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On February 8, 2007, PHMSA issued, “A Summary Evaluation of Risk Associated with Bulk Loading/Unloading of Hazmat,” a summary report of a risk assessment conducted to identify risks associated with bulk loading and unloading operations for highway and rail transportation. The report provides both a qualitative and quantitative analysis of incident reports involving loading and unloading of bulk packagings submitted to PHMSA in accordance with the reporting criteria specified in § 171.16 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The report focuses on highway and rail transportation incidents because 89% of total incidents and 97% of all serious incidents occur during transportation operations in these two modes. Serious incidents in highway and rail transportation include any unintentional release that results in death, major injury, closure of a major transportation artery, release of radioactive material from a Type B package, suspected release of certain infectious substances, or release of a bulk quantity of hazardous material. The data used for the report are from the Hazardous Materials Information System (HMIS), as of January 7, 2007. The results of the data analysis showed that:
1. Requirements Applicable to Loading and Unloading Operations
The HMR include requirements for loading and unloading railroad tank cars, Cargo Tank Motor Vehicles (CTMVs), and other bulk containers. Part 174 of the HMR, which applies to the transportation of hazardous materials by rail, establishes general loading and unloading requirements for hazardous materials and specific loading and handling requirements for shipments of Class 1 (Explosive), Class 2 (Non-flammable, Flammable, and Poison gases), Class 3 (Flammable liquid), Division 6.1 (Poison), and Class 7 (Radioactive) materials. Part 177 of the HMR, which applies to the transportation of hazardous materials by motor carrier, establishes general hazardous materials loading and unloading requirements and specific loading and unloading requirements applicable to Class 1 (Explosive), Class 2 (Non-flammable, Flammable, and Poison gases), Class 3 (Flammable liquid), Class 4 (Flammable solid, Spontaneously combustible, and Dangerous when wet), Class 5 (Oxidizer and Organic peroxide), Division 6.1 (Poison), Class 7 (Radioactive), and Class 8 (Corrosive) materials. The HMR also include additional loading requirements applicable to rail tank cars, portable tanks, cargo tanks, and intermodal bulk containers in §§ 171.31, 173.32, 173.33, and 173.35.
2. Cargo Tank Motor Vehicles and Loading/Unloading Equipment
The HMR include requirements for the inspection and maintenance of cargo transfer equipment, such as piping and transfer hoses, that is part of bulk packaging or carried on a vehicle used to transport a bulk packaging. The HMR require each operator of a CTMV to conduct periodic tests and inspections of the CTMV and its attachments and appurtenances, including piping and transfer hoses used for loading and unloading the CTMV. Each operator must conduct external visual inspections, internal visual inspections, leakage tests, and pressure tests in accordance with the schedule established in § 180.407(c). Section 180.407 also sets forth the specific procedures to be followed for each inspection or test. In addition, for CTMVs used to transport liquefied compressed gases, each operator must visually inspect each CTMV's cargo transfer equipment, including piping and hoses installed or carried on the CTMV, at least once each month (see § 180.416). These periodic inspections and tests help to ensure that each CTMV and its cargo transfer equipment are free of leaks or other defects that could adversely affect the safe operation of the CTMV, including the safety of loading and unloading operations.
3. Cargo Tank Motor Vehicle Emergency Shutdown Requirements
The HMR require DOT specification CTMVs to be equipped with emergency discharge control systems. For example, an MC 330 or 331 CTMV used to transport liquefied compressed gases must be equipped with an emergency discharge control system activated automatically or by remote control in the event of an unloading emergency. In addition, each CTMV operator must carry on the vehicle written emergency discharge control procedures for all delivery operations. An MC 338 CTMV tank must be equipped with a remotely controlled self-closing shutoff valve with both a mechanical and thermal means of automatic closure. On DOT 406, 407, and 412 CTMVs, each loading/unloading outlet must be fitted with a self-closing system capable of closing the outlet(s) in an emergency within 30 seconds of actuation. On DOT 406, 407, and 412 CTMVs used to transport flammable, pyrophoric, oxidizing, or poisonous materials, the remote means of closure must be capable of thermal activation.
