Five Steps to a Safer Facility

1. Grain Handling Standard

An aggressive approach to full compliance with the OSHA Grain Handling Standard, 29CFR 1910.272, is highly recommended.

Table 1 on page 84 covers the 14 compliance sections of the standard. This will assist you in assessing your facility�s level of compliance.

2. Employee �Education�

Section (e) of the Grain Handling Standard deals with employer training requirements. What is questionable in that portion of the standard is that nowhere in the language is the word �education� used.

The result being that employee training is considerably weakened when poor education is provided as a foundation for that training, and conversely, it�s considerably strengthened by a quality educational program.

The operative word here is �quality,� meaning that each and every employee should receive safety education in, at least, such sadly neglected areas as:

� The parameters of safety (and the fact that there is no absolute safety).

� Site-specific risk factors.

� Human risk perception.

� And most importantly, that the threat of an accident is ever-present.

3. Dust Explosion Prevention

The Grain Handling Standard was promulgated specifically to control grain dust fires and explosions.

While dust explosions can and do occasionally cause severe injuries and death, those individuals who hold safety responsibilities must also keep in mind the potential for damage to the facility itself.

I can recall a facility in Atchison, KS, where a series of dust explosions occurred, leaving it virtually destroyed. Indeed, what was left of the structure was �written off� and leveled.

An efficient program of fire and explosion control and prevention must include two distinct components:

1. Elimination and/or control of potential ignition sources such as welding and cutting, electrical, hot bearings, etc.

2. The control of fuel (grain dust).

Of the two components, considering housekeeping, labor, and equipment cost, fuel control is the most difficult and expensive to achieve.

However, assuming an initial explosion does occur, the best way to mitigate the destructive consequences of secondary explosions is by effective dust control.

4. Confined Space Entry

The regulatory requirements for confined space entry (bins, silos, and tanks) are spelled out in sections (g) and (h) of the Grain Handling Standard.

It remains only for the employer to develop and implement a mandatory confined space entry program.

Mandatory in this sense means that full employee compliance with the facility program is a condition of employment.

Note: Do not confuse the entry requirements for bins, silos, and tanks with the entry requirements of the standard for entry into permit-required confined spaces.

Permit-required spaces are those confined spaces other than bins, silos, tanks, and flat-storage structures.

A few examples of permit-required spaces are hopper cars, enclosed boot pits, some below-grade tunnels, and boilers.

5. Personal Protective Equipment

The standard for personal protective equipment (PPE) covers head, eye and face, hand, and foot protection. (Note: There also is a respiratory PPE standard covered in 29CFR 1910.134.)

It is the employer�s responsibility to provide the appropriate PPE, where it is required by the standard, at no cost to employees.

The first thing the employer must do is to conduct a facility hazard assessment to determine where PPE is needed. Table 2 on page 85 provides a handy form.

Written by Adam Schupp, safety consultant, North Fort Myers, FL; 941-731-5947.