Protection against falls

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 worker’s  compensation costs, you have to follow the money. One way or another, you have  skin in the game with worker’s 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.”

      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  over 250,000 cargo tank motor vehicles are in use across North America, with  the useful service life of this equipment approaching 30 years. Replacing  equipment with designs to eliminate the need to climb tankers is a long-term  goal, but due to the number of cargo tanks in use, and their life expectancy,  CTRMC has released a document, “North American Hierarchy Protocol for  Protection of Workers on the Top of Tanks,” that focuses on reducing 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; use of the equipment and protocols for 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 discharging heel.

  He said  that although there are certain things management is responsible for, personal  responsibility is necessary at the worker level to do what they are asked to  do—and not take 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 it  be performed from 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:

  • A  fall-protection system to keep workers back from the edges, platform and tanker  sides.

  •  Fall-prevention platforms with railings and moveable sections.

  •  Fall-arrest systems using engineered systems to stop falls once they occur.

  •  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, 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 worker’s 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.