4. Training Requirements
Each person who performs a function regulated under the HMR must be trained (see Subpart H of Part 172). This training must include general awareness, function-specific, safety, and security training. Thus, each person who performs a loading or unloading function regulated under the HMR must be trained concerning all aspects of that function, including emergency shutdown procedures. In addition, each person who performs a loading or unloading function regulated under the HMR must be trained concerning specific hazards associated with the materials handled and personal protection measures.
We are aware of a variety of existing national consensus standards that address bulk loading and unloading operations. For example, the Chlorine Institute has developed loading and unloading procedures for chlorine (e.g., Pamphlet 57, “Emergency Shut-off Systems for Bulk Transfers of Chlorine; Pamphlet 66, “Recommended Practices for Handling Chlorine Tank Cars; Pamphlet 91, “Checklist for Chlorine Packaging Plants, Chlorine Distributors and Tank Car Users of Chlorine”). The Association of American Railroads (AAR) has developed Pamphlet 34, “Recommended Methods for the Safe Loading and Unloading of Tank Cars.” The American Chemistry Council has developed the Responsible Care® management system, which establishes an integrated, structured approach to drive results in seven key areas: community awareness and emergency response; security; distribution; employee health and safety; pollution prevention; process safety; and product stewardship. PHMSA reviewed some of these industry standards to ascertain if existing standards provide the necessary amplification of the basic loading and unloading practices proposed in this notice.
The industry standards address a number of topics related to the loading and unloading of hazardous materials and are different based upon the type of hazardous material, the physical form of the material, the mode of transportation, and the type of packaging used to transport the material. While the standards exhibit differences in specific detail, there are a number of common general safety topic areas, such as, risk evaluation, development of operational procedures, maintenance and testing of equipment, training, and emergency response.
The available industry standards clearly demonstrate industry's focus on safety issues associated with loading and unloading operations. Virtually all standards specifically require the use of personal protective equipment, often specifying in detail the equipment that should be used. In addition, most standards include considerable detail concerning activities that appear to be associated with the greatest personal risk (e.g., assuring evacuation of all hazardous material residues from tanks before required interior inspections). The wide variety of industry standards applicable to loading and unloading operations provide useful information on industry standard practices, which we considered in the development of the recommended practices proposed in this notice.
PHMSA recognizes that it reviewed only a sampling of guidelines and standards that are available to the bulk hazardous materials shipping industry. The documents are representative of what is available to industry and were submitted by those industry personnel who believe additional guidance would be useful.
Proposed Recommended Practices for Loading and Unloading Bulk Quantities of Hazardous Materials
1. Loading/Unloading Safety Analysis
A shipper, carrier, or facility operator should conduct a thorough, orderly, systematic analysis to identify, evaluate and control the hazards associated with specific loading and unloading operations. The analysis should be appropriate to the complexity of the process and the materials involved in the operation. For example, the analysis should consider the hazards of the material to be loaded or unloaded, including any temperature or pressure controls necessary to ensure safe handling of the material, and conditions that could affect the safety of the process, such as access control, lighting, ignition sources, and physical obstructions. The analysis should also assess current procedures utilized to ensure the safety of loading and unloading operations and identify any areas where those procedures could be improved.
2. Loading/Unloading Operational Procedures
Based on the safety analysis, the shipper, carrier, or facility operator should develop a step-by-step guide to loading and unloading that is clear, concise, and appropriate to the level of training and knowledge of its employees. The written guide should address pre-loading/pre-unloading procedures, loading/unloading procedures, and post-loading/post-unloading procedures.
(a) Pre-loading/Pre-unloading procedures should include:
(1) Inspection of the transport unit and transfer area. For example, shippers should ensure that a DOT specification packaging is marked to indicate that it has been designed, manufactured and maintained (including periodic inspection and testing) in accordance with specification requirements.
(2) Securing the transport unit against movement.
(3) Grounding and bonding of the transport unit, as warranted.
(4) Inspection of transfer equipment and connections, including hoses and valves, to ensure that they are free of defects, leaks, or other problems that could result in an unsafe condition.
(5) Identification and verification of piping path, equipment lineups and operational sequencing and procedures for connecting piping, hoses, or other transfer connections.
(6) Identification and verification that the materials that are being loaded or unloaded are being transferred into the appropriate packagings, temporary storage facilities, or production containment vessels and that the compatibility of the material to be transferred is appropriate, authorized and consistent with applicable procedures.
