A vital practice for a safe workplace in the grain industry
Keeping a workplace clean is a cost-effective and essential measure toward workplace safety. This is especially critical for those working in the agriculture, food processing, and storage industries.
According to Matthew Thurlby, OSHA’s Omaha, NE area director, “Grain dust fires and explosions are a well-known industry hazard, which makes Legacy Grain Cooperative’s failure to control dust where a belt’s friction could easily cause ignition inexcusable. Employers must develop company-wide safety procedures to mitigate known grain handling dangers and ensure workers are trained to recognize hazards.”
The U.S. Department of Labor and OSHA regional investigators noted that they witnessed life-threatening hazards to workers at the Hemingford, NE grain elevator by citing more than $536,000 in potential fines due to the company allowing this buildup of combustible dusts and failing to maintain effective dust collection systems from their inspection addressing a complaint of unsafe working conditions.
Investigation Findings
OSHA found the company had permitted more than 1/8-inch of grain dust to accumulate in priority housekeeping areas, such as in the bottom belt tunnels and around bucket elevator equipment where the impact of whole grains inherently generates dust to the process. Grinding, drying and dust control processes are additionally prioritized and regulated by OSHA. The agency reportedly also found duct tape wrapped around the dust collection system, located in the bottom belt tunnel, in a makeshift attempt to repair the equipment. This reduced the system’s efficiency and increased its vulnerability to failure.
If left unchecked, grain dust can ignite in seconds and cause deadly fires and explosions. Grain dust accumulation and ignition sources are regulated by OSHA standards to prevent dangerous dust explosions as notably outlined to OSHA 29 CFR 1910.272, along with numerous other general duty clause regulations. Employers are required to minimize and control dust accumulations, conduct regular inspections, certify the completion of preventive maintenance, and regularly train personnel on these hazards. Failure to comply with these regulations is a safety risk that could result in serious fines from a routine inspection visit.
Avoid the Fines
This was the highest fine I’ve ever witnessed that has been imposed on a facility without having first been supported by an incident and/or injury condition. It is notably defined that a layer of combustible dust at 1/8-inch thick is more than enough to fuel for an explosion throughout a facility. An industry-based Dust Hazard Analysis (DHA) is a process that identifies, documents, and evaluates the potential of dust-related fires, explosions, and deflagrations at facilities. The process is inclusive with recommendations to manage every hazard identified by their risk. DHAs are outlined and governed by National Fire Protection Agency (NFPA) standards (specifically 61 and 652 editions). OSHA has been routinely expanding industry regulations for safe practice based on NFPA standards. NFPA recommended that all industrial facilities have a DHA completed by January 1, 2022.
DHAs are necessary to any facility that knowingly handles combustible dusts in effort to improve health and safety, lower facility insurance costs, protect assets, and avoid potential OSHA-related violations.
With 18 years directly dedicated to the agricultural industry, this is a process I’m well trained in and experienced at performing. Feel free to contact me with any questions regarding DHAs.
Justin D. Brownlee is senior designer for Clear Creek & Associates, Inc., Goshen, IN. He can be reached at 574-537-9060 or jbrownlee@ccalink.com.