由高级咨询工程师蒂姆·库利纳（Tim Cullina）Fauske＆Associates，LLC
In Part one of this series, "Close Encounters..." I discussed who is the authority having jurisdiction or AHJ. I concluded that there are many AHJs and for discussion purposes, divided them into three kinds of people: permit people, doing business people, and inspectors. (Yes, inspectors are people, too.) I did forget to include a simple statement to the effect of "NFPA不是您的AHJ。"
"Getting in bed with the AHJ" has that conspiratorial connotation at the least, and smacks of inappropriate exchanges of, shall we say, favors. That's far from what I suggest with the title. And, thinking of the permit people and inspectors as the "enemy", well, that's just old school. Old school is not a bad thing, but a lot of new learning opportunities have come up since then.
Knowing that there are many potential AHJs with myriad authority is nice. And, knowing what each AHJ can require of you and your enterprise is a necessity. More importantly, understanding what your AHJ knows and what your AHJ can do for your enterprise is equally important. Going back to NFPA 654, we find the AHJs coming into play about 23 times or so, not counting definitions and the annex. What are these AHJs doing?
For the most part, the AHJs are determining, judging, applying and approving "something that you have proposed" asacceptable to[themselves]the authority having jurisdiction.
I would not say they lessen a safety or equipment requirement, but they can approve an acceptable alternative approach to address a hazard, rather than the standardor code-stated requirement also known as the "prescriptive remedy"。In a perfect world, the AHJs would be the Solomon-like, risk-referees. They could answer many questions, including: Is this good enough? That is, if you dared to ask.
在现实世界中，他们就像我们其他人一样，受到知识范围的限制，不一定是提出一种经济高效的补救措施的专家。为了更好（或更糟），他们是批准或否认的裁判。但是很多时候，他们没有被要求。
No one wants to hear, "No." And, you know ...stuff happens. I think that approach may be defended by the old saw, "better to ask forgiveness, than ask permission". But we cannot let that thinking impair safety.
询问可以像要求特定代码或标准要求的差异一样简单。对于更复杂的替代方案，这可能需要事先对危害进行研究或分析，以确定替代方案与规定补救措施一样有效。在最简单的层面上，这种方法称为“等效性”。这也是一个很好的“反-NO”策略。与您的AHJ合作符合您的最大利益。
NFPA allows equivalency and states at the beginning of each dust standard that; "Nothing in the standard is intended to prevent the use of systems, methods, or devices of equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed by this standard”但是，适当的AHJ需要批准此替代系统，方法或设备为预期目的批准。这听起来足够公平，但是它可以授予AHJ的权威不准备使用它？那你怎么办？
我们怎么知道什么是等价的吗?这是一个很好的question and a hard question. Let’s look at the goal of a requirement first. Speaking generally, the goal is to prevent an undesirable and in many cases an unacceptable event, such as a combustible dust explosion. Therefore, we need to understand the science behind hazard. We need to determine the risks, a combination of the severity and frequency of the outcome. And, we need to know how to both prevent and mitigate the event to create options. Of course, you would expect that the alternative will also provide a benefit in either cost or flexibility, or else you would likely go with theprescribed remedyin the first place. What you should not do is nothing.
There is also the performance-based option. It is equivalency on steroids. Here you detail and propose an alternate approach that works (performs) just as well as the prescriptive remedies. It requires, "记录了所有计算，参考，假设和来自其中的物质特征和其他数据或设计师依赖于Design的某些物质方面的材料特征和其他数据的来源的分析。。"
那么，真正的区别是什么？我是这样看的。可以要求对等效性进行单独的设备的微小更换，或适应设计或材料的更改等。等效性为基于性能的选项打开了大门。但是，基于性能的选项更类似于重写自己的标准，因此您可以在同一位置受到保护。
And, what if your AHJ does not know or understand the appropriate NFPA standard? First verify that you have the correct AHJ. Second, retain firm control of your authority.
请记住，您，所有者或运营商是最强大的AHJ。只是做正确的事。
再次回想一下，普戈说：“我们面临着无法克服的机会”。利用情况，提出问题。询问您最喜欢的顾问。问AHJ。问Fauske＆Associates，LLC（FAI）。We employ scientists and engineers engaged in the science of flammability, explosibility, and hazard assessments. Our field engineers have helped clients with combustible dust problems in the Chemical, Pharmaceutical, Agricultural, Energy, and Food industries, as well as a few project less easily defined. They can help you assess your hazards, examine your alternatives, identify equivalences, and help you make your case.
但是，如果您是AHJ怎么办？不过，问FAI。Or ask the petitioner of a variance or equivalence to ask FAI. In NFPA 654, Chapter 5, Performance-Based Design Option, Section 5.1.2 Independent Review: "具有管辖权的机构应获得对拟议设计的独立第三方审查。"
Combustible Dust and the Authorities having Jurisdiction (AHJ), Part 3,” based on the Poe tale of a confused and inaccurate account of events that have become public, leading to discussion and disbelief. As a result, the narrator wishes to clear up the facts as well as he can in his own account.
Yes, indeed, we are confronted with insurmountable opportunities.
Fauske and Associates，LLC（FAI）可以为您提供适用的NFPA，OSHA和EPA标准的努力提供。我们的专家可燃的灰尘爆炸和火灾危害评估，，，，Process Hazard Analysis (PHA)，，，，Hazard Identification Risk Analysis，，，，Consequence Analysis，，，，更安全的过程规模，，，，Process Safety Program Development，，，，andRelief System Design Revieware always here to help. For more information, please contact Jeff Griffin at griffin@fauske.com or 630-887-5278.
