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Hazards of Tank Cleaning Tank Cleaning t The sources, nature snd distribution of the lead hazards- encountered : - in tank cleaning are discussed in the Tank Cleaning Heport, which is available to all Safety Engineers. Each nan should have knowledge of the data and be sufficiently familiar with the results of this study to be able to explain the character of the hazards to all persons actually concerned. It is the existence of these hazards that makes the supervision a nd precautions in Tank Cleaning necessary. However, the amount of information which should be given out will depend in each instance upon the situation. The report has established the necessity for supervising the cleaning of all tanks that have ever contained leaded gasoline. Ho matter to what use a tank has been put after it has contained leaded gasoline, and no matter how often it has been cleaned in the mean time, it is not possible to predict how dangerous it may be when entered. It follows^herefore^that no one is justified in failing to supervise the cleaning of a tank merely because.ho does not anticipate any C~J u ,1. trouble.; ____- - " ^ ^c' LUf-idfis' cn-u^ C'f t'*' , ' * WV- t/ -/.vv.' ' VYsJ-"'- - :. \./f '-//- ` (/ , . .. - . ... jo J2-.4 ' SHjrfehensn^e^^he hazard is likely to be as great in small tanks as in <"?VV; large ones. Regardless of size, whenever tanks are entered for purposes of cleaning, ft* supervision is essential and precautions must be taken. are followed. On the other hand, accidents have occurred when the specified precautions were not taken, particularly when air-line respirators were not worn. It is one of the major responsibilities of the Safety Engineer, therefore. to make sure that the instructions are followed by being present when tanks are * { lull'lt-it P.SL- r< ^ / entered and by supervising the,operation A duties and authority of supervisor The responsibility of the Safety Engineer in this connection is not limited.however, to supervision. He must see that his office receives proper notification and that warning signs are in place. Moreover,it is largely through his regular visits and discussions with the individuals responsible for cleaning the tanks that a sufficient spirit of cooperation and a satisfactory working arrangement are obtained. The Ethyl Gasoline Corporation does not accept respons- ibility for the safety of eswloyees- o-f-gaso'ltliB:'distributing companies engaged in Tank Cleaning, but through the engineering assistance which it offers them, all hazards connected with Tank Cleaning may be eliminated. It may happen that two tanks at widely separated points are t be cleaned at the same time. Under such circumstances it will be necessary for the Safety Engineer to decide which of the two operations he should supervise personally, and to make arrangements, if possible, to have another representative supervise the other cleaning K 0022921 3' There has "been a tendency on the part of some of the oil companies to allow the supervisor of the tank cleaning crews to assume complete responsibility for the cleaning of tanks. This policy has been based upon the assumption that tank cleaning crews are well trained and equipped and that their own methods are adequate for the elimination of hazards. It is not advisable, however, to rely entirely on them. The practices of such crews have been known, to vary and it is not safe to assume that they will have the same interest in the lead hazard as would one of our own safety engineers. 0022922 -4- li^js3^W&rning Signs All tanks that have ever contained leaded gasoline should "be marked with a^aming sign 'suitable - tor-bhe^f^ri^. %e type of sign or stencil and its location will vary depending upon the use and location of the tank. In installing or inspect ing these signs the safety engineer should keep in mind the function of the sign, namely to provide adequate warning and to direct the reader's attention to the detailed instructions available at the office. The sign functions as a warning and a reminder of the necessity of following instructions and is designed to supplement, not replace, discussions of the safety representative with responsible individuals concerned in tank cleaning. -w - . [//{..rfy- s'?-/s .7-V 7 /7 7 -(<r fr/ rt l /( -7 .V' 'Vl' , 1/ / f4s..c. .. / ........ 