A white paper by Glenn Drees CSP, CPCU Managing Director, Food & Agribusiness

Shipping, receiving and storing grain is a highly volatile process that carries with it a wide variety of hazards and associated risks that can result in damage to property and physical injury to individuals. Taking preventive measures to avoid potential hazards, including grain dust explosions, fire, employee engulfment and asphyxiation, are imperative for every business operation in the industry.

In 1987, these dangers associated with grain handling were outlined by OSHA in what came to be known as the 1910.272 Standard, which has since been adopted as the grain handling standard to protect agricultural workers from serious injury or death. And although this standard is specifically focused on employee safety, its benefits extend to the protection of property. For example, standards for controls in places where welding and other hot work is being done extend beyond the human element to also protect property by best practice.

The 1910.272 Standard applies to a number of facilities associated with the processing of grain, including grain elevators, flour mills, rice mills, feed mills, oil seed processing, on-farm storage of grain and any facility engaged in the receipt, handling, storage or shipment of bulk raw agricultural products such as corn, soybeans, wheat, barley, oats and sunflower seeds.

Since 2008, OSHA has had a combustible dust national emphasis program created in response to a number of serious combustible dust accidents that resulted in death and serious injuries to workers. Following an explosion in May of 2017 that killed five workers and injured a dozen others in Wisconsin, OSHA proposed a $1.8M fine against the employer stating the incident could have been prevented if the leakage and accumulation of highly combustible grain dust throughout the facility had been addressed by leadership. While OSHA cannot inspect every grain handling facility in the United States, the facilities listed above have a high likelihood of inspection.

Below is a four-step approach to reducing the risk of employee injury and damage to property that will also help protect your operation from OSHA penalties.

Step 1. Develop an Emergency Action Plan
Operations of any size should have a written emergency action plan in place made available to all employees addressing what actions to take in the event of fire, explosion, flood, confined space rescue and extreme weather conditions within your geographic area. Identifying alarm systems, as well as the responsibilities of employees in the event of an emergency, evacuation procedures, designated safe areas outside the facility and emergency escape routes help minimize risks to your workers. Clearly mark escape routes on facility maps and make sure contractors and visitors are aware of procedures upon their arrival. Regularly test your plan to evaluate efficiency and improve as needed to maximize safety.

Step 2. Create a Training Program
OSHA requires new-hire training, as well as annual retraining to refresh existing employees and job-specific training for anyone that could be exposed to new hazards. A comprehensive training program should cover the hazards found at grain handling facilities, such as cleaning procedures for chocked legs, smoking controls, lockout-tagout procedures, housekeeping requirements, procedures for performing hot work and preventive maintenance of all grain handling equipment (including grain dryers).

Step 3. Require “Hot Work” Permits 
Hot work includes welding, cutting, brazing or similar flame-producing operations. Reduce risk by mandating a permit for all hot work completed near a grain handling structure. Wherever possible, designate areas for hot work outside the grain handling structure. In cases where this is not possible, permits help keep your workers accountable and your operation safe until the hot work is completed. 

Create a permit checklist of essential processes to complete the hot work safely at your facility. All movable fire hazards in the vicinity should be taken to a secure location on-site. Fire extinguishing equipment should be available where the hot work is occurring. Beyond fire extinguishers, pails of water, buckets of sand, or hoses should be readily available in the event of an emergency. Assessing your facility for areas of hazard on a regular basis helps minimize potential threats. For example, floor openings or cracks that cannot be immediately closed should be marked and precautions should be taken so no combustible material can cause a fire. Establish a fire watch during the hot work and for a minimum of 30 minutes after job completion to detect and extinguish smoldering embers.

Step 4. Follow Confined Space Entry Regulations (Bins, Tanks, Silos) 
Grain handling facilities potentially have many confined spaces that should be catalogued and accurately marked. Confined spaces are defined as those spaces that have limited or restricted means for entry or exit and are not designed for continuous occupancy. Permitrequired confined spaces have one or more of the following characteristics: contain or has the potential to contain a hazardous atmosphere; contains material that has the potential to engulf an entrant; has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant; or contains any other recognized safety or health hazard such as an unguarded piece of machinery.

Operations should have a written confined space entry program and issue permits for entry into bins, silos and tanks. The space should be ventilated if required, and the atmosphere within the space must be sampled to detect an oxygen deficient atmosphere or the presence of a harmful gas. 

When entry occurs, a permit must be completed that identifies the entrants, attendants and the plan for rescue in the event of emergency. Any equipment in the area where entrants will be working should be locked and tagged out. Appropriate personal protective equipment should always be provided to individuals involved in entry. “Walking down the grain” and entering bridged or built-up situations should be strictly prohibited. 

Once a job is complete, all personnel should be removed, tools and debris cleared from the space and the permit should be canceled.

Additional Important Requirements 

At grain handling facilities, there are often contractors performing work at your facility. The safety of each of these individuals on your premises is important and each should be aware of the potential hazards at your facility. 

The grain handling can be made safer for employees and property by following strict safety protocol. While the list above is not exhaustive, taking the steps listed above outlining some of the most important risk mitigation tactics will lower hazardous situations at your grain facility, keep your employees safe and your operation in compliance with OSHA regulation.

About the author

Glenn is a graduate of Eastern Kentucky University with a B.S. in Fire Protection Technology. He began his career with Crum and Forster Insurance, holding several technical and managerial positions within Loss Control. Glenn’s current responsibilities as Managing Director of Gallagher’s Food and Agribusiness Practice include setting the strategic direction for the practice group that places in excess of $400M of premium annually on behalf of our clients, maintaining market relations with insurance carriers, developing best-in-class expertise for our clients and helping clients understand and reduce their cost of risk.