Who's Minding the Store?

by Mark D. Aljets
Created: October 30, 2012

How following OSHA regulations can help prevent explosions

United States Department of Labor, www.OSHA.gov

Chart 1: United States Department of Labor's Grain Elevator Explosion Chart.
Chart 1: United States Department of Labor's Grain Elevator Explosion Chart.
Piles of grain at the top of a gallery and up to 12 inches of dust in areas next to a belt conveyor.
Piles of grain at the top of a gallery and up to 12 inches of dust in areas next to a belt conveyor.
Grain/dust piles in conveying tunnels creates areas for secondary explosions.
Grain/dust piles in conveying tunnels creates areas for secondary explosions.
Grain dust accumulations on conveying equipment.
Grain dust accumulations on conveying equipment.
Photograph of a head pulley bearing without proper lubrication.
Photograph of a head pulley bearing without proper lubrication.
Internal view of head pulley bearing with rollers “vertically and horizontally misaligned."
Internal view of head pulley bearing with rollers “vertically and horizontally misaligned."
Photograph of electrical components in the “off” position.
Photograph of electrical components in the “off” position.
This photograph from an investigation site demonstrates the devastating consequences of an elevator explosion at a facility in the Midwest.
This photograph from an investigation site demonstrates the devastating consequences of an elevator explosion at a facility in the Midwest.
When an explosion occurs, the facility may suffer extensive property damage and loss of business income.
When an explosion occurs, the facility may suffer extensive property damage and loss of business income.
In the event of an explosion, the potential for serious personal injury or loss of life is very real, and could result in a lawsuit being filed by injured parties, or the families of victims.
In the event of an explosion, the potential for serious personal injury or loss of life is very real, and could result in a lawsuit being filed by injured parties, or the families of victims.
A grain facility stands to be subjected to significant fines and penalties if OSHA determines that the facility was not adhering to the Grain Handling Standard and an explosion occurs.
A grain facility stands to be subjected to significant fines and penalties if OSHA determines that the facility was not adhering to the Grain Handling Standard and an explosion occurs.
Photo by Nyemaster Goode

Mark Aljets is a member of the Litigation Department of the Nyemaster Goode PC. Law Firm in Des Moines, IA. He can be reached by emailing mda@nyemaster.com or calling (515) 283-3124.
Mark Aljets is a member of the Litigation Department of the Nyemaster Goode PC. Law Firm in Des Moines, IA. He can be reached by emailing mda@nyemaster.com or calling (515) 283-3124.

Safety precautions associated with facility
Recognition and preventive measures for hazards related to dust accumulations
Common ignition sources
Specific procedures and safety practices applicable to their job tasks for … housekeeping procedures, hot work procedures, preventive maintenance procedures.⁷

Step back and examine these OSHA requirements regarding employee training and then compare them to the training your facility is currently providing to your employees.

Devastating consequences

Bear in mind, not following the requirements listed above can have serious consequences. The facility itself may suffer extensive property damage and loss of business income due to the damage. And in those events, the potential for serious personal injury or loss of life is very real. Finally, a grain facility stands to be subjected to significant fines and penalties if OSHA determines that the facility was not adhering to the Grain Handling Standard.

Click here for pictures of the devastating consequences of an explosion.

Recommendations

Catastrophic events can occur even at the best-run grain facilities. However, the odds of preventing a dust explosion at your facility are enhanced if management takes the following steps:

Ensure written policies are in place for housekeeping procedures and preventive maintenance of equipment
Demand compliance with the policies by regularly reviewing housekeeping and maintenance log sheets
Develop and implement an employee training program for at least the following:
1. Recognition and preventive measures for hazards related to dust accumulations
2. Common ignition sources
3. Specific procedures and safety practices applicable to job tasks for housekeeping and preventive maintenance procedures

The implementation of these procedures and compliance with the provisions of the Grain Handling Standard are proactive steps to making your facility a safe and productive work environment.

The author, Mark Aljets, is a member of the Litigation Department of the Nyemaster Goode PC. Law Firm in Des Moines, IA. Mr. Aljets practices in the areas of Product Liability Defense, Construction Defect/Commercial Litigation and Complex Tort Defense Work. He can be reached by emailing mda@nyemaster.com or calling (515) 283-3124.

[1] “Grain Dust Explosions – An Unsolved Problem,” Report No. HRD-79-1 (Gov’t Accounting Office, March 21, 1979)

[2] 29 C.F.R. § 1910.272.

[3] 29 CFR 1910.272(j)(l)

[4] 29 CFR 1910.272(j)(2)(i)(ii)

[5] 29 CFR 1910.272(m)(1)(i)(ii)

[6] 29 CFR 1910.272(m)(3)(i)(ii)

[7] [1] 29 CFR 1910.272(e)

DISCLAIMER

The information presented here does not constitute legal advice, does not establish an attorney-client relationship, and does not create any duty of the firm to any reader. An attorney-client relationship with Nyemaster Goode may be established only by an engagement letter signed by a Nyemaster Goode attorney.

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