According to the statement, the U.S. Department of Agriculture's Federal Grain Inspection Service (FGIS) published Directive 9170.14, provides procedures for identifying rolling stock fall hazards and for conducting a fall-protection feasibility assessment.
However, the directive NGFA and AAGIWA stress "applies only to FGIS employees," and "officially designated agencies are not required to adopt the policy."
Instead, NGFA and AAGIWA state that officially designated agencies "may adopt the policy or use it as a guideline to establish their own policy to comply with federal and state safety and health requirements."
NGFA and AAGIWA also noted that work environments and circumstances vary greatly at grain handling facilities. The organizations encouraged their members to "establish safety policies and procedures tailored to each individual location to comply with all federal and state safety and health requirements, including those pertaining to rolling stock fall protection." However, they say, "those policies and procedures may differ from those found in the FGIS directive.
The directive was developed by FGIS in response to citations, issued by the Occupational Safety and Health Administration (OSHA) in 2011, for failing to conduct fall protection assessments, train employees on fall hazards, and train supervisors to identify potential hazards. Fall protection long has been one of OSHA's emphasis areas.
Yet, the existing regulations under OSHA's walking-working surfaces and personal-protective equipment (fall-protection systems) standard - also known as Subpart D - do not specifically include rolling stock (such as rail cars) and motor vehicles. OSHA defines "rolling stock" as any locomotive, railcar or vehicle operated exclusively on a rail or rails, or a trolley bus operated by electric power supplied from an overhead wire.