I am often asked why I am such a stickler for unloading/loading HAZMATS and where I come up all of “my requirements” for these tasks. Yes, I am a stickler for these tasks as my career has seen its fair share of unloading/loading incidents. As for “my requirements” I can not actually take credit for them, as I stole them from some state OHSA regulations and international HAZMAT codes. And being a graduate of Murray State University in Murray, KY my very first “senior project” was at an Air Products plant in Calvert City, KY. This was a project in which we were helping with the design and hazard analysis of a new truck loading area. This was my first exposure to loading/unloading practices and Air Products – KY had some very tight requirements and they taught us well. Many may find the fact that KY-OSHA, a state OSHA plan, has their own standard for receiving and unloading bulk hazardous liquids as a surprise. But the standard is well written and for those of you that have worked with me on loading and unloading activities or PHA nodes on unloading HAZMATS, you will recognize where “my standards” came from.
PLEASE keep in mind this is a REQUIREMENT for facilities in KY and ONLY A SUGGESTION for those who are looking for some guidance on how to control the risks with unloading their HAZMATS. I posted this in my HAZMAT Section, but I hope you PSM/RMP practitioners will take note of these KY requirements and consider implementing them at your facilities.
Some of the core principles this standard requires:
- The facility OWNS the unloading activity! A driver is NEVER permitted to unload a HAZMAT into the process on their own. In fact they can ONLY make connections to their truck and NOT to the process (unless the task is supervised by a trained operator)
- Implement BOTH engineering controls and administrative controls to prevent inadvertent mixing of incompatible materials (remember, both materials do not have to be HAZMATs to create a hazardous reaction!) and overflow events.
- WRITTEN procedures are required and trained on.
In Kentucky a “hazardous liquid” is defined as a chemical or mixture of chemicals that is toxic, an irritant, corrosive, a strong oxidizer, a strong sensitizer, combustible, flammable, extremely flammable, dangerously reactive or pressure generating or which otherwise may cause substantial personal injury or substantial illness during, or as a direct result of any customary or reasonably foreseeable handling or use.
803 KAR 2:019. Receiving and unloading bulk hazardous liquids, provides KY employers with specific requirements for chemical handling procedures to control receiving and transfer to storage of bulk hazardous liquids received via motor truck. This applies to chemicals which if inadvertently mixed or transferred to an inappropriate container could result in explosion and/or production of toxic gases.
This administrative regulation does NOT apply to receiving gasoline, fuel oil, or liquefied petroleum gas at retail or wholesale outlets or to industrial filling stations where the industry standard operating procedure requires the hauler to make connections and complete delivery. (NOTE: I have yet to understand what an “industrial filling stations where the industry standard operating procedure requires the hauler to make connections and complete delivery” actually is)
General Requirements
(1) Signs and labels shall be posted as follows:
(a) At bulk chemical receiving and storage facilities, (capable of unloading tank trucks or trailers) signs and labels, readily legible at normal operating positions, shall indicate appropriate contents and item identification at receiving and dispensing connections, valves, tanks, and the storage area perimeter.
(b) Prominently displayed signs at critical access points shall direct tank truck drivers to plant security stations or to supervisory personnel. Signs at the unloading area shall give specific instruction to drivers NOT to connect truck tank hoses to chemical receiving lines.
(c) Bills of lading, freight bills or accompanying paper work should have each hazardous chemical clearly identified by its shipping name (49 CFR) or if N.O.S. (not otherwise specified) by its common name. Handling information clearly indicated for receiver information should be included.
(2) Receiving liquid chemicals.
(a) Receiving of bulk liquid chemicals shall be coordinated by the receiving department or persons responsible for receiving. ONLY those persons trained and authorized shall make the required chemical identification and perform or supervise the unloading of hazardous chemicals.
(b) Prior to unloading, the authorized person shall make an inspection of the accompanying papers, check the load and ascertain its identity.
(c) If necessary for identification, chemical testing shall be accomplished prior to acceptance.
(d) The authorized person shall direct the driver to the proper unloading area.
(e) The receiving area, where chemicals are unloaded, shall be secured behind a locked fence enclosure or all receiving connections shall be under lock and key or made secure by other positive means.
(f) The authorized person shall be responsible for control of keys or combination to locking devices.
(g) The tank truck driver may make connection to the tank truck. An authorized person ONLY shall make connection to company receiving connections and supervise the unloading into storage.The tank truck driver may make both connections provided an authorized person is present to identify, check and supervise the connection and unloading.
In receiving areas where more than one (1) chemical is stored, the tank connection shall be INDIVIDUALLY keyed.
Connection to different chemical receiving systems shall be locked by SEPARATED KEYING arrangement.
Due caution shall be made to prevent spills and to assure that the receiving tank is not overfilled.
Prior arrangements shall be made to assure that inadvertent overflow is controlled without exposing employees. (It is recognized that environmental protection administrative regulations require storm or sewer drains also be protected.)
(h) Upon completion of unloading, the receiving device or the enclosure shall be locked and the key returned to its designated security location or other equivalent action be taken to secure the chemical inventory.
(i) Appropriate respiratory and other emergency personal protective equipment for the body, eyes, face, etc., shall be immediately available and used in accordance with 29 CFR 1910, Subpart I, as adopted by 803 KAR 2:308.
(3) Training.
(a) Authorized persons responsible for the acceptance of potentially hazardous chemicals shall have an understanding of the particular hazards associated with those chemicals individually and in combination.
(b) Internal WRITTEN OPERATING procedures shall be prepared. All affected employees shall be trained in these procedures.
(c) WRITTEN EMERGENCY EVACUATION plans shall be prepared, and practiced by all potentially affected employees.
(d) Copies of the operating procedures, emergency evacuation plans, and a listing of personnel authorized to receive bulk chemicals shall be on the premises and available to employees and to compliance safety and health officers.
(e) Employees subject to exposure in the storage area requiring the use of respirators shall be fitted for and trained in their use, all in accordance with 29 CFR 1910.134, as adopted by 803 KAR 2:308.
(f) Special first aid procedures shall be prepared for the potential injuries of the operation. First aid capability shall be in accordance with 803 KAR 2:310. (6 Ky.R. 652; eff. 7-2-80; Am. 23 Ky.R. 1682; eff. 12-13-96.)
CLICK HERE for a copy of 803 KAR 2:019. Receiving and unloading bulk hazardous liquids