Seyfarth Synopsis: Federal OSHA has put grain handling safety right up-front on its main homepage. OSHA wants you to "learn how to stay safe during grain handling operations."

Concerning the Agency's Grain Handling Facilities Standard, 29 C.F.R. § 1910.272, the Agency explained that "grain handling facilities are facilities that may receive, handle, store, process and ship bulk raw agricultural commodities such as ... corn, wheat, oats, barley, sunflower seeds, and soybeans." The facilities include grain elevators, feed mills, flour mills, rice mills, dust pelletizing plants, dry corn mills, soybean flaking operations, and dry grinding operations of soycake.

The Agency continues to place an enforcement emphasis on grain handling facilities because the "grain handling industry is a high hazard industry where workers can be exposed to numerous serious and life threatening hazards." The hazards include: fires and explosions from grain dust accumulation, suffocation from engulfment and entrapment in grain bins, falls from heights and crushing injuries, and amputations from grain handling equipment.

Research has found that suffocation is a leading cause of death in grain storage bins. A report issued by Purdue University found that in 2010, 51 workers were engulfed by grain stored in bins, and 26 died. "Suffocation can occur when a worker becomes buried (engulfed) by grain as they walk on moving grain or attempt to clear grain built up on the inside of a bin. Moving grain acts like 'quicksand' and can bury a worker in seconds." It is estimated that about 400 pounds of pulling force is required to extract a body out of waist deep grain.

In addition, grain dust explosions can be severe. OSHA has required enforcement of nationwide dust hazards from grain handling facilities. According to OSHA, over the last 35 years, there have been over 500 explosions in grain handling facilities across the United States, which have killed more than 180 people and injured more than 675. We had previously blogged on Updated Combustible Dust NFPA Industry Consensus Standard Gives OSHA New Tool to Cite Employers: Does Your Facility Comply? In the blog we noted that compliance with the industry standard for combustible dust is set for September 2020. But we suggested that industry not delay its compliance efforts, as OSHA is already citing employers using the not yet effective NFPA 652, Standard on the Fundamentals of Combustible Dust.

Accordingly employers who operate grain handling facilities should note federal OSHA's ongoing enforcement emphasis, and ensure they are in full compliance.

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