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Posted By BigL
Hi, appreciate this has been disgussed in various threads before, but i'm after some detailed advise if anyone can help.
We have a variety of tankers delivering and collecting products. we rarely get the same tanker twice as they're global. We also have a wide variety of loading unloading points for raw materials and finished products. They're chemicals and vary in terms of viscosity etc.
Recently i advised our purchasing to try and apply some pressure on suppliers to only supply bottom venting tankers, and ones with 2 independant hand rails, however bottom loading is not always possible in all cases, plus we have to perform certain tasks on top, all be it for a matter of seconds in some cases.
Basically i'm trying to draft a policy dictating that if a tanker isn't of a certain quality, then we dont accept it, but am struggling to know how hard to push.
Our MD is insistant that harnesses and fall arrest is the way forward, at least as a short term fix, but this is not ideal, not to mention a huge task in itself.
I'm pushing for task elimination, bottom venting and permenant access platforms etc, improved handrails and gantrys etc. We already have adjustable gantrys for height variances, insist on hand rails both sides and have good procedures for minimising time spent on top.
Can anyone help provide guidance on where we can get information on how hard we can push in dictating to tanker suppliers a desired standard, where we can get information on what standards companies providing tankers should be achieving, and basically guidance to try and ensure we're doing all we can to comply with the WAH regs.
Any advise guidance would be greatfully received as we're at a bit of a dead end at the mo, purchasing saying they can only ask for so much, we have to use them they're the cheapest, md wanting harnesses, and me, well, stuck in the middle.
Many thanks in advance.
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Posted By garyh
By bottom venting surely you mean bottom loading? I suggest that you talk to your company's Dangerous Goods Safety Advisor (if your company handles Dangerous Goods - and it sounds like you do - then under the UK Carriage regs you must have the services of one). The ADR agreement, which UK Carriage regs effectively adopts, defines what type of loading arrangements and venting are required for each material. In addition your MD doesn't appear to unedrstand about the hierarchy of control for working at heights.
I speak as someone who wrestled with these issues for years - it ain't easy, that's for sure. Designers of tankers just haven't (until recently) considered safe access - don't even get me started aboput isotanks!!
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Posted By BigL
Yes we use those as well, and yes we use a DGSA, but he's not the easiest person to get information out of.
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Posted By atm
Dont push and dont lose sleep over it make sure you have advised him in writing/email- its then all up to him as for the DGSA what is he getting paid for if he cant provide the advice?
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Posted By BigL
Long story, but basically for legal reasons, until we get our own person qualified Q3 this year.
already done the written thang, but keeps gettin thrown back "we need short term actions"....
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Posted By Merv Newman
I did know of a company (shell chemicals) that installed scaffolding (on wheels) access as a temporary measure. If that is ANY help at all.
Otherwise, get it into the contract that suppliers use tankers that have proper protection. And get the site guards authorised to refuse entry to any tanker that does not conform. Also, any chance of alternative suppliers who can conform ?
Merv
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Posted By BigL
Merv, you'd think so wouldn't you, trouble is our purchasing team keep responding with "well if you want to pay £1000 a load dearer we can use company B" and thats about where it stops, i know what price someone falling and a fatality / injury, i agree, but its very difficult, especially as most of the companies supplying raw materials sub let tankers, so they cant even guarantee what kind of tankers will be used. Appreciate we can ask them to guarantee this that or the other tanker, but thats a kind of longer term goal, we're going to write a policy that says by....date no tankers with single handrails, by....to tankers with top loading, by....date no tankers lol. I just want to know how hard we can push really, and if there are any short term measures we can impliment to cover ourselves. I read on another board somewhere about a company agreeing a 5 year plan with the HSE, maybe this would be worth considering, again anyone any thoughts ?
thanks
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Posted By Mr T
I manage a number of road tanker cleaning stations where we have tried lots of different systems, we finaly used a fall restaint system that fits all types or tankers from isotanks to Powder tanks, we also adapted it for our workshop WAH access and it has proved OPerator / driver freindly. It is interlocked so no one can gain access til the restaints are in place. It was manufacturede by Mainstream Engineering 01642 217200 (Graham Duffield).
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Posted By Merv Newman
BigL
Legally you can push as far as you want to go. I understand you have a number of off-loading positions and equiping them all would be expensive. So that will be a gradual process, depending on available budgets. Slow unless you actually have an accident. Then things usually happen fast especially if there will be a prosecution.
The fall arrest idea is good and not too expensive to implement. But still gradual and maybe too slow.
Best advice I can offer tonight is to really have a go at your purchasing people and ask them to get some really competitive quotes from your suppliers. Just for a laugh, you might even end up with cheaper quotes for safer deliveries. If purchasing know how to negotiate. usually they just know how to squeeze. I speak as a supplier (of services). And some purchasers just accept the offer price without question. I do love those people. Dearly.
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Posted By steve e ashton BigL: In terms of "how far can you push"? - I assume you've seen the 'best practice' guidance from HSE: http://www.hse.gov.uk/fa.../casestudies/tankers.htmand from the RHA site.. http://www.rha.net/publi...oups/tankers/falls.shtmlThis from the RHA site: "Eliminate the need to access the tops of tankers e.g. by bottom loading and discharge facilities, and remotely operated lids on tankers. Where access to the top of tankers cannot be eliminated, ensure that fixed gantries are provided at loading and discharge facilities that incorporate secure fencing on all sides of the high level working position from which a person could fall. Where fixed gantry loading/unloading is not reasonably practicable and Tank Top access cannot be eliminated, ensure that secure fencing is provided to all sides of the walkway of the road tanker." This document purports to be an 'agreement' between RHA and HSE around 5 years ago... If your carriers are not able / willing to comply with their own industry guidance then you have a 'supplier' (carrier) who is failing to demonstrate competence (which must include consideration of adequate levels of provision / resource for H&S). Your procurement team 'should' have procedures in place to deal with such circumstances. If not - then it may up you to advise them. My own advice - tell your MD that failure to appoint 'competent contractors' and (worse) knowingly accepting 'incompetent' ones is 'consent and connivance'. Weed 'em out or accept the consequences. Steve
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Posted By w.j. jones
bigL
I use to load these things for years. if you have the services of a good engineer you develop a type of Teagle opening. basically it is a framed handrail fitted to steps, when the steps drop onto the catwalk near the top pots, the handrail then provides the fall protection under the heirarchy for WAH. it is fairly easy to design but does need space above the tanker, also need to consider the position of loading arms etc. hopes this moves you forward.
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Posted By Mr T
Just to add a question regarding the loading of tanks. What do people do in respect of tank inspection prior to loading, ie if you load a tank that has not been cleaned correctly there may be a chemical re-action, this may be the hauliers responsibility but the incident would be on your site. We have adopted the European Cleaning Certificate (ECD) as this gives some creditaion to the clean and is recognised as the european standard by CEFIC (www.cefic.be/)& is traceable back to the originator. The coding also alows storage facility,s to introgate foreign Cleaning certificates
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Posted By BigL
Guys, thanks for all your comments, have printed them off fo follow up.
Very much appreciated though.
Rgds
BL
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