(b) Loading/Unloading procedures should include:
(1) Measures for initiating and controlling the lading flow. For example, if the material is to be heated prior to its transfer, the facility operator should analyze a sample of the material to ascertain the heat input to be applied, if warranted. The maximum heat input to be applied and the rate at which the heat input will be applied must not result in pressurization to a level that exceeds the packaging's test pressure.
(2) Measures for monitoring the temperature of the lading and pressure of the containment vessel (e.g., cargo tank or rail tank car) and receiving vessel (e.g., storage tank). For example, for loading or unloading operations involving heating of the material to be transferred, during the heating process, the facility operator should monitor the heat input applied to the containment vessel and the pressure inside the containment vessel to ensure that the heating process does not result in over-pressurization or an uncontrolled exothermic reaction.
(3) Measures for monitoring filling limits and ensuring that the quantity to be transferred is appropriate for the receiving vessel.
(4) Measures for terminating lading flow. For example, personnel responsible for monitoring a loading or unloading process should be familiar with shut-off equipment and procedures, and should be trained to take necessary actions to stop the lading flow as efficiently as possible.
(c) Post-loading/Post-unloading procedures should include:
(1) Measures for evacuation of the transfer system and depressurization of the containment vessel, as warranted.
(2) Measures for disconnecting the transfer system.
(3) Inspection and securement of transport unit fittings and closures.
(d) Review and Revision of Procedures:
The operating procedures should be reviewed as often as necessary to ensure that they reflect current operating practices, materials, technology, personnel responsibilities, and equipment. To guard against outdated or inaccurate operating procedures, the hazmat employer should consider revalidating the operating procedures annually.
3. Emergency Management
Appropriate emergency procedures should be identified and implemented, including identification of emergency response equipment and individuals authorized in its use; incident response procedures and clearly identified personnel responsibilities; personnel protection guidance and use of emergency shut-down systems; and, emergency communication and spill reporting. Emergency instrumentation and equipment appropriate to the loading or unloading operation should be identified, available, and in working order. Emergency procedures should be clear, concise, and available to workers. Emergency training, including the need for drills, should also be provided.
Loading and unloading facilities may want to consider:
(a) Instrumentation to monitor for leaks and releases.
(b) Equipment to isolate leaks and releases and to take other appropriate emergency shutdown measures, remotely if necessary.
(c) Training in the use of emergency response equipment.
(d) Procedures for incident response.
(e) Procedures for use of emergency shut-down systems and the assignment of shut down responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.
(f) Procedures for emergency communication and spill reporting.
(g) Procedures of safe startup after an emergency shut down.
(h) Procedures and schedules for conducting drills and exercises necessary to demonstrate the efficacy of the plan, and to ensure a timely and efficient emergency response.
(i) Emergency procedures should be reviewed and updated as often as necessary to ensure that they reflect current operating practices, materials, technology, personnel responsibilities, and emergency response information.
4. Maintenance and Testing of Equipment
Loading and unloading equipment and systems need to be properly maintained and tested. Shippers and carriers should develop and implement a periodic maintenance schedule to prevent deterioration of equipment and conduct periodic operational tests to ensure that the equipment functions as intended. Equipment and system repairs should be completed promptly.
Personnel involved in loading and unloading and emergency response operations need to know and understand their specific responsibilities during loading and unloading operations, including attendance or monitoring responsibilities. Consider training in the following areas:
(a) Overview of the loading/unloading process and, specifically, the portions of the process for which the employee is responsible;
(b) Safety systems and their functions;
(c) Emergency operations and procedures, including shutdown procedures;
(d) Additional safe work practices.
(e) Recurrent training as necessary to address changes to the procedures or personnel responsibilities.
