It is clear from a recently released Chemical Safety Board (CSB) report concerning a major chemical release that the driver involved was not sufficiently trained in safe cargo tank motor vehicle (CTMV) unloading operations. Are your drivers adequately trained to prevent or respond to a chemical release?
According to the Pipeline and Hazardous Materials Safety Administration (PHMSA), human error is a major contributing factor for incidents occurring during loading and unloading operations, including, but not limited to:
- Failing to attend/monitor loading/unloading operations;
- Leaving a valve in the wrong position either before, during, or after loading/unloading operations;
- Improperly connecting transfer equipment;
- Overfilling cargo tanks or receiving tanks; and
- Using defective/deteriorated devices and equipment.
In its review of the 2016 chemical release at the MGPI Processing plant in Atchison, Kansas, where the driver of a tanker truck connected the hose for the truck’s chemical with an incompatible chemical line at the processing plant, the CSB concluded that the driver for Harcros Chemicals was not following his company’s CTMV unloading procedure in two critical ways.
First, he connected the discharge hose to the first fill line he saw unlocked and opened the valve and returned to the cab of the truck. According to company procedures, he was supposed to carefully check that the material being transferred was going into the right vessel. In this case, CSB suggests that the truck driver could have traced the fill line with the facility operator or requested confirmation of a correct connection before the operator left the unloading area.
Second, the driver was supposed to continuously monitor the transfer. The CSB concluded that he did not continuously monitor the transfer because he was in the cab of the truck facing away from the unloading area.
The CSB found that the driver was likely unfamiliar with these two steps in the CTMV unloading procedure. The Board examined Harcros’s training program and determined that it was not effectively communicating the importance of the two critical safety steps that went awry on the day of the incident.
To compound the issue, the driver did not trigger the emergency shutoff switch that was located in the front of the trailer and instead tried to close the valve at the back of the trailer. PHMSA regulations for driver training require, in part, that for the operation of cargo tanks or vehicles with portable tanks with a capacity of 1,000 gallons or more, training must include “operation of emergency control features of the cargo tank or portable tank.”
Basics of a Hazmat Training Program
PHMSA recommends that an evaluation of employees’ understanding of safe loading/unloading procedures be performed on an annual basis, at a minimum. More frequent and routine practice and evaluation of operating procedures should include observation and feedback by a knowledgeable supervisor on the employee’s performance of covered functions, i.e., those regulated under the hazardous materials regulations (HMR); practice sessions; or drills.
According to PHMSA, at a minimum, a hazardous materials (hazmat) training program should include provisions to:
- Identify employees and covered duties, i.e., employees subject to training because of performance of a covered function under the HMR;
- Observe and evaluate employees’ performance of duties;
- Provide feedback regarding performance of duties;
- Establish a performance improvement plan for employees failing to perform up to standard; and
- Initiate enhanced training if employees are no longer qualified to safely perform covered duties or if performance of duties contributed to an unintentional release of hazmat.