Ctrmc falls protocol final 3.22.2011
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This document provides guidelines and recommendations for industry stakeholders to reduce risks associated with workers accessing the tops of cargo tanks. It defines key terms, outlines responsibilities for various stakeholders including shippers, manufacturers, carriers and facilities, and establishes a hierarchy of controls to minimize fall risks. The goal is an overall reduction in fall exposures across the industry through cooperation among stakeholders.
Ctrmc falls protocol final 3.22.2011
- 1. CTRMC Workers on the Top of Tanks North American Hierarchy Protocol for Protection of Workers on the Top of Tanks CTRMC March 15, 2011 1
- 2. Table of Contents Topic Page # Introduction 3 Definitions 5 Stakeholder and Worker Responsibilities 7 Hierarchy of Controls 13 Appendix A. Tanker Falls Flow Chart 14 Resources and References 15 CTRMC March 15, 2011 2
- 3. Introduction CTRMC is the Cargo Tank Risk Management Committee. Our group was formed by cargo tank industry leaders on March 17th, 2010 to enhance the safety of ‘workers on the top of tanks’. Our members represent several significant industry stakeholders; motor carriers, consignees, cargo tank manufacturers, shippers and wash rack operators. We estimate over 250,000 cargo tanks motor vehicles are in use across North America. The useful service life of this equipment can approach 30 years or more. Replacing equipment with designs to eliminate the need to climb tankers is a long term goal; however, due to the number of cargo tanks motor vehicles in use, and their life expectancy, this document focuses on reducing exposures with existing equipment and facilities. This document is intended to identify recommended best practices for industry stakeholders to employ for reducing the exposure to falls from cargo tank motor vehicles. Reducing the exposure to falls involves; • equipment design, • maintenance/inspection, • state-of-the art replacement ladders (when needed), • loading and unloading facilities, • use of the equipment and protocols for procedures, • training and policy/procedures, and • policy/ procedure enforcement. Various government agencies may have jurisdiction over safety aspects of motor vehicles and facilities. This document is intended as a proactive means to address the industry’s goal of reducing exposure to falls at the range of facilities and situations where workers will climb onto cargo tank motor vehicles. Additional details on governmental jurisdiction can be found in the TTMA Recommended Practice No. 59. This document is advisory and contains best practices; however, using this guide does not guarantee compliance with federal, state or local laws - and regulatory compliance remains the responsibility of parties using this guide. Eliminating the need to climb onto or work on the top of tanks is the preferred method of reducing exposure to falls, and should be addressed prior to considering other control measures outlined in this document. CTRMC’s long term objective is to eliminate the need for workers to perform tasks on tops of cargo tank motor vehicles. CTRMC March 15, 2011 3
- 4. The top ten reasons workers ascend the top of transportation tanks were determined to be: 1. Assuring security 2. Checking equipment including a. cleanouts b. manhole c. venting 3. Extracting samples 4. Loading or unloading product 5. Assessing liquid content levels 6. Initiating a. air unloading b. vapor recovery 7. Performing maintenance and routine inspections 8. Washing tank 9. Removing snow 10. Discharging heel CTRMC March 15, 2011 4
- 5. Definitions Fall Protection System: A system designed to protect personnel from the risk of falls when working at heights of four feet or greater. Fall Prevention: A structural design to limit a fall to the same level (e.g., guardrails, aerial lifts with work platforms). Fall Arrest System: The components of a Fall Arrest System include a full body harness, shock absorbing lanyard or self-retractable lifeline, and locking snap hooks, all of which must meet Occupational Safety & Health Administration (OSHA) criteria. Anchor points must be approved for a static load of 5000 pounds or engineered to meet a 2:1 safety factor. Cargo Tank Motor Vehicle: A motor vehicle with one or more cargo tanks permanently attached to or forming an integral part of the motor vehicle. CTRMC March 15, 2011 5
- 6. Stakeholders: Industry stakeholders fall into several major types and may fall into multiple categories. Stakeholders include: Workers: Employees and independent contractors for motor carriers, shippers, manufacturers or consignees Shippers: Businesses, organizations or individuals that that hire motor carriers to transport materials in cargo tank motor vehicles. Cargo Tank Manufacturers: Businesses or organizations that design and build cargo tank motor vehicles Equipment Maintenance Facilities: Businesses, organizations or individuals that repair or maintain rolling cargo tank motor vehicles. Consignees: Businesses, organizations or individuals that receive materials in cargo tank motor vehicles from shippers. Motor Carriers: For hire or private trucking operations operating in intrastate or interstate commerce. Cleaning and Washing Facilities: Businesses with equipment to clean cargo tanks. Industry Groups: American Chemistry Council (ACC), National Tank Truck Carriers (NTTC), Truck Trailer Manufacturers Association (TTMA) Within the stakeholders various workers may access the top of tanks, and would include: Drivers Wash rack workers Product loaders Product unloaders Maintenance workers Inspectors Management Intermodal transloaders Impacted stakeholders may or may not have direct control over the employees - such as a driver picking up a load at a shipper or consignee. The goal of this document is overall exposure reduction, and not simply the transfer of the risk or activity from one stakeholder or impacted employee to another. CTRMC March 15, 2011 6
