Dust Explosions Prevalent in Grain Industry

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Over the past six months since the Imperial Sugar Refinery dust explosion the public has been hearing from congressional leaders and the media how the manufacturing sector needs an OSHA comprehensive combustible dust regulation similar to the grain industry standard that was implemented nearly two decades ago.

Back in the 1970's a mulitude of grain silo dust explosions occurred throughout the country which resulted in dozens of fatalities. After a decade of scientific studies and governmental hearings the OSHA grain facility standard was published December 31, 1987 (52 FR 49592) with an effective date of March 30, 1988. An issue concerning the action level of whether an 1/8 inch of dust at a grain facility was impractical or feasible.

So on January 24, 1989, a ruling by the Fifth Circuit Court of Appeals, National Grain and Feed Association (NGFA) v. OSHA, 866 F.2d 717, upheld the Standard but stayed the 1/8-inch action level until the Agency reconsidered the costs. Finally, after over a decade since the series of fatal grain silo explosions in 1977, OSHA published "a supplemental statement of reasons" on December 4, 1989 (54 FR 49971) in the Federal Register, concluding that the 1/8-inch action level for priority areas was economically feasible. On April 25, 1990, 903 F.2d 308, the Fifth Circuit accepted these conclusions and lifted the stay as of August 1, 1990.

Incidents, fatalities, and injuries have diminished due to dust explosions at grain facilities, yet they still occur at an alarming rate. Through media accounts, eight explosions have occurred at grain facilities throughout the United States since the Imperial Sugar Refinery explosion. In the manufacturing sector there has been 15 combustible dust explosions since the Imperial Sugar incident. To the casual observer it would seem there are twice as many manufacturing plant explosions than grain facility explosions. But that is a false sense of what actually is occurring.

For example, of the over 300,000 manufacturing establishments in the United States, about a 100,000 of these facilities have a potential for combustible dust explosions and fires occurring. In contrast, when comparing grain facilities there is nearly 18,000 establishments that operate as grain mills and grain elevators according to the 2002 U.S. Economic Census that was released in 2005.

Reevaluating the amount of incidents between the grain and manufacturing sectors, the Combustible Dust Policy Institute has discovered that explosions in grain silos and mills are occurring at a rate three times more than the manufacturing sector over the past six months. With the high prevalence of combustible dust explosions in the grain industry, is that the proper direction all stakeholders really want to proceed with the present combustible dust bill that is awaiting a vote in the Senate?