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Comprehensive safety program for grain handling facilities in Oklahoma region to prevent falls, explosions, and hazards. Enforcement inspections, outreach activities, and assistance sources outlined.
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OKLAHOMA CITY AREA OFFICE 55 NORTH ROBINSON, SUITE 315 OKLAHOMA CITY, OKLAHOMA 73102 (405) 278-9560 OSHA HOTLINE 1-800-321-OSHA www.osha.gov
REGIONAL EMPHASIS PROGRAM FOR GRAIN HANDLING FACILITIES • Region VI – TX, OK, AR, LA, NM • Due to significant hazards to employees including: • Falls, electrocutions, engulfment, auger entanglement, struck-by, and explosions • 89 fatalities since 2000 including: • 40 grain engulfments • 32 falls • 7 combustible dust explosions • Also 38 amputation injuries in grain handling facilities since 2000
SIC/NAICS CODES INCLUDED IN REP • 2041/311211 - Flour Milling • 2044/311212 - Rice Milling • 2048/311119 - Other animal food mfg • 2074/311223 - Cottonseed oil milling • 4221/493130 - Farm products warehousing and storage • 5153/424510 - Grain and field bean wholesalers • 5159/422590 - Other farm-product raw materials wholesalers
REP ENFORCEMENT INSPECTIONS • Review of OSHA-300 injury and illness records • Review of safety and health programs • Address hazards including: • Combustible dust hazards • Engulfment hazards • Lockout/Tagout • Forklift operations • Grain entry programs and procedures • Confined space entry • Machine guarding • Housekeeping program • Fall protection program and procedures • Personal protective equipment practices • Electrical safety-related procedures
REGIONAL EMPHASIS PROGRAM IMPLEMENTATION • Outreach notification letter was sent to industry employers from OKCAO on November 1, 2010 • 60-day outreach delay to notify industry • Enforcement to begin after January 1, 2011 following outreach activities • Identifies sources for assistance to improve safety and health programs including: • OK DOL State Consultation 405-521-6100
SCHEDULING OF INSPECTIONS • Each Area Office develops a list of known grain handling facilities in the targeted SIC/NAICS codes • Random number table is applied to list and inspection cycle created • Scope of REP is comprehensive • If an unprogrammed inspection (complaint, referral, fatality) is conducted at an establishment on the REP inspection cycle, the comprehensive inspection may be conducted concurrently • Inspections will be conducted by OSHA personnel with training and familiarity with REP policy
RELATED OSHA DIRECTIVES AND PROGRAMS • CPL 02-01-004, Inspection of Grain Handling Facilities • CPL 03-00-008, Combustible Dust National Emphasis Program
How to Prepare for OSHA Inspection • 1. Read OSHA regulation of Grain handling facilities 1910.272 • www.osha.gov/regulations 2. Read OSHA publication Grain Handling OSHA 3103 www.osha.gov/publications
To Prevent Fatalities and Injuries • Plenty of information in internet and trade publications • EXAMPLE: • Safe Storage and Handling of Grain • National Ag Safety Database • www.cdc.gov/nasd/docs
Two Recent Grain Handling Accidents • 1. Fire in Grain Storage Bin (Soybeans). Firefighter dead (PEOSH jurisdiction) • Citations: • a. 5(a)(1): Cutting hole in metal wall of bin with gasoline powered abrasive wheel saw. Ignited soybean debris. Prohibit use of cutting tools that create sparks that can ignite debris.
Citations Fire in grain storage bin • 1910.27(d)(2): Using ladder over 20 ft. high without landing platforms. • 1910.212 ( c)(1): Used west bin drag conveyor to discharge soybeans with top guard section removed on discharge end. • 1910.272(g)(1)(i): employer did not issue a permit for entering bins, silos, or tanks in the grain handling facility before employees entered.
Citations Fire in grain storage bin • 1910.271(g)(iii): The atmosphere within a bin, silo or tank was not tested for combustible vapors/gases and toxic agents or oxygen content prior to employees entering. • 1910.272(g)(2): When entering bins, silos or tanks from the top, employees did not wear a body harness with lifeline or use a boatswain’s chair.
Citations Fire in grain storage bin • 1910.272(g)(4): The employer did not provide equipment for rescue operations which was specifically suited for the bin, silo or tank being entered. • 1910.272(i)(1): The employer did not inform contractors of the applicable safety rules of the grain handling facility
Citations Fire in grain storage bin • 1910.272(i)(2): The employer did not explain the applicable provisions of the emergency action plan to contractors
Employee Asphyxiated inside grain transition pit • Employee entered pit where grain had been stored for weeks. Atmospheric testing not performed. Pit had high levels of carbon dioxide. Employee found dead. • 1910.272(g)(1)(iii): The atmosphere within a bin, silo or tank in the grain handling facility was not tested for the presence of combustible gases, vapors, toxic agents and oxygen content prior to employees entering.
Employee Asphyxiated inside grain transition pit • 1910.272(g)(3): An observer, equipped to provide assistance, was not stationed outside the bin, silo, or tank being entered by employee. • 1910.272(j)(4): The housekeeping program at the grain handling facility did not address the procedures for removing grain and product spills from work area.
End • Questions? • You can email questions to delucca.jorge@dol.gov