The National Grain and Feed Association has urged the U.S. Occupational Safety and Health Administration to retain its existing grain-handling facility standard, and to exempt grain elevators, feed mills and grain processing plants already covered by those regulations from its planned development of a comprehensive combustible dust standard.
The association's statement, developed in collaboration with the American Feed Industry Association and Pet Food Institute, was submitted in response to OSHA's October 21, 2009, advance notice of proposed rulemaking, in which the agency signaled its intent to develop a broad, comprehensive combustible dust standard that would apply across different industry sectors.
The National Grain and Feed Association noted that OSHA's own regulatory review in 2003 determined that the grain-handling standard should continue without change. Fire and explosion incidents in grain-handling facilities have declined by 65%, as measured in five-year increments since 1976, according to the association. Meanwhile, the reduction in the number of injuries and fatalities has declined 86% and 94%, respectively. This improved safety record occurred even as the volume of grain being handled by U.S. facilities increased by nearly 60% over the same time span, the statement said.
The association attributed the progress to a combination of governmental safety rules and an extensive $3.5 million industry research program that discovered the causes of and developed new techniques for controlling fire and explosion risks, coupled with ongoing education and training efforts.
The statement to OSHA opposed modeling a combustible dust standard after voluntary standards developed by the National Fire Protection Association, which do not evaluate practical implementation or cost impacts, and do not permit broad public participation in their development, according to the feed group. The statement said that the National Fire Protection Association’s potential recommendation of a 1/32-inch or less action level for combustible dusts, compared with the 1/8-inch standard now applicable to grain dust in priority housekeeping areas around bucket elevators, would increase compliance costs by several fold without materially contributing to improved safety.
