Still today (2011) we come across facilities working so hard to be the best they can be in PSM/RMP and in 99% of their process they are exceeding expectations. They are doing EVERYTHING WELL and running a VERY TIGHT ship…except for the loading and unloading of their Highly Hazardous Chemical (HHC).
Just late last year SAFTENG.net LLC was asked to assist in the investigation of a significant event at a chemical unloading station involving a flammable liquid and resulting fire. This facility happened to be one we were all very impressed with and it takes a lot to impress this team as we have very high expectations for safety performance. But this facility not only had their ship in shape, they were meticulous in their documentation, procedures, testing, auditing, inspections, etc. But when we asked to see the spec sheet on their unloading and loading hoses, as well as the MI inspection reports or change-out schedule…the room went deathly silent. The one area that they had neglected to manage as tightly as their actual processing areas were actually one of the highest risks at any facility handling an HHC…loading and unloading the HHC(s).
We have seen this high risk function managed in many different ways and unfortunately we see it managed incorrectly more often than we’d like. Here is how we see the loading and unloading process managed:
- facility uses a facility hose and has a facility employee make the connection to the process and the driver to his/her truck and the facility employee stays and fills the role as the DOT Attendant
- facility uses a facility hose and has a facility employee make the connection to the process and the driver to his/her truck and then the driver is left to act as the DOT attendant.
- the facility provides a hose and the driver makes all connections and acts as the DOT attendant (facility personnel may or may not be in the vicinity during the process)
- the driver uses his/her hose, makes all connections, and acts as the DOT attendant (often having only interaction with the guards at the gate when they arrive and exit the facility)
Granted there is a lot of variability in the four methods mentioned above, with the risk increasing from #1 to #4. We see #4 scenario quite often still in 2010-11. I would like to expand on this scenario and the potential problems a facility may face during an inspection or agency investigation after a serious incident.
- Drivers trained on the facility Emergency Action Plan? If we were to look at the DOT training requirements for the person serving as the “attendant” we would see they need to be trained in how to sound an alarm, be equipped to stop the transfer in the event of a spill/release, etc. This worker is doing a highly hazardous task and he/she needs to know the basic of your facility EAP if they are going to be left alone while on company property. Another major problem we run into is that the facility is not able to account for their truck drivers in the event of an emergency. In the long run they could call the trucking company dispatcher and get the information but this could take hours to obtain this information in this manner.
- Are truck drivers trained in the unloading procedure? We take it a step further and ask are how they trained in the unloading SOP and we ask for the “means to verify knowledge” of this training. If the facility has a sign-in/out log we will use the log to pick random names of the drivers delivering one of the HHC’s and ask to see their training records and test/observation that verifies they understood the training. We also find that the unloading SOP is outside of the process SOPs and is not being annually certified.
- Are truck drivers wearing the required PPE? Keep in mind we do a lot of our work in flammable liquid facilities and in almost all of them, Flame Retardant Clothing is required gate to gate, except when inside buildings outside of blast zones. We see the drivers donn their chemical PPE (slicker suit, gloves, face shield, etc.) but they are not meeting the FRC requirement. Now you would think a driver delivering a flammable liquid would have on FRC, but you’d be surprised! Remember, FRC has to be the outer most garment and chemical gear that is also FRC rated is not cheap!
- Is the driver’s hose in their company’s MI program for inspection/testing or a rotation program? This is probably the biggest oversight at facilities. Sometime they just assume that the “delivery company is the expert in unloading the material, as that is all they do every day”. This has been a costly assumption for a lot of facilities in recent years. We have actually found hoses in use that: 1) were 20+ years old, 2) they had been run over and were almost flat in spots, 3) the bonding wire cut off as the sharp bur on it was a hazard, 4) modified by the driver with multiple fittings so as to accommodate many different hook up arrangements.
These hoses are actually the start of your covered process battery limit and should be the first piece of covered process equipment on your list of equipment. The facility should have a spec sheet on the hose that shows the materials of construction, pressure rating, temperature rating, inspection frequency or service life, etc. The facility should also identify each hose with an equipment ID# and enter this into the MI program for preventive maintenance needs. The inspection and/or pressure testing of the hose(s) should be directed by a maintenance procedure; keeping in mind that EACH TIME the hose is used, it will be inspected by the user per the Unloading SOP/Checklist. I should also mention that if a facility is making their hoses in-house this would entail a few more layers of procedures, training, verification of knowledge that covers the making of these hoses and testing of the hose before being placed into service.
Hoses used in a chemical process are usually the “weakest link in the chain”. Unloading hoses usually see more wear and tear as they are being hooked and unhooked more often than other process hoses and bottom line…they do not last forever! Having them in your MI program will go long ways to ensuring process safety.
3/28/11 UPDATE:
I have received a lot of questions about this posts in regards to where OSHA starts their enforcement and DOT ends theirs. The task of unloading and loading is covered by DOT and NOT by OSHA. There are a couple of LOI’s to this effect. HOWEVER, having been involved in several unloading incidents during my time in the chemical industry I can tell you the neighborhood you evacuate during your incident finds ZERO SOLACE in the fact that OSHA does not cover the task, nor do the lawyers give you a pass since “no OSHA standards were violated”.
Also keep in mind that when the “mode of transport” is removed from the rail car or tank truck that DOT no longer covers it, and OSHA/EPA would consider these detached tank(s) as part of your process. Basically, as long as you are truly unloading the tanker and the tractor remains under the trailer then DOT covers the task. If the tractor drops the trailer and you hook up to trailer to unload it then consider the tanker a storage tank. This is OSHA and EPA’s attempt to close the loop hole of running your process off of transportation containers rather than fixed vessels.
Bottom line, hoses are the weakest link (or at least they should be!) in your process containment. Not covering them under your MI program can be a very costly mistake.
Case in point:
http://rockrivertimes.com/1993/07/01/lisa-madigan-takes-action-against-company-involved-in-seward-ammonia-leak/