Grain handling facility requirements

The emergency action plan must include an employee alarm system, evacuation procedures, and employee training on actions to take during fires and other emergencies. The plan should specify how employees are notified (for example, public address, horns, or alarms), show emergency escape routes using floor plans or maps (color coding can help), designate an outdoor assembly area, and include procedures to account for all employees after evacuation. See 1910.38 and 1910.272 App A for these requirements.

Pick an alarm that is clearly distinguishable from normal plant noises and other signals so employees can both hear and recognize that a real emergency exists. Employers may use public announcement systems, air horns, steam whistles, or standard fire alarms, but must account for the facility’s noise and signal clutter so the alarm is distinct and recognizable. Include alarm type and location in your emergency action plan in 1910.38 and follow the guidance in 1910.272 App A.

Emergency escape routes should be shown on floor plans or workplace maps (color coding recommended), and the plan must designate a safe outdoor assembly area with procedures to account for all employees after evacuation. The employer should also consider preplanning with the local fire department to coordinate emergency response and make sure emergency services know usual employee work locations. See 1910.38 and 1910.272 App A.

Employees must be trained at least annually, and the employer should provide additional safety meetings, discussions, or drills more frequently as needed to address the tasks employees perform. Training must cover recognition and prevention of hazards specific to grain facilities and job tasks, and the standard allows employers flexibility to design a program appropriate to their operations. See 1910.272 App A for training frequency and content guidance.

Train employees on topics applicable to their work, including hot work procedures; lock-out/tag-out; bin entry and bin cleaning procedures; grain dust explosion hazards and fire prevention; handling "hot grain"; housekeeping and dust removal methods and frequency; pesticide and fumigant use; proper PPE selection and maintenance; and preventive maintenance. The Appendix also recommends addressing clothing choices (avoid polyester that melts) and using training aids such as films or extension service materials. See 1910.272 App A.

A hot work permit system should be used to control hot work and ensure appropriate safeguards, but permits are not required when the employer or the employer’s authorized representative who would otherwise issue the permit is present during the hot work, when work takes place in an employer-authorized welding shop, or when the work is performed outdoors away from the facility. Regardless, required precautions from 1910.252(a)—such as relocating or covering combustibles, providing extinguishers, and establishing a fire watch—must be followed. See 1910.252(a) and 1910.272 App A.

A hot work permit is an employer authorization certifying that required safety precautions have been implemented before hot work starts; it is not intended to be a long-term record. The permit confirms measures such as clearing or protecting combustibles, placing fire extinguishers, and arranging fire watch duties have been completed. See 1910.252(a) and 1910.272 App A.

An entry permit into bins, silos, or tanks is required unless the employer or the employer’s representative who would otherwise authorize the permit is present during the entire entry operation. The permit system ensures the employer maintains control and that employees understand the hazards before entry. See 1910.272 App A.

Before entry after fumigation, employers must ensure the atmosphere is safe by aerating continuously and using direct-reading instruments to periodically monitor toxic levels; if readings increase, prompt action is required. Employees must be trained in proper atmospheric testing methods and procedures to follow if oxygen-deficient or toxic conditions are detected. See 1910.272 App A and refer to the OSHA interpretation on oxygen-deficient atmospheres for additional context on handling oxygen-deficient or toxic atmospheres.

Treat oxygen-deficient or toxic atmospheres as immediately dangerous and ensure civilian employees are protected under 1910.134 where applicable; employers must test atmospheres, aerate when fumigants were used, and use direct-reading instruments to monitor levels, taking prompt action if unsafe readings occur. The OSHA interpretation on oxygen-deficient atmospheres explains that oxygen-deficient atmospheres must be considered IDLH and that applicable respiratory protection requirements must be followed. See 1910.272 App A for bin-entry guidance.

Employees entering from the top must use a full body harness or boatswain’s chair with a lifeline; a winch system with mechanical advantage (powered or manual) is recommended so the observer can retrieve the employee without entering the space. Observers must be trained in rescue procedures and the use of PPE. See 1910.272 App A and review 1910.134(e)(3) guidance for emergency rescue planning and observer responsibilities.

The observer must be trained, equipped to provide assistance, know how to obtain additional help, and must not enter the space until adequate additional assistance is available; the observer’s role includes monitoring the entrant and starting rescue procedures if needed. Employers should ensure the observer follows the emergency rescue procedures required by 1910.134(e)(3) and the bin-entry guidance in 1910.272 App A.

Employers should generally prohibit employees from walking or standing on grain or grain products where the depth is greater than waist high because employees can sink and be buried; if entry is necessary, use full-body harnesses and lifelines and follow safe entry procedures. See 1910.272 App A for guidance on preventing burial and suffocation in grain.

