A number of important developments have occurred in the liquid terminal industry over the past several years. One involves industry compliance with new regulatory requirements imposed by the Occupational Safety and Health Administration (OSHA). Other significant changes are taking place in facility security and in process safety management.
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Turning first to OSHA, the agency recently issued a final rule on Walking-Working Surfaces and Personal Fall Protection Systems. The rule went into effect in January 2017 and includes requirements for ladder safety, stairways, scaffolds, rope descent systems, personal fall protection system design, performance and use, and training and inspections. These changes mean that terminals will need to incorporate frequent inspections of equipment and walking-working surfaces and train employees on fall and equipment hazards, as well as the use of personal fall protection systems.
For the large number of terminals located on the US' waterways, the Coast Guard’s security regulations affect how they control unauthorised access to their facilities. During 2016, the Coast Guard issued new standards for the equipment used to verify the Transportation Worker Identification Credential (TWIC) at facilities regulated under the Maritime Transportation Security Act. As terminals consider the impact of the rule, the International Liquid Terminals Association (ILTA) is working with the Coast Guard to highlight key issues that need to be resolved before industry must implement the new requirements.
Additionally, the Department of Homeland Security (DHS) rolled out a revised Chemical Security Assessment Tool during 2016, requiring chemical facilities regulated under the Chemical Facility Anti-Terrorism Standards (CFATS) to resubmit information to the agency about the presence and amounts of certain “chemicals of interest” at their sites. Gasoline terminals have not been required to comply with the requirements of CFATS, largely due to a 2009 ILTA petition to DHS challenging their inclusion in the programme. ILTA continues to advocate for complete exclusion of gasoline terminals from the CFATS regulation.
Finally, an important recent development has occurred in the area of process safety management. As a direct result of Executive Order 13650, Improving Chemical Facility Safety and Security, issued by President Barack Obama in 2013, OSHA began the process to revise the PSM standard to further prevent major chemical accidents. During 2016, the agency commenced a small business review panel to discuss proposed updates to the PSM regulations. Several ILTA members joined the panel to provide input on the changes and reiterated that many of the potential revisions to the PSM regulations add complexity and considerable cost without providing anything of a comparable material safety benefit.
As the advocate for the liquid terminal industry, ILTA helps its members improve the efficiency and safety of their terminal operations and operate in compliance with applicable regulations. The association provides members with valuable compliance resources and services to help them fulfil their regulatory responsibilities.
The ongoing success of the liquid terminal industry relies on its ability to continuously improve operations and the safe handling of products. It also requires a regulatory system that supports job growth and competitiveness and eliminates inefficient, duplicative and unnecessary regulations.