GRAIN AND FEED ASSOCIATION OF ILLINOIS
July 25, 2014
August 20, 2012
OSHA, Onsite Consultation and the Grain and Feed Association of Illinois (GFAI) formed an Alliance to provide the GFAI members and others with information, guidance, and access to training resources that will help them protect employees' health and safety. The Alliance will focus on preventing exposure to hazards related to engulfment, amputations, electrocutions, falls and other injuries and illnesses. Steps will be taken to ensure GFAI member employees are familiar with bin entry hazards.
Implementation Team Members
John Lee, Grain and Feed Association of Illinois Safety Director and Brian Bothast, Peoria OSHA Office Assistant Area Director are the primary implementation team members.
Implementation Team Meetings
On August 20, 2013, Brian Bothast and John Lee met to discuss the alliance and implementation for 2013-2014.
Activities and Products
August 20, 2013 to August 19, 2014.
On August 20, 2013, the Area Director provided the keynote presentation for the 35th annual National Agronomic Environmental Health & Safety School held at the Asmark Institute Agricenter in Bloomington, Illinois and the CAS provided a training session on effective safety and health programs, hazard controls, OSHA emphasis areas, heat, hazard communication 2012 and industry specific hazards and controls.
On August 27-29, 2014, the CAS hosted a booth at Midwest Farm Show in Decatur, IL. in the Safety and Health tent providing handout material on grain, heat, falls, electrical, chemical, and a wide variety of hazards.
On February 17, 2014, the Assistant Area Director developed a presentation for the Statewide Grain and Feed Association of Illinois Conference in Springfield, IL. and was delivered by the Grain and Feed Association of Illinois Safety Director addressing grain handling hazards, fall hazards, bin entry, lockout, machine guarding, electrical hazards, respiratory protection, hazard communication, personal protective equipment, PIVs, and heat stress illness prevention.
On March 18, 2014, the Area Director and the AAD provided training sessions at the Illinois Grain Operations & Entrapment Prevention Symposium in Bloomington, Illinois. The Agency officials addressed OSHA's expectations for controlling hazards prior to entering bins and OSHA enforcement of the confined space standards in the industry.
On April 11, 2014, the Area Director and the AAD participated in an Alliance meeting with the Grain and Feed Association of Illinois to develop confined space entry information and help sheets for the industry.
On May 16, 2014, the Peoria Area Director provided presentation for the Grain and Feed Association of Illinois in Peoria, IL addressing the local Grain emphasis programs, heat, and a variety of questions.
On July 17, 2014, the Peoria AAD and GFAI representative discussed the alliance and general goals for the next alliance year.
Confined space help sheets were developed to assist facilities in managing potential hazards associated with boot pits and similar spaces that meet the definition of a confined space, but the only hazard is a potential atmospheric hazard during upset conditions. See help sheets below.
Requirements for Using Alternate Entry Procedures
Written evaluation must be kept of space's designation within the confined space standard according to OSHA regulation.
Conditions Within the Space
- Housekeeping practices must be implemented within the space according to OSHA Regulation.
- Dry floor conditions preferred, but damp is acceptable, absolutely no standing water without full confined space entry controls.
- Equipment within the space must be adequately guarded to prevent employee injuries.
- Access (ladder and/or stairs) must be fixed and of acceptable OSHA design to prevent employee exposure to fall while descending and ascending into and out of the space.
Requirements Prior to Entry
- Management must agree with alternate entry procedure use; must complete and retain an Evaluation for Use of Alternate Entry Procedures form; and must have written Entry Procedures specific to the space.
- Employee must conduct an initial atmospheric test of the space (including stratospheric samples at four (4) foot intervals.
- If oxygen is displaced in any amount, full permit required confined space entry procedures must be followed.
- If oxygen is not displaced, employee may enter the space without an attendant and must monitor the atmosphere within the space constantly during entry and conduct necessary work with management approval.
- If atmospheric monitor alarm sounds employee must exit space immediately and inform management of the atmospheric hazard.
- If alarm sounds management will no longer allow alternate entry procedures until they are certain hazard is eliminated which caused the dangerous atmosphere.
Special Notation: Carbon dioxide levels can be dangerous prior to alarm sounding for oxygen displacement. Consideration must be given to the commodity condition being conveyed within the space.
Name of space:___________________________
Space Evaluation Yes No Is the space large enough for full body entry?
If you answered "no" to the above question, this is not a confined space. Form is complete.
If you answered "yes" to the above question, proceed to the next section
Space Description Yes No Has limited or restricted entry or exit? (Ladders, Entry/Exit of non-standard door size, equipment obstructs path to entry/exit, etc.) Is not designed for continuous human occupancy? (Ventilation does not allow for continual air exchange, employee cannot stand erect in area, sufficient lighting is not present, etc.)
If you answered "no" to any above questions, this is not a confined space. Form is complete.
If you answered "yes" to all of the above questions, this is a confined space. Proceed to potential hazards section.
