During my PHAs and Audits, I typically find businesses that are not focused on the UNLOADING risks associated with their hazardous materials. I tend to get a lot of pushback about how Unloading is a DOT function and somehow not related to process safety. The risks associated with unloading 7,000 gallons of an HHC/EHS through “temporary connections” and a “hose(s)” may be the highest risk for many businesses. And therefore, I tend to spend time discussing the controls/barriers/safeguards the business has in place for this risk/operation. As we have discussed many times, the IFC and several chemical-specific RAGAGEPs (e.g., CGA 2.1, NFPA 58) have great designs for this operation. And just recently, the CSB issued a report on the value of “remote isolation devices” in these operations. But there tends to be an overlooked need when it comes to pre-use, monthly, and annual inspections/testing of unloading hoses (liquids/gases and vents).
PHMSA wrote a “2012 letter” after the SC NH3 fatal release related to the catastrophic failure of a transfer hose. This letter explains the inspection needs well…