Grain handling consensus standards

Yes — if the consensus standard you follow provides equal or greater protection than 1910.272, OSHA will consider you in compliance with the corresponding requirement. Appendix B states that employers who comply with provisions in the listed national consensus standards that provide equal or greater protection than those in 1910.272 will be considered in compliance with the corresponding requirements; see Appendix B to 1910.272 and 1910.272. Make sure you can document how the consensus provisions match or exceed the protection in the OSHA rule.

Use ANSI/NFPA 91 for dust removal and exhaust systems. Appendix B lists ANSI/NFPA 91 as the national consensus standard that provides guidance on design and maintenance of dust removal and exhaust systems for grain-handling facilities; see also 1910.272. Follow the NFPA guidance only when it provides equal or better protection and keep documentation showing equivalence.

Use ANSI/NFPA 68 for explosion venting. Appendix B identifies ANSI/NFPA 68 as the consensus standard for explosion venting; ensure the NFPA venting design you apply gives protection equal to or greater than the requirements of 1910.272. Document the design basis and calculations to show equivalence.

Follow ANSI/NFPA 69 for explosion prevention systems. Appendix B lists ANSI/NFPA 69 as the consensus standard for explosion prevention systems; apply it where it provides equal or greater protection than 1910.272 and keep documentation that shows the NFPA measures meet or exceed OSHA protections.

Use ANSI/NFPA 66 for pneumatic conveying systems. Appendix B indicates ANSI/NFPA 66 is the applicable consensus standard for pneumatic conveying of agricultural commodities; make sure the procedures and equipment you adopt under NFPA 66 provide protection equal to or greater than 1910.272.

Follow ANSI/NFPA 61C for feed mills. Appendix B lists ANSI/NFPA 61C as the national consensus standard for feed-mill operations; use it when it provides equal or greater protection than the related provisions in 1910.272.

Consult ANSI/NFPA 61D for facilities handling agricultural commodities for human consumption. Appendix B lists ANSI/NFPA 61D, and you should use it when it provides equal or better protection than the comparable parts of 1910.272. Keep records showing how you matched or exceeded OSHA protections.

Possibly — OSHA will consider compliance with a consensus standard if it provides equal or greater protection, but you must be able to show that the edition you used meets or exceeds the protections in 1910.272. Appendix B does not automatically approve specific editions; document the technical equivalence or superior protection of the older edition compared to the OSHA requirement and retain that justification with your safety records (Appendix B to 1910.272).

Yes — you can use provisions from different listed consensus standards so long as the combined measures provide equal or greater protection than the specific requirements in 1910.272. Appendix B allows reliance on the listed standards when they provide equal or greater protection; be prepared to document how the combined provisions address each OSHA requirement and show they are not less protective (Appendix B to 1910.272).

Following NFPA standards is optional; they are provided as acceptable alternatives when they give equal or greater protection. Appendix B lists consensus standards that employers may use to demonstrate compliance, but the underlying obligation remains to meet 1910.272. If you choose to rely on an NFPA standard, document how it provides equal or greater protection than the OSHA requirement (Appendix B to 1910.272).

Keep written documentation that shows which NFPA provisions you followed, the edition used, and a clear comparison showing each NFPA provision provides equal or greater protection than the corresponding 1910.272 requirement. Appendix B says employers who comply with listed consensus standards that provide equal or greater protection will be considered in compliance; retain the comparative analysis, design calculations (e.g., for venting or prevention), maintenance records, and training records to support that claim (Appendix B to 1910.272).

Yes — state plans can be more stringent and may adopt different or additional consensus standards. OSHA’s national guidance notes that States with OSHA-approved State plans must have standards and enforcement at least as effective as Federal OSHA but may be more stringent; check your State plan for local requirements in addition to the federal 1910.272 and Appendix B (Appendix B to 1910.272).

Use NFPA 68 when your primary control is explosion venting, and use NFPA 69 when your aim is to prevent explosions through systems like suppression, isolation, or elimination of ignition sources. Appendix B lists ANSI/NFPA 68 for explosion venting and ANSI/NFPA 69 for explosion prevention systems; pick the standard that matches the control strategy and ensure it provides equal or greater protection than 1910.272.

Yes — ANSI/NFPA 91 provides guidance on design and operation of dust collection and exhaust systems and can inform housekeeping practices, provided the resulting controls offer protection equal to or greater than 1910.272. Appendix B lists ANSI/NFPA 91; document how NFPA-based housekeeping schedules and dust collection outcomes meet or exceed OSHA’s protections.

Not necessarily — OSHA does not mandate a specific credential, but you must be able to show that the work, design, inspection, and testing meet the NFPA provisions and provide equal or greater protection than 1910.272. Appendix B allows use of consensus standards, so retain competent documentation (inspection reports, test results, contractor qualifications) that demonstrates compliance with the NFPA standard you relied on (Appendix B to 1910.272).

Follow OSHA unless you can demonstrate the NFPA provision provides equal or greater protection for that specific element. Appendix B permits reliance on consensus standards only when they provide equal or greater protection than 1910.272; you must document the technical basis showing the NFPA alternative is not less protective. If you cannot show equivalence, comply with the OSHA requirement (Appendix B to 1910.272).

Show technical evidence such as engineering calculations, test data, vendor certifications, and a written comparison that the NFPA-based design yields equal or lower risk than the OSHA-prescribed approach. Appendix B allows using listed consensus standards when they provide equal or greater protection than 1910.272; for explosion venting specifically, include NFPA 68 design calculations, vent area sizing, and test reports to demonstrate superior protection (Appendix B to 1910.272).

Appendix B lists these consensus standards as helpful cross-references but does not automatically incorporate every provision; OSHA recognizes them as acceptable alternatives when they provide equal or greater protection. See Appendix B to 1910.272 and the main 1910.272. You should treat the NFPA documents as guidance that can establish compliance only if you can document equivalence or superiority to the OSHA requirements.

The employer must implement and document that the NFPA standard provides equal or greater protection, and OSHA will evaluate that documentation during an inspection or enforcement action. Appendix B states employers who comply with listed national consensus standards that provide equal or greater protection will be considered in compliance with 1910.272; ultimately OSHA reserves the right to review whether the alternative provides comparable protection (Appendix B to 1910.272).