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Ctrmc presentation at acc 3 11


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Cargo Tank Risk Management Committee Presentation at the American Chemistry Council on March 11, 2011

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Ctrmc presentation at acc 3 11

  1. 1. Cargo Tank Risk Management Committee<br />Presented by: <br />Cynthia Harvey and Randy Vaughn<br />Presented at: <br />American Chemistry Council 3/11 Meeting<br />
  2. 2. Genesis<br />First meeting<br />Objectives<br />Steering committee<br />Second meeting<br />Mission/Scope<br />OSHA NPRM<br />Third meeting<br />Document reviews<br />Short and Long Term goals<br />Fourth Meeting<br />Next meetings<br />Open discussion<br />Topics<br />
  3. 3. Genesis<br />Aligned interest in providing a safe environment for workers<br />Shippers<br />Carriers<br />Manufacturers<br />Consignees<br />But, sometimes stakeholders protect their interests at the peril of workers<br />
  4. 4. Genesis<br />Litigation<br />Worker’s compensation claims<br />Insurance premiums<br />Lost time<br />Workers<br />Equipment<br />Managers<br />
  5. 5. Genesis<br />Recent interest of industry leaders to coalesce<br />‘No one company is large enough to effect sufficient improvement’<br />
  6. 6. A work environment where all cargo tank industry stakeholders live out the primary core value of safety first - and always. This environment will be one in which all stakeholders work in harmony to design industry-standard education, work processes, and equipment design measures that will keep workers safe on and around cargo tanks. Furthermore, the stakeholders will be represented by a committee of representatives from across the industry that are empowered with their respective segment’s knowledge and support to create and publish such guidance in a way that will be most widely accepted, universally applicable, and engineers out risk to workers as much as is reasonably possible. <br />Vision Statement<br />
  7. 7. The issues being addressed by this group are related to workers that perform functions on both straight and combination cargo tanks. <br />Stakeholders For the purposes of the work being done by the CTRMC, stakeholders include carriers, consignees, insurers, manufacturers, repairers, shippers, wash facilities, and others.<br />Workers Anyone whose job responsibilities require them to perform duties on or around a cargo tank for the purposes of cleaning, inspecting, loading, repairing, securing, or any other task essential to the bulk cargo business.<br />Scope<br />
  8. 8. Cargo tank industry stakeholders working together to create solutions aimed at reducing the hazards faced by workers on and around such equipment.<br />Mission Statement<br />
  9. 9. March 17th in Fond du Lac, WI<br />Open invitation<br />60+ industry leaders<br />Shippers<br />Carriers<br />Wash racks<br />Academia<br />Trade association<br />First Meeting <br />
  10. 10. Ideas Shared<br />Journeys of improvement<br />Data<br />Training<br />Cultural change<br />Global examples of successes<br />TTMA RP No. 59 (OSHA applicability)<br />Technology<br />Variety of tank trailer designs<br />
  11. 11. During 2004 and 2005……ITCO and the HSE produced a working understanding of the key requirements for minimizing the risks associated with working at height in the tank container industry……..<br />The ITCO members, who represent the majority of leading tank operators with the UK/Europe/World, specifically sought to produce an eight-year plan to radically improve the standards applied across the industry.<br />
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  19. 19. Ideas Shared<br />Realization that the solutions are not just a matter of tank trailer design<br />Training<br />Process change<br />PPE and employee aids<br />Electronics and automation<br />Environmental improvement<br />Consistency<br />
  20. 20. Objectives<br />1. Form a steering committee<br />Done<br />9-10 representatives from industry leaders<br />2. Take a name<br />Done<br />CTRMC<br />Why?<br />
  21. 21. 3. Publish a living document and other media that address workers on the top of tanks<br />Just starting<br />4. Draft a long term vision on how transportation tank processes and products can be improved to maximize worker safety atop tanks<br />Just starting<br />Objectives<br />
  22. 22. June 29-30th in Chicago, IL<br />Steering Committee<br />ADM<br />Cargill<br />Dairy Farmers of America<br />Liberty Mutual<br />Quality Distribution<br />Schneider National<br />Sentinel Transportation<br />Superior Carriers<br />Transport Service<br />Walker Group Holdings<br />Second Meeting<br />
  23. 23. Draft Vision, Scope, and Mission<br />Done<br />Craft response to OSHA Notice of Proposed Rulemaking<br />Done and submitted<br />Set next open invitation meeting date<br />Done<br />Objectives<br />
  24. 24. OSHA NPRM<br />Published May 24, 2010 (293 pages!)<br />“OSHA is … seeking comment on whether it should include requirements” (covering workers on motor vehicles).<br />References documents of the past two decades pondering OSHA’s role relative to motor vehicles.<br />
  25. 25. OSHA NPRM<br />“OSHA is not including any specific requirements pertinent to motor vehicles in proposed 1910.28. Rather, it will wait until the record is more fully developed to determine the appropriate course of action. If, in response to this issue, the Agency receivers sufficient comments and evidence to warrant additional rulemaking, a separate proposed rule will be issued.”<br />
  26. 26. OSHA NPRM<br />Q1: How many employees working on the top of motor vehicles are exposed to fall hazards?<br />Q2: How are these employees protected from fall hazards while working on such equipment?<br />Q3: Describe the nature and frequency of training.<br />Q4: Provide detailed information on the types and costs of the fall protection used on motor vehicles.<br />
  27. 27. Q5: Explain what technological and/or economic obstacles prevent use of fall protection.<br />Q6: Are there alternative means to protect employees from fall hazards while working on motor vehicles?<br />Q7: What is your safety experience with fall hazards on or from motor vehicles?<br />Q8: Should OSHA exclude motor vehicles from coverage under Subpart D?<br />OSHA NPRM<br />
  28. 28. September 8th in Green Bay, WI<br />Open invitation<br />35+ industry leaders<br />Third Meeting<br />
  29. 29. Approve Vision, Scope and Mission Statements<br />Done<br />Conduct think tank sessions to set Short and Long Term goals<br />Done<br />Set next meeting date<br />Done<br />Objectives<br />
  30. 30. Work with TTMA to create a new publication for a suggested retrofit ladder<br />Side handrails<br />Platform type top step<br />Retractable lower step(s)<br />Collaborate with NTTC to develop a training and education video <br />Create a North American heirarchy protocol<br />Increase participation from other major industry stakeholders at future CTRMC meetings<br />Short Term Goals<br />
  31. 31. Eliminate need to access cleanouts through technology and improvements<br />Spinners<br />Remote actuated cleanout valves<br />Provide a consistent work environment above ground level – 2020 vision<br />8 criteria identified ($, #, balcony, etc.) <br />Eliminate all ladders and walkways for worker use through the employment of technology and devices<br />Long Term Goals<br />
  32. 32. December 16th in Houston, TX<br />Steering Committee<br />Drafted “North American Hierarchy Protocol for Protection of Workers on Tops of Tanks”<br />10 pages<br />Delineates responsibilities of all stakeholders<br />Fourth Meeting<br />
  33. 33. March 15th in Chicago <br />Steering Committee<br />Move goals forward<br />June 22nd in the Midwest<br />General Meeting<br />Move goals forward<br />Next meetings<br />
  34. 34. The following slides are from the IAA Show in Hannover, DE, last fall and show how European companies address ladders and walkways on cargo tank motor vehicles.<br />A Passage to Hannover – Oct 2010<br />
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  41. 41. Questions?<br />