Additionally, I have made the following observations regarding examples of poor preventive maintenance measures involving equipment:
- Grooves worn into head pulley covers indicating an improperly aligned belt
- Bearings not consistently greased or inspected
- Rub sensors on elevator legs worn away/improper belt alignment
- Sensor wires on hazard monitoring equipment not properly attached or inspected, resulting in alarms not functioning properly
Click here for a photo gallery with examples of the observations metioned.
Housekeeping and preventive maintenance
To address these issues and to assist facilities in ensuring that proper housekeeping and preventive maintenance is being accomplished, the OSHA Grain Handling Standard provides clear guidance to the grain handling industry. Below are pertinent provisions of the standard concerning housekeeping:
“The employer shall develop and implement a written housekeeping program that establishes the frequency and methods determined best to reduce accumulations of fugitive grain dust on ledges, floors, equipment and other exposed surfaces.”3
“The employer shall immediately remove any fugitive grain dust accumulations whenever the accumulations exceed 1/8 inch (.32 cm) at priority housekeeping areas pursuant to the housekeeping program …”
Priority housekeeping areas shall include at least the following:
- Floor areas within 35 feet of inside bucket elevators
- Floors of enclosed areas containing grinding equipment
- Floors of enclosed areas containing grain dryers located inside facility4
The requirements of the Grain Handling Standard are clear: grain handling facilities must develop a written housekeeping plan as outlined above and then consistently adhere to it.
And that’s the problem. Many facilities simply do not have a written housekeeping plan in place, and as a result, housekeeping is done when an employee “gets around to it.” Still, others actually have the written housekeeping plan in place and then fail to follow it — many times because management has not made it a priority.
OSHA also provides clear guidance regarding the critical safety measure of preventive maintenance and inspection of equipment. The following are pertinent provisions of the Grain Handling Standard regarding preventive maintenance:
(1) The employer shall implement written preventive maintenance procedures consisting of:
(i) regularly scheduled inspections of at least the mechanical and safety control equipment associated with:
- Grain stream processing equipment
- Bucket elevators
- Grain dryers
- Dust collection equipment
- Safety/monitoring equipment
(ii) Lubrication and other appropriate maintenance in accordance with manufacturer’s recommendations, or as determined necessary by prior operating records.5
Additionally, “A certification record shall be maintained of each inspection containing the date of the inspection, the name of the person who performed the inspection and the equipment specified.6”
The requirements of the Grain Handling Standard regarding preventive maintenance programs are also clear. Grain handling facilities must develop a written maintenance and inspection program and then adhere to it.
The housekeeping programs and preventive maintenance plans that simply take up space in a file drawer will do nothing to assist a facility in preventing a catastrophic event through good housekeeping and preventive maintenance procedures.
These plans must be in place and then consistently followed. Quite frankly, it all starts with the attitude of management. If management demands compliance with proper housekeeping and maintenance procedures, it will happen. If management doesn’t make these procedures a priority, the programs will “go by the wayside.”
Employee training and management validation
Finally, all of these recommendations regarding proper housekeeping and maintenance can only be accomplished through regular and comprehensive employee training. As we are all aware, there are only so many hours in a day, and as such, the very real danger is that new employees at a grain facility — or current employees taking on a different role — may not be receiving adequate job training.
OSHA addresses employee training in the Grain Handling Standard as follows:
The employer shall provide training to employees at least annually and when changes in job assignment will expose them to new hazards. Employees … shall be trained in at least the following: