by William C. Schillaci
Over the past 10 years, the annual rate of accidents associated with the transfer of hazardous liquids and gases to and from tanker trucks and railcars has remained basically unchanged. While many of these accidents were spills or releases that were quickly controlled, others involved catastrophic explosions, fires, and voluminous releases that caused death, injury, extensive damage, and large-scale evacuations of the public.
These statistics have persuaded PHMSA to review the adequacy of its regulations applicable to loading and unloading bulk hazardous materials. PHMSA has also been comparing its regulations with the various "consensus" standards on bulk loading and unloading operations issued by nongovernment organizations; reviewing how its standards are supplemented by the standards of other federal agencies that oversee the handling of hazmats; and convening forums in which a wide range of government agencies, industry and employee organizations, and public advocacy and environmental groups have been asked to discuss risks and risk-management strategies associated with bulk loading and unloading.
Additional dialogs have been ongoing between PHMSA, the National Transportation Safety Board (NTSB), and the Chemical and Safety Hazard Investigation Board (CSB). Both bodies have investigated accidents that occurred in conjunction with bulk loadings and unloadings. NTSB and CSB followed their investigations with recommendations to PHMSA on ways in which safety can be improved.
In response to these developments, PHMSA is considering expanding regulations currently governing the loading and unloading of bulk hazmats. But given that rulemaking may take years to come to fruition, PHMSA has now issued a set of recommended practices that, according to PHMSA, would apply to loading and unloading operations involving hazmats in "many different types of packagings and a number of different operational and modal contexts."
PHMSA is now requesting comments on its recommendations, which, PHMSA emphasizes, are intended to supplement, not replace, PHMSA's current regulations. The recommendations are provided below.
Loading and Unloading Safety Analysis
A shipper, carrier, or facility operator should conduct a thorough, orderly, systematic safety analysis to identify, evaluate, and control 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.
Loading and 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. The written guide should be clear, concise, and appropriate to the level of training and knowledge of employees. Items addressed in the written guide should include pre-loading/pre-unloading procedures, loading and unloading procedures, and post-loading/post-unloading procedures.
- Pre-loading/pre-unloading procedures should include:
- 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.
- Securing the transport unit against movement.
- Grounding and bonding the transport unit, as warranted.
- 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.
- Identification and verification of piping path, equipment lineups and operational sequencing, and procedures for connecting piping, hoses, or other transfer connections.
- Identification and verification that the materials being loaded or unloaded are 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.
- Loading and unloading procedures should include:
Post-loading/post-unloading procedures should include:
- Measures for initiating and controlling the lading flow. For example, if the material is to be heated before 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.
- 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 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 overpressurization or an uncontrolled exothermic reaction.
- Measures for monitoring filling limits and ensuring that the quantity to be transferred is appropriate for the receiving vessel.
- 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.
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.
- Measures for evacuation of the transfer system and depressurization of the containment vessel, as warranted.
- Measures for disconnecting the transfer system.
- Inspection and securement of transport unit fittings and closures.
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 loading or unloading operations 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:
- Instrumentation to monitor for leaks and releases.
- Equipment to isolate leaks and releases and to effect other appropriate emergency shutdown measures, remotely if necessary.
- Training in the use of emergency response equipment.
- Procedures for incident response.
- Procedures for use of emergency shut-down systems and assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.
- Procedures for emergency communication and spill reporting.
- Procedures for safe start-up after an emergency shutdown.
- Procedures and schedules for conducting drills and exercises necessary to demonstrate the efficacy of the plan and ensure a timely and efficient emergency response.
- 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.
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:
- Overview of the loading and unloading process, specifically the portions of the process for which the employee is responsible,
- Safety systems and their functions,
- Emergency operations and procedures, including shutdown procedures,
- Additional safe work practices, and
- Recurrent training as necessary to address changes to procedures or personnel responsibilities.
In addition to comments on the recommendations, PHMSA is requesting feedback on related issues, including the adequacy of PHMSA's current regulations, how those regulations compare to national consensus standards, the potential cost of implementing the recommendations, and other safety issues that PHMSA has not included in its data analysis.
PHMSA is requesting that comments be submitted by February 8, 2008.
PHMSA's proposed recommended practices for bulk loading and unloading of hazmats in transportation are available here.
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