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“While no single factor is responsible for the industry’s dramatically improved safety record, these efforts are a testament to how an industry -- working in tandem with employees and government -- developed an effective standard and implemented safety improvements,” the NGFA said.

The NGFA also noted that progress made as a result of the grain-handling facility standard, as well as research and education efforts, involved the investment of hundreds of millions of dollars by the industry in dust collection systems and other more modern mechanical equipment, as well as in additional operating and housekeeping costs.

In addition, the NGFA stressed that other grain-related industry sectors already are covered by other regulatory standards that affect workplace safety and housekeeping, such as the Food and Drug Administration’s good manufacturing practice regulations that address sanitation requirements at commercial feed mills.

The NGFA’s statement to OSHA also opposed modeling a combustible dust standard after voluntary standards developed by the National Fire Protection Association (NFPA), which are complex, do not evaluate the practical implementation nor cost impacts on the regulated industry, and do not permit broad public participation in their development. Further, the NGFA said that NFPA’s potential recommendation of a 1/32nd-inch or less action level for combustible dusts -- versus the 1/8th-inch standard now applicable to grain dust in priority housekeeping areas around bucket elevators under the grain-handling facility standard -- would increase compliance costs by several fold without materially contributing to improved safety. The NGFA noted that the grain-handling industry’s improved safety record indicates that more than 80 percent of fire and explosion safety hazards have been eliminated.

“We firmly believe there is overwhelming evidence supporting the grain-handling facility standard’s effectiveness in preventing fires and explosions at a time when grain-handling capacity has increased significantly,” the NGFA concluded. “We urge OSHA not to propose any major changes to the existing standard, and to exempt all grain-related enterprises partially or fully subjected to the grain-handling facilities standard from being subject to any general industry combustible dust standard the agency ultimately may adopt.”

The NGFA also consists of 35 affiliated state and regional grain and feed associations, as well as two international affiliated associations. It has strategic alliances with the Pet Food Institute and is co-located and has a joint operating and services agreement with the North American Export Grain Association.