‘Though it’s important to know the OSHA requirements,” advises Savage, ‘never assume these are enough to maintain a safe working environment in your particular situation.” To cite just one example, vice president of sales Tom Semiklose of SafeRack, a Sumter, S.C., manufacturer of custom racks, arms, and platforms for loading and unloading, points out, ‘OSHA has fall protection rules for stationary services, but doesn’t address rolling stock. Yet if an accident occurs you can still be liable under the general duty clause since the use of fall protection is a generally accepted practice.”
Then, too, a bulk plant is a complex and dynamic operation in which ‘conditions are constantly changing as various customers access your site and as your inventory fluctuates,” observes Jason LeVine, business development manager for Total Meter Services. Based in Vaughan, Ontario, the company provides solutions for automated monitoring and bulk plant equipment design, installation, calibration, and maintenance. For that reason, plant owners who base their safety programs on static compliance with minimum published guidelines are putting themselves at risk.
And even minimum compliance is a moving target since the regulations themselves may change over time to keep up with advances in methods and materials. For example, although EPA has for decades required plant operators to have a Spill Prevention Control and Countermeasure plan, a recent amendment to the Code of Federal Regulations (40 CFR 112) resulted in a significant change. Operators can face new fines for insufficient recordkeeping and employee training. ‘This is just one example,” says Savage, ‘of how an old regulation can still be in effect, but you also need to know the impact of changes in order to remain compliant.”
A static safety program is untenable because merely reacting to change is not enough. ‘It’s a mistake to act only when you’re required to do so,” advises Savage, ‘or only when something breaks, because the problem will usually compound itself.” By contrast, a proactive stance helps operators avoid fines, avoid costly incidents, attain peace of mind, ‘and often save money on insurance premiums’which I’ve seen many operators do. Because when you improve safety, you reduce risk.”
Designs and Upgrades
Plant safety starts with the right design’and good design begins with asking the right questions. ‘What geographic areas will your terminal service? EPA and OSHA operations often regulate differently by regions and zones of the country,” reports Savage. ‘Which products will you store? Safety measures must sometimes be tailored to particular fuels and blends. And how do you plan to make transfers? You need to determine proper flow rates to ensure safety. When you have answers, you can tackle environmental and safety issues.”
Good design starts with system questions because good designers must see the big picture. ‘You should think in systems,” Savage recommends. ‘How will a meter complement what is already installed? Who is offloading your product? How will you reconcile the inventory? What can cause build-up? Remember that pushing one domino will have an effect on the rest. So you must look at the total picture of plant storage and transfer.”
For example, to reduce the risk of fire and explosion operators must be aware of many factors. ‘Consider the velocity of product in the line as well as the metallurgy of the piping,” advises Savage.
‘The faster the product velocity, the more important it is to use the right size of piping in order to reduce static build-up.” In addition, specialized guidelines for dispensing flammable fuels are stipulated by the NFPA (National Fire Protection Association) Code.
At a minimum, Savage suggests that sites be visually inspected at least once a year. ‘And as you get recommendations from independent inspectors,” he adds, ‘once you implement the changes then you market these upgrades to your insurance company and request a reduction in your premiums.”
Upgrades can likewise have important spinoff benefits. As SafeRack’s Semiklose points out, ‘A lot of equipment in use today at bulk plants is heavy and outdated. But as the workforce ages, ergonomics becomes more important in protecting your employees from injury. And tying someone to a harness won’t necessarily provide fall protection if the equipment is old or inferior.”
Employees themselves may forego the use of fall protection and other safety equipment if they believe it makes their work more laborious and difficult. In choosing equipment, bulk plant operators should keep this fact of human nature in mind. For example, in choosing between loading rack options, Semiklose advises operators to ‘take into account how your employees need to open hatches and whether they will be inspecting the interior of the tank. A good understanding of what they’re actually doing on the job is integral in engineering the best and safest solution.”
The size of an operation is yet another safety consideration. ‘Frequency of use is important to factor in,” continues Semiklose. ‘If you’re a smaller company or you make a specialty blend, you might receive only a few large loads a week. But for a plant that has 30 trucks arriving per day, a need for speed would be vital. If you work with knowledgeable equipment suppliers, they can help you identify needs and work within your time and cost constraints.”
