Behind Updates to the Management of Change Section in NFPA 61

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What is required to be addressed by manufacturers versus what is recommended to be addressed by manufacturers is the focus of a section added to the management of change section of the 2020 edition of NFPA 61.

ingredients on a shelf at a bulk material handling facility

As dust hazard mitigation is of critical importance and can protect the health and safety of employees in the ingredient handling world, we have published more than a few reminders about upcoming NFPA-instituted deadlines as well as helpful tips about performing a Dust Hazard Analysis (DHA). 

Specifically, NFPA 61 applies to industry standards for types of dust that a facility manages as a “commodity specific” standard (these materials often include agricultural dust, rather than standards that cover metal, wood and plastic dust as in NFPA 562). 

Our NFPA-related infographic is available as an easy-to-use overview of how these standards relate to select industries, but in this blog post we’ll zero in on how the management of change section in the newest 2020 edition of NFPA 61 has itself been updated. First, let’s take a look at what “management of change” particularly describes:

What is ‘Management of Change’ 

Any number of specialized equipment or processes can affect dust, fire, or explosion hazards in a facility. Management of change is meant to act as a checks and balances between proposed alterations of established ways of accomplishing day-to-day operations.

What could seem like an innocuous change might actually affect by and large the safety of a system. Safety and health implications could arise from any number of alterations that some might not consider harmful on the front end. 

Specifically, section A.8.12.3 of the 2020 edition of NFPA 61 states:

“Care must be taken when substituting raw materials. There have been cases where a seemingly equivalent material substitution resulted in a large change in the process hazard. Not all safety properties of a material are characterized in, for example, an MSDS. Chemical composition might be identical, but quite different static ignition hazards due to bulk resistivity and charge relaxation rate can appreciably increase the hazard. Flowability differences can affect the hazard probability too.”

One example of a change that could introduce serious consequences starts with the initial problem of sugar spilling off of a conveyor belt. A temporary fix such as closing the conveyor belt might be implemented by an employee. This act seems to solve the problem initially but actually introduces another problem altogether. Once the dust would be confined in this scenario, a separate opportunity for a dust explosion is actually created.  

Many seemingly small changes in a facility do not require operators to check with enforcing authorities at all, making management of change a critical function of abiding by guidelines set forth by the NFPA -- an agency that technically isn’t tasked with enforcing regulations. According to section 4.1.2 in NFPA 61, it’s up to the owner of a facility that is handling combustible dusts to mitigate the accumulation of such material through activities such as:

  • Identifying credible fire, flash fire, and explosion hazards within their facility
  • Assessing the consequences of these hazards
  • Managing these hazards
  • Communicating and informing affected personnel of these hazards 

How “in-kind” changes are defined by the NFPA

The new update relating to the management of change in the 2020 edition of NFPA 61 specifies certain replacements that do not need to be as meticulously considered. These types of changes are referred to as changes “in-kind” by the NFPA. For instance, if a valve fails and will be replaced by the same exact style or model of valve, a management of change program is not required.

On the other hand, for changes such as which ingredient is to be handled (sugar to a sugar substitute for example), all properties must be observed and compared so that a facility is sure that the material and its properties will react the same way. This would not be an “in-kind” change or alteration.

Finally, there are tricky changes -- those which may seem by nature to be an “in-kind” change, but because of situational circumstances are not. A motor being replaced, though the same model, might not run exactly in the same way as an older motor. By virtue of it being a newer motor, it could operate at a faster rate and at a lower heat. This situational aspect makes the replacement an “in-kind” change after all.  

More information about which standards apply to your plant processes can always be found directly from the NFPA. For future updates regarding dust hazard-specific industry sectors stay tuned to the AZO blog. AZO has seven decades of experience in handling raw materials and shaping ingredient automation along the way. Feel free to contact our sales team for any questions on how to help your operations run as efficiently as possible.

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