OSHA to 'Aggressively Pursue' Safety Violations in Grain Handling Operations

All equipment must be lubricated and maintained according to manufacturers’ recommendations, or as necessary. Equipment that malfunctions or operates below desired efficiency must be promptly repaired or removed from service. Repairs and inspections of equipment must be properly logged.

All employees who repair, service and operate equipment must be familiar with the employer’s lock-out and tag-out procedures.

Housekeeping

Employers must develop and implement a written housekeeping program that prevents combustible material from accumulating. According to OSHA, grain dust is the main source of fuel for explosions in grain handling facilities. The use of compressed air to remove grain dust is only permitted when all machinery that presents a source of ignition in the area is shut down, and all other known potential ignition sources are removed or controlled.

The written program must include:

• Frequency and methods of reducing dust accumulations on ledges, floors, equipment and other exposed surfaces;
• Identification of “priority” housekeeping areas known to be potential sources of ignition, including:

• Floor areas within 35 feet of inside bucket elevators;

• Floors of enclosed areas containing grinding equipment; and

• Floors of enclosed areas containing grain dryers located inside the facility.

• Methods for immediate removal of grain dust in excess of 1/8 inch in priority areas, or assurance that equivalent protection is provided; and
• Methods for removing grain (not dust) and product spills from work areas.

Emergency action plan requirements

Employers must develop and implement a written emergency action plan available to employees for review (unless the employer has 10 or fewer employees, in which case the plan may be communicated orally). The plan must include, at a minimum, procedures for the following:

• Reporting a fire or other emergency;
• Emergency evacuation, including exit route assignments;
• Employees who remain to operate critical plant operations before evacuating;
• Accounting for all employees after evacuation; and
• Employees performing rescue or medical duties.

The plan must also include the name or job title of employees who may be contacted with questions about the plan.

Alarm system

Employers must have and maintain an employee alarm system with a distinctive signal for each purpose.

Employee safety training

Employees must receive safety training at least annually and when changes in job assignments will expose them to new hazards. All employees must be trained in at least the following:

• General safety precautions, including recognition and preventative measures for the hazards related to dust accumulations and common ignition sources such as smoking; and
• Specific procedures and safety practices applicable to their job tasks, including housekeeping procedures, hot work procedures, preventative maintenance procedures and lock-out/tag-out procedures.

Employees assigned special tasks, such as bin entry and handling of flammable or toxic substances, must be provided training to perform these tasks safely.

Hot work

Employee performing “hot work,” including electric or gas welding, cutting, brazing or similar flame-producing work, must use a permit system. This is to ensure that the employer is aware of hot work being performed and that appropriate safety precautions are taken. (The required safety precautions can be found in 29 C.F.R. and sect; 1910.252(a), but are outside the scope of this article.)

The permit system is not required:

• Where the employer or employer’s representative (who would otherwise authorize the permit) is present while the hot work is being performed;
• In welding shops authorized by the employer; and
• In hot work areas authorized by the employer which are located outside of the grain handling structure.

In light of OSHA’s recent comments and increased scrutiny of the grain industry, operators would be wise to review safety policies and ensure that they are in compliance with all applicable requirements. The above requirements are provided as examples only of the types of workplace safety requirements imposed on grain handling operations. This articles does not, and is not intended to, summarize all safety requirements applicable to grain operations. Among other things, it does not consider state and other laws, which may impose worker safety requirements above and beyond those imposed by federal OSHA. For specific guidance, consult an attorney. For more information, visit the below websites.