This article is intended to walk us through the DOT requirements for UNLOADING LPG and NH3 tanker trucks.  In the DOT requirements covered in this article, we will see items that mirror OSHA's PSM and EPA's RMP requirements for DOCUMENTING Safety Systems and their intended functions.  The material covered here should be incorporated into all UNLOADING SOPs and even in the risks evalauation for a facility to specify what they want in reagrds to the delivery truck(s) emergency discharge control equipment. Remember, one of the HIGHEST risk we face is when we are transferring thousands of gallons of our hazardous material(s) through temporary connections and a hose, so our level of SAFETY should rise to the level of risks.  DOT has done a nice job structuring the requirements for Liquefied Compressed Gas (LCG) service and we should take heed as process safety and safety professionals. 

The information in this report is preliminary and will be supplemented or corrected during the course of the investigation.

On August 27, 2016, about 8:26 a.m. eastern daylight time, tank car AXLX 1702, specification DOT 105J500W, experienced a sudden tank shell crack shortly after it was filled with liquefied compressed chlorine at a rail car loading facility in New Martinsville, West Virginia. During the 2 1/2 hours after the crack developed, the entire 90-ton load of chlorine released from the crack and formed a large vapor cloud that migrated south from the facility along the Ohio River valley. The weather at the time of the accident was lifting fog after sunrise, 72°F, and light wind from the north at 1 mph.

Fire and Building Code Officials are likely seeing the new Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and new Safety Data Sheets with new chemical hazard pictograms. This ICC FACT SHEET is intended to provide Fire and Building Code Officials information relative to the modified OSHA Hazardous Communications Standard (HazCom) and address the potential impacts to current fire code and standard requirements related to hazardous chemicals and materials in the built environment.

In my HAZMAT classes, I always ask the question:  A container of diesel fuel is at its flash point and a container of gasoline is at its flash point - an ignition source is present within the container - which container ignites first?  Darn near 100% of the students will say the gasoline container and darn near 100% are WRONG!  The reason:  Diesel fuel has an LEL of around 0.5% and Gasoline has an LEL of around 1.5%, meaning that the LEL will be achieved in the diesel container MUCH FASTER.  The ONLY thing diesel fuel has that makes it more safe is a HIGH flash point; however, when we expose diesel fuel to cutting torches and grinders we can spread the heat via conduction to the diesel fuel, raising the temp of the solution and thus we create a flammable atmosphere in short order! In fact, since most workers have some level of respect for gasoline and very little for diesel fuel we see more diesel fuel tank explosions than we do gasoline.  Case in point...

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is seeking comment on proposed revisions to the U.S. Hazardous Materials Regulations to maintain alignment with international standards. The changes - which include revisions to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, air transport quantity limitations, and vessel stowage requirements - facilitate the safe transport of hazardous materials in international commerce. The proposed rule is based on recent revisions to the United Nations Model Regulations, International Maritime Dangerous Goods Code, and the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air. The U.N. Model Regulations are amended and updated biennially. Comments must be received on or before 60 days after publication in the Federal Register. The proposed rulemaking has been transmitted to the Federal Register for publication. An actual date of publication will be determined by the Federal Register, but a preview of the rulemaking proposal transmitted by PHMSA is available on the agency's website. For more information on the U.S. DOT's efforts to improve hazardous materials safety and awareness, including details about the proposed rule, visit the PHMSA website at

No, not directly, but they did issue this Safety Advisory: Possession or Use of Battery-Powered Portable Electronic Smoking Devices Around, On or While Operating a Commercial Motor Vehicle (CMV) relating to the possession and use of battery-powered portable electronic smoking devices (e.g., e-cigarettes, e-cigs, e-cigars, e-pipes, e-hookahs, personal vaporizers, electronic nicotine delivery systems (ENDS).  In this Safety Advisory, the FMCSA states:

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I am teaching another 1-Day Course for ASSE

Intro to Process Safety Management.

February 13, 2017 

The Rio, Las Vegas, NV


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