Navigating OSHA's Sweep Auger Interpretation
Understanding the facts and the mystery surrounding OSHA’s 2009 Letter of Interpretation
Once gravity or condition issues impede loadouts, sweeps are sent in to move the excess, but if the sweeps are getting hung up on damaged floors it creates a situation where a person is sent into the bin to work around it. The bin floor should be level and smooth so the sweep doesn’t catch or create a situation where things don’t advance properly.
“The real issue is you can’t predict all the conditions you’ll run into in a grain elevator,” Ver Steeg says. “It comes down to grain management: 50% on equipment; 50% on grain management.”
“Keeping your grain in good, free-flowing condition is the best way to allow a sweep to work, and avoid bin-entry circumstances,” adds Jeffrey D. Decker, product safety & litigation manager, The GSI Group, LLC.
2. No entry sweeps
Avoid entering the bin at any time to get the sweep started/engage it, or after the bin has been swept/prepare to be filled again with a “Zero” or minimal entry sweep.
3. Perfect lock-out/tag-out system
Following confined space entry procedures by enforcing lock-out/tag-out procedures is an absolute must. It may also pay off to seek practical feedback from the employees who use the equipment everyday and come up with a cost-effective practical way to make that process safer. This also helps ensure employees understand the safety procedure.
4. Use alternative equipment
Industry leaders point to using alternative equipment solutions like cyclone vacuum systems and air augers. If this technology is not a fit for your operation, consider investing in a quality, heavy-duty auger.
Decker mentions that sweep tractor drives bolted on the back of the sweep are also effective because they allow an operator to advance the sweep from outside the bin.
5. Invest in capital upgrades
Consider refurbishing existing facilities with larger entry doors — drive-in doors for Bobcats and front-end loaders for larger tanks — and adjust for larger capital costs that will allow personnel access to the bin while it’s being unloaded.
“If you are planning on long-term storage of product and unloading the silo less than twice a year consider putting in entry doors,” Zink says. “You may find the dollar not to be favorable at the time, but if you consider a 30-year amortization of the silo, it may work out better down the road unless things change for the clean out of the silos.”
For older silos, call your equipment dealer to evaluate the situation and offer solutions. If you can come up with a reasonable way to retrofit a system without getting close to the sweep auger, do it.
6. New construction considerations
In new construction projects, facilities should consider the industry practices for storage vessels with aboveground elevations of the stem walls that allow underside access to the sump of their bin sweep. The addition of larger sump holes in the floor will improve the efficiency of the reclaim system.
Decker recommends intermediate wells no further apart than 10 feet center to center to help draw the grain away from the sweep and help it move better.
The desired outcome
Until OSHA formally responds, the industry will have to wait to see where the chips fall.
“We’re at the worst case scenario,” Zink says. “In the best case scenario, OSHA will define what its intent is with guarding. Once that is clarified, the industry can put our brain trust together and adapt to the restrictions.”
Bauer agrees: “What should be happening is the industry should be working together with OSHA to come up with reasonable safety solutions.”
NGFA anticipates written communication from OSHA regarding this situation some time in 2011.
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