Good afternoon all,

I have a question I'm wondering if anyone could give some advice on. I work in an upper tier chemical site in a technical role, and have participated in a scheduled HAZOP review of one of our production plants. 

An issue has been highlighted in the HAZOP, with a task identified as high hazard/severity(fatality). Previously, it has been decided the task of opening and closing the top manway of a top fill tanker (where the filling head is positioned into), has a risk of the operator slipping and falling into the tanker. It was categorised as a risk 1and so could not be performed without safeguards. the safe guard that was decided upon, was the use of harness when opening/closing the top manway cover. 

This was proceduralised, added into the task risk assessment etc., however, a harness has never been actually used for the task. The operators filling the tankers have said its never been communicated to them and never been done. Although it is in the documentation, no one has questioned why they arent used. This is obviously very concerning and if the review of the hazard still comes to a conclusion the harness is required, it will have to be trained out and enforced immediately. 

However, my question is regarding the need for a harness for the task of opening the manway and if this is best practice or even standard practice across industries using top fill tankers? I have spoken to Stolt, one of our tanker suppliers , and they have never experienced nor heard of an incident of someone falling into the tanker via the top manway and also do not know of any guidance on use of harnesses for opening the manway.

WAH concerns are generally around falling off of the tankers... we have a purpose built gantry platform which is completely enclosed with handrails and so the risk of falling from height off the side of the tankers is sufficiently managed. 

Any thoughts would be greatly appreciated.

thanks 

Jade 

I used to work at an upper tier COMAH site where we had issues of working at height on tankers, to the extent that HSE were compelled to get involved.

This particular issue of falling into the tanker was identified in our risk assessments.  However we never proposed the use of a harness for this and I never saw that done or heard of it being done (and I talked to a lot of tanker drivers).  As far as I remember we controlled it through working practices rather than anything physical.  Things like the operator / driver adopting a kneeling position from which they cannot trip.

HSE do / did have some specific guidance about working on height on tankers.  As far as I remember it, this was focused on the risk of falling off the tanker, which as you have indicated is generally the main concern.