Workers on the Top of Tanks An Update on the Journey of the CTRMC

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Allyson Norman
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1 Workers on the Top of Tanks An Update on the Journey of the CTRMC Presented at the 2011 NTTC CTMSeminar by Randy Vaughn, Superior Bulk Logistics And Dan Wright, Kenan/Transport Service

2 Topics Genesis About CTRMC Mission / Vision / Scope First six meetings Outreach Results Current initiatives Next meetings Open discussion

3 Genesis Aligned interest in providing a safe environment for workers Carriers Consignees Insurers Manufacturers Shippers But, sometimes stakeholders protect their interests at the peril of workers.

4 Genesis Litigation Worker s compensation claims Insurance premiums Lost time Workers Equipment Managers

5 Genesis Recent interest of industry leaders to coalesce No one company is large enough to effect sufficient improvement.

6 About CTRMC Formed on March 17 th, 2010 Cargo Tank Risk Management Committee Volunteer / non-profit Nine original Steering Committee members Two added Steering Committee members

7 About CTRMC Steering Committee Archer Daniels Midland (ADM) Cargill Dairy Farmers of America (DFA) Dow* Kenan Advantage (Transport Service) Liberty Mutual* Quality Distribution Schneider Sentinel (ConocoPhillips / dupont) Superior Bulk Logistics Walker Group Holdings

8 Mission Cargo tank industry stakeholders working together to create solutions aimed at reducing the hazards faced by workers on and around such equipment.

9 Vision A work environment where all cargo tank industry stakeholders live out the primary core value of safety first - and always. This environment will be one in which all stakeholders work in harmony to design industry-standard education, work processes, and equipment design measures that will keep workers safe on and around cargo tanks. Furthermore, the stakeholders will be represented by a committee of representatives from across the industry that are empowered with their respective segment s knowledge and support to create and publish such guidance in a way that will be most widely accepted, universally applicable, and engineers out risk to workers as much as is reasonably possible.

10 Scope The issues being addressed by this group are related to workers that perform functions on both straight and combination cargo tanks. Stakeholders For the purposes of the work being done by the CTRMC, stakeholders include carriers, consignees, insurers, manufacturers, repairers, shippers, wash facilities, and others. Workers Anyone whose job responsibilities require them to perform duties on or around a cargo tank for the purposes of cleaning, inspecting, loading, repairing, securing, or any other task essential to the bulk cargo business.

11 First Meeting March 17 th, 2010 in Fond du Lac, WI Open invitation General 60+ industry leaders Academia Carriers Manufacturers Shippers Trade association Wash racks

12 First Meeting - Highlights Journeys of improvement Data Training Cultural change Global examples of successes TTMA RP No. 59 (OSHA applicability) Technology Variety of tank trailer designs Realization that the solutions are not just a matter of tank trailer design Formation of CTRMC and Steering Committee

19 Second Meeting June 29 th /30 th, 2010 in Chicago area. Steering Committee Crafted Mission / Vision / Scope Created our response to pending OSHA NPRM (see file) Planned next General Meeting.

20 Third Meeting September 8 th, 2010 in Green Bay General industry leaders Approved Mission / Vision / Scope Developed short term and long term objectives (see file)

21 Fourth Meeting December 16 th, 2010 in Houston area Steering Committee Drafted North American Hierarchy Protocol for Protection of Workers on Tops of Tanks (see file) Began establishment of website,

22 Fifth Meeting March 15 th, 2011 in Chicago, IL Steering Committee Drafted the Trailer Climbing Guidelines for training initiatives at all industry stakeholder s companies. (see file) Focused on CTRMC / TTMA industry recommended replacement ladder for one compartment liquid cargo tanks. (see file)

23 Sixth Meeting June 7 th, 2011 in Decatur, IL General industry leaders Introduced the North American Hierarchy Protocol for Protection of Workers on Tops of Tanks Trailer Climbing Guidelines New concept of a cleanout valve (see file) Developed next initiatives

24 Outreach American Chemistry Council International Society of Beverage Technologists National Tank Truck Carriers Truck Trailer Manufacturers Association

