Major Work Activities for Tank Cleaning Operations
The following information provides some of the
requirements and additional guidance to employers and employees who participate in activities related
to entry into petroleum and petrochemical ground storage tanks.
Degassing and vapor control, collection or dispersal.
Product removal and disposal.
Equipment and materials.
Electrical equipment must be
approved for its use and used as listed or labeled. In addition, most
tanks must be classified as a hazardous location due to the
flammable/combustible materials they contained. In such hazardous locations,
equipment must meet additional requirements. [1910.307]
Rescue and emergency plans and designated responders. [1910.146(k)]
Tank pre-cleaning meeting.
Additional InformationFor additional information on general safety and health
concerns, see OSHA's
Safety and Health Topics Pages on:
Before the initial work assignment begins, the employer must provide proper
training for all workers who are required to work in permit spaces. After the
training, employers must ensure that the employees have acquired the
understanding, knowledge and skills necessary to safely perform their duties.
Additional training is required when:
The job duties change;
A change occurs in the permit space program or the permit space operation
presents any new hazard; and
An employee's job performance shows deficiencies. In addition to this
training, rescue team members also require training in CPR and first aid.
Employers must certify that this training has been provided.
After completion of training, the employer must keep a record of employee
training and make it available for inspection by employees and their authorized
representatives. The record must include the employee's name, the trainer's
signature or initials and dates of the training.
Assigned Duties
Authorized Entrant
Authorized entrants are required to:
Know space hazards, including information on the means of
exposure such as inhalation or dermal absorption, signs of symptoms and
consequences of the exposure;
Use appropriate personal protective equipment properly;
Maintain communication with attendants as necessary to
enable them to monitor the entrant's status and alert the entrant to evacuate
when necessary;
Exit from the permit space as soon as possible when:
Ordered by the authorized person;
He or she recognizes the warning signs or symptoms of
exposure;
A prohibited condition exists; or
An automatic alarm is activated.
Alert the attendant when a prohibited condition exists or
when warning signs or symptoms of exposure exist.
Emergencies
Rescue Service Personnel
The standard requires employers to ensure that responders are capable of
responding to an emergency in a timely manner. Employers must provide rescue
service personnel with personal protective and rescue equipment, including
respirators, and training in how to use it. Rescue service personnel also must
receive the authorized entrants training and be trained to perform assigned
rescue duties.
The standard also requires that all rescuers be trained in first aid and CPR. At
a minimum, one rescue team member must be currently certified in first aid and
CPR. Employers must ensure that practice rescue exercises are performed yearly
and that rescue services are provided access to permit spaces so they can
practice rescue operations. Rescuers also must be informed of the hazards of the
permit space.
Harnesses and Retrieval Lines
Authorized entrants who enter a permit space must wear a chest or full body
harness with a retrieval line attached to the center of their backs near
shoulder level or above their heads. Wristlets may be used if the employer can
demonstrate that the use of a chest or full body harness is not feasible or
creates a greater hazard.
Also, the employer must ensure that the other end of the retrieval line is
attached to a mechanical device or a fixed point outside the permit space. A
mechanical device must be available to retrieve someone from vertical type
permit spaces more than five feet (1.524 meters) deep.
MSDS
If an injured entrant is exposed to a substance for which a Material Safety Data
Sheet (MSDS) or other similar written information is required to be kept at the
worksite, that MSDS or other written information must be made available to the
medical facility personnel treating the exposed entrant.
Note: These are NOT OSHA regulations. However, they do
provide guidance from their originating organizations related to worker
protection.
American Petroleum Institute
Recommended Practice 2026, Safe Access/Egress
Involving Floating Roofs of Storage Tanks in Petroleum Service.
(2006, June).
Recommended Practice 2219, Safe Operating Guidelines
for Vacuum Trucks in Petroleum Service. (2005, November).
Employers should establish, and tank cleaning entry
supervisors should implement, procedures for removing recoverable product from the tank that
cover items such as the following:
Area protection, potential sources of ignition and electrical
classification.
Bonding and grounding.
Entry onto fixed and floating roofs.
Removing recoverable product through product lines.
Recoverable product removal by suction pump through fixed connections.
Recoverable product removal by flotation through open manholes or
connections.
Recoverable product removal by vacuum pump.
Recoverable product removal through open manholes.
Note: These are NOT OSHA regulations. However, they do
provide guidance from their originating organizations related to worker
protection.
American Petroleum Institute
Recommended Practice 2003, Protection Against
Ignitions Arising Out of Static, Lightning, and Stray Currents.
American Petroleum Institute (API), (1991, December).
Employers must develop and implement the
isolation means, procedures, and practices necessary
for safe tank entry. Before entry is made, employers must document the
completion of these measures and entry supervisors must verify that all
procedures have been followed before endorsing the permit.
"Isolation" means the process by which a permit space is removed from service
and completely protected against the release of energy and material into the
space by such means as: blanking or blinding; misaligning or removing sections
of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of
all sources of energy; or blocking or disconnecting all mechanical linkages.
The isolation plan should address:
Tank
isolation requirements
Tank suction and discharge lines
Other tank lines, appurtenances and connections
Energy sources - electrical, mechanical and pressure
Cathodic protection systems
Vapor recovery systems
Tank foam protection system
Tank gauging and overfill protection alarm system
Interior devices such as mixers, etc.
