Top 5 OSHA citations and how to avoid them

Facilities that handle grain must deal with a variety of hazards. The ones that get the most attention are entrapments, engulfment's, dust explosions and fires.

All of these are serious, but the hazards responsible for the most injuries, citations and even fatalities do not get the same level of media exposure.

Each year the Occupational Safety and Health Administration (OSHA) releases its top citations. The 2022 list features hazards that have the potential to be found at any grain handling and processing facility.

Announced at the 2022 NSC Safety Congress & Expo, 2022’s most common citations were:

1. Fall Protection – General Requirements (1926.501): 5,260 violations

2. Hazard Communication (1910.1200): 2,424

3. Respiratory Protection (1910.134): 2,185

4. Ladders (1926.1053): 2,143

5. Scaffolding (1926.451): 2,058

These workplace hazards can lead to a citation and fine if found during a facility inspection. They can also lead to facility downtime and lost productivity hours on top of potential harm to employees.

Walking-working surfaces and fall protection requirements

In 2020, 18% of the 1,176,340 nonfatal work injuries resulting in days away from work 2020 were related to slips, trips and falls, according to the Bureau of Labor Statistics. They represent a serious threat to the safety of workers but are almost always preventable.

According to OSHA standards, fall protection covers many circumstances. Employers are required to inspect the work environment and determine if there is any risk of a fall from both high places (elevated walkways, the top of bins or train cars, trucks, etc.) or any other areas workers walk where slip, trips and falls might happen (passageways, storerooms, service rooms and walking-working surfaces).

The first step in protecting employees from falls is to ensure all walking-working surfaces are kept in a clean, orderly and sanitary condition to a feasible extent. For indoor areas, this includes keeping clutter from accumulating (tools, containers, extension cords, flipped-up mats and other debris.) These items should be cleaned up immediately, ensuring each item has a proper place to be stored. Employees should be trained to avoid accumulating clutter.

Outdoor walking-working surfaces must be free of sharp or protruding objects, loose boards, corrosion, leaks, spills, snow and ice. Walking-working surfaces need to be inspected regularly and as necessary and maintained in a safe condition.

Any hazards must be addressed or repaired before employees can work on those surfaces again. If fixing the hazard involves the structural integrity of the surface, a qualified person must personally make or supervise the correction or repair. Creating an environment where employees are encouraged to report any potential walking-surface hazard can ensure problems are fixed before they become an issue.

Fall protection from heights

The type of fall protection needed changes greatly depending on the situation. Employers must provide fall protection on any walking-working surface 4 feet or higher from a lower level. In these situations, it’s up to the employer to determine if a guardrail system, safety net system or personal fall protection system is the best option for the hazard.

The most common fall protection systems found in grain handling and processing facilities are guardrail systems and personal fall protection systems (personal fall arrest, travel restraint or positioning systems).

Guardrail systems protect workers from edges, holes or anything they could fall off of or in. Guardrails must be at least 42 inches high, with the top rail being smooth to avoid snagging clothing or causing cuts to employees.

Guardrails also must have mid rails, screens, mesh, intermediate vertical members, solid panels or equivalent intermediate members installed between the walking-working surface and the top edge of the guardrail system so there is no more than a 19-inch opening or gap. They must also withstand at least 200 pounds of pressure applied in a downward or outward direction within 2 inches of the top edge at any point along the top rail and 150 pounds of pressure at any intermediate members.

What is hazard communication?

The Hazard Communication Standard was the second most cited OSHA violation in 2022. Workplaces that handle hazardous chemicals must make sure those chemicals are labeled and safety data sheets available.

These workplaces must also make sure those are understandable for employees. That means training employees on how to read labels and Safety Data Sheets along with having a written hazard communication compliance program.

Every grain handling and processing facility is subject to Hazard Communication Standard as OSHA considers grain dust an explosive hazard. In June 2015, several industry associations released a 55-page hazard communication guidance document with detailed examples of correct program protocols. It can be found at: https://secure.in.gov/dhs/file....

When workers need respiratory protection

Respirators protect workers against insufficient oxygen environments, harmful dust, fog, smoke, mists, gases, vapors and sprays. In grain handling and processing facilities, the most common environment where workers will need respirators is inside enclosed spaces like grain bins, where dust, mold and heat can make breathing difficult.

Facilities need a written respiratory protection program that recognizes situations where permissible exposure levels might be exceeded and when employees are required to wear respirators.

Employees that may need to wear respirators need training on when to wear respirators, how to wear them and what type of respirator is required for the situations outlined in the respiratory protection program.

Employers should also be aware of the common symptoms of respiratory illness if an employee is unknowingly exposed to a harmful environment without a respirator. The symptoms include:

• Headache
• Dizziness
• Runny or sore eyes
• Sore throat
• Stuffy nose or sneezing
• Cough
• Wheezing or tightness in the chest
• Shortness of breath
• Nausea or vomiting
• Monday morning syndrome (When a worker spends time away from the workplace and symptoms are alleviated only to reappear when the worker returns)

Ladder safety requirements

If workers at your facility use extendable ladders, doing so incorrectly can lead to a citation or an injury. Make sure employees are trained on how to use an extendable ladder properly. OSHA has made a list of dos and don’ts to help guide workplaces.

Do:

• Maintain a 3-point contact (two hands and a foot, or two feet and a hand) when climbing/ descending a ladder
• Face the ladder when climbing up or descending
• Keep the body inside the side rails
• Use extra care when climbing the ladder at the top or bottom. Avoid tipping the ladder sideways or causing the ladder base to slide out
• Carry tools in a tool belt or raise tools using a hand line. Never carry tools in your hands while climbing up/down a ladder
• Extend the top of the ladder three feet above the landing
• Keep ladders free of any slippery materials

Don’t:

• Place a ladder on boxes, barrels or unstable bases
• Use a ladder on soft ground or unstable footing
• Exceed the ladder’s maximum load rating
• Tie two ladders together to make them longer
• Ignore nearby overhead power lines
• Move or shift a ladder with a person or equipment on the ladder
• Lean out beyond the ladder’s side rails
• Use an extension ladder horizontally like a platform

Scaffolding safety

Supported scaffolds and suspended scaffolds are not used much at grain elevators, feed mills or other processing facilities unless a construction project is underway. But scissor lifts, aerial lifts and similar types of equipment fall into this citation category.

If your facility uses powered lift equipment, OSHA standards require operators to be trained by a qualified person (someone who processes a recognized degree, certificate or professional standing, has extensive knowledge, training and experience, and has successfully demonstrated the ability to solve or resolve scaffolding problems). For the training to be complete, it must enable employees to recognize the hazards associated with the scaffolding they will be using and understand how to avoid or minimize the hazards.

The most common hazards employees face when working with scaffolding, according to OSHA, are:

• Falls from elevation due to lack of fall protection
• Collapse of the scaffold, caused by instability or overloading
• Being struck by falling tools, work materials, or debris
• Electrocution due to the proximity of the scaffold to overhead power lines

Avoiding these citations will save a facility money during its next OSHA inspection, but, more importantly, it’s vital to making sure every employee goes home at the end of the day.

For more information on these hazards and how to avoid them, visit osha.gov. For information focused on industries that handle grain, visit grainsafety.org. Both sites have handouts, articles and presentations that can help ensure employees are adequately trained and businesses have the information necessary to make good safety policies.

— Steven Kilger