Did NFPA just put Combustible Dust into a Process Safety Management System

I like to tell clients that NFPA has done what OSHA failed to do… make Combustible Dust a PSM-covered process. Well, not exactly, but NFPA 660 has certainly advanced how we manage the risks associated with Combustible Dusts. The new (2026) NFPA 660 has the following SMS elements:

  • Hazard Identification (5)
  • Dust Hazard Analysis (7)
  • Operating Procedures and Practices (8.3)
  • Housekeeping (8.4)
  • Hot Work (8.5)
  • Personal Protective Equipment (8.6)
  • Inspection, Testing, and Maintenance (8.7)
  • Training and Hazard Awareness (8.8)
  • Contractors (8.9)
  • Incident Investigation (8.10)
  • Management of Change (8.11)
  • Operational Readiness Review (8.12)
  • Documentation Retention (8.13)
  • Management Systems Review (8.14)
  • Employee Participation (8.15)
  • Hazard Management: Mitigation and Prevention (9)
  • Emergency Planning and Response (10)

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