Recent changes in food, environmental, and worker safety have caused many grain and pet food engineers to take another look at their manufacturing facilities. Some of these rules are newly changing, others are just recently subject to penalties for noncompliance and all deserve adequate attention. For greenfield sites or renovations, appropriate attention to food and workplace safety regulations from the outset will save thousands in fines down the road. No matter the situation for your grain or pet food facility, we’ve put together four key safety regulations for manufacturers to know in 2018.
4 New Food and Workplace Safety Regulations For Grain and Pet Food Manufacturing
1. Amended OSHA Slip and Fall Regulations
Violations exposing workers to fall or slip accidents occupied three of the top ten most common violations of workplace safety regulations in 2016, including non-compliant ladders, scaffolding, and fall protection equipment. Seeking to remedy these preventable accidents, OSHA amended Regulation 29 CFR 1910 Subpart D, which regulates safety requirements for walking and working surfaces, in 2016. Many of these provisions are already in effect, and several others are required as of November, 2018.
Grain and pet food manufacturers who are building up instead of out, as well as grain elevators and feed storage facilities should pay particular attention to these workplace safety regulations, some which are already enforced with fines.
- Ensuring exposed workers are trained on fall hazards (required May 17, 2017)
- Ensuring workers who use equipment are trained (required May 17, 2017)
- Inspecting and certifying permanent anchorages for rope descent systems (required November 20, 2017)
- Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections (required November 19, 2018)
- Ensuring existing fixed ladders over 24 feet … are equipped with a cage, well, personal fall arrest system, or ladder safety system (required November 19, 2018)
2. NFPA 652: New Standards on Combustible Dust
The dangers of combustible dust are no mystery to pet food and grain manufacturers. Between 2007 and 2016, 91 explosions occurred due to grain dust alone. In 2016 the National Fire Protection Association’s (NFPA) Standard 652 outlined best practices for evaluating risk and protecting against dust and powder fires. The new standard’s biggest departure from previous standards is the development of Dust Hazards Analysis on existing or future processes.
Though OSHA recently abandoned expanded regulations on combustible dust due to regulatory reform under the Trump administration, experts remind businesses that workplace safety regulations on dust hazards exist under a number of other OSHA standards. Project managers and engineers can manage their combustible dust risk in a number of ways;
- Proper machine maintenance to eliminate dust leaks.
- Separating feed mixing processes into different buildings to manage risk and loss.
- Conducting thorough risk analysis to understand threats.
- Utilizing temperature monitoring sensors to prevent sparks.
- Installing dust monitoring and dust collection systems suitable for your facility and particulates.
3. OSHA New Respirable Dust and Crystalline Silica Standards
Combustible dust laws are not the only dust-related workplace safety regulation grain and pet food manufacturers should be aware of this year. OSHA regulations governing respirable dust particles require workers to use personal protection equipment (PPE) and requires facility managers to measure, manage and keep levels within Permissible Exposure Limits (PELs). In 2017, OSHA amended regulations on exposure to crystalline silica, one of the most common types of harmful respirable dust. When crystalline silica dust is inhaled it sticks to the lungs, causing scarring and irreparable damage.
Though these workplace safety regulations are most important in the construction industry where workers are regularly exposed to hazardous crystalline silica levels, some steps in raw material feed processing, particularly cleaning, can pose respirable dust hazards. To mitigate exposure, take the following precautions;
- Know who is exposed, where, and what causes exposure.
- Measure and monitor harmful or nuisance dust levels.
- Make PPE available and cultivate a culture of safety compliance.
- Utilize dust collection with the right air intake and appropriate filtering.
4. USDA and FDA: Food Safety and Modernization Act
The USDA and FDA jointly oversee provisions within the Food Safety and Modernization Act (FSMA), including those regulating food and pet food. Signed into law in 2011, many FSMA regulations are only now going into effect and under enforcement.
FSMA covers nearly all food and pet food facilities. The FDA’s current FSMA guidance document developed solely for pet food “covers facilities that manufacture, process, pack, or hold food intended for all animal species including food-producing animals (e.g., livestock, poultry, and aquaculture species), companion animals (e.g., dogs, cats, horses, and guinea pigs), laboratory animals, and animals maintained in zoological parks. “Animal food” means food for animals other than man and includes pet food, animal feed, and raw materials and ingredients (see 21 CFR 507.3).”
Pet food and grain processors undergoing process development should be aware of FSMA regulations which concern the following cases, among others;
- Animal foods with high oil content which resist microbial heat treatments.
- Mycotoxins (Aflatoxins, Fumonisins, Deoxynivalenol, Ochratoxin etc.) proliferating in grains.
- Pesticides on grains.
- Plant toxicants (lectin, protease inhibitors, cyanogenic glycosides etc.)
- Animal-specific nutrient deficiencies and toxicity hazards.
- Process or product cross-contamination.
- Metal contamination from process equipment.
Evaluating and planning for food and workplace safety regulations during project design and installation will prevent future problems. Working with an experienced and reputable process equipment manufacturer specialized in your industry will help to anticipate safety concerns and hazards specific to your facility.