In the past few decades many things have changed in the world of Hazardous Materials and many of these changes DIRECTLY IMPACT our process safety efforts and our PSM/RMP compliance. The debate will continue as to where DOT stops and OSHA begins when it comes to compliance coverage regarding loading and unloading Hazardous Materials, but this article is more about process safety and what we can do to improve it. This article is to help those interested to better understand the components of DOT regulations that will IMPACT our process safety and PSM/RMP compliance efforts; from what content goes into our SOPs to facility siting of the loading/unloading areas. One important aspect to loading/unloading is the high level of risk and these risks can impact a covered process, even though the material(s) being loaded/unloaded is not a HHC/EHS (as noted in an earlier post). Here is a breakdown of the DOT Loading and Unloading requirements and a brief analysis of how these requirements can be worked into our current PSM/RMP programs, SOPs, as well as “safety systems” we should include in our PSI, SOPs, MOC, MI, etc.
PLEASE NOTE: I am not a DOT expert. I only work with DOT regs as they apply to process safety (i.e. loading and unloading). I am of the belief the DOT regs can be used to directly and indirectly improve process safety, as I hope to show in this article. All text in this article that is in italics is regulatory language.
Let’s begin with the DOT basic requirements of loading/unloading as they apply to Class 2 Hazardous Materials (Gases) as this class has many PSM/RMP covered chemicals. PLEASE UNDERSTAND all of the requirements below are mandated by DOT and I am just trying to explain how these requirements play a role in helping us protect our covered process(s). If you need more help with the Class 2 Hazardous Materials requirements, DOT has issued a very nice pamphlet on the changes to Class 2 materials.
177.840 Class 2 (gases) materials
(See also § 177.834 (a) to (j) for the “General Requirements” for ALL placarded HAZMATs)
(d) Engine to be stopped in cargo tank motor vehicles, except for transfer pump. No Division 2.1 (flammable gas) material shall be loaded into or on or unloaded from any cargo tank motor vehicles with the engine running unless the engine is used for the operation of the transfer pump of the vehicle. Unless the delivery hose is equipped with a shut-off valve at its discharge end, the engine of the motor vehicle shall be stopped at the finish of such loading or unloading operation while the filling or discharge connections are disconnected.
Do we have these requirements written into our Unloading SOP(s) for our Class 2.1 Flammable Gases? How many of our operators who are involved in unloading Class 2.1 Flammable Gases know the tractor engine MUST be shutoff, except when the trucks transfer pump will be used. And how many know that the truck MUST BE SHUTDOWN after the transfer and BEFORE the hoses are disconnected; unless the hose is equipped with a “shut-off valve”? If we do not have these written into our unloading SOPs (for Class 2.1 flammable gases), how do we ensure these actions are properly implemented? Do we rely 100% on the “truck driver” to implement these safety precautions? I can honestly say, even at my VPP STAR sites we would routinely find gross deviations in these critical safety measures when we relied on “drivers” to implement them!
(e) Chlorine cargo tank motor vehicles shall be shipped only when equipped:
(1) With a gas mask of a type approved by the National Institute of Occupational Safety and Health (NIOSH) Pittsburgh Research Center, U.S. Department of Health and Human Services for chlorine service; and
(2) With an emergency kit for controlling leaks in fittings on the dome cover plate.
For those of us in true industrial plants that fall under OSHA we do not have a certification choice for our respirators; our’s MUST be certified by NIOSH and I would HIGHLY RECOMMEND we require our transporters to meet the same criteria. To be honest I am not even sure if the U.S. Department of HHS even certifies respirators for “chlorine service”. The driver is required to be equipped with this mask the minute the CL2 is offered for shipment. What does this mean in regards to compliance for the trucking company: 1) written respirator program, medical evaluations, fit testing, etc.!!! The next time you see a Chlorine Driver with a beard, think back to this article!
The truck is also to be equipped with a functional CHLORINE INSTITUTE EMERGENCY KIT A, B, or C depending on how the CL2 is being shipped. The intent of this article is to consider the risk associated with the transfer of HAZMAT via a hose connection so Kit A is outside the scope of this article, but Kits B & C are those that we will find on trucks hauling 1-ton cylinders and tanker trucks of CL2. I HIGHLY recommend that the facility ALSO maintain a proper CHLORINE INSTITUTE EMERGENCY KIT for the type of containers that are delivering the CL2. In fact, in past articles I have suggested that the time sensitive materials within these kits (e.g. gaskets) be included in our CMMS so as to remind us when they are due for replacement.
(f) A cargo tank motor vehicle used for transportation of chlorine may not be moved, coupled or uncoupled, when any loading or unloading connections are attached to the vehicle, nor may it be left without the power unit attached unless the vehicle is chocked or equivalent means are provided to prevent motion. For additional requirements, see § 173.315(o) of this subchapter.
This is what many would call a “no brainer”, but we have all seen a lot of “no brainers” or more commonly referred to as “common sense” be the cause of some very serious accidents. So without a doubt we need to incorporate this basic requirement into our SOPs and Training.
(k) A carrier of carbon monoxide, cryogenic liquid must provide each driver with a self-contained air breathing apparatus that is approved by the National Institute of Occupational Safety and Health; for example, Mine Safety Appliance Co., Model 401, catalog number 461704.
