McCluer advises facilities to demonstrate that safety processes and procedures are in place by keeping thorough records of safety training and related equipment purchases.
Beyond rolling stock
Trucks, hoppers, tankers and feed trailers pose their own unique set of safety challenge.
What some grain elevators may fail to realize, or choose to ignore, is that they are responsible for the safety of anyone on their property. In the grain industry, enforcing fall protection standards is difficult given the volume of producer traffic passing through a facility.
“The way OSHA looks at it if a person is above 4 feet they must be tied-off to fall protection,” says Dale Pedersen, senior field technician, Fall Protection Systems. “Elevators deal with very independent people, but they still are liable for whatever happens to those people — doesn’t matter who they are. If a farmer climbs on his truck and falls off, it’s on you.”
Pedersen suggests elevators put signs up everywhere telling people what they can and cannot do while on site. Signs will not protect a business from a liability lawsuit, but they do communicate the facilities’ rules and hopefully will prevent an incident. Signage, like those supplied by Clarion Safety Systems (see pg. 36), allows a business to approach a customer who may be acting recklessly in a nonconfrontational way.
“What it comes down to is that you need to protect the company’s bottom line,” Pedersen says. “If someone is breaking your rules, you ask them to obey the rules or leave.”
Protecting your business and your employees
OSHA’s aggressive bid to inspect grain handling facilities should motivate companies to prepare for an inspection prior to the knock on the door. Since fall hazards aren’t the only issue open to scrutiny, it’s a good idea to have procedures in place to streamline an inspection.
“You want to guide OSHA through your facility,” Pedersen says. “Don’t just not open the door to allow them the opportunity to find things — anyone could have something that’s out of place.”
Openly discussing OSHA’s changing expectations and regulations also provides managers the opportunity to brief employees about the importance of abiding by the rules.
Here’s a checklist of the things you can do before an inspection:
1) Observe employees and visitors
Are your customers climbing on top of their trucks on your property? Do employees get on top of a railcar for any reason? Can you think of anywhere you could install passive protection, like guardrails? If the answer is yes, then what do you have in place, and what else could you add? Secondly, what do you need to do to be in compliance.
2) Ask for advice
Call your regional OSHA office to get a feel for their interpretation of fall protection compliance. If you’re nervous about that, use a private phone line or block the call.
Naturally, inviting a fall protection equipment supplier to evaluate the hazards at your facility is an alternate way to gain insight into where improvements can be made.
3) Review the available solutions
Find answers to these questions: What is the most user-friendly? What is going to be the most cost-effective over the long term? Trolley rail systems, horizontal lifeline or cable systems and many other variations are out there. (Note: A guardrail system is fall prevention; it’s not fall protection.)
4) Provide an annual training to employees
Based off the manufacturer’s recommendation, require annual employee training and inspection of the system. The small time investment will allow you to create training documentation should OSHA request documentation in the future.
Jeff Barnum, sales director with Flexible Lifeline Systems, notes the updated ANSI Standard, Z359, provides a more clearly defined set of training levels and requirements for suppliers.
“For example, there is an authorized user, who would be the user of the system with a certain level of required training; and then there is the competent person, a position a step up from the authorized user,” he explains. “We now have more defined roles or training requirements with the latest ANSI standards.”