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The National Grain and Feed Association (NGFA) has urged the Occupational Safety and Health Administration (OSHA) to retain its existing grain-handling facility standard, and to exempt grain elevators, feed mills and grain processing plants already covered by those regulations from its planned development of a comprehensive combustible dust standard.

The NGFA’s statement, developed in collaboration with and supported by the American Feed Industry Association and Pet Food Institute, was submitted in response to OSHA’s Oct. 21 advance notice of proposed rulemaking, in which the agency signaled its intent to develop a broad, comprehensive combustible dust standard that would apply across different industry sectors. OSHA posed a series of 69 questions (several of which had multiple parts) on which it solicited public comment, and said the responses would be used as the basis for developing a proposed combustible dust standard later this year. The agency’s advance notice specifically cited its existing grain handling safety standard, implemented in 1988, as an example of how such a standard could reduce the number of incidents and fatalities in an industry sector.

But OSHA’s notice did not specifically rule out at this preliminary stage developing additional regulations for any industry, including the grain, feed and processing sector. Among the questions posed by the agency was whether any revisions were needed to portions of the grain-handling standard that address fires and explosions, whether it should be harmonized with the approach ultimately taken by OSHA for other combustible dusts, whether it should be incorporated into a new combustible dust standard and, if OSHA retained it as a separate standard, whether doing so would cause portions of grain-handling facilities to be covered by two separate OSHA standards.

In its statement, the NGFA expressly opposed harmonizing the grain handling standard with any general industry combustible dust standard that may be developed as part of the rulemaking. The NGFA said doing so potentially would subject the grain handling industry to two different regulations, result in compliance confusion and perhaps misdirect industry resources from methods known to be effective in reducing fire and explosion risks. “We believe that any attempt to harmonize these standards likely would have a detrimental impact upon the proven effectiveness of the grain handling standard,” the NGFA said. “The information used (by OSHA) to arrive at a grain handling standard is specific to our industry and is unlikely to be improved by a general industry combustible dust standard. Having two different standards to address the same hazard would result in duplicative and unnecessary requirements that most likely would cause more confusion than reduce fire and explosion hazards.”

The NGFA also noted that OSHA’s own regulatory review in 2003 determined that the grain handling standard should continue without change. At that time, OSHA credited the industry with implementing improved safety procedures “in response to the NGFA’s guidelines” that resulted in an initial reduction in fire and explosion incidents five years before the agency’s standard took effect.

The NGFA’s statement noted that fire and explosion incidents in grain-handling facilities have declined by 65 percent, as measured in five-year increments since 1976. Meanwhile, the reduction in the number of injuries and fatalities has been even more dramatic -- declining 86 percent and 94 percent, respectively. This improved safety record occurred even as the volume of grain being handled by U.S. facilities increased by nearly 60 percent over the same time span, the NGFA noted.

The NGFA attributed the progress to a combination of governmental safety rules and an extensive $3.5 million industry research program that discovered the causes and developed new techniques for controlling fire and explosion risks, coupled with ongoing education and training efforts. The association noted that at the time its research was launched in the late 1970s, the ignition source and location of explosions occurring in grain-handling facilities were unknown in more than 41 percent of the incidents.

The NGFA’s subsequent research encompassed 41 separate projects that addressed fuel, confinement and ignition sources -- three of the four elements necessary for an explosion to occur. Scientists believed the fourth element -- oxygen -- could not be addressed realistically in an operating grain-handling facility. Among other things, the research revolutionized the design, layout and construction of facilities -- most notably resulting in the relocation of grain-handling equipment outside the main structure in new and renovated plants -- pioneered the use of portable suppression devices and venting of explosive pressures, and developed new methods for measuring and minimizing grain dust concentrations.