77'/ a , .. C - ' , /L- Stl. / 0022923 -5- r.f / In his function as supervisor of tank cleaning the safety engineer acts as a consultrut only. As an adviser on the hazards of tank cleaning and means of preventing them he serves as a source of information ~ealy-~and does not directly assume the responsibility for the safety of any of the workmen except insofar as that is implied by the advice he gives. He is not, therefore, in the position of an executive and has no direct authority over the employees of any of the customer "r companies. If difficulties are encountered with the personnel immediately con- ', 7y* * cerned in tank cleaning in regard to proper equipment or the following of instructions, the safety engineer should inform the safety man or executive in charge of the plant, and secure his cooperation. If not successful in this, he may offer the local manage ment the opportunity of discussing the situation with responsible members of the Ethyl Gasoline Corporation even though this necessitates a telephone call. In any event the safety engineer should inform someone in authority of the infraction which seems to threaten hazard. Such difficulties are seldom encountered and may be eliminated to a large extent if by proper discussion the requirements of the situation are understood^ /' " h-.? ' . % ' t< 0022924 Instructions The regulations set up by the Ethyl Gasoline Corporation are to he followed in addition to the precautions usually practiced hy the distributing companies. Our instructions are not designed to replace those of the refinery and should not cause any modification in their practices. Ho conflicts should arise, hut if interpretation of our instructions should seem to interfere with the local rules, the matter should he brought to the attention of our Safety, or Medical Department, In case a company has no specific regulations, the rules given in the A.P.I. Manual on Cleaning Petroleum Storage Tanks should he followed, supplemented,of cours^ hy our own instructions* These instructions follow: /\ ^ CD -`ny'.r.e who enters a tank that has contained leaded gasoline must wear e. blower- type or positive pressure air-line hose mask. This applies not only to tank cleaners hut also to repairmen and others / 'V.V -V'?/ (r . /* / / '/' " --.t ' l- y'y" / / / 'f / > J / // '/ /-'S ^ /> / J. _/ X* ','VXTVV /? >" /?' ' ! /' , x ^ // C\/x-S< .s' ' T*s-' - " ;-i K 0022925 -7-- who must enter leaded ges o^nfe-Us-torage tanks that have not h een thoroughly cleaned*i /** - The use of air-line respirators is necessary, aai-^enljr for protection against the hazard from volatile lead compounds but-ardsn to prevent the inhalation of gasoline vapors. A full face piece is preferable. 3ecause of lower cost and convenience, there has been a tendency to substitute canister masks or dust respir ators for the air-line mask, and to use the simple type hose mask without the blower when small horizontal tanks were being cleaned and 25 feet of hose appeared adequate. However the positive pressure air-line hose mask with the blower should always be ' y`.: - a- s used and in case such a mask is not available, the use of the Safety Engineer's equipment should be offered* All respirators used should have the approval of the U.S. Bureau of Mines, (2) Hose lines for air-line masks have a limited life and should be kept clean. / ZTThey should be cleaned before being put away, after each day rs use, preferably by | hosing thoroughly with water to remove adherent ..material. When any odor, as of ryi-fi'lZ-C C-d ...................... liA-t fli gasoline, can be deteot-ed in the air stream, work must be stopped profflpsfciy-aad /. .r!. . i>- j'/ y;'.- f f.` not-be-resumed.-.untll.-.the.._cause.-has__been-found. or until a new hoseline has been substituted. This will be discussed below, under Care of Equipment. (3) All workmen must wear clean overalls, shirt, underwear, and socks*-- They^muarlf also wear. acid-proof gloves K& 0022926 -8- in perfect condition. O- i f-- ,</ (4) ij Clothing must be changed and-td^-f-e^e^nd-hands_washed_h!-fore~eating7 At--the, MLd (,u A ,yL. A >2-\- L* >' end,._of- work-bhe~clothing -must -he chaxiged~and..a...hath.~taken. 5?he-l-ethAsg^mfcn:ot he worn_Jj3n^r--than-cne.-day, ~after-.whicirt -SSt^lCiAundfer^aL. Beets. aadAglov.es... sasbxbBuwsBhedrdaiky. If clothing is accidentally soaked with sludge, the workmen must "bathe at once and put on clean clothes* / Where "bathing facilities are not available at the plant, workmen should go to their hotel or home and "bathe, v/hen the job is finished, even though it is not the end of the working day* - ' ; ' / 4 r >tS f ._____ _ _ y* ./ /,N '0 fj tJ (5) Sludge is dangerous material even after removal~from t he tank, 'and~iilien there A is any likelihood of exposure to its vapors, suitable precautions should he taken. Sludge should he buried where it will not contaminate streams or he uncovered accidentally. ^-^aoii]dA^-e-.kept.