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TAKE IT FROM THE TOP SAFETY • THE FACT THAT DRIVERS ARE SOMETIMES REQUIRED TO ACCESS THE TOP OF A TANK CONTAINER RAISES SIGNIFICANT RISKS. ITCO HAS DESIGNED SOME GUIDANCE TO HELP GOVERNMENTS HAVE BEEN regulating health and safety in the workplace for well over a century now, so it is disappointing to see that there are many industrial facilities that fail to take their duty of care seriously. Enforcement agencies, while on the one hand keeping a close eye on process safety management in the high-hazard industries, are also constantly warning of the risks of slips, trips and falls in the work environment, which cause any number of minor and more serious injuries – and even death. One area where accidents happen too often, and has proven difficult to address – perhaps because addressing it involves spending money – is the risk of people falling from height when
undertaking operations involving vehicles, usually (but not always) at third-party facilities. It seems bizarre under the prevailing health and safety at work legislation in many jurisdictions that drivers visiting a site to load product are being expected to clamber on top of a road tanker, tank container or other vehicle in order to carry out the loading. For a start, they are trained to drive and, if they are carrying dangerous goods, trained to know what to do in the case of an emergency. They are not trained to operate equipment at other sites and nor are they necessarily trained in the precautions that they must take when handling different dangerous goods.
Yet this is just what is happening at facilities all around the world, despite the fact that in most places these facilities have a duty of care not only to their own employees but also to anyone visiting their site, whatever their role. This is despite the threat of heavy fines or, in some parts of the world, corporate manslaughter charges in the event that someone dies while working on their property. This threat seems to be outweighed by the cost of installing proper safety equipment. USE THE EQUIPMENT Perhaps one cause of this apparent blindspot is that tank containers and road tankers are normally fitted with a ladder at the rear and a walkway along the top, inviting the idea that they are there to be used. But, as a new publication from the International Tank Container Organisation (ITCO) says, working on top of a tank container should be the last resort and, if possible, should be eliminated altogether. ITCO’s Guidance for working on top of a tank container sets out the legal position as regards working at height and is designed to assist companies in undertaking the risk assessment needed to ensure safe work, whether that is on top of the tank or on the ground. As ITCO explains, tank containers are primarily designed for filling and discharge at a shipper’s terminal facility that is equipped with permanent top access gantries. The tank container is fitted with a ladder and top walkway only as a secondary provision, in recognition of the occasional need for personnel to gain access to the top of the tank for other reasons. The guidance document details the specifications for the tank-top walkway and the ladder, highlighting the issues experienced by personnel during the transition from the ladder to the walkway. It also looks at the use of collapsible guard rails which, ITCO says, “are not recommended as an alternative to terminalinstalled on-site fall protection systems”. However, when used, such guard rails should meet the relevant standards (ISO 1496.3 and EN 13374) and should be designed in such a way as to provide effective fall protection on all sides of
HCB MONTHLY | JUNE 2020