SafeRack’s recently introduced Erecta Step product is an example of how manufacturers and suppliers can address safety needs identified by bulk plant operators. The modular platform and stairs can be easily assembled and configured for specific installations, thereby allowing workers to safely step over pipes and walls.
Ultimately, Semiklose believes the greatest threat to safety is inaction. ‘Complacency is common for companies that are used to operating a certain way,” he cautions. ‘But what if a worker is unaware of potential dangers? The law says it’s your responsibility to provide a level of protection. But unfortunately, sometimes it takes a fall or a near-miss to shake up our complacency. Merely focusing on the upfront cost, rather than looking at how your employees can be safer, is a big mistake.”
At Fredericks Fuel and Heating Service, Whritenour concurs with the need for a proactive approach to safety. ‘Federal and state regulations require daily, monthly, and quarterly inspections,” he reports, ‘but we also prevent spills through training.” The company’s safety plan includes a semiannual ‘spill drill.” After each drill, he explains, ‘We critique ourselves and talk to our drivers to see if we could do something different. The drill is great for experienced drivers whose jobs can be monotonous, and also beneficial for new employees who will often make innovative suggestions.”
If the worst occurs, the three Fredericks plants have fail-safes in place for spills and leaks. ‘Our plants are built self-enclosed in preparation for a spill,” says Whritenour. ‘There is a dike underneath the tank for containment. So if a truck leaks, oil travels into a pipe and is directed into the dike. The spilled oil then just needs to be pumped out.”
Hoping for the best and not planning for the worst can have disastrous consequences. ‘I’ve heard horror stories about other plants that had a truck that didn’t hook up correctly or have a shut-off valve,” Whritenour relates. ‘It caused a major clean-up when product flowed down the street and into the river.” By contrast, a few years ago Fredericks became concerned about aging tanks and voluntarily tore down one of its plant in order to build a better and safer one. ‘We consulted a construction company that specialized in tanks and building petroleum plants. Along with a qualified engineer, we designed an optimal site,” he reports.
At all three Fredericks plants, safety protocols are rigorous. Trucks are grounded to prevent static discharges. Fire extinguishers are provided in all loading areas. At night and during slower months, sites are fenced and well-lit, and all vehicles and pumps are locked. Even so, Whritenour believes there is no substitute for the naked eye. ‘I can’t stress enough,” he urges, ‘the importance of walking around your facility to see things for yourself.”
Along with periodic personal inspections, LeVine of Total Meter Services believes that 24/7 automated monitoring of inventory and fueling activity is also vital. The company’s TMS6000 solution, he says, meets the need for an affordable Windows-based system. Monitoring not only generates data important for management decision-making but also provides capabilities to improve safety and security.
‘Monitoring access to the facility is the first step to securing the site as you ensure that only authorized persons get through the gate,” relates LeVine. Through an automated solution such as his company’s TMS6000, drivers seeking entrance to the plant must use a card reader or PIN pad to identify themselves. ‘You can track expiration dates of safety protocols, be alerted if a driver’s license is expired, and otherwise make sure a driver maintains all safety procedures. Without automated credentialing to control access to the loading platform, any person with the least bit of mechanical know-how might potentially access your product.”
Next to ensuring that ‘the wrong people don’t access your site,” continues LeVine, ‘is making sure the amount of fuel that goes into a truck isn’t too much. You don’t want overfills so that product is pouring down the street or pooling on the concrete pavement below the truck.”
Though sensors are helpful in determining when a tank is at capacity, automation can prevent a spill earlier in the chain of events. ‘Skids should always be equipped with an overfill device,” relates LeVine, ‘but automation also allows you to manage drivers, carriers, and trucks with preset boundaries.
‘So if a trailer can hold 5,000 gallons, but the driver attempts to input a 6,000, then you’ll get an alert and can prevent the transaction.”
Over the years LeVine has seen bulk plants that lack even gated access. ‘First, understand the importance of the simple, basic things you must do to ensure safety and security,” he counsels. ‘And then remember that it’s critical for you, as a bulk plant operator, to have the capabilities required for commanding and controlling access to and information about your facility.”
Mark Ward Sr. also contributed to this report.