The same would apply here as it did with the air-purifying respirator for the CL2 drivers; although this requirement specifically requires a SCBA. Again, check your drivers facial hair and this will be a good indication of how much we should rely on the drivers to follow OUR safety requirements when on site!
(l) Operating procedure. Each operator of a cargo tank motor vehicle that is subject to the emergency discharge control requirements in § 173.315(n) [see below] of this subchapter must carry on or within the cargo tank motor vehicle written emergency discharge control procedures for all delivery operations. The procedures must describe the cargo tank motor vehicle’s emergency discharge control features and, for a passive shut-down capability, the parameters within which they are designed to function. The procedures must describe the process to be followed if a facility-provided hose is used for unloading when the cargo tank motor vehicle has a specially equipped delivery hose assembly to meet the requirements of § 173.315(n)(2) of this subchapter.
173.315(n) Emergency discharge control for cargo tank motor vehicles in liquefied compressed gas service —
(1) Required emergency discharge control equipment. Each cargo tank motor vehicle in liquefied compressed gas service must have an emergency discharge control capability as specified in the following table
(2) Cargo tank motor vehicles in other than metered delivery service. A cargo tank motor vehicle in other than metered delivery service must have a means to automatically shut off the flow of product without the need for human intervention within 20 seconds of an unintentional release caused by a complete separation of a liquid delivery hose (passive shut-down capability).
(i) Designed flow of product through a bypass in the valve is acceptable when authorized by this subchapter.
(ii) The design for the means to automatically shut off product flow must be certified by a Design Certifying Engineer. The certification must consider any specifications of the original component manufacturer and must explain how the passive means to shut off the flow of product operates. It must also outline the parameters (e.g., temperature, pressure, types of product) within which the passive means to shut off the flow of product is designed to operate. All components of the discharge system that are integral to the design must be included in the certification. A copy of the design certification must be provided to the owner of the cargo tank motor vehicle on which the equipment will be installed.
(iii) Installation must be performed under the supervision of a Registered Inspector unless the equipment is installed and removed as part of regular operation (e.g., a hose). The Registered Inspector must certify that the equipment is installed and tested, if it is possible to do so without damaging the equipment, in accordance with the Design Certifying Engineer’s certification. The Registered Inspector must provide the certification to the owner of the cargo tank motor vehicle.
(3) Cargo tank motor vehicles in metered delivery service. When required by the table in paragraph (n)(1) of this section, a cargo tank motor vehicle must have an off-truck remote means to close the internal self-closing stop valve and shut off all motive and auxiliary power equipment upon activation by a qualified person attending the unloading of the cargo tank motor vehicle (off-truck remote shut-off). It must function reliably at a distance of 45.72 m (150 feet). The off-truck remote shut-off activation device must not be capable of reopening the internal self-closing stop valve after emergency activation.
(i) The emergency discharge control equipment must be installed under the supervision of a Registered Inspector. Each wireless transmitter/receiver must be tested to demonstrate that it will close the internal self-closing stop valve and shut off all motive and auxiliary power equipment at a distance of 91.44 m (300 feet) under optimum conditions. Emergency discharge control equipment that does not employ a wireless transmitter/receiver must be tested to demonstrate its functioning at the maximum length of the delivery hose.
(ii) The Registered Inspector must certify that the remote control equipment is installed in accordance with the original component manufacturer’s specifications and is tested in accordance with paragraph (n)(3)(i) of this section. The Registered Inspector must provide the owner of the cargo tank motor vehicle with this certification.
(4) Query systems. When a transmitter/receiver system is used to satisfy the requirements of paragraph (n)(1)(v) of this section, it must close the internal self-closing stop valve and shut off all motive and auxiliary power equipment unless the qualified person attending the unloading operation prevents it from doing so at least once every five minutes. Testing and certification must be as specified in paragraph (n)(3) of this section.
The requirements for these “safety systems” for unloading “liquefied compressed gases” is relatively new (since 1/1/2000) and is still not fully in place as far as I can tell (12 years later!). Even though these systems are intended for the driver to activate, the receiving facility should include them in their SOPs as a “safety system” for the unloading operation. I would HIGHLY recommend we document these safety systems in our PSI if we intend to take any type of credit for the system in our PHA(s). Ask your delivery company for their documentation and certifications of these systems so that we can maintain a copy in our files, ESPECIALLY if we claim them as safeguards in our PHA(s).
(m) Cargo tank motor vehicle safety check. Before unloading from a cargo tank motor vehicle containing a liquefied compressed gas, the qualified person performing the function must check those components of the discharge system, including delivery hose assemblies and piping, that are readily observed during the normal course of unloading to assure that they are of sound quality, without obvious defects detectable through visual observation and audio awareness, and that connections are secure. This check must be made after the pressure in the discharge system has reached at least equilibrium with the pressure in the cargo tank. Operators need not use instruments or take extraordinary actions to check components not readily visible. No operator may unload liquefied compressed gases from a cargo tank motor vehicle with a delivery hose assembly found to have any condition identified in § 180.416(g)(1) of this subchapter or with piping systems found to have any condition identified in § 180.416(g)(2) of this subchapter.
(g) Rejection criteria.
