Guidelines for Safe Degassing of Rail Tank Cars
**SUE**
Issue 2 / May 2016
TABLE OF CONTENTS
- INTRODUCTION AND SCOPE
- SAFETY MANAGEMENT SYSTEM
- DEGASSING FACILITIES
- DEGASSING OPERATIONS
- GAS TESTING
- TANK ENTRY
- PREPARING A RAIL TANK CAR FOR DEPARTURE
- GLOSSARY
Disclaimer
This document is intended for information only and sets out guidelines for safe degassing of rail tank cars. The information contained in these guidelines is provided in good faith and, while it is accurate as far as the authors are aware, no representations or warranties are made about its completeness. It is not intended to be a comprehensive guide to all detailed aspects of safe degassing of rail tank cars. No responsibility will be assumed by CEFIC in relation to the information contained in these guidelines.
1. INTRODUCTION AND SCOPE
In Europe, degassing of Rail Tank Cars (rtc’s) is mostly done at rtc workshops and not at specialized cleaning stations. Workshops offer this activity as an extra service to their customers.
The degassing operations and associated activities like tank entry and nitrogen purging, are hazardous activities which require the right equipment, skilled personnel, detailed procedures and, above all, a proper safety management system.
The scope of this document includes:
- Degassing (gas freeing) of rtc’s containing flammable gases (LPG, propylene, butadiene, C4 mixtures...)
- Testing the rtc atmosphere during and after degassing
- Tank entry after degassing
- Nitrogen purging
- Labelling and marking of rtc’s, degassed or to be degassed
Some elements of this guideline can also be used for other products example: tank entry, nitrogen purging, labelling, etc. These guidelines are aimed at advising rtc workshops in order to perform these activities in a safe way.
2. SAFETY MANAGEMENT SYSTEM
2.1 Safety Policy
A strong safety culture is only possible if the management is committed to safety and if this is reflected in the daily operations. It should be clear to all personnel that the management wants to maintain a safe work environment. Safety should be the first priority in all circumstances.
Policy should include:
- A statement articulating the company’s safety objectives and goals and the management’s commitment to achieve these.
- Clearly described duties and responsibilities of employees at all levels to ensure maximum safety and occupational health.
Key points:
- Roles, duties, responsibilities, and accountabilities related to safety should be clearly identified.
- Policy should be endorsed by the CEO to demonstrate top management’s commitment.
- Policy should be publicized, understood, and reviewed regularly.
2.2 Safe Operating Procedures and Risk Assessments
Safe operating procedures (SOP’s) must be developed and implemented for all activities, ensuring the safety of work. This requires conducting risk assessments to identify all potential hazards.
Assessed risks might include:
- Moving rtc’s in the degassing area.
- Release of gas, health hazards, fire, and explosion risk.
- Line systems under pressure.
- Flashback of flame into the rtc.
- Use of mechanical tools (creating sparks).
- Entry into rtc’s (asphyxiation, explosion hazard).
- Working at height.
- Noise.
- High temperature (steam).
Methods to identify risks:
- Fine & Kinney method:
- Determine and rate factors: Probability of occurrence, Severity of the effect, Exposure.
- Risk is the product of these factors.
SOPs must be:
- Clearly written, communicated, and reviewed regularly.
- Readily available to all personnel concerned.
- Used in conjunction with a Permit To Work system for certain activities like tank entry and hot work.
2.3 Training
Identify the training needs of each function and implement a training programme to provide all employees with the required skills and knowledge to carry out their job safely and effectively.
Training programme should cover:
- Degassing operations.
- Handling of dangerous goods.
- Risks of dangerous goods.
- Labelling and marking of rtc’s.
- Use of Personal Protective Equipment.
- Permit To Work system.
- Entry into confined spaces.
- Gas testing.
- Emergency procedures.
- Firefighting.
- First aid.
- Incident and near miss reporting.
Refresher trainings should be organized regularly, minimum every 3 years.
2.4 Safety Meetings
Regular safety meetings should be organized to encourage participation in the discussion of safety and health issues arising from the workplace. Safety committee meeting minutes should be recorded and communicated. Tool-box meetings should be organized at shift or section level. Safety reminders, warnings, precautions, DOs and DON'Ts, and other relevant safety information should be made available to employees.
2.5 Reporting of Incidents
All incidents should be properly investigated, and measures should be taken to prevent recurrence. Written procedures must include criteria for the seriousness of incidents to be investigated. A system should ensure that recommendations are addressed and disseminated. Incident statistics should be analyzed to identify problematic areas for appropriate action.
2.6 Reporting of Near Misses and Unsafe Situations
A system should exist to report and investigate near misses and unsafe situations.
Effective reporting system requirements:
- Inform employees on identifying and reporting Near Misses and Unsafe Situations.
- Encourage reporting and provide incentives.
- Simple, effective, and well-documented reporting system.
- Maintain a no-blame culture.
- Ensure analysis and corrective actions.
- Communicate actions taken.
- Close the PDCA loop.
2.7 Safety Promotion
Management should establish promotional programmes to demonstrate a commitment to maintaining a safe and healthy work environment.
Examples:
- Safety bulletin boards in each department.
- In-house safety campaigns.
- Display safety posters.
- Incentive schemes to recognize good safety performance.
2.8 Evaluation, Selection, and Control of Contractors
A system should exist for assessing and evaluating contractors to ensure competence and compliance with safety standards.
Key points:
- Safety performance indicators for selection criteria.
- Include safety, health, and environmental responsibilities in contracts.
- Organize safety inductions before work begins.
- Monitor and evaluate contractor's safety performance.
