Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
saqibmd  
#1 Posted : 28 November 2024 15:49:41(UTC)
Rank: New forum user
saqibmd

Dear Experts, 

I need your opinion around the fall protection requirements when connecting and disconnecting hoses from a bottom discharge ISO tanks on the skelly. (Please note this is not related to getting onto the top of the tank) 

The drivers of these tankers have to get at the back of the cab to connect the air line and other connections whilst the operators have to get on back of the tanker skelly (few feet above the ground in both cases) to connect the hoses. Is it okay to get on and off to do this and this we what I see commonly across the industry.

I am after the practices around doing these activites. Is there a HSE requirement that mandates the fall protection for these activites? According to OSHA, work at hight is considered to be a work that is 1.2m high from the lowest level, however, in UK, any work is essentially WAH. So why dont we see a fall protection on these as there is a potential fall or the sides and also backwards. 

Container on Trailer

ISO tank skelly | SDC Trailers

Edited by user 28 November 2024 15:52:55(UTC)  | Reason: Not specified

Kate  
#2 Posted : 28 November 2024 17:34:02(UTC)
Rank: Super forum user
Kate

It's a good question.  The reason fall protection isn't usually provided in this case is that it's quite difficult to do - not that there isn't a risk, or that you shouldn't try to do it.  (Note - I do not mean fall arrest systems, as they don't work at such a low height.  I mean some kind of barrier to prevent a fall.)

Some years ago the HSE ran a campaign on falls from vehicles and published a lot of materials on the topic including some detailed case studies and guidance.  This was mainly but not exclusively about falling from the tops of vehicles, and they did include some materials about falling from the lower parts of vehicles.  This would have been in around 2008.

I see on their current guidance page on the topic of falls from vehicles (which has been substantially dumbed down since that campaign) there is a link to an archive. It looks like this goes to the original campaign materials and might have something relevant for you.

Topic link:

https://www.hse.gov.uk/workplacetransport/information/falls.htm

Archive link:

https://webarchive.nationalarchives.gov.uk/ukgwa/20200806161500/https://www.hse.gov.uk/fallsfromvehicles/index.htm

thanks 3 users thanked Kate for this useful post.
Roundtuit on 28/11/2024(UTC), peter gotch on 29/11/2024(UTC), saqibmd on 04/12/2024(UTC)
Roundtuit  
#3 Posted : 28 November 2024 19:38:53(UTC)
Rank: Super forum user
Roundtuit

Thee question of cab connections applies to a driver connecting to any form of trailer so not only ISO tanks.

Invariably it is such a short duration task that applying fall protection would be a disproportionate control.

Regarding your operator question the blue painted image actually shows a step platform and grab handles integrated in to the trailer design

thanks 2 users thanked Roundtuit for this useful post.
saqibmd on 04/12/2024(UTC), saqibmd on 04/12/2024(UTC)
Roundtuit  
#4 Posted : 28 November 2024 19:38:53(UTC)
Rank: Super forum user
Roundtuit

Thee question of cab connections applies to a driver connecting to any form of trailer so not only ISO tanks.

Invariably it is such a short duration task that applying fall protection would be a disproportionate control.

Regarding your operator question the blue painted image actually shows a step platform and grab handles integrated in to the trailer design

thanks 2 users thanked Roundtuit for this useful post.
saqibmd on 04/12/2024(UTC), saqibmd on 04/12/2024(UTC)
peter gotch  
#5 Posted : 29 November 2024 13:43:05(UTC)
Rank: Super forum user
peter gotch

Hi saquibmd

Like OSHA, the UK used to have an arbitrary height from which someone might fall before legislation kicked in. That was generally set at 6 feet 6 inches, amended to metricate to 2 metres. The exception was any kind of ladder there this threshold didn't apply.

However, as you indicate the WAH Regs did away with any threshold, BUT requires doing what is reasonably practicable. 

As Roundtuit indicates the short duration of the tasks to be performed is one of the factors to be considered when working out what might be reasonably practicable or NOT.

However, there are many other factors to take into account. As example, if you have the same operation being perfomed in the same place on lots of similar trailers, then perhaps a working platform would be reasonably practicable when it wouldn't be for a one off operation.

thanks 1 user thanked peter gotch for this useful post.
saqibmd on 04/12/2024(UTC)
stevedm  
#6 Posted : 30 November 2024 10:57:11(UTC)
Rank: Super forum user
stevedm

...speaking from a human factors points of view you may need to be cautious here as introducing something could make the task more complicated than it is and result in more incidents not less...just something to bear in mind... staff will always find the best and shortest way of doing something..  ;)

thanks 1 user thanked stevedm for this useful post.
saqibmd on 04/12/2024(UTC)
Acorns  
#7 Posted : 01 December 2024 21:53:24(UTC)
Rank: Super forum user
Acorns

From a fleet risk perspective, Air lines- in some cases you can keep driver on the ground, typically with close-coupled trailers where they have a sliding coupling to both unit & trailer with the driver in/coupling by standing at the side of the unit, a short duration event, fitting restraints in the ‘confined, space is not reasonably practicable, a safe catwalk with steps along with training is the route most take.
Can’t quite see why the driver needs to climb on the trailer for discharge whether it’s ISO or not, looking at your photo example, why is the skelly still extended or why is the container so far forward?

Edited by user 01 December 2024 21:57:13(UTC)  | Reason: Not specified

thanks 1 user thanked Acorns for this useful post.
saqibmd on 04/12/2024(UTC)
saqibmd  
#8 Posted : 04 December 2024 18:34:33(UTC)
Rank: New forum user
saqibmd

Originally Posted by: Roundtuit Go to Quoted Post

Thee question of cab connections applies to a driver connecting to any form of trailer so not only ISO tanks.

Invariably it is such a short duration task that applying fall protection would be a disproportionate control.

Regarding your operator question the blue painted image actually shows a step platform and grab handles integrated in to the trailer design


The operator has to stay onto the trailer for some time to connect hose to the bottom discharge and cannot hold the handrail during this time. I have taken these pictures from the internet. The ones that are usually avaiable on the market have worse design. 

Users browsing this topic
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.