--wet-andkbiirl.e.ii-. as- s oon- -a s - p os s ii>ie~aft er-removal from-the-tank. Provision should he made for its disposal as it is taken out and under no circumstances should it he allowed to lie about near the manhead unfcAl-Hkt &* has-arll-heen-removed^from-t-he--tank. V/hen sludge has to he hauled for long distances \y in wheelbarrows or cans the workman jssa&fc-wear a canister mask. Men burying sludge in a JL/U^C pits are also exposed to its vapors and^aat wear air-line respirators. - O-J Ct //.L k & 9-cf( l'(y, /A"' V7^ - ..A /wv /> ~ 9 ''1 /' / i-rrt {> ... rV Ct'S A r/f <( ;*!4>Zu.j<-e-K ^<u ' '/ J/i There are numerous ways of disposing of sludge and it is not possible to~ rj-y anticipate the many situations in which exposure may occur. The Safety Engineer \i 0022927 should keep in mind.the dangerous nature of the material and should not .consider- his supervision of the tank cleaning completed until all of the sludge has "been disoosed of. i* r V /r" uy (S) Repairs and other cold work should preferably Tao carried-out- after tanks ..have MLuuu-m been cleaned. YJel&ing and other hot work should -tpe*_done--oftiy.-after tanks have been cleaned and the areas to be heated are down to baaghffc metal. ^he use of air-line masks for welding and other repair work is ;not always feasible, and if the tank has been thoroughly cleaned in advance, they need not be used, ^he surfaces to be worked on should have all the adherent material removed and iH*3rgh.t metal exposed; this should be done during the regular cleaning operation with all precautionary measures taken including the use of air-line respirators. . A sufficiently large area should be prepared so that no uncleaned surfaces will be heated by the wuldtngu&urch-or contaminate the clothes of the- .- repairmen. After preliminary cleaning.and the settling or removal of dust caused // by it, repairmen may proceed with their work. /'l /,//& y< <z If L/-k. ~ . c. <y' r / &'/ , r" /'/''/if V us : <... < r -? * ~/7 soft, <? /? / PJy? ^ '/,:f //- /'/ - /s/. ,^/3 K'E 0022928 -10- '/jri T\ / :<c' ' / ' If tanks are thoroughly cleaned and aired they are safe for repair work. However there seems to he no general agreement as to what constitutes a clean tank. The decision as to whether or not a tank is Safe for entering without masks must he made and since the Safety Engineer properly has more information onthe hazards of tank cleaning than any other individual concerned, it may he up to him, as an advisor, to decide this question. Prom the point of view of subsequent contamination of the product, removal of gross amounts of scale and sludge is considered adequate hy many operators. Prom the point of view of safety, however, a perfect cleaning would he one in -which all metal was exposed. Such a result obviously can not he obtained in a routine cleaning operation, hut in any event all non-adherent materials should he removed; in the case of the walls, hy hosing or brushing, and from the floor of the tank, hy flushing with large quantities of water followed hy sweeping with a stiff broom,or scraping with a shovel, as indicated. Even after these procedures, small quantities of sludge will remain about the girders and rivets and in the seams. The supervisor should he certain that the work has been done as thoroughly as practi.1 --.T -'? ' -co of cable and that the tank is free from odorsof the compound &r .dust: before repairmen 'h are permitted to enter it. Dismantling of tanks dismantling and transportation of tanks is a special problem. The Ke 0022929 -11- following procedures designed to eliminate the hazards from Sthyl Sluid are recom- mended, and are to he used in addition to the precautions usually taken: (l) Tanks should he thoroughly cleaned and sludge disposed of in accordance with instructions. ^2ir, If the tank is to he dismantled, the roof should he removed and such other plates as alre necessary to secure adequate ventilation. All portions v* of the metal including those plates that have been removed should he covered itfith a A coating of light oil, to elminate dust. The side plates and then t he bottom are dismantled. (If the tank has been thoroughly cleaned, special precautions are not necessary for these operations.) hi Dismantled tank plates should he wire-brushed, sand-blasted, or burned out, depending upon which procedure can he carried out most easily. If burned off, air-line respirators should he used inthe final cleansing v of the plates. '3*te*-aasks are adeouate in case scraping or brushing is done. / After any of these types of cleaning, the material can he handled without special precautions. /- y x A certain number of small tanks.after a more or less complete cleaning ) > " ' \ are transported in toto for use in gasoline service elsewhere.(J_Prdinarily these need no particular supervision other than that of the cleaning operation and disposal of 0022930 the sludge. If, howSver, it is possible for the tank to be entered, any manheads or other openings which would permit entrance should be blanked off before the tank is Li released. f 'V,-/. '' ; /l/.