NFPA 660 and bakeries: when should it apply?

[Not Norman]

At what scale of production does one start applying NFPA 660 to a bakery? Reading chapter 21 of the standard (on agricultural and food handling facilities) doesn't provide any guidance as to when the explosion hazard in a bakery becomes enough to start requiring controls beyond normal food safety practice, because it's not like one hears about cake bakers and donut shops exploding, yet clearly it's enough of a concern that NFPA 660 doesn't exclude bakeries from its scope. (Note that chapter 24 for wood products has an express partial exception for small shops in 24.1.1.2, so there's precedent for scope limitations within the text of NFPA 660.)

NB: I plan to leave a public comment on NFPA 660 raising the issue but wanted to put this feeler out here beforehand to see if there was something I was missing.

 

[Not Norman]

(P.S. NFPA 660 is the new consolidated NFPA standard on combustible dust hazards)

 

[Yankee Chronicler]

NFPA 660 isn't a referenced standard in the 2021 IBC or IFC, and it's not a referenced standard in the 2024 IBC or IFC. Unless a jurisdiction specifically adopts it -- there is no legal basis on which to apply it.

 

[ICE]

The standard was officially released and became effective on December 6, 2024, marking a significant update to dust safety protocols.

NFPA 660 merges content from six legacy standards:

• NFPA 652: Fundamentals of combustible dust.
• NFPA 61: Agricultural and food processing.
• NFPA 484: Combustible metals.
• NFPA 655: Sulfur.
• NFPA 664: Woodworking.
• NFPA 654: All other combustible dust types.

 

[Yankee Chronicler]

The standard was officially released and became effective on December 6, 2024, marking a significant update to dust safety protocols.

NFPA 660 merges content from six legacy standards:

• NFPA 652: Fundamentals of combustible dust.
• NFPA 61: Agricultural and food processing.
• NFPA 484: Combustible metals.
• NFPA 655: Sulfur.
• NFPA 664: Woodworking.
• NFPA 654: All other combustible dust types.

I understand that it's a new standard. That's the point.

I don't know how California works. When my state adopts a new state building code, we adopt some (not all) of the ICC model codes, by year and by printing. We amend each model code we adopt. The adopted versions include the chapters on Referenced Documents (occasionally with amendments to the list). NFPA 660 is not listed as a Referenced Document in the model 2024 IBC or the model 2024 IFC. That means unless a jurisdiction goes out of its way to adopt NFPA 660 separately, or writes it into the IBC and/or the IFC by amendment -- there's no code path to enforce it.

That doesn't mean a design professional can't use it for guidance, but unless adopted by a jurisdiction it can't be enforced.

At one point my state was more than a decade behind in adopting a new code cycle. Our adopted code actually referenced some referenced standards that were so old they were out of print -- they weren't even available from the organizations that had originally published them. Everyone knew they were out of date. Most design professionals were using the current versions of the standards. But ... code officials could only enforce the old version that the state had adopted. That's the law.

We are late adopting the 2024 I-Codes. It was supposed to happen this year, but it's now not going to happen until 2026. I just checked the draft amendments. They do NOT include NFPA 660 in the amended list of Referenced Documents. Which means that even after we adopt the new codes, code officials will not be able to enforce NFPA 660. They can look at it for guidance, but we will only be able to enforce the standards listed in the Referenced Standards chapters of the respective codes.