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Best Practice Guidelines For The Safe Working At Height In The Chemical Logistics Supply Chain

Draft

DISCLAIMER​

This document is intended for information only and sets out best practice guidelines for safe working at height within the chemical logistics supply chain. The information provided 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 with regards to its completeness. It is not intended to be a comprehensive guide to the safe working at height within the chemical logistics supply chain. Cefic/ECTA/Fecc will assume no responsibility in relation to the information contained in these Guidelines.

TABLE OF CONTENTS​

  • DISCLAIMER
  • TABLE OF CONTENTS
  • INTRODUCTION
    1. SCOPE AND OBJECTIVES
    • OBJECTIVES
    • SCOPE
    1. RESPONSIBILITIES
    • 2.1 MANAGEMENT OF SITE
    • 2.2 MANAGEMENT OF TRANSPORT COMPANY
    • 2.3 SITE PERSONNEL
    • 2.4 VEHICLE DRIVERS
    1. LEGAL REQUIREMENTS
    1. RISK ASSESSMENT AND MANAGEMENT
    • HIERARCHY OF CONTROL FOR ALL PRODUCT TYPES
    • NEAR MISS AND ACCIDENT/INCIDENT REPORTING

INTRODUCTION​

The risks associated with working at height require all parties involved in loading, unloading, storage, cleaning, repair/maintenance and shipping/rail terminal operations to introduce safe systems of work based on risk assessment and management.

These guidelines which have been developed by industry experts aim to promote best practice guidance for safe working at height in the entire chemicals supply chain.

There is a legal requirement for all participants in the supply chain to conduct risk assessments of their operations to eliminate or minimise risks, to protect employees and other personnel, and to co-operate and co-ordinate their activities. See Directive 2001/45/EEC of the European Parliament and of the Council of 27 June 2001 amending Council Directive 89/655/EEC concerning the minimum safety and health requirements for the use of work equipment by workers at work (second individual Directive within the meaning of Article 16(1) of Directive 89/391/EEC).

Within these overall obligations and measures taken to eliminate or minimise risk, a clear hierarchy of control should guide this process (see section ..).

With regard to the number of serious incidents (see EU-OSHA statistics), personal injuries, and near-misses that are encountered in the logistics supply chain with various types of equipment and locations, the authors (ECTA/Cefic/Fecc) feel it is imperative to develop these working at height guidelines to assist in the overall reduction of falls from height that cause death and injury.

Every working at height activity should be evaluated in detail. This will identify whether there are ways to avoid the working at height activity.

If working at height is unavoidable, the risk assessment will identify which infrastructure/equipment/procedure is the most suitable to carry out the work safely. In this regard, the hierarchy of control (see section …) has been identified as the central guidance. In this context, the fact that the site management is legally responsible for providing a safe working environment for working at height should be taken into account.

The following website provides more background information on safe working conditions: http://osha.europa.eu

1. SCOPE AND OBJECTIVES​

OBJECTIVES​

All participants in the supply chain need to conduct comprehensive risk assessments and introduce safe systems of work based on risk assessment, management and appropriate procedures, and taking the corresponding actions.

The objective of these guidelines is to provide guidance on how to mitigate and manage the risks associated with working at height within the chemical supply chain.

SCOPE​

The following activities are within the scope of these guidelines: Transport, Warehousing, Tank Cleaning and Repair stations, transfer terminals and depots at which the following activities are carried out:

Loading/Unloading of bulk or packaged goods, Top loading/unloading, opening/closing of covers/valves, connections/disconnections, sealing, sampling, etc.

2. RESPONSIBILITIES​

Analysis of accident statistics indicates that a majority of transport-related incidents and accidents occur during loading/unloading operations. Further detailed analysis shows that the human factor is by far the most important cause. It is therefore essential to increase safety during loading and unloading by clearly defining the respective responsibilities and by influencing human behaviour (see Cefic/ECTA BBS Guidelines for the safe loading and unloading of freight vehicles).

2.1 MANAGEMENT OF SITE​

The management of the site should ensure that the site access requirements are communicated to the hauliers and that safety procedures are communicated to the drivers upon arrival. Site management should promote and maintain safety awareness, particularly during product handling. Site management should ideally ensure that loading/unloading operations are carried out under supervision. There is a clear legal duty on the site management to ensure the safety of all people operating on their sites. This includes contractors, drivers, visitors, etc. Over recent years we’ve seen an increase in the practice of sending drivers off site to check manlids and this must be avoided as it increases safety risks.

Therefore, the risks to the health and safety of these people should be assessed and eliminated or minimized. With working at height, the risk assessment should take account of all tasks and must seek to prevent persons falling.

For an un/loading site, the working at height activity should be evaluated in detail. This will identify whether there are ways to avoid the working at height activity. If working at height is unavoidable, then steps must be taken as to which infrastructure/equipment is the most suitable to ensure that the work can be undertaken safely. (Annex 1, Annex 2)

2.2 MANAGEMENT OF TRANSPORT COMPANY​

EQUIPMENT
The management of the transport company should always supply equipment that is fit for purpose for the operation to be carried out and that all applicable legal requirements have been complied with. The management of the transport company is responsible for the provision and maintenance of adequate personal protective equipment and the training in its use. Specifically, this is likely to include safety harnesses, especially for sites where a fall arrest system is in place.

