August 9, 2021

How Operators Can Prepare for Increased OSHA Inspections & Enforcement

President Biden has tapped former Cal/OSHA chief Doug Parker to lead the federal Occupational Safety and Health Administration. Parkers’ nomination is still awaiting confirmation by the Senate. 

The move signals a turn toward stricter federal policies on workplace safety. Examples may include lower permissible exposure limits (PEL) for chemical agents, tougher ergonomic requirements and measures to prevent illness and injury on the job.

Now is the time for employers to prepare for more frequent inspections and more rigorous enforcement actions. This can begin with updating and implementing written policies, training employees on all protocols and clearly documenting all safety and health procedures. 

For companies that work with dry bulk materials, correct use of bulk bags or Super Sacks® is a key component of any safety and health plan. Also known as flexible intermediate bulk containers or FIBCs, bulk bags offer many advantages. Proper handling reduces a number of safety hazards and lowers the risk of costly fines.

OSH Act of 1970

Employers have a general duty to protect worker safety under Section 5 of the federal Occupational Safety and Health Act, or OSH Act. The law requires workplaces to be “free from recognized hazards that are causing or are likely to cause death or serious physical harm.” Employers may be found in violation of the so-called “general duty clause” under the following circumstances: 

  • A recognized serious hazard exists in the workplace
  • The employer fails to take reasonable action to prevent or abate the hazard

In addition to the OSH Act, employers must comply with all rules, regulations and orders issued by OSHA. A comprehensive workplace safety plan should have the full commitment of management as well as employee participation. It should include detailed hazard and prevention and control measures, training for all personnel and regular worksite analysis. 

Selecting the Right FIBC & Equipment

According to the Flexible Intermediate Bulk Container Association (FIBCA), safety begins with choosing the correct FIBC for the product being handled and the operation environment. 

Different FIBC types are designed to handle different materials, such as hazardous substances, food ingredients, pharmaceuticals and industrial chemicals. Other considerations include the presence of electrostatic charges, flammable or explosible materials. Operators must adhere to all applicable regulations, manufacturer instructions and inspection procedures. 

Lifting Devices

Filled bulk bags are typically handled by forklift, crane or hoist. Operators must prioritize safety in every aspect of the application to ensure compliance with regulations and industry standards. 

In one instance, a plant received an OSHA citation due to improper lifting of an FIBC with a forklift. An operator was found to be lifting the bag with its loops directly on the forklift tines (a practice also known as free-rigging), without using an appropriate lifting adapter. This increased the risk of the forklift tipping over and spilling the bag contents. The company abated the problem by purchasing a heavy duty lifting adapter to ensure safe lifting and transport. 

OSHA standards governing powered industrial trucks, such as forklifts, cover a range of issues from operator training to loading procedures and operation. Companies can reduce the likelihood of a violation by following accepted industry standards such as ASME or ANSI. Forklift operators, for example, must follow ANSI B56.1, which affects all aspects of forklift safety such as design, construction, application, operation and maintenance. Crane operators are expected to adhere to ASME Standard B30. Below-the-hook lifting devices, also called spreader bars, must meet ASME B30.20 and ASME BTH-1 standards. 

FIBCA offers additional guidelines for the safe use of bulk bags. All handling equipment must be specifically designed to accommodate FIBCs, must include appropriate safety latches and must be rated for the weight of the filled bag. Forklift tines and other lifting devices must be free of sharp edges to protect bag loops, and operators must never be allowed to stand underneath a suspended bag. 

Diagram of operator improperly lifting bulk bag with forklift

Filling & Unloading Bags

The FIBC must be specifically designed for the filling and emptying environment in which it is used. The bag spout must be securely sealed prior to filling. Follow additional safety protocols to ensure safe bulk bag filling:

  • Proper support: Always use a suitable filling frame designed to support the weight of the filled bag. This reduces the risk that the bag will lean or topple over. Never fill the bag while it is suspended from a non-permanent structure such as a crane or forklift. 
  • Dust containment and sealing: Use static protective bags when necessary and follow all dust control measures. Operators must never hold the bag in an awkward position or use inferior sealing devices such as bungee cords. Ensure proper ventilation to reduce the risk of dust exposure. 
  • Overfilling and overloading: Never exceed the bag’s safe working load (SWL) rating, which can be found on the Bag Tag. Overfilling by size or overloading by weight could cause the bag to topple, burst or loops to become detached. 

Flexible intermediate bulk container bag tag

Safe bulk bag unloading is also essential for avoiding injuries and fines. In one scenario, a company was cited for improper discharge when the operator was observed standing directly under an elevated bag and dismounting a forklift while a bag was suspended above the hopper. Maneuvers like this increase the risk of injury. In this case, the problem was corrected by using a support system built to hold the weight of the filled bag and provide safe access to the spout for discharge. 

Diagram of operator improperly standing underneath lifted bulk bag

Operators must also avoid employee contact with pinch points which can cause injury to hands and arms during unloading. Common pinch points include the following: 

  • Massage systems with hinged paddles or bars
  • Spout sealing systems such as pneumatic sealing, ring or compression plate designs
  • Bag elongation systems

Dust Control

Industries using FIBCs must take proactive steps to avoid dust explosions, and to lower the risk of dust inhalation by employees. 

Many materials that won’t burn in large particles may still be flammable in dust form. Examples of combustible dusts include food products like candy, sugar, spices, starch and flour. Other flammable dusts include plastics, rubber, wood, pesticides, pharmaceuticals, and even metals such as aluminum, chromium, iron and zinc. These types of dusts are used across a range of industries including agriculture, chemical manufacturing, fossil fuel power generation and recycling. Dust explosions can cause death, injury and property damage and expose companies to expensive fines and lawsuits. 

Companies can reduce the risk of dust explosion by reducing the static charge that can occur when filling or emptying bulk bags. For example, groundable Type C bags include a carbon-infused grid that directs electrical charges to a grounding point. Type D bags are made from static dissipative fabric and do not require grounding at all. 

Dust mitigation efforts must also include measures to protect against accidental inhalation of dusty or aerated materials. Companies must follow OSHA standards pertaining to ventilation and contaminants which may contribute to indoor air pollution. The general duty clause of the OSH Act may also apply in cases related to indoor air quality

Proper spout sealing prior to opening an FIBC helps to guard against this problem. An insolation valve, such as an iris valve, allows the operator to untie the spout and close an access door prior to discharge. A glove box access feature provides even greater protection when working with hazardous products. 

Proactive dust control should also include routine inspections, testing and housekeeping. Companies can implement proper dust collection methods and invest in filtering systems and surfaces that resist dust accumulation. 

At FormPak, we have decades of expertise in the safe handling of FIBCs. We work directly with customers to design bulk bag handling equipment that meets operational needs and reduces the risk of injury and fines. 

If you’re looking to boost the safety and compliance of your operations, reach out to us today. You can call us at 800-936-7672 or contact us online.