- >'-C A certain number of small tanks are sold to second-hand dealers and nay be resold into gasoline service, junked, or converted to other uses. At the present t me we know very little about the fate of a large number of these tanks. In such cases the safety engineer should inform himself, if possible, of the cir cumstances and the use to which the tank will be put, and should inform the safety department fully concerning it. Tanks which have contained leaded gasoline must not be used subsequently for storage of drinking water, food, and the like. This applies equally to tank cars or tank trucks, as no satisfactory practical way has yet been found to insure complete removal of all traces of lead from such containers Equipment The safety engineer should have the necessary equipment to take care of normal installations and tank cleaning operations as well as any emergencies that may arise in the transportation or handling of Ethyl I'luid. Eor his protection and for loan to others, where situations warrant it, the following equipment is provided: 2 Long-sleeved white coveralls fitting close tothe neck; 2 White washable caps or hats that can be worn with the respirators; 2 Suits of long underwear of cotton or wool; 2 Pairs of white socks; 2 White sweaters (pullovers or sweat shirts) that can be worn over the underwear in cold weather; 1 Pair of white, acid-proof gloves, forearonj-ength; 1 Pair of knee-lengt^r^be'r'Foots;'' 2 Towels ^ .....-- 1 Pair of goggles with shatterproof glass; 1 Dust respirator; ^ KE 0022931 -13- 1 Canister mask; 1 Air-line hose mask consisting of blower, 3 lengths of air hose, safety rope, safety belt and trunk for the above; 1 Vapor-proof flashlight of approved type; 1 Spark-proof scraper; 1 Tool kit containing the follovfing: 1 Screw driver, Lenox ^6 . 1 Pair of pliers. Crescent Tool** 925-8 1 Brass hammer, AMPCO 18" Crescent wrench 2 7/8 x 1-1/16 open-end wrenches, Williams #*34. 2 1-l/lG x 1-1/4 open-end wrenches, Billings ^37-1140 1 Adjustable spanner wrench, 2" to 4-3/4", Williams 1 Eductor nozzle wrench . 1 18" TBIMO wrench 1 Pair of shears, f T412 Cresent Tool 1 Package of emery cloth 1 Wire brush , 1 3-1/2 x l/4 Ashcroft Comp, gage, 30"-30-f\ Misc. packing and gasket material 1 Stencil for blending tanks 1 Stencil brush P.eports and record forms; Quarterly inspection report blanks Permanent record cards :Safety Activities. report form ' Supply of medical regulations for Tank equipment Drum to weigh'tank Drum equipment Complete set of blue prints Supply of forms, INSPECTION REPORT Oil ETHYL FLUID SHIPMENT Poison placards for tank cars Red t age reading DRUM TO BE REPAIRED The tools are for use in demonstration and may be loaned to workmen under supervision. It is not intended that safety engineers engage in work for the customer companies. All clothing, protective devices and other equipment must be kept in good condition by proper care and replacement when necessary. Care of equipment1' Face pieces of mask should be washed thoroughly with soap and water after 0022932 use. If contaminated "by sludge they must he cleaned with kerosene and the ke'roseiie removed with soap and water. If the mask has "been used hy some person other than the safety engineer the face piece can he sterilized effectively hy the use of 2^ Iysol in water,or a similar antiseptic solution. If this equipment- is subject to frequent loan, an extra face piece will he provided for the exclusive use of the safety engineer. The canister mask should he kept in its hox when not in use, and the canister sealed to delay deterioration. A time record of the use of each canister should he kept hy the safety engineer, and replacements made at the same intervals as required of licensees. The face piece may he kept in a cloth or paper hag while in storage or when not in use. Safety hose must he cleaned before it is put away. If it has been contaminated heavily with sludge, all adherent material must he removed hy washing with kerosene followed hy large amoflnts of water and the hose should he dried thoroughly before it is replaced. Careful and frequent inspection of the air-line hose is necessary, and the user should at all times he on his guard for the appearance of odor of gasoline or lead compounds inthe air stream. It is not safe to rely upon the external appearance of hose lines as evidence of their resistance to penetration hy gasoline or tetraethyl lead. Odor inthe air stream may he due to a leaking connection or a faulty gasket. If, after these have been checked, the odor persists, a new hose should he substituted and the old :hose shipped to the Kettering laboratory 0022933