Document NGK55Ne42nQ4GeVxKo23zXomp

Et h y l Ga s o l in e Co r p o r a t io n Ch r y s l e r Bu il d in g 405 Le x in g t o n Av e n u e G>1. Gl^si_X >(Ew Yo r k (0-/0 L G^--J) /j^z. (Aa ^o _ L^T f\0s*^ tr A** t "Tl A CaJAn -<^ ^6v-p (2^-m^-,m,"' <JL_j yO>--> THE TANK CLEANING PROBLEM St\ Since the growth to major proportions of the tank cleaning inspection activity, many unforeseen angles have presented themselves. The activity haa become far larger then was at first anticipated. It has sncroschec, in many cases, on time which field representatives sight have been giving to their normal sales projects. Moreover, it has become an extremely expensive affair. !lo one ho is familiar with the reasons for the program ana who appreciates the tremendous value to our company of this preventive effort will begrudge for a moment either the time or the money. Moreover, there are few of us who question the need for indefinite continuation of this work with unrelaxed vigilance. I?e should, however, examine periodically the current status, of the program, review what it has accomplished, end determine hat its future course is to be and *hat improvements might be sac. from efficiency and economy standpoints. At present the tank cleaning inspection work' is being carried on substantially in the same way in which it sas started. This consists of educational and missionary efforts among notification ana authority men, coupled with actual' inspection throughout each cleaning. The reports covering the various calls and inspections are reviewed at the division headquarters * and are carefully studied ana coordinated in the 3e* 2ork Office. This method has proven quite satisfactory gad is entirely thor ough and efficient. A network of contacts ha.- been built up end hunured of frisnoly end cooperative relatione vith our customer companies have been estab lished. kh a result the number of tank cleanings inspected ir nearly the ase asthe number occurring. Our effort'- have brought the ieaced 0022965 gasoline tank hazard forcibly to the attention of gasoline suppliers, Conformance to our suggestions, has inevitably caused t- tremendous Improve ment in gasoline teak cleaning technique throughout the incus try. Moreover our campaign ha;-, resulted in the purchase and proper maintenance of suit able tank cleaning safety equipment by nearly all person, anu firm*. engaged in this ork. fcafety meetings ana personal calls have served to improve the gafety-sindedness of oil company executives generally. The cost of this wori to the Ethyl Gasoline Corporation hae been very large, not only in money but also in man-hours. Had the expenditure been tsdee or three times as large, it sould still have been thoroughly justified in the Light of the really remarkable results obtained, h'e should now consider the feasibility of utilising the accomplishments of the campaign as a possible means of reducing the expenditure without jeop ardising in any *ay the continued safety of men engaged in tank clean in., sork. It has been pointed out that the tank cleaning campaign nan created an increased safety-mindedness among gasoline suppliers, that it has crestsd an undersbanding of the scope ana character of the lead hazard in tank cleaning, that it has been the means of improving gasoline tank deaniag technique generally, end that it has been in trumental in ob taining proper and veil cared for safety equipment for most tank cleaning crawa. These beneficial improvements are more apt to be permanent in the organizations of our large customers, commonly referred to as the "major" companies. It is also likely that these companies carry cut the majority of tank cleaning *ork, because their appropriations for care end aain- tenaiice of equipment are generally large. Also the ownership sun control of a very large percentage of the country's gasoline storage facilities is vested in thii so-called major group, bisny of the large companies have highly organized safety de- v *7- ^ - ;'V'. **. K 0022966 partaents under the leadership of able end conscientious sen. Some of the are lapiementea with considerable authority ana are e&powerec to exercise rigid control over the methods used for carrying out hazardous work. If proparly educated on the subject of the lead hazard in tank cleaning, and if properly coapo.- ed codes of procedure were adopted by them, ouch com panies aould be perfectly capable of preventing the occurrence of accidents resulting from residual lead in gasoline storage tanks.. One of the reasons for the initial institution of our present method of procedure was that the potentiality of the lead hazard, and in many cases its very existan.ee, was not recognized by the owners yf gasoline storage equipment. Until the character of the hazard and the means of combatting and eliminating it could be analysed, and a thorough knowledge circulated throughout the industry, it naturally fell to the Ethyl Gasoline Corporation, for humanitarian reasons as well as for the protec tion of its own good name, to undertake whatever steps were needed to pre vent the occurrence and recurrence of accidents from ufais source. When our tank cleaning activity was initiated few, if any, oil company safety orders, end probably no semi-public codes (;.uch as that issued by the API) recognised the existence of a hazard from residual lead in the clean ing of gasoline storage tanks. Sporadic cases of well defined lead, in toxication occurred and would probably have multiplied rapidly with the increase in leaded gasoline gallonage had *e not taken immediate end drastic action. The present situation, however, it a very different one. A majority of those oil companies which make use of a formal safety code have incorporated therein adequate instruction for protection against lead hazard. Those which have not yet revised their codes could probably be persuaded to do so. A new API cod (shortly to be issued) will be so com posed as to cover the lead danger thoroughly. Our own tank cleaning field reports reflect an ever increasing improvement in technique, equipment, and 44 2 / * 002236 cooperation. Certain companies would probably improve sore repiuly if aads wholly responsible