North American Hierarchy Protocol for Protection of Workers on the Top of Tanks
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,
- 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.
The top ten reasons workers ascend the top of transportation tanks were determined to be:
- Assuring security
- Checking equipment including – a. Cleanout caps; b. manholes; c. venting
- Extracting samples
- Loading or unloading product
- Assessing liquid content levels
- Initiating – a. air unloading; b. vapor recovery
- Performing maintenance and routine inspections
- Washing Tanks
- Removing snow
- Discharging heel