NEAR MISS & INCIDENT REPORTING
The management of the transport company should ensure that there is a procedure to report all near misses, incidents, loading/discharge problems, and unsafe situations or conditions, including follow-up. There should be a system in place to share information on important near-misses, incidents, or unsafe situations with the principal.

2.3 SITE PERSONNEL​

Continuous monitoring of the (un)loading process or other activity by the site loading operator and driver in close co-operation, is essential. To this end, the site loading operator and driver should be well aware of each other’s responsibilities.

2.4 VEHICLE DRIVERS​

The driver has to fulfil and respect safety/security guidelines at the loading/unloading point and follow the instructions from the staff at the plant.

Drivers must not work at height unless it is safe to do so.

If there are no appropriate tools available and a safe working environment is not guaranteed, the driver must stop the activity and contact his management.

Directive 2001/45/EEC Of the European Parliament and of the Council of 27 June 2001 amending Council Directive 89/655/EEC concerning the minimum safety and health requirements for the use of work equipment by workers at work (second individual Directive within the meaning of Article 16(1) of Directive 89/391/EEC).

Furthermore, the provisions of Annex 4 “Provisions concerning the use of work equipment provided for temporary work at a height” within Directive 2009/104/EC will apply.

For the application of Directive 2001/45/EC of the European Parliament and of the Council concerning the minimum safety and health requirements for the use of work equipment by workers at work, a non-binding guide to good practice is available in different languages at the Publications Office of the European Union.

4. RISK ASSESSMENT AND MANAGEMENT​

Site Management are legally required to undertake and document the Working at Height risk assessment. It is recommended that all risk assessments associated with working at height are performed by competent personnel who are trained in risk techniques and assessment (Annex 1, Annex 2).

These risk assessments should identify the critical activities in the supply chain and shall:

  • Identify all risks and hazards for each activity.
  • Where possible, eliminate the risk through not working at height.
  • Where it is not possible to eliminate the risk, identify proportionate risk management measures.
  • Identify the severity of the risks for each activity by the use of a Risk Matrix.
  • Identify persons who may be involved in the work associated with identified risks.

Any risk assessment should be documented, retained, and periodically reviewed.

HIERARCHY OF CONTROL FOR ALL PRODUCT TYPES​

The main way to ensure safety is to avoid the need to get on top of the vehicle in the first place. Measures should be undertaken to ensure this. The hierarchy of control should establish the action to be followed to determine the most safe and practical method to be used:

  1. Where access to the top of vehicles cannot be eliminated, fixed gantries should be provided at loading and discharge facilities that incorporate secure fencing on all sides of the high-level working position from which a person could fall.

  2. Where a fixed gantry loading/unloading is not reasonably practicable – and vehicle top access cannot be eliminated – ensure that secure fencing is provided to all sides of the walkway or load platform of the vehicle. A possible way to achieve this is the use of mobile gantries to access working at height areas. These have the advantage of being less expensive than fixed gantries and can be manufactured to cater for both tanker and packed goods operations.

  3. Use of personal fall restraint – or fall arrest systems – should be seen as the last resort, or used as an interim solution, pending application of the points above and then only if all of the previous control measures are not reasonably practicable. Where used, rigorous controls and training measures need to be applied to support this, and consideration needs to be given to how a person would be rescued who is suspended in a harness.

The fitment of a “safety rail” should not be seen as a safe means of working at height, but merely as a guide to the edge of the vehicle. It is also a means for the driver to use when moving forward on the vehicle. The use of the handrail to affix a safety harness onto is considered unacceptable as the strength of the handrail will NOT support a person if they happen to fall.

Although these are the most common situations that occur in the industry, consideration should also be given to other types of work at height such as vehicle maintenance tasks, that should also be assessed.

NEAR MISS AND ACCIDENT/INCIDENT REPORTING​

It is a known fact that most near misses are NOT reported when they occur.

A Near Miss is an undesirable, unplanned event or condition which under other circumstances could have led to injury, damage to equipment, material release or security breach. Examples include: defective safety equipment, unsafe acts, unsafe conditions or chemical exposure.

Vehicle operators should have a clear process in place describing how a Near Miss or an Accident/Incident is reported. In this respect, support is also necessary from the site management, so that no disadvantage results to a driver who has reported a potential unsafe situation. Furthermore, it should be possible for the site staff to report internal Near Misses and Accidents/Incidents to their own management too.

Annex 1 – Flow chart​

Annex 2 – Hazards and controls matrix​

The following matrix is designed to show a range of possible controls to consider when doing a risk assessment for working at height. IT DOES NOT REPLACE THE RISK ASSESSMENT

The idea is that you can use your standard template for doing the risk assessment having considered which of the potential controls listed below are actually in place.