- 7. Stakeholder Responsibilities Shippers Review methods to eliminate needs to access the top of tanks. Work with customer contacts to reduce needs for tank top samples. Provide safe access to the top of tanks, with protection from weather, whenever practicable. Ensure proper fall protection is available where tanks are loaded, unloaded and inspected. Ensure fall protection, and access to the top of tanks, is maintained in good condition. Ensure all employees are trained in task expectations Conduct observations to enforce procedures Document policies, procedures, training and compliance reviews Provide training for impacted workers on using fall arrest systems Include fall protection and fall arrest systems in facility design Design and follow PM programs for fall arrest systems, stairs, walkways etc that are part of the fall exposure reduction strategy Adopt a safety based performance program to drive awareness for falls and consequences Assure all workers performing work tasks are properly trained per federal, state and local regulations Conduct root cause analysis protocols for injuries and near misses Participate in industry activities and committees, including CTRMC, addressing safety and fall related exposures and controls across the industry Cargo Tank Manufacturers Comply with TTMA Recommended Practice No. 59 (Tank Trailer Ladders and Walkways) Provide safety decals to warn stakeholders of risks associated with using the equipment Understand, and design to, equipment operator’s needs and intended use Provide customer support for equipment operators in assessing adequacy of ladders and walkways on their tank trailers Assure all workers performing work tasks are properly trained per federal, state and local regulations Conduct root cause analysis protocols for injuries and near misses Participate in industry activities and committees, including CTRMC, addressing safety and fall related exposures and controls across the industry CTRMC March 15, 2011 7
- 8. Consignees Adopt practices to reduce or eliminate tasks performed on the top of tanks Provide stairs, platform and /or fall protection, when possible, if tasks on the top of tanks cannot be eliminated Use the ladders and walkway provided on trailer as a last resort for access the top of tanks Supply an area on premise – protected from the weather, when feasible - for drivers to check and secure their load in order to stay in DOT Compliance guidelines Assure all workers performing work tasks are properly trained per federal, state and local regulations Conduct root cause analysis protocols for injuries and near misses Participate in industry activities and committees, including CTRMC, addressing safety and fall related exposures and controls across the industry Motor Carriers Recognize a duty to ensure the safety of all employees faced with the possibility of working on the top of tanks Assess risks associated with work functions requiring workers to be on the top of tanks Eliminate where practical any job functions that require workers to be on the top of tanks Establish policies addressing expectations of employees with regards to performing remaining tasks that require work on the top of tanks Publish procedures that are aligned with the safest methods of working on the top of tanks that are in accordance with the hierarchy of control published in Appendix A. Train employees on these policies and procedures Audit employees on their adherence to these policies and procedures Cooperate with shippers, consignees, and equipment manufacturers to ultimately design systems and cargo tank motor vehicles that do not require any work to be performed on the top of tanks Assure all workers performing work tasks are properly trained per federal, state and local regulations Conduct root cause analysis protocols for injuries and near misses Participate in industry activities and committees, including CTRMC, addressing safety and fall related exposures and controls across the industry CTRMC March 15, 2011 8
- 9. Equipment Maintenance Facilities Provide fall arrest equipment per CFR 29 for workers assessing the top of tanks Provide a clean, well lit work environment Reduce tank top access to locations where fall arrest systems are available when possible Inspect every cargo tank motor vehicle ladder and walkway in accordance with TTMA TB # (new) even when not requested by the tank owner Notify and document tank owner of any unsafe condition found during ladder and walkway inspections Document all ladder and walkway tank inspections Offer replacement ladders in accordance with TTMA TB # (new) Assure all workers performing work tasks are properly trained per federal, state and local regulations Conduct root cause analysis protocols for injuries and near misses Participate in industry activities and committees, including CTRMC, addressing safety and fall related exposures and controls across the industry Cleaning/Washing Facilities Provide fall protection/arrest systems and equipment Develop standard operating procedures and or work expectations to ensure employees and other workers understand their roles and responsibilities Periodically audit fall protection programs and audit more frequently when near misses or serious events occur Conduct root cause analysis protocols for injuries and near misses Establish processes to recognize compliance and non compliance with operating procedures and work task expectations Assure all workers performing work tasks are properly trained per federal, state and local regulations Conduct root cause analysis protocols for injuries and near misses Participate in industry activities and committees, including CTRMC, addressing safety and fall related exposures and controls across the industry CTRMC March 15, 2011 9
- 10. Worker Responsibilities Drivers Have proper dress for the job including PPE based on the tasks Understanding customer site specific rules and procedures Comply with customer site specific rules and procedures Conduct equipment pre trip and routine inspections Follow documented task expectations Communicate with company management/shippers/consignees Use fall arrest equipment when available and or required Comply with motor carrier task expectations for using ladders and working on tanks Report defective equipment Place defective equipment out of service Document inspections required as part of work tasks Meet essential job functional capacity requirements Wash Rack Workers Comply with task expectations for access and working on the top of tanks Use required fall protection when accessing tops of trailers Identify and communicate safety issues or concerns Be empowered not to commit any unsafe act regarding accessing the top of tanks Report unsafe acts to the proper management Use proper hand protection, work shoes/boots and other PPE per the job expectations Understand and comply with site work rules and task expectations Product Loaders Comply with task expectations for access and working on the top of tanks Use required fall protection when accessing tops of trailers Identify and communicate safety issues or concerns Be empowered not to commit any unsafe act regarding accessing the top of tanks Report unsafe acts to the proper management Use proper hand protection, work shoes/boots and other PPE per the job expectations Understand and comply with site work rules and task expectations CTRMC March 15, 2011 10
