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Set up for a fall
FALL PREVENTION The wealth of fall protection and prevention systems on the market often forces purchasers to choose between safety and savings. But thinking the problem through on the basis of best practice helps the user determine what is the most appropriate solution
Fitting or re-fitting a fall prevention system at a tank container or truck loading facility can be one of the most worthwhile and cost-effective projects that can be undertaken. Knowing what systems are best, in terms of protecting the workforce and meeting local health and safety legislation, is not always simple. Different rules apply in different locations and trade associations and standards-setting bodies have their own best practice. Facility owners will also no doubt be subject to advice and sales pitches from manufacturers and suppliers of equipment. Here the Bulletin looks at some of the guidance available.
The first question to be considered is: fall protection or fall prevention? “Fall protection is actually an ‘active’ system whereas fall prevention is a ‘passive’ system,” says Pete Singleton, vice-president of market development for Carbis Inc. “One way to sum it up is passive systems prevent the fall from occurring in the first place – active systems only prevent personnel from hitting the ground after a fall occurs.”
Fall protection is effected through such means as harnesses, lanyards and other personal protective equipment (PPE). It is cheaper than fall prevention measures, at least in the short term.
However, says Kiran Shaw, operations manager for IFC Inflow: “Our advice to our customers is always ‘Prevent the operator from falling rather than trying to catch them when they do!’”
Hierarchy of protection
Shaw’s school of thought reflects the recommendations of the UK’s Working at Height Regulations 2005. “In these regulations there is a hierarchy for managing and selecting the equipment for working at height,” he says. This runs:
1. Avoid working at height wherever possible.
2. Use work equipment or other measures to prevent falls where working at height cannot be avoided.
3. Where the risk of falling cannot be eliminated, use work equipment or other measures to minimise the distance of a fall.
In the US, the Occupational Safety and Health Administration (OSHA) has the similar Hierarchy of Fall Protection Controls.
“In practice this means that collective fall protection measures such as gantries, safety cages and guardrails should be given priority over personal protection measures such as safety harnesses,” Shaw continues. “Where tankers are loaded at fixed gantries, secure fencing is required where possible. Prevention is the priority.”
Singleton looks at how this translates to the loading rack. “In consideration of OSHA’s Hierarchy of Fall Protection Controls, and given that the fall hazards cannot be engineered out, the best option is to utilise a passive fall protection system,” he says. “Passive systems do not require special equipment or active participation from the worker. In this case, a passive system, such as an access gangway and safety cage, could be installed around the perimeter of the work area on top of a tank truck or rail car to stop the fall from occurring in the first place.”
The UK Health & Safety Executive (HSE) provides some succinct advice on this topic as part of its guidelines, Prevention of falls from road tankers and tank containers enforcement standards1. HSE and the International Tank Container Organisation (ITCO) also address the issue in the joint protocol document, Prevention of falls from tank containers2, which includes a helpful risk assessment flowchart in Appendix C and an overview of the practical implementation of this hierarchy.
Active protection and PPE equipment
Where gangways and safety gantries are impracticable, active systems such as harness systems can be used, where operators have either a fixed-point or horizontal lanyards connected between their harness and a fixed anchor or an overhead beam and trolley system. In the US, fall protection systems must be “capable of supporting at least 5,000 pounds (22 kN) per employee attached” or be part of a complete system that maintains a safety factor of at least two, including the support system.
So-called ‘active’ protection systems have a downside: in the event of a fall they can injure the operator, and even endanger his/her life. “The major concern with fall arrest systems is ‘What happens if the operator does fall?’ He could hit his head, rendering him/her unconscious and unable to attract attention. If left in a harness for 20 minutes, there is a real risk of orthostatic suspension, which can and has proved to be fatal. Equally a fall in a poorly applied or loose harness can be very dangerous,” says Alec Keeler, managing director of Loadtec Engineered Systems.
“A person can die in minutes while suspended after a fall occurs if not rescued quickly,” Singleton adds. “You have to have a rescue plan in place in the event of a fall. Also the use of fall protection is not recommended where flammable products are being handled. If a fire occurs it becomes difficult to escape quickly when you are attached to a fall arrest device.”
