(81bg) Process Safety Considerations During Railcar Loading and Unloading

The general principles of process safety are relevant to the loading and unloading of transportation vehicles, vessels and containers at process plants, trans-loading stations and similar facilities. A challenge to the effective implementation of process safety guidelines for railcars is that unlike fixed equipment at a process facility, a railcar typically spends considerable time (such as when the railcar is in transit) outside of the immediate control and monitoring of plant personnel who load and / or unload railcars. As an example, personnel charged with the task of unloading a newly received railcar often have little if any information about how that particular railcar was loaded, the condition of the interior of the railcar when it was loaded, the condition of the product as-received and the overall functional condition of the railcar appurtenances. A consequence of these conditions is that railcar loading and unloading personnel, especially at high throughput facilities, should pay heightened attention to safety procedures and controls that may potentially provide information about these unknowns. In addition, the overall design of railcar loading and unloading stations should be performed with the general principles of process safety in mind. In this paper, a number of guidelines drawn from the general principles of process safety and tailored to the unique environment of railcar loading and unloading are presented with the goal of reducing or eliminating hazards. These guidelines involve a consideration of the often numerous and occasionally overlapping requirements provided by a variety of regulations and standards. These might include US Department of Labor OSHA regulations (perhaps including PSM requirements), US Department of Transportation Hazardous Materials Regulations (if hazmat is involved), Association of American Railroads (AAR) standards and / or recommended practices (such as AAR Pamphlet 34), and additional product manufacturer / shipper handling instructions (such as might typically be provided in an MSDS). In addition, the guidelines presented in this paper have been developed based on findings from the investigation and analysis of a number of incidents involving railcar loading and unloading at a variety of facilities.