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?

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.

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.

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

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.. :)