April 26, 2011

Training Proposed for Hazmat Cargo Tanks

Ensuring that employees engaged in hazmat loading and unloading of cargo tank motor vehicles (CTMVs) receive training sufficient to reduce the likelihood of accidents appears to be the main objective of a rule proposed by PHMSA.

In addition to establishing requirements for cargo tank carriers and facilities that engage in regulated loading or unloading, the proposal includes provisions for facilities that provide transfer equipment for CTMVs.

According to PHMSA, the proposal addresses safety concerns raised by the National Transportation Safety Board and the Chemical and Safety Hazard Investigation Board, as well as PHMSA’s internal review of hazmat incident data. PHMSA’s analysis suggests that human error is the greatest single primary cause of incidents during loading and unloading operations, accounting for 33 percent of serious incidents.

PHMSA further found that human error generally was a result of inattention to detail when performing a loading or unloading function.

Examples include failure to attend or monitor the operation, leaving valves in the wrong position, or improperly connecting hoses and other equipment. Overfilling packagings or receiving tanks accounted for 25 percent of incidents. Defective or deteriorating devices or components (e.g., valve failure, gasket leak) as the primary cause accounted for approximately 16 percent of serious incidents, and a variety of other causes (e.g., freezing temperatures, lading plugs in piping, lading/vessel incompatibility) accounted for the remainder.

The incident analysis further suggests to PHMSA that specific safety regulations targeting the loading and unloading of CTMVs used for highway transportation would address the majority of serious loading and unloading incidents.

Accordingly, PHMSA is proposing to require that cargo tank carriers and facilities engaging in loading or unloading operations:

• Assess the risks of loading and unloading operations and develop written operating procedures.
• Train hazmat employees in the relevant aspects of the operational procedures.
• Annually qualify hazmat employees who perform loading and unloading operations.

PHMSA is also proposing that facilities providing transfer equipment for cargo tank loading and unloading:

• 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.
• Ensure that the equipment meets the performance standards in 49 CFR Part 178 for specific cargo tanks.

PHMSA estimates the cost of implementing the proposal at $18.5 million over 20 years and the total monetized benefits at $18.3 million also over 20 years.

PHMSA’s proposed requirements for loading and unloading CTMVs was published in the March 11, 2011, FR.