Safely first

Aug. 1, 2009
Storage terminal operators need a fall-protection plan

To the well-known list of the unalienable American rights of life, liberty and the pursuit of happiness you can add one more: a safe and healthful workplace for all employees. From tank truck drivers to loading rack operators, workers want, and are entitled to, appropriate protection from workplace hazards.

While the Occupational Safety and Health Administration (OSHA) and the Occupational Safety and Health Act of 1970 have done a tremendous job protecting the worker from workplace hazards, no system is perfect, and workplace accidents and incidents do continue to happen. One area that annually features a notable number of incidents is fall protection. In fact, according to OSHA's list of most frequently cited workplace violations, lack of — or inadequate — fall protection ranked third in 2006 and second in 2007.

On top of that, the Department of Labor lists falls as one of the leading causes of traumatic occupational death. In the Bureau of Labor's (BOL) National Census of Fatal Occupational Injuries (CFOI) in 2007, which was released in August 2008, a total of 5,488 fatal work injuries were reported in the United States in 2007. While this was a decrease of 6% from the 5,840 fatal work injuries recorded in 2006, the number of fatal falls rose to 835, a 39% increase from 1992 when the CFOI program was initiated and an overall series high. In addition, the number of fatal falls in 2007 accounted for nearly 15% of the number of fatal work injuries during the year.

According to the BOL, the increase in falls overall was driven primarily by an increase in the number of same-level falls, which were up 21% from 2006, and falls from non-moving vehicles, the reports of which increased 17% from the previous year. And overall, about one-fourth of all occupational fatalities in 2007 involved workers in transportation and materials-moving occupations, although the number of fatalities among these workers declined by 5% in 2007.

Without a doubt, these numbers are sobering, and they are made more so by the fact that when it comes to fall protection, the standards and regulations are open for interpretation. The Department of Labor says that any time a worker is at a height of four feet or more, the worker is at risk and needs to be protected. Regardless of distance, fall protection must always be provided when working over dangerous equipment and machinery.

However, OSHA's actual fall-protection requirements are somewhat nebulous: “a…site must maintain a ‘safe’ work environment.” With no exact definition offered for the word “safe,” this means that, potentially, one man's simple stubbed toe could be another's just cause for a multi-million-dollar lawsuit.

Terminal worries

Falling into the sweet spot in the debate over what constitutes employment that is “free from recognized hazards that are causing or are likely to cause death or serious physical harm” are the workers at the nation's terminal, tank-farm and bulk-plant facilities. These spend their days scrambling to the tops of railcars and tank trucks to unload bulk liquids — be they mainstream chemicals, petrochemicals, biofuels or niche chemicals — which must be shepherded into aboveground storage tanks that can range in capacity from 5,000 to 500,000 gallons, and stand as high as 10 stories.

To help ensure that employees at these facilities are kept safe and aware of the standards that govern fall protection, the Safe Tank Alliance, which is a partnership between OSHA, the National Fire Protection Association and the American Petroleum Institute, has created a brochure titled “Fall Prevention for Aboveground Storage Tanks.”

The brochure points out that proper use of equipment like guardrails, stair rails, travel-restraint systems, safety nets, arrest systems (harnesses), self-retracting lifelines/lanyards and ladder-safety devices have been designed to keep terminal workers from falling and, if they do, avoiding a hard landing.

Required training must define and explain the fall-protection system, how to recognize fall hazards, proper scaffold inspection, proper use of ladders and manlifts, manufacturer's recommendations on fall-protection personal-protective equipment and when there is a need for specially qualified personnel. Employees also must be taught to recognize fall hazards in and around tanks — things like holes in walking or working surfaces; poorly secured ladders; faulty scaffolds; untidy or congested work areas; obstructed walkways; improper use of equipment or procedures; slippery floors; and obstacles inside the tank.

