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Chapter ~ CONSTRAINTS The implementation of safety measures to prevent dust explosions requires consideration of a number of contraints, some that can be overcome and others that can be overcome only with some difficulty or not at all. COST OF DUST CONTROL The economics of dust control can be divided into two categories; that applying to new design and that applying to existing facilities. The cost of a dust control system generally will be much less if it is incorporated into the design for a new elevator than if it has to be added to an existing facility; however, the cost for existing facilities will vary greatly (e.g., some equipped with dust control systems may require only a few modifications in equipment and practices whereas others, in which little attention was given during design to the hazard of dust explosions, may require a considerable amount of new equipment and additional labor}. The cost of a dust control system also will depend partially on the size of the facility, whether new or existing. For example, operators and designers of small facilities may find that greater cost benefits are derived from a different balance between manual housekeeping efforts and the installation and use of mechanical dust collection systems or other dust control systems. In all cases, measures to reduce the explosion hazard will generate capital and operating costs that cannot be ignored but may lead to a decrease in insurance costs. New equipment, when required, and the labor ' involved in its installation can represent a considerable expenditure. Even when only modification of an existing system is required, labor costs cannot be ignored. The cost of down-time while modifications are being made or new equipment is being installed also may be a factor,' although this work usually can be done in off-shift time. The cost of Operating and maintaining dust control equipment will be a continuing business expense, and additional labor for manual housekeeping may be required.' The loss that results from the low market value of dust also must be considered. Although collected dust represents only a small percentage of the received grain (0.1 percent of the tote! volume of grain handled {U.S. Department of Agriculture 19801) discarding it or selling it at a sacrifice represents a much larger percentage 1068 in the elevator's income. Balanced against these costs are the benefits to be derived. If a facility has no dust collection system, it must do some manual housekeeping. This labor cost will be considerably reduced if a dust 39

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40 collection system is installed. The re-introduction of collected dust into the grain stream and its subsequent sale as grain adds an additional burden and hazard downstream if the grain is delivered to-a second elevator. However, if the dust is used, for example, to make pelletized animal feed, part of the collection cost is offset. Portable-pelletizing equipment may permit even the 'smallest country elevator to recover some of the costs of dust collection. Although no specific mention ha" been made in this report of occupational safety, it was, of course', a major stimulus for the panel.' s study. Thus, the panel notes that hospitalization costs, insurance costs, and costs of damage' suits resulting from deaths and injuries occurring in explosions must be considered in any assessment of the costs and benefits of measures required to reduce the explosion hazard. INSURANCE The panel's study has indicated that insurance is a mixed blessing to the grain-handling industry. Insuring against accidental loss and injury is a . . . legitimate business practice; however, there is little incentive for improving safety when the losses due to explosions in high-risk facilities are absorbed by the insurance premiums of well run,.low-risk facilities. The panel has found that the insurance industry, in general, has scant' knowledge of the type or degree of explosive hazard found in elevators and mills as evidenced by the fact that dirty {dusty) facilities seem to have -little difficulty obtaining . . insurance, although in some cases they must pay increased rates. This is due mainly to a lack of standards for defining grain dust explosion hazards. As long as this situation exists there will always be some members of the grain-handling industry who will consider insurance as a safeguard in place of adequate safety measures that no one has either bothered or been.able to define. - . GavERmENr-INDusTRy RELATION; Cooperation between government regulatory agencies and industry to increase safety in elevators and mills is something that has yet to be fully developed. Regulatory agencies, both federal and local, are viewed with suspicion by both industry and'labor. In general, labor feels that there is not enough regulatory activity and industry feels that most regulatory activity is unnecessary. This is especially true with respect to the Occupational Safety and Health Administration, Federal Grain Inspection Service, and - Enviro Dental Protection Agency. The reluctance of elevator management to Cooperate with the panel was evident during its investigation of one explosion \because of an imagined association between the work of the panel and a regulatory agency investigation. This same general attitude was noted in the panel's previous report (National Materials Advisory Board 19801. On the other. hand, too close an association between those responsible for what is inspected and those doing the inspecting can lead to problems as well. The panel believes that a greater dependence by regulatory agencies on performance ' standards in place of inspections By the book. would alleviate the feelings of animosity and better serve the goal of increased safety.

