RoadHampton, NE 68843
E 08/09/2012
CMD-AGR
Kent C. Quinney
PrincipalThe Amalgamated Sugar Company LLC1951 South Saturn Way, Suite 100Boise, ID 83709-2924US Beet Sugar AssociationAlternate: Brian G. Deutsch
U 03/03/2014CMD-AGR
Jeffrey K. Rogers
PrincipalAg Processing Inc.PO Box 2047Omaha, NE 68103-2047National Oilseed Processors AssociationAlternate: Jim E. Norris
U 7/26/2007
CMD-AGR
Mark L. Runyon
PrincipalMarsh Risk Consulting111 SW Columbia, Suite 500Portland, OR 97201
I 10/23/2013CMD-AGR
Lee M. Sargent
PrincipalTodd & Sargent, Inc.2905 SE 5th StreetAmes, IA 50010-7716
SE 7/1/1993
CMD-AGR
Robert D. Shafto
PrincipalZurich Insurance1093 Tall Pines TrailHighland, MI 48356Alternate: Glen R. Mortensen
I 3/1/2011CMD-AGR
Jeffery W. Sutton
PrincipalGlobal Risk Consultants Corporation350 Highway 7, Suite 220Excelsior, MN 55331-3170
SE 4/3/2003
CMD-AGR
P. D. (Nick) Thielen
PrincipalGeneral Mills, Inc.9000 Plymouth Avenue, NorthGolden Valley, MN 55427
U 3/2/2010CMD-AGR
Erdem A. Ural
PrincipalLoss Prevention Science & Technologies, Inc.2 Canton Street, Suite A2Stoughton, MA 02072
SE 3/2/2010
CMD-AGR
Clyde Waller
PrincipalPowder Process Solutions1610 Lake Drive WestChanhassen, MN 55317Alternate: Venkateswara Sarma Bhamidipati
IM 8/9/2011CMD-AGR
Stephen L. Wees
PrincipalHayes & Stolz Industrial Manufacturing, Ltd.3521 Hemphill StreetFort Worth, TX 76110
M 3/21/2006
2
Address List No PhoneAgricultural Dusts CMD-AGR
Susan Bershad06/09/2015
CMD-AGR
J. Anthony Yount
PrincipalConAgra Food Ingredients11 ConAgra DriveOmaha, NE 68103
U 3/21/2006CMD-AGR
Chris Aiken
AlternateCargill, Inc.15407 McGinty Road West, MS 63Wayzata, MN 55391Principal: Craig Froehling
U 07/29/2013
CMD-AGR
Venkateswara Sarma Bhamidipati
AlternatePowder Process Solutions1620 Lake Drive WestChanhassen, MN 55317Principal: Clyde Waller
IM 10/29/2012CMD-AGR
David B. Clayton
AlternateExponent, Inc.5401 McConnell AvenueLos Angeles, CA 90066-7027Principal: Timothy J. Myers
SE 10/20/2010
CMD-AGR
Brian G. Deutsch
AlternateMichigan Sugar Company2600 South Euclid AvenueBay City, MI 48706US Beet Sugar AssociationPrincipal: Kent C. Quinney
U 03/03/2014CMD-AGR
Paul T. Kelly
AlternateUnderwriters Laboratories Inc.333 Pfingsten Road60062-2096Northbrook, IL 60062-2096Principal: Donald W. Ankele
RT 03/03/2014
CMD-AGR
Steven A. McCoy
AlternateIngredionPO Box 1084Indianapolis, IN 46206Principal: Kevin M. Hudson
U 10/18/2011CMD-AGR
Glen R. Mortensen
AlternateZurich Services CorporationRisk Engineering21337 West Crescent DriveMundelein, IL 60060-3399Principal: Robert D. Shafto
I 3/1/2011
CMD-AGR
Jim E. Norris
AlternateBunge North America11720 Borman DrivePO Box 28500St. Louis, MO 63146-1000National Oilseed Processors AssociationPrincipal: Jeffrey K. Rogers
U 10/20/2010CMD-AGR
Ronald A. Stein
AlternateAon Global Risk Consultants4801 Main Street, Suite 350Kansas City, MO 64112Principal: Brian L. Eklow
I 07/29/2013
CMD-AGR
Peter M. Telthorst
AlternateFM Global540 Maryville Center Drive, Suite 400St Louis, MO 63141Principal: Amy Brown
I 03/07/2013CMD-AGR
Matthew I. Chibbaro
Nonvoting MemberUS Department of LaborOccupational Safety & Health Administration200 Constitution Ave. NW, Room N3609Washington, DC 20210Alternate: William R. Hamilton
E 3/4/2009
3
Address List No PhoneAgricultural Dusts CMD-AGR
Susan Bershad06/09/2015
CMD-AGR
William R. Hamilton
Alt. to Nonvoting MemberUS Department of LaborOccupational Safety & Health Administration200 Constitution Ave. NW, Room N3609Washington, DC 20210Principal: Matthew I. Chibbaro
E 3/4/2009CMD-AGR
Robert W. Nelson
Member Emeritus28 Wing RoadPO Box 418Pocasset, MA 02559
SE 1/1/1989
CMD-AGR
Susan Bershad
Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471
04/16/2014
4