Annex 8. Access to tank and bulk tops, working at height

 1 Risk Assessment

Before accessing tank and bulk CTU tops, management of the packing and unpacking facilities and the transport companies should undertake a thorough risk assessment of the practices. Such assessments should cover:

1.1 Competence of operators

Operators should be fit for duty, having successfully completed all the training necessary to fulfil the legislative requirements and site requirements, in particular regarding the handling of dangerous goods.

1.2 Site Instructions

Site access requirements should be communicated to the hauliers and safety procedures communicated to the drivers upon arrival. Management should promote safety awareness and emphasize that it should be maintained, particularly during product handling. Management should ensure that loading/unloading operations are carried out under supervision.

1.3 Working at height

Safe conditions for working at heights should be provided, as discussed in section 3 of this annex.

1.4 Product Quality

The preferred option is product acceptance on the basis of a Certificate of Analysis. Taking samples from CTUs should be avoided. If the taking of samples is absolutely necessary, management should ensure that sampling is done by qualified site personnel or by appointed surveyors with adequate safety precautions taken.

1.5 Emergency preparedness

Necessary site safety equipment should be available at the loading and unloading locations, e.g.: fire extinguisher(s), eye wash, safety shower, first aid equipment, emergency escape routes, emergency stop, decontamination equipment, and absorbent materials.

1.6 Near miss and incident reporting

There should be a procedure to report all near misses, incidents, loading/discharge problems and unsafe situations or conditions, including follow-up. There should be a system in place to share information on important near misses, incidents or unsafe situations with all parties involved.

 2 CTU ladders

2.1 CTUs used for bulk transport will often require access to their tops, in order to gain access to the interiors, to open and close the loading hatches or to sample the cargo. These units usually have some built-in means of access, e.g. ladders or toe-holds, but these are generally for emergency purposes rather than regular use. As such, they may be restrictive with irregularly spaced steps and/or large gaps between ladder rungs.

2.2 Tank containers, swap tanks and road tankers will usually have ladders built into their rear frames, some of which may be readily apparent as ladders (see figure 8.3), while others appear to be climbing frames (see figures 8.1 and 8.2).

2.3 Ideally, inbuilt ladders should be constructed with two stiles and should have steps that are at least 300 mm wide with high friction surface and the steps uniformly spaced about 300 mm apart. The pictures above show good and less satisfactory versions.

2.4 The designs of tank containers, swap tanks and road tankers generally facilitate placement of feet while accessing their tops. Access to the tops of bulk CTUs is generally far less satisfactory, often only provided by a number of shaped bars attached to the doors (see figure 8.4). The example shows five shaped bars, the bottom and top steps quite narrow and the spacing varies from 480 mm to 640 mm. Operators attempting to climb onto and from the roof may find these steps difficult.

2.5 Where routine access to the top of a CTU is necessary, the CTU will bear a warning decal adjacent to the means of access. The decal provides warning of overhead hazards in general and power cables in particular (see figure 8.5). Operators, when deciding whether to access the top of the CTU, should make themselves aware of all potential hazards directly overhead and immediately adjacent to the CTU. This warning is particularly important for operations in rail transfer depots but may affect other handling operations.

2.6 As the process of climbing onto the top of a CTU entails risks of slipping and falling, a built-in ladder should only be used for emergency access. Operational access to tank container tops should be made using suitable mobile steps or from a gantry.

2.7 When a tank or dry bulk CTU is loaded onto a chassis, the bottom of the ladder can be as much as 1,600 mm, and the top of the CTU as much as 4.3 m off the ground. Furthermore on some designs of chassis, the CTU will be slightly inclined with the front end elevated which would mean that the ladder would be inclined backwards towards to the operator.

2.8 The steps/rungs are generally manufactured from steel or aluminium and can be slippery in the cold and wet. Operators can easily miss their step when climbing these ladders.

2.9 When transitioning from the ladder to the walkway on the CTU top, there are limited hand holds available for the operator to grip (see figure 8.6) making the manoeuvre hazardous. An operator climbing onto the top of the tank container shown in figure 8.7 will be presented with either the walkway securing bracket or the miss-stacking plate, neither of which are ideal handholds. Climbing off the top of the CTU can be more hazardous as the operator is attempting to locate rungs/steps which are not visible and in an awkward position.

 3 Working at height safety

3.1 Typical health and safety regulations provide that every employer ensure that work is not carried out at height where it is reasonably practicable to carry out the work safely otherwise than at height. Where work is carried out at height, every employer should take suitable and sufficient measures to prevent, so far as is reasonably practicable, any person falling a distance liable to cause personal injury.

3.2 The measures should include:

3.2.1 Ensuring that the work is carried out:

• From an existing place of work; or

• (In the case of obtaining access or egress) using an existing means, which complies with guidelines with those regulations, where it is reasonably practicable to carry it out safely and under appropriate ergonomic conditions; and

• Where it is not reasonably practicable for the work to be carried out in accordance with the previous paragraph, sufficient work equipment should be provided to prevent, so far as is reasonably practicable, a fall occurring.

3.2.2 Where the measures taken do not eliminate the risk of a fall occurring, every employer should, so far as it is reasonably practicable, provide sufficient work equipment to minimize:

• The distance and consequences; or

• Where it is not reasonably practicable to minimize the distance, the consequences, of a fall; and

• Without prejudice to the generality of section 3.2, provide such additional training and instruction or take other additional suitable and sufficient measures to prevent, so far as is reasonably practicable, any person falling a distance liable to cause personal injury.

3.3 The regulations can generally be interpreted to mean that wherever possible working at height should be avoided, but where that is not possible, then it should be made as safe as possible by providing facilities and equipment to minimize the risk of injury (see figure 8.8).

 4 Access and safety equipment

4.1 Where regular access to the top of CTUs is required, alternative access solutions should be considered. Some operators have provided more substantial access ladders attached to trailers as shown in figure 8.9. This type of ladder satisfies the step dimension recommendation and can be adjusted so that the lowest step is just off the ground. However there are no guard rails on the ladder or on the work platform so the operator may still be at risk of a fall. As an alternative, mobile steps similar to those shown in figure 8.10 can be used which can be positioned beside the CTU and from which the operator can safely step.

4.2 At facilities where regular access is required the CTU should be positioned next to a fixed access gantry (see figure 8.11). Once the CTU is positioned next to the gantry the operator can lower the counterbalanced handrail/barrier to provide additional safety while working on the CTU top.

4.3 If the CTU is mounted on a chassis, the operator should not attempt to access the top of the CTU unless the tractor unit has been disconnected or immobilized to prevent accidental movement of the CTU.

4.4 A fall arrest system may be the best item of personnel safety equipment that can be employed. Operators should wear an approved harness and attach themselves to the overhead cables. In figure 8.12 a number of "T" shaped stanchions are positioned about the area where an operator will work on the top of the container. The connecting overhead cables have counterbalanced arrest drums supported from them to which the operator will attach a harness.

4.5 The top of the CTU should not be overcrowded. The walkways are limited in size and strength. Furthermore with too many people on the top of the CTU moving about can be hazardous.