The city of Buffalo, New York is home to what’s known as “elevator alley”—a moniker that refers not to people-moving elevators we’re all familiar with, but to modern grain elevators. Buffalo not only houses the largest number of grain elevators in the world today, it’s also where the grain elevator was born.
What does this fun fact about Buffalo have to do with OSHA compliance? Well, grain elevators are one type of “grain handling facility” for which OSHA maintains specific work safety requirements in Title 29 of the Code of Federal Regulations
(29 CFR). Others include feed mills, flour mills, rice mills, pelletizing plants, and dry corn mills.
What Is a Grain Elevator Under 29 CFR?
Grain elevators are facilities engaged in the receipt, handling, storage, and shipment of bulk raw agricultural commodities, such as corn, wheat, oats, barley, sunflower seeds, and soybeans. Due to the inherent risks associated with these activities, the agency promulgated a standard within the General Industry regulations devoted entirely to grain handling facilities (29 CFR 1910.272).
Grain Handling Safety Risks—Falls, Fires, Explosions, Engulfment, and Entrapment
When it comes to grain handling, among the most widely recognized risks are those associated with grain dust fires, explosions, engulfment, entrapment, and falls from elevated surfaces.
When dealing specifically
with grain storage bins, suffocation is a leading cause of death. Workers are fatally injured due to engulfment (i.e., becoming buried) by grain typically as a result of walking on it or trying to clear away grain buildup.
Apart from the seriousness of engulfment hazards, explosions at grain facilities have a longstanding history of resulting in catastrophic events. OSHA reports that over the past several decades more than 180 people have been killed and over 675 injured in grain facility explosions.
Not surprisingly, the leading cause of explosions at these facilities is dust from the grain. When workplace conditions allow for the right amount of combustible grain dust particles to become suspended in air, any nearby ignition source can lead to a substantial explosion. Of particular concern within grain handling facilities are the numerous ignition sources to be found, including welding, cutting, and brazing activities; misaligned conveyor belts; overheated motors; and hot bearings.
Additional Grain Handling Hazards—Machines and Fumigants
Other types of commonplace machinery like augers and conveyors present serious hazards of their own, which can entangle workers and cause amputations.
In some cases, additional hazards are “introduced” into the work environment. Take, for example, the use of fumigants to prevent insect infestation. Inhalation of fumigants can lead to long-term health effects, such as heart disease, damage to the central nervous system, and cancer. In terms of short-term exposure, workers may be overcome by breathing in fumigants, possibly leading to loss of consciousness.
OSHA Emergency Action Plans (EAP)
OSHA begins its grain handling facility standard with a focus on the Emergency Action Plan (EAP). Employers who operate grain handling facilities must develop and implement an EAP that meets to the requirements of 29 CFR 1910.38.
Among those EAP requirements are to establish:
- Procedures for reporting a fire or other emergency.
- Procedures for emergency evacuation, including type of evacuation and exit route assignments.
- Procedures to be followed by employees who remain to operate critical plant operations before evacuation.
- Procedures to account for all employees after evacuation.
- Procedures to be followed by employees performing rescue or medical duties.
- The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties. [29 CFR 1910.38(c)]
Employees working at grain handling facilities must be trained annually,
and more frequently as necessary, whenever changes on the job expose them to new hazards. At a minimum, training content must cover general safety precautions at the facility, including recognition and preventive measures for hazards related to dust accumulations and common ignition sources (combustible dust).
In addition, employees must be trained on specific procedures and safety practices relative to the job, including, but not limited to, cleaning grinding equipment, clearing choked legs, housekeeping measures, performing hot work, carrying out routine preventive maintenance on equipment, and following written lock-out/tag-out procedures. For those employees assigned more hazardous, specialty types of tasks (e.g., handling flammable or toxic substances), additional training is required.
Working Safety in Grain Silos, Tanks, and Bins
OSHA’s grain handling facility standard also addresses other safety concerns related to specific tasks. Employees at these facilities commonly access the inside of a grain storage structure like a silo, tank, or bin. Under the standard, a permit system should be in place prior to authorizing employee entrance. In addition, employers must have safety procedures in place before allowing employees to enter flat storage structures where there is a risk of engulfment.
OSHA Housekeeping for Grain Handling Facilities
Housekeeping plays a very important role in maintaining a safe work environment where operations involve moving and storing grain. So much so that OSHA requires employers to have a written housekeeping program that lays out the best methods for reducing the amount of grain dust that accumulates on floors, equipment, ledges, and other exposed surfaces.
Certain “priority housekeeping areas” are identified within paragraph (j) of the standard, and employers are expected to “immediately remove any fugitive grain dust accumulations whenever they exceed 1/8 inch (0.32 cm) at priority housekeeping areas….”
In terms of planning for emergencies, employers must provide for at least two means of escape from galleries (bin decks) as well as tunnel areas of grain elevators built after the standard’s effective date (1987). OSHA’s grain handling facility standard also contains rules for the following:
- Hot work permits, paragraph (f)
- Contractors, paragraph (i)
- Grate openings, paragraph (k)
- Filter collectors, paragraph (l)
- Preventive maintenance, paragraph (m)
- Grain stream processing equipment, paragraph (n)
- Continuous-flow bulk raw grain dryers, paragraph (p)
- Inside bucket elevators, paragraph (q)
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