Grain handling facility hazards

Employees must be trained at least once a year and whenever a job change exposes them to new hazards. See 1910.272(e) for the annual and change-of-assignment requirement.

• Training must cover general safety and job-specific procedures required by the standard (see 1910.272(e)(1)).
• Keep records or evidence that current employees and new hires received required training before or when they start assigned tasks.

Training must teach general safety precautions including how to recognize and prevent hazards from dust accumulations and common ignition sources such as smoking. See 1910.272(e)(1)(i).

• Employers should explain why grain dust is combustible and how poor housekeeping or ignition sources (hot bearings, electrical sparks, smoking) can start fires or explosions.
• Practical examples and site-specific controls (no-smoking rules, dust-control practices) should be part of the training.

Employees must be trained in job-specific procedures such as cleaning grinding equipment, clearing choked legs, housekeeping, hot work procedures, preventive maintenance, and lockout/tagout. See 1910.272(e)(1)(ii).

• Training should include step-by-step safe methods for tasks (e.g., how to clear a choked leg safely rather than 'jogging' a motor without control measures).
• If employees perform special tasks (bin entry, handling toxic/flammable substances), provide the additional training required by 1910.272(e)(2).

A hot work permit is required for all hot work in grain handling structures unless one of three exceptions applies. See 1910.272(f)(1).

• Exceptions: no permit is needed when (i) the employer or the employer’s representative who would authorize the permit is present during the hot work; (ii) the work is done in employer-authorized welding shops; or (iii) the hot work area is outside the grain-handling structure (1910.272(f)(1)(i)-(iii)).
• The permit must certify that the requirements of 1910.252(a) have been implemented before starting hot work (1910.272(f)(2)).

The hot work permit must certify that the safeguards required by 1910.252(a) for welding and hot work have been implemented prior to beginning hot work. See 1910.272(f)(2).

• This includes applicable fire prevention and control measures described in the welding/hot work provisions of 1910.252(a).
• Keep the permit on file until the hot work is complete, per 1910.272(f).

Employers must deenergize and prevent operation of any mechanical, electrical, hydraulic, or pneumatic equipment that could endanger employees inside the storage structure by disconnecting, locking-out and tagging, blocking-off, or using other equally effective methods. See 1910.272(g)(1)(ii).

• This is effectively a lockout/tagout requirement for equipment that presents a danger during entry; employers should follow appropriate energy-control procedures.
• If you need further detail on alternatives to full isolation for brief testing or operation, see OSHA’s interpretation on lockout/tagout temporary re-energization procedures: https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

The atmosphere must be tested for combustible gases, vapors, toxic agents, and oxygen content whenever the employer has reason to believe those hazards may be present; action is required if oxygen is below 19.5%, combustible gases exceed 10% of the LFL, or toxic agents exceed applicable ceiling values. See 1910.272(g)(1)(iii).

• If oxygen is less than 19.5% or combustible gases are over 10% of the lower flammable limit, 1910.272(g)(1)(iii)(A)-(B) requires ventilation until the unsafe condition is eliminated or use of appropriate respirators when ventilation cannot remove the hazard, consistent with 1910.134. OSHA’s interpretation on oxygen-deficient atmospheres provides additional context about using the 19.5% threshold: https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

If ventilation cannot eliminate oxygen deficiency, combustible gas, or toxic hazards, employees entering must wear an appropriate respirator and the employer must continue ventilation when it can reduce the hazard. See 1910.272(g)(1)(iii)(A)-(B).

• Respirator selection and program must comply with 1910.134.
• OSHA’s interpretation on oxygen-deficient atmospheres explains the 19.5% oxygen threshold and application of 1910.134.

'Walking down grain' or similar practices where an employee walks on or in moving grain is expressly prohibited. See 1910.272(g)(1)(iv).

• The prohibition exists because walking on flowing or moving grain creates an engulfment hazard—employees can rapidly sink and be buried.
• Use mechanical or safe alternative methods for freeing bridged material rather than putting a worker on moving grain.

Employers must equip employees with a body harness and lifeline or a boatswain’s chair that meet Subpart D requirements; the lifeline must prevent sinking deeper than waist-deep. See 1910.272(g)(2).

• If the employer can demonstrate harness/lifeline is not feasible or creates greater hazard, an alternative means that prevents sinking deeper than waist-deep may be used (must be demonstrated).
• Ensure harnesses, lifelines, and anchorage comply with applicable Subpart D provisions referenced in the standard.

