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OCR for page 39
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
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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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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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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 .
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Representative terms from entire chapter:
dust explosions
