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dbrewer  
#1 Posted : 09 September 2019 11:23:27(UTC)
Rank: New forum user
dbrewer

Hi All,

I'm managing HSE on a site where we have 6 weekly tanker deliveries of chemical by an external contractor, where the driver needs to access the top of the tank to open a valve (offtake is from ground level).  There is a fixed ladder at the back of the tanker and a moveable handrail at the top, but I have concerns as there is a point at the top where the driver has reached the top of the ladder and has no further fall protection until they have pulled the handrail up.  The RA provided by the haulier is pretty abysmal, putting the control measures as relying either on the handrail, or on the sites building in access gantries.

I've found what look to be voluntary codes from chemical industry groups, and advice from HSE, but nothing legislative specifically to this task apart from WAH regs.  Can anyone give any advice please?

O'Donnell54548  
#2 Posted : 09 September 2019 11:33:26(UTC)
Rank: Super forum user
O'Donnell54548

Originally Posted by: dbrewer Go to Quoted Post

Hi All,

I'm managing HSE on a site where we have 6 weekly tanker deliveries of chemical by an external contractor, where the driver needs to access the top of the tank to open a valve (offtake is from ground level).  There is a fixed ladder at the back of the tanker and a moveable handrail at the top, but I have concerns as there is a point at the top where the driver has reached the top of the ladder and has no further fall protection until they have pulled the handrail up.  The RA provided by the haulier is pretty abysmal, putting the control measures as relying either on the handrail, or on the sites building in access gantries.

I've found what look to be voluntary codes from chemical industry groups, and advice from HSE, but nothing legislative specifically to this task apart from WAH regs.  Can anyone give any advice please?

What does the contractor's RA calculate the likelihood of a fall to be? Does their RA calculate that the existing controls are adequate based upon the likelihood? Seems a little presumpuous to claim their RA is abysmal when you cannot identfy what else they could do.  

dbrewer  
#3 Posted : 09 September 2019 12:50:17(UTC)
Rank: New forum user
dbrewer

The likelihood isn't given, just states the risks as falls from tank ladders or top of the tank and that serious injuries could occur from falling. After putting the control measures of mobile handrails, instruction on climbing, use of PPE, assessment of weather conditions and inspection of ladders, the risk is still stated as high, which in my reasoning means they do not feel these control measures are adequate, hence the abysmal.

My thinking would be for the haulier to add some sort of fall and arrest or manway type system to the tanker, but I'm not an expert on tankers, which is why I asked for the advice.  I'd like to be able to go back to them with a suggestion on how to mitigate the risk as the driver is transferring onto the top of the tanker.

stevedm  
#4 Posted : 09 September 2019 13:19:02(UTC)
Rank: Super forum user
stevedm

I had a simialr issues a few years back...this HSL document helped me at the time...

http://www.hse.gov.uk/research/hsl_pdf/2005/hsl0504.pdf

thanks 1 user thanked stevedm for this useful post.
dbrewer on 09/09/2019(UTC)
Roundtuit  
#5 Posted : 09 September 2019 13:45:26(UTC)
Rank: Super forum user
Roundtuit

The risk will be high in reflection of the potential severity - falling from the top of the vehicle on to concrete or tarmac can potentially be fatal, and if not would likely see a fracture (or two) and an over seven day injury.

The likelihood however will be low as it is an infrequent activity.

My question to the supplier would be why the valve cannot be actuated from ground level as the vehicle will have electricity or compressed air. Eliminating the need to access tanker tops is identified as the first control in the Chemical Industries Association guidance.

The second control is to provide access gantries typical of the tank farms where the tankers are filled - financially probably quite hard to justify for your eight deliveries a year.

The third is fixed ladders and collapsible hand rails (as currently being provided).

The fourth is moveable ladders.

Finally we get to fall arrest systems which is where your thought process has leapt - PPE must always be the last resort.

thanks 2 users thanked Roundtuit for this useful post.
Dave5705 on 15/09/2019(UTC), Dave5705 on 15/09/2019(UTC)
Roundtuit  
#6 Posted : 09 September 2019 13:45:26(UTC)
Rank: Super forum user
Roundtuit

The risk will be high in reflection of the potential severity - falling from the top of the vehicle on to concrete or tarmac can potentially be fatal, and if not would likely see a fracture (or two) and an over seven day injury.

The likelihood however will be low as it is an infrequent activity.

My question to the supplier would be why the valve cannot be actuated from ground level as the vehicle will have electricity or compressed air. Eliminating the need to access tanker tops is identified as the first control in the Chemical Industries Association guidance.

The second control is to provide access gantries typical of the tank farms where the tankers are filled - financially probably quite hard to justify for your eight deliveries a year.

The third is fixed ladders and collapsible hand rails (as currently being provided).

The fourth is moveable ladders.

Finally we get to fall arrest systems which is where your thought process has leapt - PPE must always be the last resort.

thanks 2 users thanked Roundtuit for this useful post.
Dave5705 on 15/09/2019(UTC), Dave5705 on 15/09/2019(UTC)
dbrewer  
#7 Posted : 09 September 2019 15:02:02(UTC)
Rank: New forum user
dbrewer

I agree PPE must be the last resort, and I would look at it in addition to the fixed ladder and handrail as a way of covering the transfer onto the top of the tanker.  The possibility of being able to open the valve from the ground would be the best option, now I know that could be a possibility, however we're due a delivery in the next few weeks, so I'm looking at both short and long term options I guess.

Thanks everyone

Holliday42333  
#8 Posted : 09 September 2019 15:26:32(UTC)
Rank: Super forum user
Holliday42333

Originally Posted by: dbrewer Go to Quoted Post

My thinking would be for the haulier to add some sort of fall and arrest or manway type system to the tanker, but I'm not an expert on tankers, which is why I asked for the advice.  I'd like to be able to go back to them with a suggestion on how to mitigate the risk as the driver is transferring onto the top of the tanker.

Just before you think further about fall arrest, consider how they would get down should they fall and be arrested.  At best they would be uninjured and have to try to scramble back up the tanker barrel at worst they are injured and someone has to try to get them down in a satisfactory time period.  Both scenarios are unlikely to be robust and succesful.  Fall restraint is unlikely to be effective as it would be likely be too restrictive to traverse the tanker and access any controls/lids etc.

Double handrails are the only feasable tanker mounted solution in my experience.  The more pregressive companies have these as standard on their fleets.  Perhaps you can negotiate a different haulier with better controls.  You never know it may even work out cost negligable.

stevedm  
#9 Posted : 12 September 2019 09:01:11(UTC)
Rank: Super forum user
stevedm

Was digging around in some old files and came across a 2004 HSE RR 276 Safe Site Driver Perceptions...might help you to review it as part of implementation of your control measures.. :)

Kate  
#10 Posted : 13 September 2019 14:36:14(UTC)
Rank: Super forum user
Kate

I've seen many chemical tankers with handrails fitted for working on top, and usually they could be raised from the ground without having to climb up first.  The one you describe sounds like bad design and perhaps it can be upgraded.

Another option is to invest in a gantry system on your site with a guard rail that drops over the tanker.  It doesn't sound as if you have enough deliveries to be able to justify this.

I can't see a reliable PPE solution for this.  The tanker probably isn't high enough that a fall system arrest would have time to bring a fall to a stop before hitting the ground.

So pretty much what Roundtuit said!

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