(1) No operator may use a delivery hose assembly determined to have any condition identified below for unloading liquefied compressed gases. An operator may remove and replace damaged sections or correct defects discovered. Repaired hose assemblies may be placed back in service if retested successfully in accordance with paragraph (f) of this section.
(i) Damage to the hose cover that exposes the reinforcement.
(ii) Wire braid reinforcement that has been kinked or flattened so as to permanently deform the wire braid.
(iii) Soft spots when not under pressure, bulging under pressure, or loose outer covering.
(iv) Damaged, slipping, or excessively worn hose couplings.
(v) Loose or missing bolts or fastenings on bolted hose coupling assemblies.
(2) No operator may use a cargo tank with a piping system found to have any condition identified in this paragraph (g)(2) for unloading liquefied compressed gases.
(i) Any external leak identifiable without the use of instruments.
(ii) Bolts that are loose, missing, or severely corroded.
(iii) Manual stop valves that will not actuate.
(iv) Rubber hose flexible connectors with any condition outlined in paragraph (g)(1) of this section.
(v) Stainless steel flexible connectors with damaged reinforcement braid.
(vi) Internal self-closing stop valves that fail to close or that permit leakage through the valve detectable without the use of instruments.
(vii) Pipes or joints that are severely corroded.
This is a lot of specifics and it is this kind of data that MUST BE incorporated into our SOPs and quite possibly into our Maintenance Procedures as well. This requirement actually requires the driver (or operator if he/she meets the definition of “qualified” under DOT definitions) to walk down the piping from the hose connection to the tank BEFORE he/she begins the transfer! I have always made this inspection be documented in an “in-hand checklist” that is an appendix to the SOP, but there are many ways to accomplish these inspections and document them. How many of us know for certain these inspections are taking place before EACH DELIVERY?
(n) Emergency shut down. If there is an unintentional release of product to the environment during unloading of a liquefied compressed gas, the qualified person unloading the cargo tank motor vehicle must promptly shut the internal self-closing stop valve or other primary means of closure and shut down all motive and auxiliary power equipment.
Again, these actions are intended for the driver/attendant to undertake, but they need to be incorporated into our Unloading SOPs.
(o) Daily test of off-truck remote shut-off activation device. For a cargo tank motor vehicle equipped with an off-truck remote means to close the internal self-closing stop valve and shut off all motive and auxiliary power equipment, an operator must successfully test the activation device within 18 hours prior to the first delivery of each day. For a wireless transmitter/receiver, the person conducting the test must be at least 45.72 m (150 feet) from the cargo tank and may have the cargo tank in his line of sight.
We always required the transporter to maintain a record of this test and it was one of our pre-checks in our SOP. Surprisingly enough, when we began incorporating this check in our unloading SOPs my phone rang off the desk as we found so many drovers who were not doing their test. We took this so seriously that anytime a driver arrived without the documentation or just forgot to do the test, we would allow them to do the test in our presence so we could verify the ESD system worked properly.
(p) Unloading procedures for liquefied petroleum gas and anhydrous ammonia in metered delivery service. An operator must use the following procedures for unloading liquefied petroleum gas or anhydrous ammonia from a cargo tank motor vehicle in metered delivery service:
(1) For a cargo tank with a capacity of 13,247.5 L (3,500 water gallons) or less, excluding delivery hose and piping, the qualified person attending the unloading operation must remain within 45.72 meters (150 feet) of the cargo tank and 7.62 meters (25 feet) of the delivery hose and must observe both the cargo tank and the receiving container at least once every five minutes when the internal self-closing stop valve is open during unloading operations that take more than five minutes to complete.
(2) For a cargo tank with a capacity greater than 13,247.5 L (3,500 water gallons), excluding delivery hose and piping, the qualified person attending the unloading operation must remain within 45.72 m (150 feet) of the cargo tank and 7.62 m (25 feet) of the delivery hose when the internal self-closing stop valve is open.
(i) Except as provided in paragraph (p)(2)(ii) of this section, the qualified person attending the unloading operation must have an unobstructed view of the cargo tank and delivery hose to the maximum extent practicable, except during short periods when it is necessary to activate controls or monitor the receiving container.
(ii) For deliveries where the qualified person attending the unloading operation cannot maintain an unobstructed view of the cargo tank, when the internal self-closing stop valve is open, the qualified person must observe both the cargo tank and the receiving container at least once every five minutes during unloading operations that take more than five minutes to complete. In addition, by the compliance dates specified in §§ 173.315(n)(5) and 180.405(m)(3) of this subchapter, the cargo tank motor vehicle must have an emergency discharge control capability that meets the requirements of § 173.315(n)(2) or § 173.315(n)(4) of this subchapter. (see the discussion above regarding the emergency discharge control capability)
This is one task the drivers tend to do a nice job with; however, nothing is fool proof and I have walked up on several transfers in my time with the driver ASLEEP in his/her cab or taking a break in the air conditioned break room well beyond 25′ away and no where near in “line of sight of the tanker”!!!
(q) Unloading procedures for liquefied petroleum gas and anhydrous ammonia in other than metered delivery service. An operator must use the following procedures for unloading liquefied petroleum gas or anhydrous ammonia from a cargo tank motor vehicle in other than metered delivery service:
(1) The qualified person attending the unloading operation must remain within 7.62 m (25 feet) of the cargo tank when the internal self-closing stop valve is open.