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41 Air pollution regulations have already been mentioned in this report. It is interesting to' note that some representatives of labor and industry are on the same side of the fence with regard to EPA's emission air quality regulations. Both feel that the regulation preventing the discharge of dust to the outside of the elevator has increased the explosion hazard. The panel determined that improper response to the regulation is the problem. The actions of state governments with respect to dust control'have already been discussed in this report. Education as to the explosive hazard represented by grain dust must not be limited to the industry and its employees. LEGAL ENVIRONMENT The current litigious environment significantly affects the prevention of grain duct explosion accidents in that owners, operators, workers, designers, suppliers, witnesses, and investigators may either be held' responsible for an accident with attendant civil and criminal penalties, or be harassed outside and inside the court room. An insurance firm may indicate to an insured that dangerous conditions exist within a facility and that such conditions should be corrected. If an accident occurs before the correction is made the company may be held responsible in that it knew of the dangerous condition or failed to notify the responsible public authorities. If a governmental agency fails to detect a hazardous condition that is then involved in the chain of events leading to an accident, it may 'be deemed that they should have detected such a fault. New design data may be developed as well as unconventional equipment; however, significant risk accompanies its introduction because any accident that subsequently occurs can be blamed on this limited precedent technology. Witnesses are reluctant to provide information relating to accidents since they fear they will jeopardize a pcssible-'financial settlement if they have been injured or been served with a subpoena to provide testimony. The results of accident investigations, which should be released immediately to prevent the repetition of similar hazardous conditions leading to an explosion, must be suppressed to avoid their citation. HOUSEKEEPING Because housekeeping is the easiest part of elevator operation to ignore, it is usually assigned the lowest priority. If the press of business is great, e.g., three-shift operation, there is a tendency to postpone cleanup Aerations. This, of course, is exactly the worst time to delay housekeeping. It is looked upon as an expense without an immediate economic return. Those times when it is most needed are also the periods when there is the greatest chance that temporary help will be employed. Inexperienced and untrained temporary help, as a group, are those least likely to realize the hazards of dust explosions, and if they are employed in housekeeping work the situation is doubly hazardous.

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42 1 \ PSYCHOLOGICAL FACTORS The influence of human factors has already been discussed at some length as part of the dust explosion problem. However, because human attitudes, unlike the actions of mechanical devices, are not susceptible to rigorous control, they are a constraint to reduction of the hazard of dust explosions. Personnel can contribute subtly to the explosion hazard. There are those who realize the hazard but have a fatalistic attitude in that they accept a certain amount of danger as a fact of life. Others fee} that there is no danger, either because they do not know or do not believe dust can explode. These same attitudes once prevailed in other fields such as mining, aviation, and the chemical industry but have since been corrected through education and employee-management communication. Since total elimination of the human factor is never possible, it is an ever present hazard that management must guard against. Employees are not the only group whose attitudes affect safety. Owners and operator-managers, even though they usually are aware of the danger, tend to procrastinate concerning actions to improve safety, especially if they can rationalize a delay on the basis of economics or on the press of additional immediate business. In this context, peer pressure can have either a negative or a positive effect. Some owners and pperators~managers also have the same opinions as employees and this is especially true of those who recognize that an explosion is more remote a possibility than the 100-year flood. Finally, there is the universal human characteristic that responds to a pressure by res isting . REE13RENCES National Materials Advisory Board, Panel on Causes and Prevention of Grain Elevator Explosions, she Investigation of Grain Elevator Explosions, Report OMAN 367-1, National Academy of Sciences, Washington, D.C., 1980. U.S. Department of Agriculture, Prevention of Dust Explosions in Grain ~1 evators--An Achievable Goal , USDA, Washington, D.C., p . 40 , 198 0 . 1