By Daniel P. Vascik, Safety Specialist / Quality and Customer Care, Canal Barge Company North/ Illinois Marine Towing
The use and transportation of chemicals are commonplace in our industry. Though highly regulated by OSHA, USDOT, the Coast Guard (USCG), and the EPA, industries, including shipyards, in the U.S. are susceptible to hazards in the workplace involving chemical exposure to employees; causing potential fires in storage; inadvertent and accidental spills; and releases to either ground, decks, and even water—including navigable waterways, ports, and watersheds that are environmentally protected. All federally regulated agencies mandate a structured accountability system of documentation, reporting, training, and management to ensure full compliance.
However, in many cases, chemical storage of paints, solvents, lubricants, fuels, and chemicals are stored together, which may cause inadvertent mixing and incompatibility causing fires or violent reactions. Safety Data Sheets (SDS) are critical and should be managed and updated as necessary by designated employees managing chemical programs. OSHA covers this extensively in 29CFR1200 (Hazard Communication) as well as 29CFR 106 (Flammable Liquids).
However, regulations and standards change over time, and the 29CFR 1915,17,18 Standards currently do not identify in detail how to store chemicals and flammables as its General and Construction Industry-standard counterparts.
The National Fire Protection Association (NFPA) standards robustly identify flammable hazards in its lists NFPA 30, 77, 497 regarding electrical hazard zoning, static potential discharge protection as well as storage of both bulk and non-bulk commodities. The USCG also has references, such as its 46CFR Subpart O (150&151) Certain Dangerous Cargoes, as well as its CHRIS Manual.
Canal Barge had an up-close and personal experience in this when we had a vapor explosion of Acetone while venting a cargo hold in preparation for cleaning a tank barge. Many factors included insufficient grounding, ordered steps unintentionally not followed, lack of supervision, etc.
What was learned was the understanding of chemical characteristics and behavior. In any industry whether you’re managing, processing, manufacturing, recovering, or cleaning, safety comes down to paying attention to detail, communication, housekeeping, preplanning, and having a respect for the product.
As listed in the SDS, the product or chemical in its pure or mixture state will give detail and handling measures. Reading instruction labels on containers, placards on tank trailers, and cargo placards on tank barges is imperative. Whether preparing coated surfaces, mixing two-part chemicals (fiberglass resin and activator), transferring chemicals from shore to vessel, always ensure workers are adequately prepared.
Ways to ensure safe operations include but not limited to:
- Ensure SDS, work instructions, procedures are up to date and current;
- Ensure the above is available to all workers (shipyard employees, contractors);
- Conduct a Risk Assessment before conducting work or a change in a scope of work;
- Conduct an active conversation on hazards of the chemical(s) that they will be working with;
- Ensure all adequate control measures are in place: Elimination, Substitution, Engineering, Administrative, PPE;
- Never use chemical(s) in an enclosed location unless adequately ventilated (use intrinsic safe equipment where needed in the presence of flammable vapors
- Never leave chemicals or products;
- Periodically check that housekeeping measures are in place during work and post work activities;
- Prioritize work and schedule by hazard on work conducted in close proximity;
- Empower the workers and contractors, including visitors or vendors, to stop any unsafe work activities;
- Follow all recommendations that are given by the marine chemist and the shipyard competent person, where activities may involve confined or enclosed spaces;
- Conduct periodic site audits of storage areas to ensure compliance per regulates standards; and
- Work with local fire prevention officers where fire departments have jurisdiction in the area.
Five years ago, I personally asked the local fire department to visit our shipyard. Sure, the local fire inspector did its annual inspection, but the fire department itself did not have a grasp on our full operation. So, I had invited the engine and ambulance companies, as well as the HAZMAT and Technical Rescue team leaders, to a walk-through of our facilities.
We also had conducted a Tank Barge 101 program to educate their teams on the mode of transportation. They never had realized the extent of our operations that lay within the community—a community that has two separate rail lines and major roadways and expressways where chemical traffic is heavily traveled, including a large refinery at the edge of its jurisdiction. Relationships with agencies matter and managing chemicals matter where there is an impact on people, operations, and business.