2.9 Safety Tours / Spot Checks / Audits
Set up an inspection programme consisting of safety tours, spot checks, and safety audits by competent persons. Use checklists for identifying hazards and ensure appropriate findings and recommendations are communicated.
2.10 Maintenance Regime
Establish a maintenance regime for equipment and tools to prevent accidents due to failure.
Maintenance programme should include:
- A list of tools, machinery, and equipment.
- Inspection and maintenance schedule.
- Inspection/maintenance reports.
Ensure competent personnel conduct inspections and maintenance.
2.11 Emergency Preparedness
A response plan for on-site emergencies should be in place, including:
- Emergency situations and their impact.
- Emergency team and responsibilities.
- Alarm procedures.
- Evacuation and rescue procedures.
- First aid.
- Involvement of local authorities.
- Communication plan.
Conduct emergency drills at least once a year with local emergency services assistance.
2.12 Document Control and Review
Control, maintain, and update documents according to ISO 9001 standards.
3. DEGASSING FACILITIES
3.1 Degassing Area
- Degassing should occur in open air at a remote location, segregated from other traffic, with signage warning of flammable gases.
- Area should be horizontal, impervious, drained, and equipped with gas detection equipment.
- Prevent connection to underground drainage systems within 10 m of the area.
- Install safety devices to prevent rtc movement during operations.
- Maintain good housekeeping.
3.2 Equipment
- Classify the area according to the ATEX directive and use approved equipment.
- Secure rtc’s with appropriate measures (e.g., rail hook) and ensure earthing before hose connection.
- Test hoses annually and maintain other safety items like fire extinguishers and emergency showers.
3.3 Lines and Flare/Incinerator
- Mark lines and hoses appropriately and ensure connections to prevent backflow.
- Install water seal drums and flame arrestors in the flare line.
- Prefer incinerators over flares for better combustion efficiency and safety.
4. DEGASSING OPERATIONS
4.1 Product Information and Identification
Maintain a list of permitted products and ensure proper identification of the product in the rtc before degassing.
4.2 Personal Protective Equipment (PPE)
Minimum PPE requirements include safety shoes, protective gloves, safety glasses, helmet, and warning vest. Extra PPE should be indicated for specific tasks.
4.3 Operating Instructions and Checklists
Provide accessible written operating instructions and checklists for all degassing tasks.
4.4 Inspection of Rail Tank Cars
Inspect rtc’s for damages or leakages before entering the workshop.
4.5 Preparation
Verify rtc number and secure the rtc with appropriate measures before degassing.
4.6 Degassing by Filling with Water
Follow detailed steps for degassing by filling the rtc with water, ensuring safety measures are in place.
4.7 Degassing by Nitrogen Purge
Use nitrogen for degassing and follow specific procedures to ensure safety and effectiveness.
4.8 Bringing the RTC Under Air
Flush the rtc with air until safe levels are reached, then disconnect hoses and secure the rtc.
4.9 Marking and Labelling for Internal Use
Clearly label and mark rtc’s to indicate their internal condition and ensure repair or maintenance work is done on gas-free rtc’s only.
5. GAS TESTING
5.1 General
Authorized personnel who are trained in using gas measuring instruments should conduct gas testing.
5.2 Measuring Apparatus and Calibration
Use appropriate gas testing equipment, ensure periodic calibration, and provide training for users.
6. TANK ENTRY
6.1 Risks
Identify and mitigate risks associated with confined spaces, such as low/high oxygen levels and flammable/toxic atmospheres.
6.2 Permit for Entry into Confined Spaces
Use a confined space entry permit to authorize and document safe entry into rtc’s.
6.3 Tank Entry
Follow procedures to ensure safe entry into rtc’s, including the use of appropriate equipment and a stand-by attendant if necessary.
6.4 Respiratory Protection
Follow guidelines for respiratory protection based on atmospheric conditions within the rtc.
6.5 Emergency Rescue
Establish a rescue procedure, either by own personnel or local emergency services, and conduct regular rescue exercises.
7. PREPARING A RAIL TANK CAR FOR DEPARTURE
7.1 Labels
Remove or hide danger labels and orange placards after cleaning/degassing according to RID regulations.
7.2 Documents
Provide a cleaning/gas-free/purging certificate to the customer, including cleanliness inspection results and atmospheric conditions.
8. GLOSSARY
RTC: Rail Tank Car
Fine & Kinney Method: A method to assess risks by ascribing values to probability, exposure, and severity.
SOP: Safe Operating Procedure
Toolbox Meeting: Short daily discussions or presentations by supervisors focused on specific topics, often related to safety.
Near Misses: Unsafe acts, situations, or learning experiences that, under different circumstances, could have resulted in an incident.
VCA: Safety Checklist for Contractors, valid for 3 years after an audit by an independent organization.
LEL: Lower Explosion Limit
UEL: Upper Explosion Limit
OEL: Occupational Exposure Limit
STEL: Short Time Exposure Limit
Derailer: A device used to prevent unauthorized movements of trains by derailing them.
ATEX Directive: Directives for equipment and workplaces in potentially explosive atmospheres.
Jacks: Equipment to lift or support heavy equipment.
CIM: Consignment document for rail transport.
PID: Photo Ionization Detector for measuring volatile organic compounds and gases.
Lone Worker Alarm System: A system for monitoring safety of employees working alone, raising alarms if needed.
UIP Cleanliness Key: A system developed by UIP to indicate internal cleanliness levels of rtc’s.
For more detailed guidelines and safety measures, refer to the structured sections above. Ensure adherence to safety protocols and regular review of processes for maintaining a safe work environment.