A written housekeeping program must specify where, how, and how often dust accumulates will be removed; manual methods (vacuuming or sweeping with soft-bristle brooms) that minimize suspending layered dust are typically required, and the program should include contingency plans for sudden heavy accumulations and procedures for handling spills. The program should cover all workspaces (walls, beams, motors, bearings) and prioritize areas around equipment that can ignite dust. See 1910.272 App A.

Grain spills are not considered dust accumulations and should be cleaned per the housekeeping plan, but fully enclosed horizontal belt conveying systems where the return belt is inside the enclosure must have inspection access (sliding panels or doors) to permit checking for dust and facilitate cleaning. Include inspection and cleaning schedules for these enclosures in your housekeeping program. See 1910.272 App A.

Employers should analyze the stock handling system to locate dust emission points and use measures such as patching holes in spouting and casings, minimizing free falls by choke feeding, and using dust-tight enclosures at transfer points; cleaning schedules must also address dust on motors, bearings, and potential ignition sources. The housekeeping program should specify these control measures and disposal methods for collected dust. See 1910.272 App A.

No — employers should not rely solely on pneumatic dust collection systems; such systems must be properly designed and installed by competent contractors, and they should not replace routine manual housekeeping, which is still necessary to control dust accumulations. If a pneumatic system fails to perform, have the filter manufacturer or design firm evaluate and correct it. See 1910.272 App A.

For inaccessible areas requiring ladders or scaffolds, employers may use compressed air with long lances or periodic water washing via hoselines to remove dust, but these methods must be specified in the written housekeeping program along with safety precautions and appropriate PPE (eye protection, respirators) for workers performing the cleaning. See 1910.272 App A.

Employers must ensure outside contractors are aware of grain facility hazards, the employer’s permit systems, and the facility emergency action plan; contractors should develop and coordinate their hot work and bin-entry procedures with the employer, inform their employees, and be prepared to act as part of the facility’s emergency response. This coordination helps employers know what work is being done, where, and whether it endangers employees. See 1910.272 App A.

Employers should train entrants and observers in planned rescue procedures, ensure the observer is equipped to provide assistance and obtain help, have an employee trained in CPR available, and ensure observers do not enter until adequate assistance is available; follow the rescue-procedure requirements in 1910.134(e)(3). See 1910.272 App A for additional guidance on rescue preparation.

An employer should require an acceptance test period of 30 to 45 days of operation for a new or upgraded pneumatic dust control system to verify it operates as intended. This acceptance period is recommended to ensure the system functions under normal operating conditions and to identify adjustments or maintenance needs before final acceptance (1910.272AppA).

• Make sure the acceptance test is documented and that the manufacturer or designer provides maintenance, testing, and inspection information for ongoing safe operation (1910.272AppA).

Aspiration of other legs is acceptable when a prototype leg installation has been instrumented and shown to keep dust levels at least 25% below the lower explosive limit during normal operations, and the other legs have similar size, capacity, products handled, and the same design criteria; the prototype test report must be available on site. This allows OSHA to accept repeating the same design where performance is proven (1910.272AppA).

• Keep the prototype instrument test report on site so it can be used to justify applying the same aspiration design to other like legs.

Yes — enclosing the conveying system, pressurizing the general work area, and maintaining lower pressure inside the enclosure can control dust, but adequate access to the inside of the enclosure must be provided for frequent removal of dust accumulations (including on so-called "self-cleaning" systems). This ensures dust still gets removed before it creates an ignition hazard (1910.272AppA).

• Design for routine access points and cleaning methods so accumulated dust can be removed as required by your housekeeping program.

Yes, edible oil sprayed into a moving grain stream can reduce dust emissions, but any specific oil treatment used on products intended for food or feed must be approved by the Food and Drug Administration before use. Employers should be aware that repeated handling might require additional oil treatment to remain effective (1910.272AppA).

• Confirm FDA approval for the exact oil and application method if the grain will be used for food or animal feed before implementing this control.

A dust accumulation of 1/8 inch anywhere within a priority area is the maximum allowed before employers must initiate cleaning action under the standard's action level. Employers must remove accumulations at or above this action level using designated means or methods as part of their housekeeping program (1910.272AppA).

• Use a ruler or other measuring device to check accumulations; treat the 1/8 inch measurement as the upper limit requiring action.

Any accumulation greater than 1/8 inch in a priority area where no cleaning action has been initiated constitutes a violation unless the employer can demonstrate an equivalent level of protection. Employers should minimize dust accumulations because dust is the fuel for fires and explosions (1910.272AppA).

• If you claim an alternative (equivalent protection), document and be prepared to show how it provides equal safety to the 1/8 inch housekeeping requirement.

Filter collectors should be properly sized with the air-to-cloth ratio set according to the manufacturer's recommendations, and acceptable monitoring devices for filter pressure are a photohelic gauge, magnehelic gauge, or manometer — any of these meet paragraph (l)(1) of the standard. Set a service threshold consistent with the manufacturer's guidance to indicate when maintenance is required (1910.272AppA; 1910.272(l)(1)).

