ITCO guidance on tank top working

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

the work area. When not in use, the guard rail must be stored within the ISO frame dimensions and should be secured with an automatic fail-safe safety catch: if the rail inadvertently lifts during transport it can cause severe problems.

WHO DOES THE WORK? One alternative that helps avoid the need for anyone to work on top of a tank is the use of bottom filling and discharge; the only issue is that the ‘airline’ vapour valve, normally fitted on top of the tank, needs to be opened to allow the tank to vent as it is filled. It is possible to install remote units to allow this valve to be opened from ground level, or the airline can be piped to the bottom of the tank.

Which raises the question: who should be operating the tank during the loading or discharge? Is it the driver, whose job it is to drive, or the facility personnel, whose responsibility it is to operate the site? ITCO is clear: the tank container operator and its employees provide a logistics service, delivering the tank to and from the shipper’s facility. When it is at the shipper’s or receiver’s facility, the tank should be ‘operated’ by the terminal personnel, who should be responsible for the filling and discharge process, as well as sampling. These personnel should be fully trained and qualified in those activities, as well as in safety in working at height.

“The tank logistics operator’s personnel, including any contracted personnel such as a truck driver, should not be involved in the filling and discharge of the tank at the shipper’s terminal,” ITCO’s guidance states. A contract should exist (and is possibly assumed to) between the facility and the tank operator or sub-contracted haulier, setting out the terms and conditions that apply to any activity required by the terminal and agreed by the tank operator.

However, ITCO recognises that, in some countries, trucking company personnel may be asked to carry out tasks at the loading or discharge terminal, which might involve working on top of the tank. In such cases there should be a risk assessment and appropriate function-specific training. Tank operators should not instruct contracted drivers to undertake operational tasks at the terminal site, as they are not fully trained or qualified to do so.

DRIVERS SHOULD CERTAINLY NOT BE ASKED TO WORK

ON TOP OF A TANK CONTAINER AND ANY PERSONNEL

WHO DO DESERVE TO HAVE PROPERLY INSTALLED OPTIONS AVAILABLE ITCO’s guidance document goes on to discuss the various types of gantry and fall arrest systems available, with the pros and cons of each. It also looks at the specific situations applicable at tank repair depots, tank cleaning stations and inspection facilities. Specific comments are given relating to interior access – and ITCO is planning some further guidance on tank entry, due to be published shortly.

Examples are given of the types of fixed and mobile inspection gantries, mobile ladders with pulpit, mobile stairs and access platforms, fall-arrest body harnesses and repair yard ladders.

The guidance document concludes with an example of the items that need to be considered during a risk assessment, along with a hierarchy of controls. This starts from the assumption that tank top working should be eliminated and that procedures should be reviewed to determine the possibility that a process change could be introduced to ensure that all tasks are undertaken at ground level.

ITCO’s Guidance for working on top of a tank container, number TG04 in its series of technical guides, is available from the ITCO website free of charge at www.international-tank-container.org/ storage/uploads/ITCO_Guidance_for_working_ on_top_of_a_tank_container.pdf.