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PHMSA wants comments on hazmat loading/unloading RPs

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is asking for comments on proposed recommended practices for loading and unloading operations involving hazardous materials, according to information published in the Federal Register January 4.

PHMSA plans to consider strategies for enhancing the safety of bulk loading and unloading operations, including whether additional regulatory requirements may be necessary. The agency also is seeking comments on whether there are existing gaps and/or overlaps in regulations promulgated by PHMSA, the Occupational Safety and Health Administration, Environmental Protection Agency, and the US Coast Guard that adversely affect the safety of these operations, and how any identified gaps and/or overlaps in federal regulations should be addressed. Comments should be submitted by February 8, 2008.

PHMSA has been conducting studies on the subject, and reports in the notice for comments that hazardous materials transportation incidents occurring over the past decade indicates that roughly one-quarter to one-half of all serious hazardous materials incidents may be associated with loading and unloading operations involving bulk packagings, such as cargo tank motor vehicles and rail tank cars. In addition, the National Transportation Safety Board (NTSB) and the Chemical and Safety Hazard Investigation Board (CSB) have investigated a number of accidents associated with loading and unloading operations.

The proposed recommended practices for loading and unloading bulk quantities of hazardous materials are listed below.

Loading/Unloading Safety Analysis

A shipper, carrier, or facility operator should conduct a thorough, orderly, systematic analysis to identify, evaluate and control the hazards associated with specific loading and unloading operations. The analysis should be appropriate to the complexity of the process and the materials involved in the operation. For example, the analysis should consider the hazards of the material to be loaded or unloaded, including any temperature or pressure controls necessary to ensure safe handling of the material, and conditions that could affect the safety of the process, such as access control, lighting, ignition sources, and physical obstructions. The analysis should also assess current procedures utilized to ensure the safety of loading and unloading operations and identify any areas where those procedures could be improved.

Loading/Unloading Operational Procedures

Based on the safety analysis, the shipper, carrier, or facility operator should develop a step-by-step guide to loading and unloading that is clear, concise, and appropriate to the level of training and knowledge of its employees. The written guide should address pre-loading/pre-unloading procedures, loading/unloading procedures, and post-loading/post-unloading procedures.

Pre-loading/Pre-unloading procedures should include:

  • Inspection of the transport unit and transfer area. For example, shippers should ensure that a DOT specification packaging is marked to indicate that it has been designed, manufactured and maintained (including periodic inspection and testing) in accordance with specification requirements.
  • Securing the transport unit against movement.
  • Grounding and bonding of the transport unit, as warranted.
  • Inspection of transfer equipment and connections, including hoses and valves, to ensure that they are free of defects, leaks, or other problems that could result in an unsafe condition.
  • Identification and verification of piping path, equipment lineups and operational sequencing and procedures for connecting piping, hoses, or other transfer connections.
  • Identification and verification that the materials that are being loaded or unloaded are being transferred into the appropriate packagings, temporary storage facilities, or production containment vessels and that the compatibility of the material to be transferred is appropriate, authorized and consistent with applicable procedures.

Loading/Unloading procedures should include:

  • Measures for initiating and controlling the lading flow. For example, if the material is to be heated prior to its transfer, the facility operator should analyze a sample of the material to ascertain the heat input to be applied, if warranted. The maximum heat input to be applied and the rate at which the heat input will be applied must not result in pressurization to a level that exceeds the packaging's test pressure.
  • Measures for monitoring the temperature of the lading and pressure of the containment vessel (for example, cargo tank or rail tank car) and receiving vessel (for example, storage tank). For example, for loading or unloading operations involving heating of the material to be transferred, during the heating process, the facility operator should monitor the heat input applied to the containment vessel and the pressure inside the containment vessel to ensure that the heating process does not result in over-pressurization or an uncontrolled exothermic reaction.
  • Measures for monitoring filling limits and ensuring that the quantity to be transferred is appropriate for the receiving vessel.
  • Measures for terminating lading flow. For example, personnel responsible for monitoring a loading or unloading process should be familiar with shut-off equipment and procedures, and should be trained to take necessary actions to stop the lading flow as efficiently as possible.

Post-loading/Post-unloading procedures should include:

  • Measures for evacuation of the transfer system and depressurization of the containment vessel, as warranted.
  • Measures for disconnecting the transfer system.
  • Inspection and securement of transport unit fittings and closures.

Review and Revision of Procedures: The operating procedures should be reviewed as often as necessary to ensure that they reflect current operating practices, materials, technology, personnel responsibilities, and equipment. To guard against outdated or inaccurate operating procedures, the hazmat employer should consider revalidating the operating procedures annually.

Emergency Management

Appropriate emergency procedures should be identified and implemented, including identification of emergency response equipment and individuals authorized in its use; incident response procedures and clearly identified personnel responsibilities; personnel protection guidance and use of emergency shut-down systems; and, emergency communication and spill reporting. Emergency instrumentation and equipment appropriate to the loading or unloading operation should be identified, available, and in working order. Emergency procedures should be clear, concise, and available to workers. Emergency training, including the need for drills, should also be provided. Loading and unloading facilities may want to consider:

  • Instrumentation to monitor for leaks and releases.
  • Equipment to isolate leaks and releases and to take other appropriate emergency shutdown measures, remotely if necessary.
  • Training in the use of emergency response equipment.
  • Procedures for incident response.
  • Procedures for use of emergency shut-down systems and the assignment of shut down responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.
  • Procedures for emergency communication and spill reporting.
  • Procedures of safe startup after an emergency shut down.
  • Procedures and schedules for conducting drills and exercises necessary to demonstrate the efficacy of the plan, and to ensure a timely and efficient emergency response.
  • Emergency procedures should be reviewed and updated as often as necessary to ensure that they reflect current operating practices, materials, technology, personnel responsibilities, and emergency response information.

Maintenance and Testing of Equipment

Loading and unloading equipment and systems need to be properly maintained and tested. Shippers and carriers should develop and implement a periodic maintenance schedule to prevent deterioration of equipment and conduct periodic operational tests to ensure that the equipment functions as intended. Equipment and system repairs should be completed promptly.


Personnel involved in loading and unloading and emergency response operations need to know and understand their specific responsibilities during loading and unloading operations, including attendance or monitoring responsibilities. Consider training in the following areas:

Overview of the loading/unloading process and, specifically, the portions of the process for which the employee is responsible.

  • Safety systems and their functions.
  • Emergency operations and procedures, including shutdown procedures.
  • Additional safe work practices.
  • Recurrent training as necessary to address changes to the procedures or personnel responsibilities.

The proposal can be seen in the Federal Register online.

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