- 11. Product Un-loaders Comply with task expectations for access and working on the top of tanks Use required fall protection when accessing tops of trailers Identify and communicate safety issues or concerns Be empowered not to commit any unsafe act regarding accessing the top of tanks Report unsafe acts to the proper management Use proper hand protection, work shoes/boots and other PPE per the job expectations Understand and comply with site work rules and task expectations Maintenance Workers Comply with task expectations for access and working on the top of tanks Use required fall protection when accessing tops of trailers Identify and communicate safety issues or concerns Be empowered not to commit any unsafe act regarding accessing the top of tanks Report unsafe acts to the proper management Use proper hand protection, work shoes/boots and other PPE per the job expectations Understand and comply with site work rules and task expectations Inspectors Comply with task expectations for access and working on the top of tanks Use required fall protection when accessing tops of trailers Identify and communicate safety issues or concerns Be empowered not to commit any unsafe act regarding accessing the top of tanks Report unsafe acts to the proper management Use proper hand protection, work shoes/boots and other PPE per the job expectations Understand and comply with site work rules and task expectations Management Develop, implement, communicate and enforce work task expectations for tasks and operations under their authority. Document work task expectations and observations or measurements to verify compliance with work task expectations. Assure all workers performing work tasks are properly trained per federal, state and local regulations Conduct root cause analysis protocols for injuries and near misses Participate in industry activities and committees address safety and fall related exposures and controls across the industry CTRMC March 15, 2011 11
- 12. Intermodal Transloaders Comply with task expectations for access and working on the top of tanks Use required fall protection when accessing tops of trailers Identify and communicate safety issues or concerns Be empowered not to commit any unsafe act regarding accessing the top of tanks Report unsafe acts to the proper management Use proper hand protection, work shoes/boots and other PPE per the job expectations Understand and comply with site work rules and task expectations CTRMC March 15, 2011 12
- 13. Hierarchy of Controls As previously stated the document goal is to reduce risk to all stakeholders and not transfer the risk or exposure from one group to another. Stakeholder interaction may be required to assess risk and develop strategies to reduce tank top work task exposures. Each stakeholder should be involved in the assessment of risk to identify tasks performed on the top of tanks and develop solutions based on the hierarchy of controls listed below. Hierarchy of Control Situations Avoid tank top work tasks Typically requires specific tank equipment to match loading/unloading/sample collection needs. Railings fully surrounding work area More practical at larger locations with with access by stairs frequent loading/unloading. Requires compatibility with tank equipment. Moveable gantry style equipment with Provides more flexibility for larger stair access that fully surrounds work locations where a variety of equipment will area be loaded/unloaded/washed etc. Fully surrounding gantry system with Provides more flexibility for larger special equipment to fit specific tank locations where a variety of equipment will tops to provide protection based on be loaded/unloaded/washed etc. but has unique tank features/exposures multiple access points/ports that are used infrequently Cargo tanks with built in access Provides options for locations where systems and tank top walkway fall deliveries are infrequent and other options protection with lower risk are not available Fall arrest or restraint devices using For use where lower risk controls are not harness and other fall arrest system practical or available components secured to tested anchor points used by workers trained and supervised in use of the system Ladder access with no protection or Should be avoided other systems used by workers trained in work task methods CTRMC March 15, 2011 13
- 14. Appendix A. Tanker Falls Flow Chart CTRMC March 15, 2011 14
- 15. References and Resources ANSI Z359 Fall Protection Code http://webstore.ansi.org/RecordDetail.aspx?sku=ANSI%2fASSE+Z359+Fall+Protection +Code+Package Cargo Tank Risk Management Committee Materials include: North American Hierarchy Protocol for Protection of Workers on the Top of Tanks Minimum suggested standards for driver training to reduce the potential for falls while climbing rolling stock tank trailers http://www.cargotanksafety.org ITCO (International Tank Container Organization) Prevention of Falls from Tank Containers www.itco.be OSHA Fall Protection http://www.osha.gov/SLTC/fallprotection/index.html ACC/Responsible Care www.americanchemistry.com/s_responsiblecare/sec.asp?CID=1298&DID=4841 TTMA http://www.ttmanet.org/index.php/publications No part of this document may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying, recording, or by any information storage or retrieval system without written permission from the CTRMC. This document is advisory. We assume no responsibility for management or control of stakeholder safety activities or for implementation of recommended measures. We have not tried to identify all hazards. We do not warrant that requirements of any federal, state, or local law, regulation or ordinance have or have not been met and meeting those requirements is the responsibility of the individual stakeholders. CTRMC March 15, 2011 15