(2) The qualified person attending the unloading operation must have an unobstructed view of the cargo tank and delivery hose to the maximum extent practicable, except during short periods when it is necessary to activate controls or monitor the receiving container.
DOT defines “Metered Delivery Service” as a cargo tank unloading operation conducted at a metered flow rate of 378.5 L (100 gallons) per minute or less through an attached delivery hose with a nominal inside diameter of 3.175 cm (11⁄4 inches) or less. So unless the flow of the delivery system is RESTRICTED to 100 gallons or less the driver must remain within 25′ of the hose connection at the truck and have UNOBSTRUCTED view of the connection when the truck valve is OPEN. I like to add this as a CAUTION note in my SOP. I will discuss the requirements for a “qualified person” later in this article, but there are some things we have to work out if we plan to make our employee the “qualified person”.
(r) Unloading using facility-provided hoses. A cargo tank motor vehicle equipped with a specially designed delivery hose assembly to meet the requirements of § 173.315(n)(2) of this subchapter may be unloaded using a delivery hose assembly provided by the receiving facility under the following conditions:
(1) The qualified person monitoring unloading must visually examine the facility hose assembly for obvious defects prior to its use in the unloading operation.
(2) The qualified person monitoring unloading must remain within arm’s reach of the mechanical means of closure for the internal self-closing stop valve when the internal self-closing stop valve is open except for short periods when it is necessary to activate controls or monitor the receiving container. For chlorine cargo tank motor vehicles, the qualified person must remain within arm’s reach of a means to stop the flow of product except for short periods when it is necessary to activate controls or monitor the receiving container.
(3) If the facility hose is equipped with a passive means to shut off the flow of product that conforms to and is maintained to the performance standard in § 173.315(n)(2) of this subchapter, the qualified person may attend the unloading operation in accordance with the attendance requirements prescribed for the material being unloaded in § 177.834 of this section.
This requirement is CRITICAL in my eyes as all of my facilities STOPPED using the truck’s hoses in the mid 1990’s. After several major releases during unloading operations I came to the conclusion that we needed to set the standards of excellence and thus the first thing we did is instute the requirement that ALL hazardous materials transfers be done in company issues, inspected and tested hose(s). We also implemented an extensive MI program for all of our hoses; including a tagging program with critical safety data on each hose.
(s) Off-truck remote shut-off activation device. For a cargo tank motor vehicle with an off-truck remote control shut-off capability as required by §§ 173.315(n)(3) or (n)(4) of this subchapter, the qualified person attending the unloading operation must be in possession of the activation device at all times during the unloading process. This requirement does not apply if the activation device is part of a system that will shut off the unloading operation without human intervention in the event of a leak or separation in the hose.
(t) Unloading without appropriate emergency discharge control equipment. Until a cargo tank motor vehicle is equipped with emergency discharge control equipment in conformance with §§ 173.315(n)(2) and 180.405(m)(1) of this subchapter, the qualified person attending the unloading operation must remain within arm’s reach of a means to close the internal self-closing stop valve when the internal self-closing stop valve is open except during short periods when the qualified person must activate controls or monitor the receiving container. For chlorine cargo tank motor vehicles unloaded after December 31, 1999, the qualified person must remain within arm’s reach of a means to stop the flow of product except for short periods when it is necessary to activate controls or monitor the receiving container.
This requirement is more abused than any! Take NOTICE there is ONLY ONE exceptions to this requirement and that is when the “qualified person” is activating controls or monitoring the receiving container!!! If a truck carrying a Class 2 material AND it is not equipped with an “emergency discharge control equipment” the “qualified person” MUST remain within arm’s reach of a means to close the internal self closing stop valve. This holds true come “hell or high water” and matters not what the weather conditions are at the time of the transfer. If the weather is such that the “qualified person” can not meet this requirement then the transfer MUST STOP (or not even begin) and the internal valve on the tanker CLOSED.
(u) Unloading of chlorine cargo tank motor vehicles. Unloading of chlorine from a cargo tank motor vehicle must be performed in compliance with Section 3 of the Chlorine Institute Pamphlet 57, “Emergency Shut-off Systems for Bulk Transfer of Chlorine” (IBR, see § 171.7 of this subchapter).
This CI pamphlet can be downloaded for FREE from the Chlorine Institute website.
This section lists ALL the unloading requirements that apply to ALL placarded HAZMATs. It also defines the skills and ability a “qualified person” must possess.
177.834 General requirements.
(c) No smoking while loading or unloading. Smoking on or about any motor vehicle while loading or unloading any Class 1 (explosive), Class 3 (flammable liquid), Class 4 (flammable solid), Class 5 (oxidizing), or Division 2.1 (flammable gas) materials is forbidden.
(d) Keep fire away, loading and unloading. Extreme care shall be taken in the loading or unloading of any Class 1 (explosive), Class 3 (flammable liquid), Class 4 (flammable solid), Class 5 (oxidizing), or Division 2.1 (flammable gas) materials into or from any motor vehicle to keep fire away and to prevent persons in the vicinity from smoking, lighting matches, or carrying any flame or lighted cigar, pipe, or cigarette.
