Take it from Peter Van Dyne, technical director for Liberty Mutual Insurance and secretary of the Cargo Tank Risk Management Committee (CTRMC): Falls are the key.
“When you look historically at the trucking industry, falls are the biggest injury source we've had over time — falls from equipment, falls out of tractors, falls in the yard and even falls in the shower at truck stops,” he said. “Falls are where the money is. If you're looking at controlling your workers' compensation costs, you have to follow the money. One way or another, you have skin in the game with workers' compensation. The more you can attack where that money is going, the better off you're going to be and the more competitive you will be in the long run.”
Van Dyne addressed fall protection during the National Tank Truck Carriers Tank Truck Safety & Security CouncilandTank Cleaning & Environmental Council annual seminars, both of which were held in New Orleans, Louisiana, in early June.
CTRMC was formed by cargo tank industry leaders on March 17, 2010, to enhance the safety of “workers on the top of tanks,” and its members represent stakeholders such as motor carriers, consignees, cargo tank manufacturers, shippers, and wash-rack operators.
CTRMC estimates that more than 250,000 cargo tank motor vehicles are in use across North America, with the useful service life of this equipment approaching 30 years. Replacing tanks with equipment designed to eliminate the need to climb tankers is a long-term goal. However, due to the number of cargo tanks in use, and their life expectancy, CTRMC published “North American Hierarchy Protocol for Protection of Workers on the Top of Tanks,” a document that focuses on ways to reduce exposures with existing equipment and facilities.
Van Dyne said that eliminating the need to climb onto or work on the top of tanks is the preferred method of reducing exposure to falls, and should be addressed prior to considering other control measures outlined in the document. CTRMC's long-term objective is to eliminate the need for workers to perform tasks on tops of cargo tanks.
“When the steering committee got together, we could see there are certain exposures truckers have when working with tankers,” he said. “We didn't want people just trying to shift the risk: ‘We can prevent falls here by having this other company employee do that particular part of the task.’ Stakeholders may or may not have direct control over the employees, such as a driver picking up a load at a shipper or consignee. The goal of this document is overall exposure reduction, and not simply the transfer of the risk or activity from one stakeholder or impacted employee to another.
“So we wanted to look at a variety of things. Is the design of the equipment part of it? Sure. Does behavior play a large role in the injuries we see? Sure. Is there a better way or can we eliminate certain tasks? We wanted to take that into account.”
He said reducing the exposure to falls involves equipment design; maintenance/inspection; state-of-the art replacement ladders (when needed); loading and unloading facilities; equipment use protocols and procedures; training and policy/procedures; and policy/ procedure enforcement.
Van Dyne said the top 10 reasons for being on tank tops are: assuring security; checking equipment (cleanouts, manhole, and venting); extracting samples; loading or unloading product; assessing liquid content levels; initiating air unloading and vapor recovery; performing maintenance and routine inspections; washing the tank; removing snow; and managing heels.
He said that although there are certain things management is responsible for, personal responsibility is necessary at the worker level to promote working safely and not taking shortcuts.
“Yes, you want management to enforce policies, but you also want people to be concerned about their own safety,” he said. “We looked at hierarchy of control — everything from avoiding tank-top work to where there is absolutely no other way other than climbing the ladder. You want to make sure you have good equipment and the right footwear — things where we didn't want to rely on training. I think training is probably the weakest link. Just because someone knows what to do doesn't mean they're going to do it.”
If the work can't be performed at ground level without accessing the tank top, can workers be protected on platforms with fixed stairs and railings with protection at the openings? If not, conduct a risk assessment to identify work tasks and risks, then adopt a strategy for reducing exposure to falls:
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A fall-protection system to keep workers back from the edges, platform and tanker sides.
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Fall-prevention platforms with railings and moveable sections.
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Fall-arrest systems using engineered systems to stop falls once they occur.
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Systems that use a combination of fall-protection, fall-prevention, or fall-arrest.
After that, provide and document work-task performance expectations; evaluate performance and enforce task expectations; provide and document maintenance and inspections on equipment and related components.
“The more you can use your people and equipment and take the theories and turn them into company polices you can measure and enforce, the better off you can be,” he said. “It'd be like driving with a safe-following-distance policy, where 'Here it is, versus our company's safe-following-distance policy.
“Once we know that people understand how tasks should be done, have you enforced these policies? Have you gone out and seen whether people are doing them? If you go outside in your yards, there are certain tasks you can't see. I work with a line company where the office windows look right out on the fuel island. Each time I go out, I see that about half of the drivers are getting out facing away.
“They have about 15% of the costs related to getting in and out of the tractor. Well, if drivers are not doing it correctly right in front of you, the chances they are going to do it correctly once they leave the yard are slim. Focus on these areas. If you know where the money is going and focus on those activities and then start working and pushing on them, ‘Hey, this is important for us to stay in business’ … If you worked with other truckers over the years, you know the cost of workers' comp is one of the few costs you have that can vary more than 100% between truckers. There are very few costs you have that will vary by 100%.”
He said the updated document is available at http://www.cargotanksafety.org. ♦