An observer must maintain communications (visual, voice, or signal line) with the entrant, be trained in rescue procedures and notification methods, and the employer must provide rescue equipment specifically suited for the bin or tank being entered. See 1910.272(g)(4)-(5).

• Communications must be reliable so the observer can detect distress and summon help immediately.
• Rescue equipment should fit the geometry of the structure (e.g., retrieval systems sized for the opening) and be kept readily available.

Employees shall not enter bins, silos, or tanks underneath a bridging condition or where buildup on the sides could fall and bury them. See 1910.272(g)(6).

• Removing bridged material must be done from above using safe procedures that prevent collapse onto workers below.
• Use mechanical methods or remote tools where possible to break bridging from a safe location.

Each employee who walks or stands on stored grain where the depth poses an engulfment hazard must be equipped with a lifeline or an alternative means that the employer demonstrates will prevent sinking deeper than waist-deep. See 1910.272(h)(1).

• The alternative must be documented and show it provides equivalent protection to a lifeline.
• Communication and rescue procedures remain essential when employees are on top of stored grain.

Paragraphs (a) through (n) of the grain-handling standard apply to grain elevators, feed mills, flour mills, rice mills, dust pelletizing plants, dry corn mills, soybean flaking operations, and dry grinding operations of soycake. See 1910.272(b)(1).

• Other parts of the standard (o–q) apply only to grain elevators per 1910.272(b)(2).
• Employers should confirm which paragraphs of the standard apply to their specific operation.

A 'choked leg' is a material buildup in the bucket elevator that stops material flow and bucket movement; a bucket elevator is not considered choked if the up-leg is partially or fully loaded but the boot and discharge are clear allowing bucket movement. See the definition in 1910.272(c).

• Employers should train employees on safe clearing procedures for choked legs as required by 1910.272(e)(1)(ii).
• Avoid unsafe practices such as 'jogging' motors without energy control or establishing safe procedures.

An entry permit must be issued for entering bins, silos, or tanks unless the employer or the employer’s representative who would authorize the permit is present during the entire operation; the permit must be kept on file until completion of entry operations. See 1910.272(g)(1)(i).

• The permit certifies that the precautions in paragraph (g) have been implemented before entry.
• Keep the permit accessible and available for inspection until the entry task is finished.

The employer must develop and implement an emergency action plan that meets the requirements of 1910.38, as required by 1910.272(d).

• The plan should cover evacuation routes, alarm systems, employee training on the plan, and procedures for accounting for personnel during an emergency.
• Test and update the plan periodically and after significant facility changes.

Employees who enter grain storage structures must receive training about engulfment and mechanical hazards and how to avoid them. See 1910.272(e)(2).

• Training should cover use of harnesses and lifelines, observer and rescue procedures, lockout/tagout of equipment, and recognizing bridging conditions.
• Document that this specific training was given before employees perform entry tasks.

The employer may waive the formal hot work permit when (i) the employer or employer’s representative who would otherwise authorize the permit is present during the hot work, (ii) the work is done in employer-authorized welding shops, or (iii) the hot work area is located outside the grain handling structure. See 1910.272(f)(1)(i)-(iii).

• Even when a formal permit is not issued, the employer must ensure all required safeguards from 1910.252(a) are in place.
• Presence of the employer means active supervision during the hot work operation.

When ventilation cannot eliminate oxygen deficiency, combustible gas, or toxic hazards inside bins/silos/tanks, employees must wear appropriate respirators selected and used in accordance with 1910.134, as required by 1910.272(g)(1)(iii)(B).

• Implement a written respiratory protection program, fit testing, medical evaluation, and training per 1910.134.
• Consider OSHA’s interpretation on oxygen-deficient atmospheres for context on the 19.5% oxygen threshold: https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

You must deenergize and physically prevent any equipment that could endanger the worker from operating before the employee walks or stands on grain that poses an engulfment hazard. Under 1910.272(h)(2)(i) the employer shall deenergize and shall disconnect, lock-out and tag, block-off, or otherwise prevent from operating (by other equally effective means) any equipment that presents a danger (for example, augers or other moving grain transport equipment).

• If a task cannot be completed without momentary re-energization (for testing, positioning, etc.), follow the controlled sequence described in OSHA’s lockout/tagout guidance (see the LOTO interpretation explaining temporary re-energization and required employee protections).

No. "Walking down grain" or standing on moving grain is prohibited. 1910.272(h)(2)(ii) explicitly forbids practices where an employee walks on grain to make it flow or is on moving grain.