25 Outreach Best practices in Canada Europe New Zealand

Hierarchy protocol Trailer climbing guideline

32 Results Grass-roots formation of a purposeful group, committed to improvements OSHA NPRM comments Hierarchy protocol Trailer climbing guideline Website Progress on TTMA TB s Replacement ladder Cleanout valve

33 Current Initiatives Investigate feasibility of RFID/ electronic security seals to reduce the need to climb cargo tanks to install/inspect seals. Work with spinner manufacturers (wheeled robot, or telescoping arms) to eliminate need for cleanout ports. Promote TTMA RP No. 102 and TB No. 122, regarding vapor recovery and air unloading from ground level. Revise hierarchy protocol to set responsibilities of different stakeholders for equipment inspection. Amend hierarchy to include position on pulling samples relevant to stakeholders.

34 Next Meetings Steering committee in November General group March 7 th, 2012 in Houston area, hosted by Sentinel (ConocoPhillips / dupont)

35 North American Hierarchy Protocol for Protection of Workers on the Top of Tanks

36 Where we are with this document Steering committee worked on developing over the past year Drafts reviewed by the steering committee Changes made Approved by the steering committee Posted on the CTRMC web site Cargotanksafety.org

37 Document Objectives: To identify recommended best practices for industry stakeholders to employ for reducing the exposure to falls from cargo tank motor vehicles. Reducing the exposure to falls involves; Equipment design Maintenance/inspection State-of-the art replacement ladders (when needed) Loading and unloading facilities Use of the equipment and protocols for procedures Training and policy/procedures Policy/ procedure enforcement

38 This document is: Advisory Contains best practices Using this guide does not guarantee compliance with federal, state or local laws Regulatory compliance remains the responsibility of parties using this guide Eliminating the need to climb onto or work on the top of tanks is the preferred method of reducing exposure to falls, and should be addressed prior to considering other control measures outlined in this document. CTRMC s long term objective is to eliminate the need for workers to perform tasks on tops of cargo tank motor vehicles.

39 Top 10 Reasons for being on tank tops 1. Assuring security 2. Checking equipment including cleanouts manhole venting 3. Extracting samples 4. Loading or unloading product 5. Assessing liquid content levels 6. Initiating a. air unloading b. vapor recovery 7. Performing maintenance and routine inspections 8. Washing tank 9. Removing snow 10. Discharging heel

40 Stakeholders: Workers Shippers Cargo Tank Manufacturers Equipment Maintenance Facilities Consignees Motor Carriers Cleaning and Washing Facilities Industry Groups Impacted stakeholders may or may not have direct control over the employees - such as a driver picking up a load at a shipper or consignee. The goal of this document is overall exposure reduction, and not simply the transfer of the risk or activity from one stakeholder or impacted employee to another.

41 Stakeholder responsibilities Company groups Employee/worker groups

42 Hierarchy of Control Avoid tank top work tasks Railings fully surrounding work area with access by stairs Moveable gantry style equipment with stair access that fully surrounds work area Situations Typically requires specific tank equipment to match loading/unloading/sample collection needs. More practical at larger locations with frequent loading/unloading. Requires compatibility with tank equipment. Provides more flexibility for larger locations where a variety of equipment will be loaded/unloaded/washed etc. Fully surrounding gantry system with special equipment to fit specific tank tops to provide protection based on unique tank features/exposures Provides more flexibility for larger locations where a variety of equipment will be loaded/unloaded/washed etc. but has multiple access points/ports that are used infrequently Cargo tanks with built in access systems and tank top walkway fall protection Fall arrest or restraint devices using harness and other fall arrest system components secured to tested anchor points used by workers trained and supervised in use of the system Provides options for locations where deliveries are infrequent and other options with lower risk are not available For use where lower risk controls are not practical or available Ladder access with no protection or other systems used by workers trained in work task methods Should be avoided

43 Tanker Falls flow Chart

44 Open Discussion

45 Thanks!

Supplement to Trucking 106

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