Potential Hazards Yes No NA Potential for flammable gas, vapor, or mist in excess of 10% of its Lower Flammable Limit? Potential of airborne Combustible dust which obscures vision at a distance of 5' or less? Potential for atmospheric concentration below 19.5% or above 23.5%? (20.8% Normal) Potential for atmospheric concentration of a toxic substance which exceeds Permissible Exposure Limit? Check MSDS for chemicals which may be present. Contains internal configuration which entrant could be trapped or asphyxiated by inwardly converging walls or a floor which slopes downward and tapers to a smaller cross-section? Contains equipment, lines, springs or pipes with stored energy which could release and affect an entrant? Any energized mechanical equipment that could be started by a person unaware of a person in the space? Any live, unguarded electrical circuits or wires that could arc to the person in the space? Could product be delivered into space by someone unaware of entrant? Any other recognized safety or health hazard that could expose participant to serious injury or death?(fire, explosion, radiation, high/low temp)
If you answered "no" to all questions above, this is a Non-Permit Required Confined Space. Evaluation is complete.
If you answered "yes" to any above questions, this is a permit required confined space. Proceed to Possible Hazard Mitigation Requirement Section.
Possible Hazard Mitigation Required Yes No NA Hung-up material - Remove material (Pits) Bridged Material - Bridge must be collapsed prior to entry (Pits) Steep Product Slope - Reduced to natural angle of repose (Pits) Engulfment - Material confirmed stable otherwise use lifelines while in product. No product can be delivered into space. (ensure entrant cannot become engulfed more than waist deep) (Pits) Entrapment - Can insert ladders, otherwise utilize retractable lifelines Hazardous Atmosphere - Ventilation until eliminated, Continuous monitoring required Extreme Temperature - Ventilate or heat, frequent breaks Combustible Dust - Ventilate by following Class II Div. 1 or 2 guidelines Group G Mechanical Equipment - LOTO Electrical Circuits - De-energize and LOTO Guard Entrance by Barricade
Space Evaluation For Use of Alternate Entry Procedures
Name of Space__________________________
Yes No 1 Has space been evaluated according to OSHA's confined space regulation 1910.146(c)(1)? 2 Does the space meet the conditions of no standing water, no sludge from decaying grain, and housekeeping is in accordance with OSHA standards for grain handling facilities? 3 Is the entry/exit(s) from the space (ladders/stairs) in compliance with OSHA standards? 4 Machine guarding is in compliance with OSHA standards. 5 Have potential hazards outside of the space, which may contribute to a hazardous atmosphere within the space during entry procedures, been mitigated or eliminated to the best of the facility's ability?
If you answered "No" to any of the above questions, alternate entry procedures cannot be used.
Hazards which are located outside the space, but may affect the atmosphere within the space under certain conditions: (circle all that apply)
traffic (carbon monoxide)
other (identify below)
Note: If required task, in itself causes a hazard or can cause a hazardous atmosphere (hot work/fumigation, etc.) alternate entry procedures cannot be used.
Signature of Evaluator:____________________________
Alternate Entry Procedures
Step 1 Employee will bump test atmospheric monitor to ensure calibration drift has not occurred. (Documented verification of this process is required.) Step 2 Initial atmospheric testing will be conducted from outside the space which will include a stratospheric check of the space atmosphere. (4 ft. increments) Step 3 In spaces which have no atmospheric hazard present and the potential for atmospheric hazards to occur during entry have been mitigated to the best of the facility's ability, entry may be made by the employee. Step 4 Employee must continuously monitor the atmosphere during entry. Step 5 Employee will maintain three points of contact as they descend into the space. Step 6 Employee will safely complete their task as assigned. Step 7 Employee will maintain three points of contact during their ascension while exiting the space.
This is only a sample, each facility must complete entry procedures which are designed for each space's individual characteristics.
Alternate Entry Procedure Atmospheric Testing Results
Results of Outreach for current year
Type of Activity
Number of Individuals Reached or Trained
Presentation for the 35th National Agronomic Environmental Health & Safety School in Bloomington, IL addressing effective safety and health programs, hazard controls, OSHA emphasis areas, heat, hazard communication 2012 and industry specific hazards and controls.
OSHA booth at Midwest Farm Show in Decatur, IL. providing handout material on grain, heat, falls, electrical, chemical, and other hazards.
Presentation at Statewide Grain and Feed Association of Illinois Conference in Springfield, IL. addressing grain handling hazards, fall hazards, bin entry, lockout, machine guarding, electrical hazards, respiratory protection, hazard communication, personal protective equipment, PIVs, and heat stress illness prevention.
Presented training sessions at the Illinois Grain Operations & Entrapment Prevention Symposium in Bloomington, Illinois addressing OSHA's expectations for controlling hazards prior to entering bins and OSHA enforcement of the confined space standards in the industry.
Presentation for the Grain and Feed Association of Illinois in Peoria, IL addressing the local Grain emphasis programs, heat, and a variety of questions.
For the next alliance year, OSHA and the Grain and Feed Association of Illinois have agreed to work on developing a compliance audit measurement system to ensure managers evaluate, eliminate and control confined space and other hazards.
Report prepared by: Brian BothastBack to Top