In today’s episode of the Dust Safety Science podcast, we’re giving an incident update on a 2023 grain dust explosion in Decatur, Illinois. This explosion happened in April of 2023. Local news had reported a large explosion with multiple injuries, and there was very little information available at the time.
We found out that the place where the explosion happened had been inspected by OSHA seven times. Two of those inspections found a risk of things catching fire easily. We also found records of other incidents in our own database, like explosions in November 2018 and January 2019, and fires in May 2019 and October 2019. About two weeks ago, the U.S. Occupational Safety and Health Administration (OSHA) announced fines for the company involved in the incident.
OSHA Fines Reviewed
These OSHA citations were given out on October 17th, 2023. They include a total of $324,796 in fines for four violations.
The first date mentioned on the OSHA citations is November 1st, 2023. It’s important to note that the company’s responses to these documents aren’t publicly available. We can’t tell if they’ve challenged the citations, discussed them with OSHA, or if they’ve accepted and paid them. We don’t know their current stance. That’s why we’re not revealing the company names in this podcast episode. The situation might change.
However, the OSHA documents, including the violations and fines, are public, and they help us understand what concerns OSHA had during their assessment at this facility. It’s possible that the assessment isn’t directly related to the explosions caused by combustible dust, but given the timing, there’s a chance they are connected. We’ll cautiously say they might be related, but it’s not certain.
These citations aren’t connected to the incident we’re discussing, but they provide the best available information. If you work at a grain processing site anywhere in the world and come across similar violations, the details we’re about to discuss may be useful for your clients. You can say, “Look, this is an example from this year where workers got hurt, and the company faced fines in the hundreds of thousands of dollars. Maybe it’s a good reason to start talking about making the facility safer.” That’s the main reason we’re sharing this on the podcast.
Let’s look at the four violations. There are four of them. The first one carries a penalty of about $12,000. The next two have penalties of $156,000 each. The fourth violation is about walking and working surfaces but doesn’t have a specific penalty associated with it.
An Overview of the OSHA Violations
The first violation is related to housekeeping near bucket elevators, which goes against the grain handling standard, specifically Section J on housekeeping. To be more precise, it violates Subsection 2 on housekeeping programs for grain elevators and Subsection II as well. The violation states that the employer must promptly remove any accumulated grain dust when it exceeds one-eighth of an inch in designated housekeeping areas, as required by the Housekeeping Program, or demonstrate that equivalent protection is provided through an approved housekeeping program.
In this case, the violation was classified as serious, but it wasn’t considered willful, and it came with a $12,000 fine. Specifically, it was noted that on or around April 19th, there was a build-up of fugitive grain dust within 35 feet of the south transfer leg bucket elevator casing. The violation extended to various other locations in the vicinity, where the dust levels exceeded one-eighth of an inch. These locations included the surfaces of electrical conduits, pipes, horizontal wall beams, I-beam surfaces, discharge boats, and more. Several spots were identified where fugitive dust exceeded the permissible level.
To rectify this violation, the employer was instructed to implement a written housekeeping plan that ensures the immediate removal of any fugitive grain dust accumulations exceeding one-eighth of an inch in priority housekeeping areas. The deadline to address this violation was set for November 1st, 2023. This is the first violation, and it’s the one with the lowest monetary penalty among those with fines.
The second violation relates to the general duty clause, which obligates companies to ensure the safety of their employees by addressing known hazards. This particular violation is classified as both willful and serious, resulting in a total fine of $156,000.
Specifically, the violation statement highlights that one of the bucket elevator lags was operated in a way that posed risks related to combustible grain dust and deflagration explosion hazards. The conditions within this lag presented a potential combination of fuel, oxidant, contaminant, suppression, suspension, and ignition sources, all simultaneously.
Furthermore, the deflagration detection and chemical suppression system for this lag were not being adequately maintained in a fully operational state. Regular inspections and tests were not being conducted, and the most recent quarterly inspection of the system, as well as the last annual inspection and test, were performed back in late 2016. It’s essential to note that the explosion occurred in 2023, making it a seven-year gap since the last documented inspection and annual testing of this system. To address this violation, a deadline for abatement was set for December 8th, 2023.
There’s a significant emphasis on the deflagration detection and chemical suppression systems in these violations, particularly regarding their inspection and maintenance. The first or second violation falls under the general duty clause. Moving on to the third violation, it pertains to the preventative maintenance section, specifically Section M, Subsection 1, of the grain handling standard. This section requires regularly scheduled inspections, including mechanical and safety control equipment related to dryers, grain stream processing equipment, dust collection equipment (including filter collectors), and bucket elevators as part of the preventive maintenance program. This violation is categorized as both willful and serious, with a proposed penalty of $156,000.