Feet on the ground
The first element of the hierarchy asks whether the work in question can be carried out safely otherwise than at height. In terms of the loading of road tankers, tank containers and rail tank cars, the obvious answer to this is bottom loading. This is by far the safest option, since the operator remains firmly on the ground – and having nowhere to fall is a foolproof means of fall prevention.
Bottom loading has been successfully implemented throughout petroleum tanker loading facilities worldwide. However, its widespread implementation is making slow progress, as Kiran Shaw, operations manager at IFC Inflow, explains: “The main challenges faced by most sectors involved in tanker loading is the need for cooperation between all parties involved in the supply chain. In practice this means that for bottom loading to work the consignor of the load, the tanker or haulage operator, the loading terminal operator and the delivery location all have to be set up for bottom loading and unloading.
“Up to now, for most sectors apart from the petroleum industry, the practicalities and cost implications of this fundamental change have driven companies to look at operator safety whilst working at height, rather than wholesale conversion to bottom loading.”
When operations must be conducted at height, the first consideration must be how will workers access the high level? With stairs, falls can still occur so the surface must be non-slip and have drainage to remove surface water.
The Health & Safety Laboratory’s paper Safety of workers when accessing the top of tank containers3 contains useful recommendations for employers to bear in mind when specifying and purchasing new equipment. Taken from the BSI standard BS prEN 13586: Cranes Access, the following guidance for specifying non-slip stairs and walkways is included:
The walkway surface should be non-slip. The following are considered to be non-slip surfaces:
• Diamond tread – closed surface plating with raised diamond shaped patterns or lugs on the surface;
• Open-grip – grating with raised perforated buttons;
• Open-grip – grating with open diamond pattern having serrated edges;
• Sandcoat – surface coated with sand-containing paint or paint to which sand has been applied before drying;
• Flex-tread – high friction textured adhesive sheet material, comprised of a plastic film-coated with silicon carbide abrasive particles.
The slope of the walkway should not exceed 10 degrees (this may have implications for accessing the tank top while on a road trailer).
A border or ‘toeboard’ is recommended to prevent a foot slipping off the side if a slip should occur.
A good access system ‘should be designed to enable the user to use simultaneously two hands and one foot, or two feet and one hand while ascending descending or moving about,’ Section 8 of the paper states.
HSE’s tanker access enforcement standards say: Where a tanker is loaded at a fixed gantry, personnel should be protected from falling by secure fencing. Portable staging or ladders are unlikely to be suitable due to their difficulty of use, making operators resistant to using them.
All secure fencing should include a top and intermediate rail. Single guardrails are not acceptable and access should be prohibited where this is the only protection provided. The dimensions of the guardrails should be as at Schedule 3 Part 1 to the Work at Height Regulations 2005.
The Health & Safety Laboratory3 recommends that handrails are fitted with “at least one mid-rail and a toeboard”. The height of the top rail above the walkway should be between 1,000 mm and 1,100 mm (1,100 mm preferred), as in BS prEN 13586.
“With some planning you can install one sophisticated fall prevention system that meets all tanker requirements and allows the site to consolidate tanker loading and unloading into, potentially, a single location, actually providing a saving in the long run,” says Keeler.
1 UK Health & Safety Executive (HSE), ‘Prevention of falls from road tankers and tank containers enforcement standards’. Issued 2009, reviewed 2011. www.hse.gov.uk/foi/internalops/hid/spc/spctg04.htm
2 UK HSE and International Tank Container Organisation (ITCO), ‘Prevention of falls from tank containers’ (summary of UK protocol). Issued 2005, revised 2010. www.itco.be/download/ITCO_Prevention_of_Falls_TC.pdf
3 D Riley, Health & Safety Laboratory, ‘Safety of workers when accessing the top of tank containers’, 2004. www.hse.gov.uk/research/hsl_pdf/2005/hsl0504.pdf
OSHA information on suspension trauma and orthostatic intolerance: