According to the DOT's Pipeline and Hazardous Materials Safety Administration, railcar and tank truck loading and unloading Haz-Mat incidents are common challenges in the process industry, resulting in as many as 11,500 incidents annually.
Specifically, the DOT describes a hazardous materials nonaccidental release (NAR) as the "unintentional release of a hazardous material while in transportation, including loading and unloading while in railroad possession, that is not caused by a derailment, collision or other rail-related accident."
"In other words, it needs to survive normal transportation conditions such as vibrations, temperature changes or anything like that," said Jennifer Barnett, learning and development specialist for Olin. "That basically says these inspections should identify that, and you should be able to prevent all this."
Furthermore, the DOT regulation states that "NARs consist of leaks, splashes and other releases from improperly secured or defective valves, fittings and tank shells, and also include venting on nonatmospheric gases from safety relief devices."
"If you do have a leak in transportation, the DOT will assume that you did not do the proper inspection of that car," Barnett said.
The average NAR fine is $8,900.
"This is the average fine," Barnett stipulated. "This isn't including manpower and other costs for cleanup. It's just the fine itself."
According to Barnett, these DOT regulations are in place to prevent the releases of product. "You have to inspect your cars before you can ship them," she said.
But operators must first be properly trained to conduct those inspections, a concept that is not without its own challenges.
"When we talk about some of the challenges, one of them is the quality of training our new operators are getting," Barnett said. "What's the consistency of that training?"
Olin training, Barnett said, consists of pairing new operators with a senior operator and having the new operator shadow them.
"The training is only as good as the training that senior operator is providing," she stated.
According to Barnett, another challenge is determining how organizations can best train its operators to mitigate incidents before they occur.
"One of those things is training them on proper preloading inspections and post-loading inspections, how to identify equipment defects, etc.," Barnett said.
Yet another challenge to operators in the shipping and loading environment, she said, is "not only are they having to certify in that area, process or loading rack and the procedures and policies for the site, but they also have to certify for DOT certifications, and they have to learn DOT regulations."
The advantages of digital training
In response to these challenges, Barnett said Olin has implemented an automated, cloud-based digital platform in its training program to ensure inspections of railcars, trucks and marine vessels are performed consistently, minimizing risk of NARs.
The platform's photorealistic view for railcar inspections has markedly helped develop operators' competency, giving them the knowledge to do proper inspections.
"All DOT requirements and regulations were included in the simulator, which is another important inclusion," Barnett said. "It gave the loaders the ability to practice doing these inspections on their own time, as they wanted to. It was not dependent on whether or not a railcar was available for inspection. It provided them a way to be able to do these inspections within the safety of the control room or wherever they wanted to do it. It didn't have them doing it in the railyard itself."
Barnett also cited the platform's action checklist on the loaders' tablets as a valuable tool.
"I actually do an onboarding railcar training class for all of our new hires in the corporation, and once I'm done with the classroom training, we go out and walk around cars and inspect," she said. "But then I get on a plane and leave. What the digital training is able to do is continue the classroom training. They're able to take it with them, and it's almost like I'm still there training them. They have everything that I've taught them in the classroom right there in their hands."
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