I have said this many times… one of the most hazardous tasks that can take place on industrial property is the loading/unloading of hazardous materials. So many things can go wrong and with the quantities being handled, hazards can get out of control quickly. So DOT has seen fit to require a “qualified attendant” during the loading and unloading process. However, DOT has offered a safe alternative to having a human “attend” each unloading/loading task. But this exemption comes with some true “engineering controls”. Here are the requirements for having a single human “attend” multiple unloading activities at the same time:
(3) A qualified person “attends” the loading or unloading of a cargo tank only if, throughout the process:
(i) Except for unloading operations subject to §§ 177.837(d) and 177.840(p) and (q), the qualified person is within 7.62 m (25 feet) of the cargo tank. The qualified person attending the unloading of a cargo tank must be alert and have an unobstructed view of the cargo tank and delivery hose to the maximum extent practicable during the unloading operation;
OR
(ii) The qualified person observes ALL loading or unloading operations by means of video cameras and monitors OR instrumentation and signaling systems such as sensors, alarms, and electronic surveillance equipment located at a remote control station, and the loading or unloading system is equipped as follows:
(A) For a video monitoring system used to meet the attendance requirement, the camera must be mounted so as to provide an unobstructed view of all equipment involved in the loading or unloading operations, including all valves, hoses, domes, and pressure relief devices;
(B) For an instrumentation and signaling system used to meet the attendance requirement, the system must provide a surveillance capability at least equal to that of a human observer;
(C) Upon loss of video monitoring capability or instrumentation and signaling systems, loading or unloading operations must be immediately terminated;
(D) Shut-off valves operable from the remote control station must be provided;
(E) In the event of a remote system failure, a qualified person must immediately resume attending the loading or unloading of the cargo tank as provided in paragraph (i)(3)(i) of this section;
(F) A containment area must be provided capable of holding the contents of as many cargo tank motor vehicles as might be loaded at any single time; and
(G) A qualified person must personally conduct a visual inspection of each cargo tank motor vehicle after it is loaded, prior to departure, for any damage that may have occurred during loading;
OR
(iii) Hoses used in the loading or unloading operations are equipped with cable-connected wedges, plungers, or flapper valves located at each end of the hose, able to stop the flow of product from both the source and the receiving tank within one second without human intervention in the event of a hose rupture, disconnection, or separation.
(A) Prior to each use, each hose must be inspected to ensure that it is of sound quality, without defects detectable through visual observation; and
(B) The loading or unloading operations must be physically inspected by a qualified person at least once every sixty (60) minutes.
(4) A person is “qualified” if he has been made aware of the nature of the hazardous material which is to be loaded or unloaded, has been instructed on the procedures to be followed in emergencies, and except for persons observing loading or unloading operations by means of video cameras and monitors or instrumentation and signaling systems such as sensors, alarms, and electronic surveillance equipment located at a remote control station and persons inspecting hoses in accordance with paragraph (i)(3)(iii) of this section, is authorized to move the cargo tank, and has the means to do so.