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

1. Cargo Tank Risk Management Committee Presented by: Cynthia Harvey and Randy Vaughn Presented at: American Chemistry Council 3/11 Meeting

2. Genesis First meeting Objectives Steering committee Second meeting Mission/Scope OSHA NPRM Third meeting Document reviews Short and Long Term goals Fourth Meeting Next meetings Open discussion Topics

3. Genesis Aligned interest in providing a safe environment for workers Shippers Carriers Manufacturers Consignees But, sometimes stakeholders protect their interests at the peril of workers

4. Genesis Litigation Worker’s compensation claims Insurance premiums Lost time Workers Equipment Managers

5. Genesis Recent interest of industry leaders to coalesce ‘No one company is large enough to effect sufficient improvement’

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. Vision Statement

7. The issues being addressed by this group are related to workers that perform functions on both straight and combination cargo tanks. Stakeholders For the purposes of the work being done by the CTRMC, stakeholders include carriers, consignees, insurers, manufacturers, repairers, shippers, wash facilities, and others. 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. Scope

8. Cargo tank industry stakeholders working together to create solutions aimed at reducing the hazards faced by workers on and around such equipment. Mission Statement

9. March 17th in Fond du Lac, WI Open invitation 60+ industry leaders Shippers Carriers Wash racks Academia Trade association First Meeting

10. Ideas Shared Journeys of improvement Data Training Cultural change Global examples of successes TTMA RP No. 59 (OSHA applicability) Technology Variety of tank trailer designs

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…….. 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.

19. Ideas Shared Realization that the solutions are not just a matter of tank trailer design Training Process change PPE and employee aids Electronics and automation Environmental improvement Consistency

20. Objectives 1. Form a steering committee Done 9-10 representatives from industry leaders 2. Take a name Done CTRMC Why?

21. 3. Publish a living document and other media that address workers on the top of tanks Just starting 4. Draft a long term vision on how transportation tank processes and products can be improved to maximize worker safety atop tanks Just starting Objectives

22. June 29-30th in Chicago, IL Steering Committee ADM Cargill Dairy Farmers of America Liberty Mutual Quality Distribution Schneider National Sentinel Transportation Superior Carriers Transport Service Walker Group Holdings Second Meeting

23. Draft Vision, Scope, and Mission Done Craft response to OSHA Notice of Proposed Rulemaking Done and submitted Set next open invitation meeting date Done Objectives

24. OSHA NPRM Published May 24, 2010 (293 pages!) “OSHA is … seeking comment on whether it should include requirements” (covering workers on motor vehicles). References documents of the past two decades pondering OSHA’s role relative to motor vehicles.

25. OSHA NPRM “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.”

26. OSHA NPRM Q1: How many employees working on the top of motor vehicles are exposed to fall hazards? Q2: How are these employees protected from fall hazards while working on such equipment? Q3: Describe the nature and frequency of training. Q4: Provide detailed information on the types and costs of the fall protection used on motor vehicles.

27. Q5: Explain what technological and/or economic obstacles prevent use of fall protection. Q6: Are there alternative means to protect employees from fall hazards while working on motor vehicles? Q7: What is your safety experience with fall hazards on or from motor vehicles? Q8: Should OSHA exclude motor vehicles from coverage under Subpart D? OSHA NPRM

28. September 8th in Green Bay, WI Open invitation 35+ industry leaders Third Meeting

29. Approve Vision, Scope and Mission Statements Done Conduct think tank sessions to set Short and Long Term goals Done Set next meeting date Done Objectives

30. Work with TTMA to create a new publication for a suggested retrofit ladder Side handrails Platform type top step Retractable lower step(s) Collaborate with NTTC to develop a training and education video Create a North American heirarchy protocol Increase participation from other major industry stakeholders at future CTRMC meetings Short Term Goals

31. Eliminate need to access cleanouts through technology and improvements Spinners Remote actuated cleanout valves Provide a consistent work environment above ground level – 2020 vision 8 criteria identified ($, #, balcony, etc.) Eliminate all ladders and walkways for worker use through the employment of technology and devices Long Term Goals

32. December 16th in Houston, TX Steering Committee Drafted “North American Hierarchy Protocol for Protection of Workers on Tops of Tanks” 10 pages Delineates responsibilities of all stakeholders Fourth Meeting

33. March 15th in Chicago Steering Committee Move goals forward June 22nd in the Midwest General Meeting Move goals forward Next meetings

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. A Passage to Hannover – Oct 2010

41. Questions?