About 3:30 a.m. on June 4, 1999, a Quality Carriers, Inc., truckdriver arrived at the Whitehall Leather Company1 tannery in Whitehall, Michigan, to deliver a load of sodium hydrosulfide solution. The truckdriver had never been to the plant before. Upon arrival, he asked a tannery employee for assistance. The employee called the shift supervisor, who met the driver at the plant employee's work station. The shift supervisor stated that the only chemical shipment he had previously received on the third shift was "pickle acid" (ferrous sulfate).2 He said he had not been told to expect the delivery of another chemical on the shift,3 so he assumed this load was also pickle acid. The supervisor stated that because the driver did not know the plant's layout and was unfamiliar with where to unload his cargo, he walked the driver through the plant and out to the pickle acid transfer area. The supervisor did not verify what chemical was being delivered. The shipping documents identified the cargo as sodium hydrosulfide solution. The shift supervisor showed the driver the ferrous sulfate connection (the only working transfer connection at that location) so he could deliver his product. (See figure 1.) The shift supervisor then unlocked a gate to allow the driver to bring his vehicle onto the plant property. The driver asked the supervisor to sign the shipping documents so he would not have to find the supervisor after the transfer was completed. According to the supervisor, he signed the paperwork without reading it and left the area. The signature block that the supervisor signed stated the following: "I have checked the documents for this shipment and verify that there is adequate storage room to receive this shipment and connection has been made to the proper storage facility."
About 7:15 a.m. eastern standard time on November 19, 1998, a cargo tank truck arrived at a Automotobile Plant in Louisville, Kentucky, to deliver a liquid mixture of nickel nitrate and phosphoric acid (a solution designated CHEMFOS 700 by the shipper). A plant employee told the truckdriver to park his vehicle next to the chemical transfer station outside the bulk storage building and wait for a pipefitter to assist him in unloading the chemical. According to testimony, a short time later, the pipefitter arrived at the transfer station and told the driver that he would assist him in unloading the cargo tank. The pipefitter opened an access panel containing six identical pipe connections. Each pipe connection served a different storage tank, and each connection was marked with the plant's designation for the chemical stored in that tank. The driver told the pipefitter that he was delivering CHEMFOS 700 and then went to the driver's side of the cargo tank and took out a cargo transfer hose. The pipefitter connected one end of the hose to one of the transfer couplers, while the driver connected the other end of the hose to the cargo tank's discharge fitting. Unknown to the pipefitter or the truckdriver, the pipefitter had inadvertently attached the hose to the coupler marked "CHEMFOS LIQ. ADD" instead of to the adjacent coupler marked "CHEMFOS 700." The storage tank served by the coupler marked "CHEMFOS LIQ. ADD" contained sodium nitrite solution. The driver climbed to the top of the cargo tank, connected a compressed air hose to a fitting, and pressurized the cargo tank. The driver and the pipefitter then reviewed the cargo manifest and bill of lading. The pipefitter signed three different certifications on the cargo manifest, one of which certified that the transfer hose was "connected to the proper receiving line." The pipefitter asked the driver how long it would take to unload the contents of the cargo tank, and the driver told him the transfer would take about 30 to 40 minutes. The pipefitter then left the loading area, leaving the driver to complete the unloading by himself. About 8:15 a.m., after the air pressure was built up in the cargo tank, the truckdriver started the transfer. When the nickel nitrate and phosphoric acid solution from the truck mixed with the sodium nitrite solution in the storage tank, a chemical reaction occurred that produced toxic gases of nitric oxide and nitrogen dioxide. The driver stated that about 10 minutes after he started the transfer, he saw an orange cloud coming from the bulk storage building. He said he closed the internal valve of the cargo tank to stop the transfer of cargo and waited for someone to come out of the building. After several minutes, the pipefitter ran out of the building and gestured for the driver to stop the unloading process. Here is the full NTSB investigation:
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.
Those of you that have followed me and my ramblings for years know that I am a stickler for unloading/loading operations involving HAZMAT(s). Some of the worst accidents in my career in the chemical industry involved the unloading/loading of HAZMATs. I have written many times about the hazards of unloading even mildly hazardous materials into the wrong tank resulting in serious consequences or about hose failures and even drive-off incidents, all resulting in serious consequences. I am often told that "truck unloading/loading" is "outside the scope of your audit" but I forge ahead knowing the potential outcomes if the issues we identified go unchecked! Now the Pipeline and Hazardous Materials Safety Administration (PHMSA), a part of DOT, has published a "Best Practice" manual for Cargo Tank Motor Vehicle (CTMV) Loading/Unloading operations. This document is intended to aid hazmat employers and others responsible for cargo tank motor vehicle (CTMV) loading/unloading by offering recommended best practices to further enhance the safety of these operations.