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)
