New ‘Boot Pit’ Guidance Document Available

By Jess McCluer, NGFA Director of Safety and Regulatory Affairs

The National Grain and Feed Association Safety, Health and Environmental Quality Committee recently developed a guidance document to assist grain handlers in evaluating if a “boot pit” is a Permit Required Confine Space (PRCS) under the Occupational Safety and Health Administration’s standards.

Over the last year, OSHA’s current enforcement position appears to be that boot pits are – by default – PRCSs because there is always some potential (no matter how remote) that water will enter a boot pit and mix with grain and dust to form an atmospheric hazard, such as hydrogen sulfide. Based on numerous citations reported by NGFA members across the country, the SHEQ Committee concluded that boot pits seem to be becoming the “new” area of OSHA enforcement focus, particularly in some regions where grain handling facilities are part of the local emphasis enforcement program.

As a result, the SHEQ Committee recommended that NGFA take a proactive approach by developing appropriate guidance tools to describe the necessary procedures for assessing whether boot pits are PRCSs. The guidance document provides an overview of the requirements to determine if a “boot pit” is a confined space or a PRCS based on OSHA’s Permit-Required Confined Space standard and OSHA’s Confined Spaces Advisor.

Once it is determined if the “boot pit” is a confined space, the document offers additional steps to take to determine whether it is a PRCS. Also included in the document are frequently asked questions and links to numerous OSHA letters of interpretations and compliance directives related to the definition and determination of confined spaces and which specific standards apply.

Note: The material in the boot pit guidance document is designed to assist grain handling facilities in evaluating their boot pits to determine whether they meet OSHA’s definition of permit-required confined spaces. Grain handling facilities should contact experienced safety and health legal counsel or a third-party expert if they have questions about the proper way to determine if boot pits are permit-required confined spaces under the OSHA standard.

Grain Journal will host a boot pit/PRCS webinar on Oct. 22 at 3 p.m. Melissa Bailey, managing partner, Ogletree Deakins, will deliver the presentation. NGFA retained Bailey to work with the SHEQ committee in developing the material for the guidance document. For registration information, please visit Grain Journal’s website.

In addition, the SHEQ Committee is finalizing a guidance document for sweep auger operations that will highlight the 10 safety principles contained in OSHA’s May 3 memorandum to its regional administrators. In the memo, OSHA states that employees are allowed to be present inside a grain bin with operating equipment if they utilize both administrative and engineering controls. The NGFA guidance is due for completion by the end of October.