• Standard Number:

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 31, 1991

Mr. Kevin J. Schultze
Continental-Agra Grain Equipment, Inc.
1400 South Spenser Road
Post Office Box 525
Newton, Kansas 67114

Dear Mr. Schultze:

This is in response to your April 18 letter with supporting information enclosures requesting interpretations and clarifications of 29 CFR 1910.272 as delineated in Occupational Safety and Health Administration (OSHA) Instruction, [CPL 02-01-004] on Grain Handling Facilities. Please accept our apology for the delay in response.

Your first request is to clarify the terminology "making contact with the interior leg casing" in [CPL 02-01-004 (formerly CPL 2-1.4C), paragraph 19] which interprets the "partially inside the leg" terminology of the 29 CFR 1910.272(p)(4)(ii) bearing monitor standard. Note that bearings can be installed inside, partially inside or externally with respect to the leg casing of bucket elevators. Therefore, 29 CFR 1910.272(p)(4)(ii) is interpreted to require bearing monitoring unless the bearing assembly including associated inner dust seals are installed externally, that is, without touching, to the leg casing. Also, note that the "interior leg casing" describes that part of the bucket elevator which is inside of the grain elevator structure. The 29 CFR 1910.272(p)(4)(ii) bearing monitoring requirement only applies to "inside bucket elevators" as defined in 29 CFR 1910.272(c)(5). Thus, the monitoring requirements of 29 CFR 1910.272(p)(4)(ii) do not apply to bearings mounted inside or partially-inside the interior leg casings of other bucket elevators for example, those which have the boot and no more than 20 percent of the total leg height inside the grain elevator structure.

Your other request is to clarify that the 29 CFR 1910.272(p)(7) standard does not preclude the applicability of the 29 CFR 1910.272(p)(4) bearing monitoring standard to grain handling facilities with less than one million bushels permanent storage capacity. This literal interpretation of the aforementioned standards will be emphasized in a revision to the OSHA Instruction, [CPL 02-01-004]. Expanding on your recommendation, the following clarification addresses the interpretation more specifically. Monitoring equipment shall be installed on inside bucket elevators except when bearings are mounted externally to the interior leg casing in compliance with 29 CFR 1910.272(p)(4)(i) or when a fire and explosion suppression system or pneumatic or other dust control system or method is installed as provided by 29 CFR 1910.272(p)(8).

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.


Patricia K. Clark, Director
[Directorate of Enforcement Programs]

[Corrected 05/28/2004]