The violation statement itself points out that the employer operated the South Transfer Lag Bucket elevator without conducting regularly scheduled inspections of the deflagration detection and chemical suppression systems on the lag for explosion protection and deflagration propagation since late 2016. This mirrors the focus of the second violation but addresses penalties in a slightly different manner. The penalties for the first violation are proposed under the general duty clause, emphasizing the failure to maintain a hazard-free workplace for employees, while the second aspect is covered by violation number three, which is within the preventive maintenance section of the grain handling standard.
These two violations constitute the largest portion of the proposed penalties, totaling over $350,000. Lastly, violation number four falls under the walking working surfaces category, specifically 1910.22 Subsection D, Subsection Two, which mandates the correction and repair of hazardous conditions on walking working surfaces before employee use. In this case, the violation pertains to a floor hole on one of the walking surfaces within the facility. It’s labeled as “other than serious” with a $0 penalty, but its significance should not be underestimated.
So that’s it for this update. Again, we just kind of wanted to provide a short update on this incident where there wasn’t much information available to date. I did note at the outset, and I’ll note here again that these are proposed penalties, proposed violations. It is up to the company to come back and contest them if they choose to have open discussions with OSHA on reducing penalties on how to pay the fines and that sort of thing. So it’s still a work in progress, but at least this publicly available document gives us some insight to some of the considerations that OSHA is talking about in regards to this facility around the time that they had this explosion. And so the big focus here was around fugitive dust accumulation and then inspection and maintenance of deflagration detection and suppression devices. So it is unclear if this played a role in the explosion or not because there is no incident investigation available. But it’s worth just noting if you have a site that has chemical detection suppression systems or detection systems and chemical suppression systems, these need to be, I believe, inspected quarterly and inspected and tested annually.
But go check the relevant standards to double check that. But if you’re looking at your system and realizing, hey, it hasn’t been inspected for several years. One. it might not work when it’s called on. It’s not clear if that’s the case in this particular explosion, but there certainly is an amount of information suggesting that that’s the focal point of OSHA in this case. And we’ll be interesting if we do get any incident report or investigation over time to understand how that may have contributed. And also fugitive dust accumulation in and around grain bucket elevators and high priority areas may have contributed to the severity of this explosion as well and the injuries that occurred.
That wraps up this update. Once again, our aim was to provide a brief update on this incident, as there hasn’t been much information available until now. we want to emphasize that these are proposed penalties and violations. It’s ultimately the company’s decision whether to contest them and engage in discussions with OSHA to potentially reduce the fines or determine how to pay them. This remains an ongoing process. However, the publicly available document does shed light on some of the aspects OSHA is concerned about regarding this facility around the time of the explosion.
The primary focus here revolves around the accumulation of fugitive dust and the inspection and maintenance of deflagration detection and suppression devices. Whether these factors played a role in the explosion is unclear because there’s no incident investigation report available. But it’s essential to note that systems with chemical detection and suppression components typically require quarterly inspections and annual testing. However, we recommend consulting the relevant standards for verification.
If you find that your system hasn’t been inspected for several years, it raises concerns about its functionality when needed. While it’s not confirmed in this specific explosion, there is evidence to suggest that OSHA is prioritizing these aspects. It will be interesting to see if we receive an incident report or investigation in the future, which may provide insights into how these factors could have contributed. Additionally, the accumulation of fugitive dust in and around grain bucket elevators and high-priority areas may have played a role in the severity of the explosion and the resulting injuries.
Conclusion
This update underscores the importance of ongoing safety measures and vigilance in workplaces, especially those involving combustible materials like grain dust. It serves as a reminder of the critical role of regular inspections and maintenance in preventing accidents and ensuring the safety of workers.
If you have questions about the contents of this or any other podcast episode, you can go to our ‘Questions from the Community’ page and submit a text message or video recording. We will then bring someone on to answer these questions in a future episode.
Resources mentioned
The resources mentioned in this episode are listed below.
Dust Safety Science
Combustible Dust Incident Database
Dust Safety Science Podcast
Questions from the Community
Dust Safety Academy
Dust Safety Professionals
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DSS246: Incident Update – 2023 Grain Dust Explosion in Decatur, Illinois