for the proper protection of their employees, end thu:; were forced to depend to a lesser extent upon our field observers and on Ethyl Gasoline Corporation equipment. It hafc been mentioned above that the rather startling increase in bank cleaning notifications in many of our Divisions ha* made it neces sary to impress many salea representatives into this work, often for ex tended periods. Thus the tank cleaning work has prevented tne initiation of projects that ^ould have required the uninterrupted attention of field sen. Up to sos this sort of thing has been an unfortunate necessity. If it is possible to work out soae meant of simplifying our .'hare oi the problem, the Corporation will benefit by being able to re-direct the efforts of the field staff into normal channels. Another problem in connection iith the tank cleaning work, par ticularly that portion of it which has to do with the actual observation and inspection work on. the job itself, gout be recognised. In spite of the unquestioned importance of field inspection and the occasional need for prompt action end *ounc judgement, the bulk of such work is aonotous to a degree, and frequently demands little or nothing of the inspector except his presence, buch work rapidly becomes irksome to a technically trained man accustomed to action and to work demanding the use of his knowledge and skill. There are indications that this difficulty is already making itself felt in some quarters, and we certainly should g o anything we can to prevent its growth to large proportions in the next few years. Should this happen, and should we find ourselves with a group of unhappy and dissatisfied people on our staff, it would be too late to uo anything ef fective about it. Moreover, it would appear to be poor economy to use comparatively well paid men, many of the* with university training, for work of this sort indefinitely, if any satisfactory alternate could be developed.. 0022968 What, then, can be done? A serious hasard in the cleaning of tanks that have been u.ed for the blending or storage of gasoline treated with tetraethyl lead will exist so long a? such gasoline is manufactured and distributed. The seasonal neea to change the product in tanks at bulk terminals, the normal accumulation of residue, and the periodic need for repair end inspection *111 always make it necessaiy for men to enter tanks from time to time. Much work has been done on toe development of methods and equipment designee to make possible the cleaning of tanka, particularly the smaller sises, without need for toe actual entrance of men. Unfortunately much -till remain- to be none before a thoroughly sa tisfactory means is developed. Excellent methoat of mechanical ventila tion have often developed in the last several years, but, while such devices shorten tank cleaning jobs and lessen the danger, they do not and cannot eliminate the neea for men to enter tanks occasionally. There is, however, one method that might serve to le.sen toe Corporation's tank, cleaning investment and responsibility. That is by takin-, advantage of the educational work that has been none anu of the ac companying improvement in technique end equipment, by turning over the ac tual responsibility of field inspection end supervision to certain "major" companies that are capable Of handling it ana that can be depended upon to cariy on adequately and conscientiously. It is not claimed that such a transition can be made suddenly or even within any specified period. A foundation of mutual understanding and agreement woula have uo be estab lished. Any company with which the responsibility wait to be shared would neea to have not only a suitable code but also an organ!isation so arranged ae to implement the coas through well trained field inspectors ana tank cleaning crews. Much preparatory ground work would have to be done by our safety staff in collaboration with that of the customer. It is believed that ouch & program could be started with a aeries K? 0022969 of persons! calls by ona of our 8.X, staff men on. a selected group of our larger customers. All phases of the problea should be discussed and an ex pression of opinion xsolicited as to whether the customer would be willing to assume the burden. If he would, all codes sue safety orders should be carefully studied to determine their adequacy A delegation of responsibility 1 should be made end suitable training given. Finally a system or records should be placed in use so that proper and complete tank histories would be maintained. It in not the intention of this suggestion to stop all tank clean ing communication between our company and any customer. On the contrary, frequent visits should be made on those persons in the customer company to ' 'rhoai responsibility for supervision and maintenance of records has been dele gated. Actually the only change wouid consist in a shifting of the field inspection fro our organisation to that of the customer. An understanding would have to exist to the effect that any relaxation of vigilance on the part of the customer would make necessary a reinstntnent of the present method. For the time being, at least, we should continue our present serv ice unchanged for any customer who specifically requests it. If thas9 ideas are thought to be at all meritorious, it is sug gested that the details ba worked out and a trial made with one large customer ouch as The Texas Company otf one of the "Standard** groups. There are necessarily many smell refiners and contractors who have organisations co loosely knit, or who have no safety personnel whatever, that we would never wish to give the responsiblity for carrying on without notification and observation by a member of our own staff. It la further recognised that no such policy a- that outlined herein '..hould or will contiy^bute to the lessening or cessation of this Corporation*$ interest or vigilance in connection with the cleaning of leaned gasoline storage tanks. It has as its goal merely such savings in money and man-hours as may properly 0022970 be effected as a logical result of the very large investaent in, sno the excellent results of, our campaign so far. \ KE 0022971