What NFPA 660 Means for Combustible Dust Programs in Processing

Frequently Asked Questions

What does NFPA 660 change for a combustible dust program?

NFPA 660 brings combustible dust requirements into a more unified framework. For most sites, the key takeaway is to check whether current controls, procedures, and assumptions still match actual plant conditions instead of assuming an older program is already aligned.

Do we need to redo our dust hazard analysis because of NFPA 660?

The post recommends a quality check of your dust hazard analysis rather than just a filing update. It should reflect current equipment, process changes, upset scenarios, connected system risks, and cleaning tasks, and if you have never completed a formal DHA, this is the time to set that baseline.

What should housekeeping rules include for combustible dust?

Housekeeping rules should clearly define what dust must be cleaned, where inspections occur, how often they happen, who is responsible, which cleaning methods are allowed or prohibited, and how removal is verified and documented. The post also says to pay special attention to overheads, hidden spaces, equipment surfaces, and any use of compressed air for cleanup.

How should management of change handle combustible dust risks?

Your MOC process should require a combustible dust review before changes go live. The review should involve EHS, engineering, maintenance, and operations, and it should trigger updates to procedures, training, drawings, preventive maintenance tasks, and the DHA when needed.

What are the next steps EHS leaders should take for NFPA 660?

The post recommends a structured gap assessment instead of a rushed rewrite. Key steps include mapping your program against NFPA 660 and site risks, validating the DHA in the field, reviewing housekeeping and equipment suitability, strengthening MOC, refreshing training, and setting an audit cadence.