This would be another “no brainer” response for many, but as my website photos show us, there are plenty of workers who fail to respect the hazards of these materials. The one area that is open for debate is the verbiage “to prevent persons in the vicinity from smoking, lighting matches, or carrying any flame or lighted cigar, pipe, or cigarette”. One thing that seems to get overlooked in some “facility siting analysis” is the location of “break areas” and “smoking areas”! We have found smoking areas inside tank farms that contain flammables and vegetation surrounding the tanks. We have also seen unloading spots that are directly on the property line and right next to a public sidewalk with residents walking within 5-10′ of the hose connection on the truck (another serious facility siting issue!). So how does a facility control who walks down a public sidewalk and what they are doing as they walk by the unloading of a flammable material. The answer here is not cheap, but it is one that needs to be on every 5-year capital plan and that is to MOVE the unloading station!
(e) Handbrake set while loading and unloading. No hazardous material shall be loaded into or on, or unloaded from, any motor vehicle unless the handbrake be securely set and all other reasonable precautions be taken to prevent motion of the motor vehicle during such loading or unloading process.
As fundamental as this requirement may sound, it may be the most common omission from SOPs, as well as in the field. I have to think it is one of the Top 10 DOT Citations issued as well, but I cannot confirm this.
(f) Use of tools, loading and unloading. No tools which are likely to damage the effectiveness of the closure of any package or other container, or likely adversely to affect such package or container, shall be used for the loading or unloading of any Class 1 (explosive) material or other dangerous article.
This requirement is heavily debated as some read this to mean “non-sparking tools” and some read this to merely mean “use the correct size wrenches”. I will leave this debate up to each reader, but my take is “non-sparking tools” and it applies to all flammables and combustibles (just to be supper safe).
(i) Attendance requirements —
(1) Loading. A cargo tank must be attended by a qualified person at all times when it is being loaded. The person who is responsible for loading the cargo tank is also responsible for ensuring that it is so attended.
(2) Unloading. A motor carrier who transports hazardous materials by a cargo tank must ensure that the cargo tank is attended by a qualified person at all times during unloading. However, the carrier’s obligation to ensure attendance during unloading ceases when:
(i) The carrier’s obligation for transporting the materials is fulfilled;
(ii) The cargo tank has been placed upon the consignee’s premises; and
(iii) The motive power has been removed from the cargo tank and removed from the premises.
(3) Except for unloading operations subject to §§ 177.837(d), 177.840(p), and 177.840(q), a qualified person “attends” the loading or unloading of a cargo tank if, throughout the process, he is alert and is within 7.62 m (25 feet) of the cargo tank. The qualified person attending the unloading of a cargo tank must have an unobstructed view of the cargo tank and delivery hose to the maximum extent practicable during the unloading operation.
(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, he has been instructed on the procedures to be followed in emergencies, he is authorized to move the cargo tank, and he has the means to do so.
The biggest thing in the general “attendance requirements” is in #4 where DOT defines what skills the “qualified person” must possess. They break this down into three (3) skills/capabilities:
- 1.been made aware of the nature of the hazardous material
- 2.been instructed on the procedures to be followed in emergencies
- 3.is authorized to move the cargo tank and has the means to do so.
I read #1 as the attendant has received and understood the HAZCOM training regarding the chemical hazards. This is something his/her employer MUST provide under OSHA’s 1910.1200.
#2 is not quite so simple for a facility, but if they intend to leave the driver to be the sole attendant I read this requirement that the driver must be trained in the facility’s emergency action plan (EAP), as well as any other emergency systems he/she would be expected to activate (e.g. ESD buttons, deluge system trips, etc.). At the very least I always had the site emergency phone number posted at ALL loading/unloading stations, as well as a map of the facility that showed the assembly areas, safety showers, and wind socks. This way if the driver was ever left alone, he/she would have the most basic information at their fingertips. I also made sure that an emergency phone was at each station for the drivers to use and these phones were on a Quarterly PM as part of our PSM/RMP program.
#3 is the tricky one for when we expect our employees to fulfill the role of the DOT Attendant, while the driver is sent to a “safe haven” during the transfer activities. It also calls into question what happens when the trailer is “dropped” and unloaded without being attached to a tractor. I know for a fact the employees at my facilities were never allowed to drive a truck owned by a vendor (and vice-versa). So allowing (or sending) the driver to a break area or some type of safe haven may create DOT compliance issues, unless this area is in very close proximity AND the employee has a means to communicate DIRECTLY with the driver in a timely fashion. Now for trailers that are not attached to a tractor brings in a whole new debate since the attendant would not have a “means” to move the cargo tanker should there be an emergency need to move it (e.g. fire in the area). This one is very tricky as I have heard many arguments about how they would just get a yard truck to move the trailer; as if the site has extra yard trucks parked in an emergency spot and only used for emergencies! I find this position quite laughable, especially when the attendant has a mere minute or two to move the tanker to safety, we think he/she will be able to travel to the yard truck, inspect the yard truck, drive back to the unloading spot, hook up the trailer, and move the cargo tanker to safety. Yeah that sounds like a plan!!!!
