Grain Elevators
The written record of the OSHA rule (Docket H-117) consists of several thousand pages, including comments and hearing transcripts. These documents are available in microfiche form for public viewing at the OSHA Public Reading Room in Washington, D.C. This material was examined for four days and photocopies were obtained of (1) representative samples of hearing testimony and (2) reports prepared for OSHA (for example, by Arthur D. Little and Booz, Allen) and those submitted by such organizations as the National Grain and Feed Association and the AFL-CIO. Some of these documents are cited specifically in the notes to chapter 3. Only the reports are cited below.
The Occupational Safety and Health Reporter, a loose-leaf service published by the Bureau of National Affairs, reports extensively on current developments at OSHA. Various stories from 1978 through 1985 provided background for this case study.
The official record of NFPA standards is published in technical committee reports (TCRs) and technical committee documentation (TCDs), which are circulated to the general membership before the semiannual meetings. The TCRs and TCDs for both the 1980 and 1986 versions were obtained directly from NFPA. Earlier versions of the standard were examined at the NFPA Technical Library in Quincy, Massachusetts.
The following documents were the primary written sources, other than those described above, for the grain elevator case study:
Barringer, Felicity. "OSHA's Grain Elevator Rule Delayed." Washington Post, August 1, 1983.
Bluhm, Delwyn D. "Grain Elevator Explosions: A University View." In International Symposium on Grain Elevator Explosions . National Materials Advisory Board, Washington, D.C., July 11–12, 1978. Ames: Iowa State University, 1978.
"Deadlock over Explosive Dust." Science 222 (November 4, 1983): 485–87.
Drapkin, Larry. "OSHA's General Duty Clause: Its Use Is Not Abuse—A Response to Morgan and Duvall." Industrial Relations Law Journal 5 (Spring 1983): 322–33.
Factory Insurance Association. "Preventing and Minimizing the Effects of Dust Explosions in Manufacturing Plants." Special Hazard Study, no. 5. Hartford, Conn.: Factory Insurance Association, 1940.
Kauffman, C. W., and Robert F. Hubbard. "An Investigation of Fourteen Grain Elevator Explosions Occurring Between January 1979 and April 1981." Prepared for the Directorate of Safety Standards, Occupational Safety and Health Administration. May 1984.
Kelman, Steven. Regulating Sweden: A Comparative Study of Occupational Safety and Health Policy . Cambridge, Mass.: MIT Press, 1981.
Lublin, Joann S. "Grain-Elevator Rule Forges Unusual Link as AFL-CIO Backs Labor Agency's Plan." Wall Street Journal, August 24, 1983, 50.
Minter, Stephen G. "Grain Dust: OSHA Proposes a Controversial New Standard." Occupational Hazards, March 1984, 59–62.
Morgan, Dan. Merchants of Grain . New York: Penguin Books, 1980.
Morgan, Donald L., and Mark N. Duvall. "OSHA's General Duty Clause: An Analysis of Its Use and Abuse." Industrial Relations Law Journal 5 (Spring 1983): 283–321.
Morgan, Donald L. "Reply to Drapkin." (Article on OSHA's general duty clause.) Industrial Relations Law Journal 5 (Spring 1983): 334–37.
National Academy of Sciences. National Materials Advisory Board. Panel on Causes and Prevention of Grain Elevator Explosions. Prevention of Grain Elevator and Mill Explosions . NMAB 367-2. Springfield, Va.: National Technical Information Service, 1982.
National Academy of Sciences. Pneumatic Dust Control in Grain Elevators: Guidelines for Design Operation and Maintenance . NMAB 367-3. Springfield, Va.: National Technical Information Service, 1982.
National Grain and Feed Association. Dust Control for Grain Elevators . Papers presented at the Dust Control Seminar, St. Louis, Mo., May 7–8, 1981. Washington, D.C.: NGFA, 1981.
National Grain and Feed Association. Retrofitting and Constructing Grain Elevators … for Increased Productivity and Safety . Papers presented at the Five Years of Progress Conference, New Orleans, La., September 27–28, 1984. Washington, D.C.: NGFA, 1985.
Theimer, O. F. "Cause and Prevention of Dust Exposions in Grain Elevators." Powder Technology 8 (1973): 137–47.
Townsend, A. S. "Reduction of Explosion Hazard in Grain Risks." Best's Review (Prop/Casualty) 83, no. 3 (July 1982): 48–56.
Underwriters Laboratories. "Electrical Equipment for Hazardous Locations" Typescript. N.d
Underwriters Laboratories. Control of Floating Dust in Terminal Grain Elevators, UL Bulletin of Research, no. 1. Fifth Printing. Chicago: UL, 1964.
Underwriters Laboratories. UL 1604, Electrical Equipment for Use in Hazardous Locations (Class I and Class II, Division 2, and Class III, Divisions 1 and 2) . Northbrook, Ill.: UL, 1982.
Underwriters Laboratories. UL 844, Electric Lighting Fixtures for Use in Hazardous (Classified) Locations . 9th ed. Northbrook, Ill.: UL, 1984.
U.S. Department of Health and Human Services. National Institute for Occupational Safety and Health. Occupational Safety in Grain Elevators and Feed Mills . DHHS (NIOSH) Publication no. 83-126. Washington, D.C.: Government Printing Office, September 1983.
U.S. Office of Management and Budget. Executive Office of the President. "OSHA's Proposed Standards for Grain Handling Facilities: April 1984." Attached to letter from Christopher DeMuth, administrator for information and regulatory affairs, to Francis Lilly, solicitor, Department of Labor, April 11, 1984.
U.S. Senate. Committee on Labor and Human Resources. Subcommittee on Labor. "Hearing an Oversight of OSHA Regulations for Grain Handling Facilities, 1984." 98th Cong., 2d. sess. Washington, D.C.: Government Printing Office, 1984.
Verkade, M., and P. Chiotti. "An Overview of Grain Explosion Problems." Ames: Energy and Mineral Resources Institute, Iowa State University, 1976.
Viscusi, W. Kip. Risk by Choice: Regulating Health and Safety in the Workplace . Cambridge, Mass.: Harvard University Press, 1983.