To the well-known list of the unalienable American rights of life, liberty and the pursuit of happiness, one more should be added: a safe and healthful workplace for all employees. 

 
 From the clerk at the local gasoline station to the ethanol processing plant operator, every American worker wants, and is entitled to, appropriate protection from workplace hazards.
 
 The United States Department of Labor's Occupational Safety & Health Administration is responsible for ensuring that employers are providing these conditions to their employees. 
 
 The agency is required to guarantee the safety and health of America's workers by setting standards, providing training, outreach and education, establishing partnerships, and encouraging continual improvement in workplace safety and health.
 
 Workplace safety in the U.S. became standardized nearly four decades ago with the enactment of the Occupational Safety and Health Act of 1970. At the heart of this legislation is what is referred to as the General Duty clause, which requires employers to "furnish to each of his or her employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his or her employees" and to "comply with the occupational safety and health standards promulgated under this act."
 
 In addition to looking out for the health and well-being of workers, the OSH Act of 1970 also serves a dual purpose of safe-guarding all industries from excessive employee absences since personal injuries and illnesses arising out of work situations can impose a substantial burden on interstate commerce in terms of lost production, wage loss, medical expenses and disability-compensation payments.
 
 The Best-Laid Plans
 While OSHA and the OSH Act of 1970 have done a tremendous job protecting the worker from workplace hazards, no system is perfect and workplace accidents and incidents do continue to happen. One area that annually features a notable number of incidents is fall protection. In fact, according to OSHA's list of most frequently cited workplace violations, lack of—or inadequate—fall protection ranked third in 2006 and second in 2007.
 
 On top of that, the U.S. Department of Labor lists falls as one of the leading causes of traumatic occupational death. According to the U.S. Bureau of Labor's 2007 National Census of Fatal Occupational Injuries, a total of 5,488 fatal work injuries were reported in the United States in 2007. While this was a decrease of 6 percent from the 5,840 fatal work injuries recorded in 2006, the number of fatal falls rose to 835, a 39-percent increase from 1992 when the CFOI program was initiated and an overall series high. In addition, the number of fatal falls in 2007 accounted for nearly 15 percent of the number of fatal work injuries during the year. According to the labor bureau, the increase in falls overall was driven primarily by an increase in the number of same-level falls, which were up 21 percent from 2006, and falls from non-moving vehicles, the reports of which increased 17 percent from the previous year. And overall, about one-fourth of all occupational fatalities in 2007 involved workers in transportation and materials-moving occupations, although the number of fatalities among these workers declined by 5 percent in 2007.

 
 Without a doubt, these numbers are sobering, made more so by the fact that when it comes to fall protection, the standards and regulations are open for interpretation. The Department of Labor says that any time a worker is at a height of four feet or more, the worker is at risk and needs to be protected, while, regardless of the distance, fall protection must always be provided when working over dangerous equipment and machinery. However, OSHA's actual fall-protection requirements are somewhat nebulous: "a…site must maintain a ‘safe' work environment." With no exact definition offered for the word "safe." This means that, potentially, one man's simple stubbed toe could be another's just cause for a multi-million dollar lawsuit.
 
 Terminal Worries
 Falling into the sweet spot in the debate over what constitutes employment that is "free from recognized hazards that are causing or are likely to cause death or serious physical harm" are the workers at the nation's terminal, tank-farm and bulk-plant facilities. Workers at these facilities spend their days scrambling to the tops of railcars and tank trucks to unload bulk liquids—be it mainstream chemicals, petrochemicals, biofuels or niche chemicals—before they are shepherded into aboveground storage tanks that can range in size from 5,000 to 500,000 gallons at be as much as 10 stories tall.
 
 To help ensure that employees at these facilities are kept safe and aware of the standards that govern fall protection, the Safe Tank Alliance, which is a partnership formed between OSHA, the National Fire Protection Association and the American Petroleum Institute, has created a brochure titled "Fall Prevention for Aboveground Storage Tanks." The brochure states that proper use of equipment such as guardrails, stair rails, travel-restraint systems, safety nets, arrest systems (harnesses), self-retracting lifelines/lanyards and ladder-safety devices have been designed to keep terminal workers from falling or, if a fall does occur, avoiding a hard landing. The brochure also offers a comprehensive list of do's and don'ts regarding fall protection:
 
 Do:
 › Look for hazards and ways to avoid them
 
 › Get enough light to see what you're doing
 
 › Choose and use proper procedures and equipment
 
 › Use walkways, especially on tank dikes

 
 › Keep walking and climbing pathways clear
 
 › Make sure a tank roof will support your weight before walking on it; reinforce roofs, if needed
 