• Monitor differential pressure across the filter and establish a target reading and servicing procedures in your preventive maintenance program.

Your preventive maintenance program must include the instrument target reading (consistent with the manufacturer's recommendations) that signals when the filter needs servicing, and procedures to achieve that maintenance level; these items help minimize filter blinding and failure of the pneumatic dust control system (1910.272AppA; 1910.272(l)).

• Document the target reading, inspection frequency, and maintenance actions so they can be followed consistently.

No — filter collectors on portable vacuum cleaners and filter collectors used where fans are not part of the system are not covered by the requirements of paragraph (l) of the standard. Paragraph (l) applies to the fixed filter collectors that are part of pneumatic dust control systems (1910.272AppA; 1910.272(l)).

• Even when excluded from paragraph (l), portable equipment should be maintained and used safely as part of your overall dust control and housekeeping program.

Employers should implement a scheduled preventive maintenance program that includes periodic inspection and lubrication of potential ignition sources like bearings, belts, buckets, pulleys, and milling machinery, and may use vibration detection or heat-sensitive tape to detect failing components. The employer has flexibility on frequency but must show the program is effective at identifying and correcting problems promptly (1910.272AppA; 1910.272(l)).

• Base maintenance scheduling on manufacturer's recommendations and your facility experience, and prioritize safety-critical equipment such as bucket elevator bearings and alarm/shutdown systems.

Keep records that identify the date, the equipment inspected, and the maintenance performed (including open work orders with scheduled future repairs) as evidence of an effective preventive maintenance program. This documentation helps refine schedules and shows priority was given to safety-related repairs as required by the standard (1910.272AppA; 1910.272(l)).

• Use written logs, tagged work orders, and inspection checklists to demonstrate compliance and continuous improvement.

Locks must be used as the positive means to prevent operation of equipment being serviced, tags must meet the requirements in 1910.145(f), and locks and tags may only be removed by the employee who placed them or by that employee's supervisor. All employees who repair, service, or operate equipment must be familiar with the employer's lock-and-tag procedures (1910.272AppA; 1910.145(f)).

• For tasks that require temporary re-energization (testing/positioning), follow the sequence in 1910.147(f)(1) and provide equivalent protections while energized; see OSHA's explanation of temporary re-energization procedures in its lockout/tagout interpretation (LOTO interpretation).

Acceptable means include permanent or electromagnets to remove ferrous material from grain streams, and these separators must be cleaned regularly and kept in good repair as part of the preventive maintenance program to maximize effectiveness (1910.272AppA).

• Schedule routine inspections and cleaning of magnets and foreign-object separators to prevent sparks and downstream equipment damage.

At least two means of escape must be provided from galleries, and these means of emergency escape may include any available means of egress components defined in [1910.35] (exit access, exit, and exit discharge), controlled descent devices (landing velocity ≤ 15 ft/sec.), or emergency escape ladders; the escapes must be addressed in the facility emergency action plan and employees must know their locations and actions to take (1910.272AppA; 1910.35).

• Train employees on escape routes and include escape procedures in the written emergency action plan.

Liquefied petroleum gas vaporizers should be installed at least ten feet from the dryer, gas piping should be protected from mechanical damage, and employers should establish procedures to locate and repair leaks when there is a strong odor of gas or other signs of leakage (1910.272AppA).

• Include a clear leak response procedure (stop operations if necessary, evacuate, ventilate, isolate the gas, and make repairs) in your maintenance and emergency plans.

For elevators with permanent storage capacity of less than one million bushels, daily visual inspection of belt alignment and bucket movement may be substituted for alignment-monitoring devices and motion-detection devices. This substitution recognizes smaller elevators may be effectively monitored by close daily observation (1910.272AppA).

• Document daily inspections and findings to demonstrate that this visual inspection alternative is performed reliably.

Belts purchased after the effective date must have surface electrical resistance not to exceed 300 megohms; acceptable test methods include ASTM D257-76 and International Standards Organization #284, and a manufacturer's written certification showing testing by one of these methods is acceptable evidence of compliance (1910.272AppA).

• When using conductive belts, ensure the head pulley and shaft are grounded (for example, via motor ground) to provide electrical continuity and reduce static ignition risk.

Employers may install instruments such as a zero motion switch to detect rotary discharge valve failure and a level indicator to detect hopper buildup; installations should follow the manufacturer's recommendations, be readable at an accessible location, and be checked as frequently as specified in the preventive maintenance program (1910.272AppA; 1910.272(l)).

• Ensure alarm/shutdown logic tied to these instruments is maintained so that hopper plugs or valve failures do not allow progressive filter clogging.