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THE INTERNATIONAL TANK Container Organisation (ITCO) has published a fifth document in its technical series, TG05, Safe Entry into a Tank Container. The document provides guidance for ITCO member companies – and others – that engage in activities that require personnel to enter the interior of a tank container for the purposes of inspection, maintenance or remedial cleaning. The document focuses solely on the tank entry process, presenting the inherent risks that will be encountered and must be managed properly. ITCO says that, ideally, procedures should be reviewed to see if there are any ways
Those involved in tank entry, whether as personnel entering a tank or those responsible for managing the process, need to be aware of the potential for those inside a tank to be asphyxiated through a lack of oxygen or intoxicated by gases and vapours that are present in the tank. Those are two different things but have the same risk: that the person inside the tank may be overcome and, in the worst case, can die. DEFINE THE SPACE Before considering the safety risks involved in tank entry, it is important to establish the
limited means of access and egress, and is not designed for continuous employee occupancy. Permits are required when such a confined space contains or may contain a hazardous atmosphere. Operators need to be aware that tank configurations may result in gases being trapped or concentrated in particular parts of the tank, meaning that a single gas measurement may not give a complete picture of the risks inside. There is also a need to take account of baffles, pumps and other equipment that can present a trip hazard. In any case, a Tank Entry Permit must be issued prior to any work inside a tank; this must be completed by a competent person who has assessed the risks and put procedures in place to mitigate those risks. The permit should assess the tank’s conditions, in particular the nature of the last cargo carried in the tank and whether it has been cleaned or contains residues. ITCO stresses that the Tank Entry Permit should not be confused with the Cleaning Receipt or Cleanliness Certificate, and provides examples of all three documents.
to allow the relevant tasks to be carried out without the need to physically enter the tank, such as the use of CCTV. ITCO also notes that national legislation governing confined space entry should take precedence over its guidance and users should always comply with the appropriate legislation as a matter of course.
precise conditions inside a tank. ITCO refers to definitions used by the US Occupational Safety and Health Administration (OSHA), which clarify a distinction between ‘confined space’ and ‘permit required confined space’. A confined space is one that has adequate size and configuration for employee entry, has
ITCO also stresses the importance of training, not just for those entering a tank but also for the person issuing the Tank Entry Permit and any personnel on hand to provide safety assistance. This applies equally to external contractors or inspectors. The nature of the required training is often
SAFETY • ITCO IS CONTINUING ITS MISSION TO IMPROVE SAFETY IN THE USE OF TANK CONTAINERS WITH NEW GUIDANCE ON SAFE TANK ENTRY
HCB MONTHLY | JULY 2020