177.837 Class 3 materials (See also 177.834 (a) to (j)
(a) Engine stopped. Unless the engine of a cargo tank motor vehicle is to be used for the operation of a pump, Class 3 material may not be loaded into, or on, or unloaded from any cargo tank motor vehicle while the engine is running. The diesel engine of a cargo tank motor vehicle may be left running during the loading and unloading of a Class 3 material if the ambient atmospheric temperature is at or below −12 °C (10 °F).
Much like when unloading Class 2 Flammable Gases, the engine of the tractor must off during the transfer, unless it needs to be on to power the pump on the truck. They also make an exception for when the tractor is a diesel engine and the ambient temperature is at or below 10°F. This exception is NOT permitted with Class 2 Flammable Gases!
(b) Bonding and grounding containers other than cargo tanks prior to and during transfer of lading. For containers which are not in metallic contact with each other, either metallic bonds or ground conductors shall be provided for the neutralization of possible static charges prior to and during transfers of Class 3 (flammable liquid) materials between such containers. Such bonding shall be made by first connecting an electric conductor to the container to be filled and subsequently connecting the conductor to the container from which the liquid is to come, and not in any other order. To provide against ignition of vapors by discharge of static electricity, the latter connection shall be made at a point well removed from the opening from which the Class 3 (flammable liquid) material is to be discharged.
How many SOPs actually specify that the FIRST connection of the bonding cable be made to the container to be filled and then to the cargo tanker? Now if we are going to a fixed storage tank, this is easy as the ground and bonding connection to this fixed tank is ALWAYS connected so it will be the FIRST connection on every unload; however, there are occasions where cargo tankers are unloaded to ISO Containers, totes, smaller transport containers, etc. and this is where this sequence becomes CRITICAL and must be included as a CRITICAL ORDER in our SOP(s). You also noticed that the regulation calls for the connection on the cargo tanker to be removed from any location where the material or its vapor is discharged, another critical aspect that needs to be covered in our SOP(s).
(c) Bonding and grounding cargo tanks before and during transfer of lading.
(1) When a cargo tank is loaded through an open filling hole, one end of a bond wire shall be connected to the stationary system piping or integrally connected steel framing, and the other end to the shell of the cargo tank to provide a continuous electrical connection. (If bonding is to the framing, it is essential that piping and framing be electrically interconnected.) This connection must be made before any filling hole is opened, and must remain in place until after the last filling hole has been closed. Additional bond wires are not needed around All-Metal flexible or swivel joints, but are required for nonmetallic flexible connections in the stationary system piping. When a cargo tank is unloaded by a suction-piping system through an open filling hole of the cargo tank, electrical continuity shall be maintained from cargo tank to receiving tank.
(2) When a cargo tank is loaded or unloaded through a vapor-tight (not open hole) top or bottom connection, so that there is no release of vapor at a point where a spark could occur, bonding or grounding is not required. Contact of the closed connection must be made before flow starts and must not be broken until after the flow is completed.
(3) Bonding or grounding is not required when a cargo tank is unloaded through a nonvapor-tight connection into a stationary tank provided the metallic filling connection is maintained in contact with the filling hole.
Another set of CRITICAL ORDER steps that are regulatory driven and very rarely find their way into Loading SOP(s). I will say this now, as I have said it many times in my other flammable liquid articles, bonding and grounding is NOT common sense and is an ABSOLUTE CRITICAL PRACTICE when handling flammable liquids. Take a day and audit your flammable liquid procedures, inspect/test your bonding and grounding stations, and observe their use and you will most likely be shocked at the deficiencies you find. At a bare minimum we should have ALL of our bonding and grounding stations included in our inspection and testing program at some frequency, but at least annually.
(d) Unloading combustible liquids. For a cargo tank unloading a material meeting the definition for combustible liquid in § 173.150(f) of this subchapter, the qualified person attending the unloading operation must remain within 45.72 meters (150 feet) of the cargo tank and 7.62 meters (25 feet) of the delivery hose and must observe both the cargo tank and the receiving container at least once every five minutes during unloading operations that take more than five minutes to complete.
You may have noticed the distance the attendant can wander is now 150′ vs. 25′ for flammable liquids, but take notice that the distance to the hose connection REMAINS 25′.
This section gets into the Emergency Response information that is to be on hand, what info must be included, where the info must be located. Both the receiving facility AND the carrier are responsible for maintaining this information. A well-written MSDS from our Process Safety Information (PSI) and/or Emergency Response Plan will cover these requirements.
172.602 Emergency response information.
(a) Information required. For purposes of this subpart, the term “emergency response information” means information that can be used in the mitigation of an incident involving hazardous materials and, as a minimum, must contain the following information:
(1) The basic description and technical name of the hazardous material as required by 172.202 and 172.203(k), the ICAO Technical Instructions, the IMDG Code, or the TDG Regulations, as appropriate (IBR, see § 171.7 of this subchapter);
(2) Immediate hazards to health;
(3) Risks of fire or explosion;
(4) Immediate precautions to be taken in the event of an accident or incident;
(5) Immediate methods for handling fires;
(6) Initial methods for handling spills or leaks in the absence of fire; and
(7) Preliminary first aid measures.