The brochure also offers a comprehensive list of Do's and Don't's:


  • Look for hazards and ways to avoid them

  • Get enough light to see what you're doing

  • Choose and use proper procedures and equipment

  • Use walkways, especially on tank dikes

  • Keep walking and climbing pathways clear

  • Make sure a tank roof will support your weight before walking on it; reinforce roofs, if needed

  • Have reliable communication when working alone

  • Check sour tanks for H2S before climbing on top, and have respiratory protection available

  • Check scaffolds and their inspection tags

  • Use a helper to hold extension ladder when climbing to tie-off the ladder


  • Ignore a hazard if it can hurt someone

  • Go on a floating roof without required permits — it may be a confined space

  • Run or jump from elevators

  • Stand on the top two rungs of a ladder or allow two or more people on the same ladder

  • Carry tools while climbing

  • Use unknown scaffolds

  • Walk on wind girders without railings

  • Use safety belts, harnesses or climbing devices without training

  • Expect someone else to prevent a fall

Tools of the Trade

In many instances, common sense can be enough to prevent the most obvious fall incidents, but when terminal employees are required to walk along the tops of railcars or 40-foot-high storage tanks, there is obviously the need for some type of equipment that will either prevent or arrest a fall.

With this in mind, there are several types of equipment that have been designed specifically for use in terminal and bulk-plant applications:

Lifeline Cables: These pre-engineered, usually synthetic, cables are lightweight and have excellent resistance to weather and chemicals. These cables are hung between supports along a railway bed, or truck depot, allowing the worker to hook onto them and traverse the car or truck without fear of a fall to the ground. Recent technological advances have led to the creation of lifeline-support systems that have pass-through devices that allow workers to walk past intermediate supports without having to disconnect their lifeline.

Trolley Beam Fall Protection: In this application, an I-beam (used to capture the load requirement that the fall protection system puts on a structure) is suspended over the truck or railcar loading position and workers clamp onto it. The system can be sized for single or multiple trucks or railcars, can be retrofitted to existing structures and can be designed for one to four users at a time. If no other roof structure exists, vertical supports would still be required.

Safety Cages: A wide variety of safety cages for tank-car use have been created. In general, they are portable and come with a variety of mounting options. Their operation allows for the cage to adjust with the height of the gangway and allows them to be raised or lowered to the railcar

Permanent Platforms, with Gangways/Safety Cages: These permanent structures can be equipped with both single- and double-sided platforms that can be track-mounted on a tracking system that is virtually maintenance-free. The system is built with two tracking sections on each end with handrails in between. In a railcar application, tracking gangways may be used if the railcars vary in length or cannot be uncoupled.

Mobile Access Units (Trucks): These types of units, which are easily moved into place by an individual, are ideal for loading and unloading operations for tank trucks. They can adjust to the height of the vehicle and come in parallel or perpendicular configurations depending on the amount of space needed to complete the operation. The safety cage at the top of the unit protects workers from falls.

Mobile Access Units (Railcars): Able to be easily moved into place, these units feature a telescoping ladder that can be raised or lowered to conform to varying heights of railcars. A safety cage with a handrail height of, generally, 42 inches keeps the worker safe.

While preventing falls can, in many cases, be as simple as workers doing the things they were taught to do as children, many industries — including the liquid bulk terminal industry — present unique challenges in preventing falls. In addition to knowing the Do's and Don't's of fall protection, the best companies — with oversight from OSHA and other agencies — provide their employees with the equipment they need to best ensure that no catastrophic accidents do happen.

Tom Semiklose is Vice President for SafeRack, LLC, a company committed to providing stronger, safer and easier-to-handle truck and railcar loading-rack and fall-protection equipment. Semiklose can be reached at [email protected] or (866) 761-7225. Headquartered in Sumter, SC, SafeRack has more than 200 years of combined experience in offering high-quality equipment that has been customized for each customer's unique loading applications. For more information on Fall Protection, Safety Cage or Gangway products from SafeRack, LLC, Sumter, SC, please contact us at (866) 761-7225 or go to

About the Author

Tom Semiklose