 › Have reliable communication when working alone
 
 › Check sour tanks for hydrogen sulfide before climbing on top, and have respiratory protection available
 
 › Check scaffolds and their inspection tags
 
 › Use a helper to hold an extension ladder when climbing to tie-off the ladder
 
 Don't:
 
 › Ignore a hazard if it can hurt someone
 

 › Go on a floating roof without required permits—it may be a confined space
 
 › Run or jump from elevators
 
 › Stand on the top two rungs of a ladder or allow two or more people on the same ladder
 
 › Carry tools while climbing
 
 › Use unknown scaffolds
 
 › Walk on wind girders without railings
 
 › Use safety belts, harnesses or climbing devices without training
 
 › Expect someone else to prevent a fall
 
 Tools of the Trade

 In many instances, the use of common sense by the worker can be enough to prevent the most obvious fall-protection incidents, but when terminal employees are required to walk along the tops of railcars or 40-foot storage tanks, there is obviously the need for some type of equipment that will either prevent or arrest a fall incident.
 
 With this in mind, there are several types of equipment that have been designed specifically for use in terminal and bulk-plant applications, including:
 
 ›Lifeline Cables: These pre-engineered, usually synthetic, cables are lightweight and have excellent resistance to weather and chemicals. These cables are hung between supports along a railway bed, or truck depot, allowing the worker to hook onto them and traverse the car or truck without fear of a fall to the ground. Recent technological advances have led to the creation of lifeline-support systems that have pass-through devices that allow workers to walk past intermediate supports without having to disconnect their lifeline.
 
 ›Trolley Beam Fall Protection: In this application, an I-beam (used to capture the load requirement that the fall protection system puts on a structure) is suspended over the truck or railcar loading position and workers clamp onto it before making their way along the vessel. The system can be sized for single or multiple trucks or railcars, can be retrofitted to existing structures and can be designed for one to four users at a time. If no other roof structure exists, vertical supports would still be required.
 	
 ›Safety Cages: A wide variety of safety cages for tank-car use have been created. In general, they are portable and come with a variety of mounting options. Their operation allows for the cage to adjust with the height of the gangway and allows them to be raised or lowered to the railcar
 	
 ›Permanent Platforms, with Gangways/Safety Cages: These permanent structures can be equipped with both single- and double-sided platforms that can be track-mounted on a tracking system that is virtually maintenance-free. The system is built with two tracking sections on each end with handrails in between. In a railcar application, tracking gangways may be used if the railcars vary in length or cannot be uncoupled. 
 	
 ›Mobile Access Units (Trucks): These types of units, which are easily moved into place by an individual, are ideal for loading and unloading operations for tank trucks. They can adjust to the height of the vehicle and come in parallel or perpendicular configurations depending on the amount of space needed to complete the operation. The safety cage at the top of the unit protects workers from falls.
 	
 ›Mobile Access Units (Railcars): Able to be easily moved into place, these units feature a telescoping ladder that can be raised or lowered to conform with the varying heights of railcars. A safety cage with a handrail height of approximately 42 inches keeps the worker safe.
 
 While the prevention of falls can, in many cases, be as simple as workers doing (or not doing) the things that their parents have been telling them since they were children, many industries—including the liquid bulk terminal industry—present unique challenges in preventing falls, fatal or otherwise. In addition to knowing the do's and don'ts of fall protection, the best companies—with oversight from OSHA and other agencies—provide their employees with the equipment they need to best ensure that no catastrophic accidents do happen. 

 
 Tom Semiklose is vice president of SafeRack LLC. Reach him at <a href="mailto:tsemiklose@saferack.com">tsemiklose@saferack.com</a> or (866) 761-7225.

Employees tasked with unloading bulk liquids from railcars are at risk of falls and should be offered protection to help ensure their safety. According to the U.S. Department of Labor, any time a worker is at a height of four feet or more, they are a

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Adequate fall protection equipment continues to be a concern for agencies tasked with ensuring employee safety. Terminal operators striving to make their storage facilities as safe as possible should consider various safety systems to help employees avoid possible accidents.

Proper Safety Equipment can Prevent Costly Falls

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Upcoming Events

2024 International Fuel Ethanol Workshop & Expo

Biodiesel Summit: Sustainable Aviation Fuel & Renewable Diesel

Carbon Capture & Storage Summit

North American SAF Conference & Expo

2025 International Biomass Conference & Expo

Proper Safety Equipment can Prevent Costly Falls