(b) Form of information. The information required for a hazardous material by paragraph (a) of this section must be:
(1) Printed legibly in English;
(2) Available for use away from the package containing the hazardous material; and
(3) Presented—
(i) On a shipping paper;
(ii) In a document, other than a shipping paper, that includes both the basic description and technical name of the hazardous material as required by §§ 172.202 and 172.203(k), the ICAO Technical Instructions, the IMDG Code, or the TDG Regulations, as appropriate, and the emergency response information required by this subpart (e.g., a material safety data sheet); or
(iii) Related to the information on a shipping paper, a written notification to pilot-in-command, or a dangerous cargo manifest, in a separate document (e.g., an emergency response guidance document), in a manner that cross-references the description of the hazardous material on the shipping paper with the emergency response information contained in the document. Aboard aircraft, the ICAO “Emergency Response Guidance for Aircraft Incidents Involving Dangerous Goods” and, aboard vessels, the IMO “Emergency Procedures for Ships Carrying Dangerous Goods”, or equivalent documents, may be used to satisfy the requirements of this section for a separate document.
(c) Maintenance of information. Emergency response information shall be maintained as follows:
(1) Carriers. Each carrier who transports a hazardous material shall maintain the information specified in paragraph (a) of this section and § 172.606 of this part in the same manner as prescribed for shipping papers, except that the information must be maintained in the same manner aboard aircraft as the notification of pilot-in-command, and aboard vessels in the same manner as the dangerous cargo manifest. This information must be immediately accessible to train crew personnel, drivers of motor vehicles, flight crew members, and bridge personnel on vessels for use in the event of incidents involving hazardous materials.
(2) Facility operators. Each operator of a facility where a hazardous material is received, stored or handled during transportation, shall maintain the information required by paragraph (a) of this section whenever the hazardous material is present. This information must be in a location that is immediately accessible to facility personnel in the event of an incident involving the hazardous material.
174.67 Tank car unloading.
For transloading operations, the following rules must be observed:
NOTE: DOT defines “translating” as the transfer of a hazardous material by any person from one bulk packaging to another bulk packaging, from a bulk packaging to a non-bulk packaging, or from a non-bulk packaging to a bulk packaging for the purpose of continuing the movement of the hazardous material in commerce.
(a) General requirements.
(1) Unloading operations must be performed by hazmat employees properly instructed in unloading hazardous materials and made responsible for compliance with this section.
(2) Each hazmat employee who is responsible for unloading must apply the handbrake and block at least one wheel to prevent movement in any direction. If multiple tank cars are coupled together, sufficient hand brakes must be set and wheels blocked to prevent movement in both directions.
(3) Each hazmat employee who is responsible for unloading must secure access to the track to prevent entry by other rail equipment, including motorized service vehicles. This requirement may be satisfied by lining each switch providing access to the unloading area against movement and securing each switch with an effective locking device, or by using derails, portable bumper blocks, or other equipment that provides and equivalent level of safety.
(4) Each hazmat employee who is responsible for unloading must display caution signs on the track or on the tank cars to warn persons approaching the cars from the open end of the track and must be left up until after all closures are secured and the cars are in proper condition for transportation. The caution signs must be of metal or other durable material, rectangular, at 30.48 cm (12 inches) high by 38.10 cm (15 inches) wide, and bear the word “STOP.” The word “STOP” must appear in letters at least 10.16 cm (4 inches) high. The letters must be white on a blue background. Additional words, such as “Tank Car Connected” or “Crew at Work,” may also appear in white letters under the word “STOP.”
(5) The transloading facility operator must maintain written safety procedures (such as those it may already be required to maintain pursuant to the Department of Labor’s Occupational Safety and Health Administration requirements in 29 CFR 1910.119 and 1910.120) in a location where they are immediately available to hazmat employees responsible for the transloading operation.
(6) Before a manhole cover or outlet valve cap is removed from a tank car, the car must be relieved of all interior pressure by cooling the tank with water or by venting the tank by raising the safety valve or opening the dome vent at short intervals. However, if venting to relieve pressure will cause a dangerous amount of vapor to collect outside the car, venting and unloading must be deferred until the pressure is reduced by allowing the car to stand overnight, otherwise cooling the contents, or venting to a closed collection system. These precautions are not necessary when the car is equipped with a manhole cover which hinges inward or with an inner manhole cover which does not have to be removed to unload the car, and when pressure is relieved by piping vapor into a condenser or storage tank.
Note that the DOT regs for unloading a rail car of hazardous materials mentions OSHA’s PSM standard and HAZWOPER standard. But it is what’s in section (6) that needs to be addressed in our Unloading SOPs.
(b) After the pressure is released, for unloading processes that require the removal of the manhole cover, the seal must be broken and the manhole cover removed as follows:
(1) Screw type. The cover must be loosened by placing a bar between the manhole cover lug and knob. After two complete turns, so that the vent openings are exposed, the operation must be stopped, and if there is any sound of escaping vapor, the cover must be screwed down tightly and the interior pressure relieved as prescribed in paragraph (a)(6) of this section, before again attempting to remove the cover.
NOTE: Make a trip out to the rail car unloading station and ask the employees to show you the “bar” they place between the manhole cover lug and the knob when they are checking to ensure the car has been relieved of its pressure.
(2) Hinged and bolted type. All nuts must be unscrewed one complete turn, after which same precautions as prescribed for screw type cover must be observed.
