This article is taken from the October 13, 2023 National Grain and Feed Association Newsletter.
Occupational Safety and Health Administration (OSHA) authorities this week clarified that a new inspection program should not apply to grain handling facilities with certain storage structures. Early this month, OSHA Compliance Safety and Health Officers (CSHOs) from the Region 7 Kansas City and Wichita Area Offices visited grain handling facilities to conduct inspections under the National Emphasis Program (NEP) on Warehousing and Distribution Center Operations that became effective on July 13.
Deputy Administrator Ryan Hodge sent an Oct. 5 alert to OSHA Area Offices to distinguish between farm product warehousing and storage facilities and grain handling facilities, noting the NEP should not apply to grain handling facilities since the storage is considered “intermittent” (e.g., short-term – days to weeks).
Further, he said the CSHOs should have visited the facilities to conduct outreach, not to conduct actual inspections. He also encouraged NGFA members to contact his office directly with any future issues related to NEP inspections.
The NEP on Warehousing and Distribution targets warehouse-related industries as identified by seven NAICS codes, as well as a set of “high-injury retail establishments,” as identified by five NAICS codes, including Farm Product Warehousing and Storage 493130.
However, the 424510 Grain and Field Bean Merchant Wholesalers (which applies to many grain elevators) is not on the list. Flat storage structures are not traditional warehouses and are not part of the farm product warehousing NAICS code.
NGFA members can contact Jess McCluer, NGFA’s vice president, safety and regulatory affairs, with questions or more information.
For more information, visit www.osha.gov.