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Lessons Learned:
Preventing Cross-Drops In The Bulk Chemical Transport Industry

Delivery errors are serious service failures, whether an overfill of a home heating oil tank, loading gasoline into the kerosene tank at a local service station, or one of these industrial-scale incidents.

Cross-Drop #1
On June 4, 1999, a carrier with a load of sodium hydrosulfide arrived at a Whitehall, MI leather tannery. The shift supervisor directed the driver to the ferrous sulfate transfer area -- the only area he’d ever seen used on third shift. The supervisor signed the shipping documents without reading them and left the driver to unload his product. The driver unloaded the sodium hydrosulfate into the through-the-wall connection that was clearly labeled “ferrous sulfate.” The result was a release of poisonous hydrogen sulfide gas. After regaining consciousness, a tannery employee evacuated the building and called 911. The driver was found dead approximately 230 feet from the transfer area.

Cross-Drop #2
On November 19, 1998 at Ford Motor Company’s Louisville, KY plant, a driver arrived with CHEMFOS 700, a solution of nickel nitrate and phosphoric acid. A pipefitter directed the driver to a chemical transfer area, which had an access panel with six identical connections. While the driver connected the hose to the tanker, the pipefitter connected the other end of the hose to a connection marked CHEMFOS LIQ.ADD (Ford’s designation for sodium nitrate solution). The pipefitter signed the shipping papers and left the area. The driver connected a compressed air line to the tanker, began to transfer the material and noticed an orange cloud (nitric oxide and nitrogen dioxide). The driver closed the internal valve on the tanker. Approximately 2,400 people were evacuated from the plant and neighboring facilities. Three police officers, three Ford employees, and the truck driver were treated for injuries.

Incidents like the above occur throughout the country and result in releases or loss of product. To minimize the potential for mis-delivered products, environmental contamination, impact to surrounding communities, worker injury, and /or death, both the carrier and the receiving facility must use proper loading and unloading procedures. Clearly defining each person’s roles and responsibilities helps to ensure a smooth transfer process.

Practice The Loading/Unloading Top 10

  1. Many bills of lading include a statement that must be signed by a facility representative. Make sure your shipping papers include a statement, and remind drivers to ask the question in addition to telling the consignee “sign here.” (Both cross-drops #1 and 2 above had these signed documents.)
  2. Know your customers’ facilities. Ideally, you should have diagrams of delivery sites, including designations of tank storage, and the receiving site would have a matching diagram. At the least, drivers should report unusual delivery conditions so dispatch can warn prior to the next delivery.
  3. Facilities must make the dispatching terminal and individual drivers aware of changes, such as construction or storage location. Drivers may have a comfort level at a facility where they have delivered the same product to the same tank for years. Label with hazard classes at the tanks and at the fill inlet. Are your signs current and readily visible?
  4. Tags marked with indelible ink provide another check for drivers to verify the contents of a tank prior to unloading. In multiple compartment tankers, this is very important as drivers may have filled a tank the night before and may incorrectly remember the order in which the tanks were filled. Also tag tanks with the identity of any residual contents.
  5. Use DOT names on all labels. Even if the facility refers to a chemical by a common name or an industry-specific name, any tank, piping, fill port or other markings, which a delivery driver may use as a reference, should include the proper shipping name. This provides for consistency during all phases of the delivery process.
  6. Customers should designate authorized personnel at all shifts to assist and/or provide guidance to chemical delivery drivers. Provide a list of these employees to the dispatching terminal to include on their work orders, with instructions to permit only those people to assist and sign off.
  7. Drivers should be in attendance (within 25 feet), awake and have an unobstructed view of the tanker during the unloading of hazardous materials (49 CFR 177.834). If the receiving facility wants to take control of the process, management should agree on clear precautions and responsibilities.
  8. Customer representatives should remain in attendance during the initial stages of the unloading process (10 to 15 minutes). This allows for a knowledgeable person to perform emergency duties, which a driver unfamiliar with the facility may not know.
  9. Carriers should dedicate tanks for certain commodities, if possible. If the commodities are changed, the tank should be cleaned and analyzed. Transporters should request specification ranges from customers before using tanks with residual contamination.
  10. Drivers should use extra caution, if customers elect to use “dial-in” fill ports or other connections out of their control. Drivers should request schematics, SOPs, instructions, or a combination of the three to achieve the proper settings. If customer representatives dial-in connections, drivers should ensure those personnel are trained and authorized.

Essentially, the problems and preventative actions associated with cross-drops and cross-contamination in bulk delivery revolve around communication. Effective communication requires training, labeling, shipping papers, and facility layout and procedures. If carriers and customers communicate with one another, as well as with their employees, the industry will make great strides in reducing the frequency of these incidents.

The Shipper’s Responsibilities

  • Appropriately identify the material being transported
  • Use standard shipping papers for all bulk chemical shipments

Ensure the shipping papers are properly completed, including:

  • The proper shipping name as designated in 49 CFR 172.101. Also include in parentheses on the shipping papers. the technical or chemical group name(s) that indicates the contents of solutions.
    1. The hazard class or division
    2. The identification number specified in 40 CFR 172.101
    3. Packing group (for non-bulk shipments)
    4. The quantity of the material
    5. A signature section that certifies the contents of the shipment
  • Provide bills of lading (cargo manifests) for the customer’s signatures to prove that the shipment has been received.

The Carrier’s Responsibilities

  • Make sure you know what is being transported and any special instructions.
  • Ensure the shipping papers are properly completed.
  • Provide bills of lading for the customer’s signatures to prove that the shipment has been properly received.
  • Use tags on the discharge pipes to indicate the contents of a tank
  • To prevent contamination, clean tanks prior to filling when a different chemical or different chemical grade is to be loaded.
  • Train and retrain drivers on precautions for an accurate delivery.
    The Customer’s Responsibilities
  • Label storage containers with the identity of the chemical and hazard warnings (29 CFR 1910.1200). Make sure facility personnel are aware of any other names used to identify the chemical.
  • Train and test employees who perform functions that directly affect hazardous materials transportation every three years (49 CFR 171.702). This includes:
    • General awareness training – This includes a general overview of DOT HAZMAT standards such as labeling, placarding, and other requirements.
    • Function-Specific training – This includes specific information related to the commodities they will handle and loading/unloading procedures.
    • Safety training – This includes proper handling procedures, emergency response procedures, and measures to protect employees such as personal protective equipment and how to detect exposure.
    • Any OSHA, EPA or other training that may be applicable.
    • Advise employees as to who is/is not authorized to assist in bulk transport unloading
    • Provide proper instructions for use of central filling ports that are used to fill multiple tanks
    • Decontaminate hoses and “dial-in” connections or provide dedicated hoses

XL Environmental • Risk Control Division • 520 Eagleview Boulevard, PO Box 636, Exton, PA 19341 • Phone: 800-327-1414 • Fax: 610-458-7285 • xlenvironmental.com

XL Environmental is a division of XL Specialty Insurance Company.

 
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