(3) Interior type. All dirt and cinders must be carefully removed from around the cover before the yoke is unscrewed.
(c) When the car is unloaded through a bottom outlet valve, for unloading processes that require the removal of the manhole cover, the manhole cover must be adjusted as follows:
(1) Screw type. The cover must be put in place, but not entirely screwed down, so that air may enter the tank through the vent holes in threaded flange of the cover.
(2) Hinged and bolted type. A non-metallic block must be placed under one edge of the cover.
(3) Interior type. The screw must be tightened up in the yoke so that the cover is brought up within one-half inch of the closed position.
(d) When unloading through the bottom outlet of a car equipped with an interior manhole type cover, and in each case where unloading is done through the manhole (unless a special cover with a safety vent opening and a tight connection for the discharge outlet is used), the manhole must be protected by asbestos or metal covers against the entrance of sparks or other sources of ignition of vapor, or by being covered and surrounded with wet burlap or similar cloth material. The burlap or other cloth must be kept damp by the replacement or the application of water as needed.
(e) Seals or other substances must not be thrown into the tank and the contents may not be spilled over the car or tank.
(f) The valve rod handle or control in the dome must be operated several times to see that outlet valve in bottom of tank is on its seat before valve cap is removed.
(g) The valve cap, or the reducer when a large outlet is to be used, must be removed with a suitable wrench after the set screws are loosened and a pail must be placed in position to catch any liquid that may be in the outlet chamber. If the valve cap or reducer does not unscrew easily, it may be tapped lightly with a mallet or wooden block in an upward direction. If leakage shows upon starting the removal, the cap or reducer may not be entirely unscrewed. Sufficient threads must be left engaged and sufficient time allowed to permit controlled escape of any accumulation of liquid in the outlet chamber. If the leakage stops or the rate of leakage diminishes materially, the cap or reducer may be entirely removed. If the initial rate of leakage continues, further efforts must be made to seat the outlet valve (see paragraph (f) of this section). If this fails, the cap or reducer must be screwed up tight and the tank must be unloaded through the dome. If upon removal of the outlet cap the outlet chamber is found to be blocked with frozen liquid or any other matter, the cap must be replaced immediately and a careful examination must be made to determine whether the outlet casting has been cracked. If the obstruction is not frozen liquid, the car must be unloaded through the dome. If the obstruction is frozen liquid and no crack has been found in the outlet casting, the car may, if circumstances require it, be unloaded from the bottom by removing the cap and attaching unloading connections immediately. Before opening the valve inside the tank car, steam must be applied to the outside of the outlet casting or wrap casting with burlap or other rags and hot water must be applied to melt the frozen liquid.
(h) Unloading connections must be securely attached to unloading pipes on the dome or to the bottom discharge outlets before any discharge valves are opened.
(i) Throughout the entire period of unloading and while a tank car has unloading equipment attached, the facility operator must assure that the tank car is:
(1) Attended by a designated hazmat employee who is physically present and who has an unobstructed view of the unloading operation; OR
(2) Monitored by a signaling system ( e.g., video system, sensing equipment, or mechanical equipment) that is observed by a designated hazmat employee located either in the immediate area of the tank car or at a remote location within the facility, such as a control room. The signaling system must—
(i) Provide a level of surveillance equivalent to that provided in subparagraph (1) of this paragraph (i); and
(ii) Provide immediate notification to a designated hazmat employee of any system malfunction or other emergency so that, if warranted, responsive actions may be initiated immediately.
(j) Attendance is not required when piping is attached to a top outlet of a tank car, equipped with a protective housing required under § 179.100-12 of this subchapter, for discharge of lading under the following conditions:
(1) All valves are tightly closed.
(2) The piping is not connected to hose or other unloading equipment and is fitted with a cap or plug of appropriate material and construction.
(3) The piping extends no more than 15.24 centimeters (6 inches) from the outer edge of the protective housing.
(k) In the absence of the unloader, a tank car may stand with unloading connections attached when no product is being transferred under the following conditions:
(1) The facility operator must designate a hazmat employee responsible for on-site monitoring of the transfer facility. The designated hazmat employee must be made familiar with the nature and properties of the product contained in the tank car; procedures to be followed in the event of an emergency; and, in the event of an emergency, have the ability and authority to take responsible actions.
(2) When a signaling system is used in accordance with paragraph (i) of this section, the system must be capable of alerting the designated hazmat employee in the event of an emergency and providing immediate notification of any monitoring system malfunction. If the monitoring system does not have self-monitoring capability, the designated hazmat employee must check the monitoring system hourly for proper operation.
(3) The tank car and facility shutoff valves must be secured in the closed position.
(4) Brakes must be set and wheels locked in accordance with paragraph (a)(2) of this section.
(5) Access to the track must be secured in accordance with paragraph (a)(3) of this section.
(l) As soon as a tank car is completely unloaded, all valves must be made tight by the use of a bar, wrench or other suitable tool, the unloading connections must be removed and all other closures made tight.
(m) Railroad defect cards may not be removed.
(n) If oil or gasoline has been spilled on the ground around connections, it must be covered with fresh, dry sand or dirt.
(o) All tools and implements used in connection with unloading must be kept free of oil, dirt, and grit.