(173c) Beyond Compliance:  Using PSM to Enhance the Grain Handling Standard

The purpose of OSHA’s Process Safety Management standard, 29 CFR 1910.119, is to prevent fires, explosions, and toxic releases. The PSM standard covers processes based on chemical properties, but it is well recognized that not all facilities that are vulnerable to fires, explosions, and toxic releases are covered under the PSM standard. Moreover, fire, explosion, and toxic hazards based on physical properties are not addressed at all by the PSM standard. One industry segment that is not covered is the segment comprised of handling combustible dusts. Instead, combustible dusts are addressed, in part, by the Grain Handling standard, 29 CFR 1910.272.

Recognizing the contribution that process safety management has to make to improving safety in the grain handling industry, there is a movement by some in the industry to apply the principals of process safety management to the design, operation, and maintenance of grain handling facilities. Nonetheless, even as they incorporate the elements of PSM into grain handling, these facilities are still compelled to comply with the requirements of Grain Handling standard. To the extent that grain handling facilities can use process safety management to comply with 29 CFR 1910.272, the effort will be more efficient and easier to sell to other parts of their organization.

This paper compares and contrasts the two standards and shows how the elements of the PSM standard can be used to comply with the grain handling standard. It also shows the gaps in the grain handling standard addressed by the PSM standard and how PSM strengthens the overall process safety effort. Finally, it discusses the implementation of this approach in a recently constructed grain handling facility.