• Employers must use mechanical or safe alternative methods to remove bridging and keep grain flowing rather than having employees enter or walk on the grain.

A lifeline or alternative fall protection may be removed only when the employer can demonstrate the walking/standing surface is free from engulfment hazards. The note to paragraph 1910.272(h)(1) states that if the employer demonstrates the surface is free from engulfment hazards, the lifeline or alternative means may be disconnected or removed.

• Keep documentation or a safe procedure showing how you determined the surface is free from engulfment before removing the lifeline.

No. Employees must not be allowed underneath bridging conditions or in locations where accumulated grain could fall and engulf them. 1910.272(h)(3) prohibits permitting employees to be under bridging conditions or where accumulation on sides or elsewhere could fall and engulf the employee.

• Employers must identify bridging hazards and control access until the hazard is eliminated by safe means.

The employer must inform contractors of known fire and explosion hazards and explain the facility’s applicable safety rules and emergency plan provisions. 1910.272(i)(1) requires informing contractors of known potential fire and explosion hazards related to their work and area, and 1910.272(i)(2) requires explaining the applicable provisions of the emergency action plan to contractors.

• Provide contractors written or verbal briefings, and make sure they understand hot work, ignition sources, and dust-control rules relevant to their tasks.

You must have a written housekeeping program that states how often and by what methods you will reduce fugitive grain dust on ledges, floors, equipment, and other exposed surfaces. 1910.272(j)(1) requires a written program establishing the frequency and methods determined best to reduce dust accumulations.

• The program should identify responsible persons, cleaning methods (e.g., vacuuming with explosion-rated equipment, not blowing with compressed air except as allowed), and inspection frequency.

Priority housekeeping areas include floors within 35 feet of inside bucket elevators, floors of enclosed grinding equipment areas, and floors of enclosed areas containing grain dryers; dust in those priority areas must be removed immediately when accumulations exceed 1/8 inch. 1910.272(j)(2)(i)(A), 1910.272(j)(2)(i)(B), 1910.272(j)(2)(i)(C) list the priority locations and 1910.272(j)(2)(ii) requires removal whenever fugitive dust exceeds 1/8 inch (.32 cm) or demonstrate equivalent protection through the housekeeping program.

• Use measurement methods or routine visual checks to determine when 1/8 inch is reached and document corrective actions in your program.

You may use compressed air to blow dust only when all machinery that could ignite dust is shut down and all other known ignition sources are removed or controlled. 1910.272(j)(3) limits compressed-air cleaning to situations where ignition sources are eliminated.

• Prefer vacuum systems designed for combustible dust where possible; if compressed air is used, lockout/tagout or other controls must ensure no ignition sources are present during blowing.

No. Grain and product spills are not considered fugitive grain dust accumulations, but your housekeeping program must include procedures for removing those spills. 1910.272(j)(4) states spills are not fugitive dust but 1910.272(k) and the housekeeping provisions require procedures for removing spills.

• Treat spills promptly per your written procedures to prevent grinding into dust or creating slip/engulfment hazards.

Receiving-pit feed openings must be covered by grates with openings no larger than 2½ inches. 1910.272(k) requires grates over truck or railcar receiving-pits and limits grate opening width to a maximum of 2.5 inches (6.35 cm).

• Inspect grates regularly for damage and secure attachment; replace grates that exceed the maximum opening size.

Fabric dust filter collectors in pneumatic dust collection systems must have a monitoring device indicating pressure drop across the filter, and collectors installed after March 30, 1988 must be outside or in specially protected/separated areas. 1910.272(l)(1) requires a pressure-drop monitoring device, and 1910.272(l)(2) with subparts (i)-(iii)–(https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.272#1910.272(l)(2)(iii)) requires that units installed after the date be located outside, or inside but protected by explosion suppression, or inside in a one-hour fire-resistance room adjacent to an exterior wall and vented to outside.

• Use the pressure-drop monitor to detect filter plug-up or failure and take prompt corrective action.

You must implement scheduled inspections and maintenance (including lubrication) for mechanical and safety control equipment, and keep certification records of each inspection listing date, inspector, and equipment identifier. 1910.272(m)(1)(i) requires regularly scheduled inspections, 1910.272(m)(1)(ii) requires lubrication/maintenance per manufacturers' recommendations or operating history, and 1910.272(m)(3) requires maintaining a certification record for each inspection with date, inspector name, and serial number or other identifier of equipment inspected.

