Recently, I had the opportunity to help a client gain the full picture of what has to be done regarding the BULK TRANSFER hoses to unload their HHC/EHS from Tanker Trucks/ISO Containers and Railcars. Now, before we get into the specifics, I know a number of folks will fall back on the compliance position that unloading/loading our HHCs/EHSs are DOT-regulated functions. Through my career, I have learned the hard way that the risks associated with these unloading/loading activities are among the highest in my processes (even across the entire facility!). Such that my first Node in any PHA I facilitate is to cover Unloading of the HHC/EHS. A client who does not want to include this function in the PHA is no longer a client – that is how seriously I take these matters. Do as you wish, but I do hope your facility will embrace this risk and attack it head-on using the information provided in this article.