• Keep inspection logs current and available for review; promptly fix malfunctioning dust collectors per 1910.272(m)(2).

Locks and tags must be removed only following established procedures and generally only by the employee who installed them or, if that employee is unavailable, by that employee’s supervisor. 1910.272(m)(4) requires procedures for tags and locks to prevent inadvertent application of energy, and section 16 of the standard states such locks and tags shall be removed in accordance with established procedures only by the installing employee or, if unavailable, by his or her supervisor.

• Maintain a written LOTO procedure and training that documents who may remove locks/tags and the steps to follow.

Grain stream processing equipment must have an effective means to remove ferrous (metal) material from the incoming grain stream. 1910.272(n) requires devices such as magnetic separators to prevent metal from entering grinding equipment.

• Inspect and maintain metal-removal devices regularly as part of your preventive maintenance program.

Galleries (bin decks) must have at least two means of emergency escape, and existing grain-elevator tunnels must have at least one means of emergency escape. 1910.272(o)(1) requires at least two escapes from galleries, and 1910.272(o)(2) requires at least one escape in tunnels of existing elevators.

• For tunnels constructed after the standard’s effective date, two means of escape are required (see 1910.272(p) introductory text). Ensure escape routes are kept clear and well marked.

Direct-heat grain dryers must have automatic controls that shut off the fuel supply if there is power or flame failure or interruption of air movement, and that stop grain feed if excessive exhaust temperature occurs. 1910.272(p)(1)(i) and 1910.272(p)(1)(ii) require these automatic shutoffs to prevent fires and overheating.

• Test and maintain these safety controls regularly as part of preventive maintenance per 1910.272(m).

Direct-heat grain dryers installed after March 30, 1988 must be located outside the grain elevator, or inside in an area protected by fire or explosion suppression, or inside in a one-hour fire-resistance separated area. 1910.272(p)(2)(i), 1910.272(p)(2)(ii), and 1910.272(p)(2)(iii) set these siting options.

• If inside, verify suppression systems or fire-resistance construction meet the standard’s criteria and are maintained.

No. Bucket elevators must not be jogged to free a choked leg. 1910.272(q)(1) explicitly prohibits jogging to clear a choke.

• Use safe, manufacturer-recommended clearing procedures that include lockout/tagout and isolation before reaching into or opening the elevator.

If bearings are mounted inside or partially inside the leg casing, you must provide vibration or temperature monitoring or other means to monitor their condition; otherwise mount bearings externally. 1910.272(q)(4)(i) and 1910.272(q)(4)(ii) require external mounting or monitoring for internal bearings.

• Use motion, vibration, or temperature alarms to catch bearing failure early and include these checks in preventive maintenance records per 1910.272(m)(3).

Bucket elevators must have a motion-detection device that shuts down the elevator if belt speed drops by 20% and either a belt-alignment alarm or a system that maintains belt tracking; smaller elevators and some with suppression or dust-control systems have exceptions. 1910.272(q)(5) requires motion detection that stops the elevator when speed reduces by no more than 20%, and 1910.272(q)(6)(i) or 1910.272(q)(6)(ii) require belt-alignment alarm or continuous alignment system.

• Exceptions: 1910.272(q)(7) exempts elevators in facilities with <1 million bushels if daily visual inspection is done; 1910.272(q)(8) exempts elevators with operational suppression covering head and boot sections or with dust-control systems keeping dust at least 25% below the lower explosive limit.

Bucket elevators are exempt from some monitoring requirements if they have pneumatic or other dust-control systems or methods that keep the dust concentration inside the elevator at least 25% below the lower explosive limit (LEL) at all times during operations. 1910.272(q)(8)(ii) describes this exemption.

• Document how your dust-control system maintains dust concentrations below the specified threshold and monitor performance regularly to support the exemption.

Employers must promptly correct or remove from service any dust collection systems that are malfunctioning or operating below designed efficiency. 1910.272(m)(2) requires prompt correction.

• Tag-out or remove defective units from service until repaired, and record corrective actions in maintenance logs per 1910.272(m)(3).

A pressure-drop monitor is required to indicate when the filter surface is loading or failing so corrective action can be taken before the collector operates inefficiently or dangerously. 1910.272(l)(1) requires all fabric dust filter collectors in pneumatic systems to have a device indicating pressure drop across the filter surface.

• Use the monitor to schedule filter cleaning/replacement and to detect ruptures or bypass conditions; tie readings into preventive maintenance records under 1910.272(m)(3).