Verification of isolation prior to issuing permits
Vapor and gas freeing occurs after all product, tank
bottoms and residue has been removed from a tank and the tank has been properly
isolated. Employers must establish and implement safe vapor and gas freeing
procedures. Acceptable entry conditions must be specified and verified through
appropriate testing and monitoring, prior to tank entry.
Procedures should include:
Vapor and gas freeing (degassing) methods
Identification and control of ignition sources including bonding and
grounding
Elimination and/or control of toxic hazards including, but not limited to,
H2S, nitrogen, pyrophorics, CO2, etc.
Blower and educator selection and location
Requirements for vapor and gas freeing (degassing) the tank
Collection, control or dispersal of vapors and gas
Purging, inerting, flushing, or ventilating the tanks as necessary to
eliminate or control atmospheric hazards.
Additional Information
Exposure to Hazards Associated with Temporary
Enclosures. OSHA Safety and Health Information Bulletin, (2002, May
30), 31 KB
PDF, 4 pages.
Hazards of Nitrogen Asphyxiation. U.S. Chemical
Safety and Hazard Investigation Board, Safety Bulletin, (2003, June), 218 KB
PDF, 10 pages. Provides additional attention to the
continuing hazards of nitrogen asphyxiation.
Accessibility Assistance:
Contact the OSHA Directorate of Cooperative and State Programs at 202-693-2200 for assistance
accessing OSHA PDF materials.
The employer must specify acceptable entry conditions and
verify that the conditions in the tank are acceptable for entry throughout
entry. [1910.146(d)(5)]
In addition, conditions around, on top of and below may need to be monitored to
assure that safe levels exist.
Eye Safety. National Institute for Occupational Safety and Health (NIOSH)
Safety and Health Topic.
Hearing Loss Prevention. National Institute for Occupational Safety and
Health (NIOSH) Safety and Health Topic. Provides references for noise
solutions in the workplace.
Note: These are NOT OSHA regulations. However, they do
provide guidance from their originating organizations related to worker
protection.
American Petroleum Institute
STD 2015, Safe Entry and Cleaning of Petroleum
Storage Tanks. (2001,
August).
Recommended Practice 2016, Guidelines and
Procedures for Entering and Cleaning Petroleum Storage Tanks, First Edition.
(2001, August).
Recommended Practice 2219, Safe Operating
Guidelines for Vacuum Trucks in Petroleum Service. (2005, November).
Publication 2217A, Guidelines for Work in Inert
Confined Spaces in the Petroleum Industry. (2005, January).
Steel Tank Institute (STI) and Steel Plate Fabricators
Association (SPFA)
Publication 04-03 Tank Builders Scaffold Guidelines
(English).
Publication 04-04 Tank Builders Scaffold Guidelines
(Spanish).
Tank cleaning entry supervisors must determine, administer and
implement safe work procedures and appropriate safe limits for employee's exposure
to hydrocarbon vapors and gases and toxic gases, and required oxygen
concentrations both when working outside of tanks and when entering and working
in tanks during tank cleaning operations, in accordance with applicable
regulations and facility confined space entry requirements.
Falls from Elevation.
National Institute for Occupational Safety and Health (NIOSH) Safety and
Health Topic.
Lockout/Tagout. OSHA Fact Sheet,
(2002), 212 KB
PDF, 2 pages. A 355 KB
PDF (Spanish version) is also available.
Personal Protective Equipment
Eye Safety. National Institute for Occupational Safety and Health (NIOSH)
Safety and Health Topic.
Hearing Loss Prevention. National Institute for Occupational Safety and
Health (NIOSH) Safety and Health Topic. Provides references for noise
solutions in the workplace.
Note: These are NOT OSHA regulations. However, they do
provide guidance from their originating organizations related to worker
protection.
American Petroleum Institute
STD 2015, Safe Entry and Cleaning of Petroleum
Storage Tanks. (2001, August).
Recommended Practice 2009, Safe Welding and Cutting
Practices in Refineries, Gasoline Plants, and Petrochemical Plants, Seventh
Edition. (2002, February).
Recommended Practice 2027, Ignition Hazards Involved
in Abrasive Blasting of Atmospheric Storage Tanks in Hydrocarbon Service.
(2002, March).
Publication 2207, Preparing Tank Bottoms for Hot
Work. (1998, September).
Steel Tank Institute (STI) and Steel Plate Fabricators
Association (SPFA)
Publication 04-01 Basic Safety Rules for Fabrication,
Field Erection, and Warehousing (English).
Publication 04-02 Basic Safety Rules for Fabrication,
Field Erection, and Warehousing (Spanish)
Safe work procedures for working inside and around a tank should address:
Permit requirements
Ventilation
Hot work
OSHA Requirements
1910.252, Welding, Cutting, and Brazing, general requirements.
Lockout/Tagout. OSHA Fact Sheet, (2002), 212
KB
PDF, 2 pages. A 355 KB
PDF (Spanish version) is also available.
Personal Protective Equipment
Eye Safety. National Institute for Occupational Safety and Health (NIOSH)
Safety and Health Topic.
Hearing Loss Prevention. National Institute for Occupational Safety and
Health (NIOSH) Safety and Health Topic. Provides references for noise
solutions in the workplace.
Accessibility Assistance:
Contact the OSHA Directorate of Cooperative and State Programs at 202-693-2200 for assistance
accessing OSHA PDF materials.
De-isolation and Returning
the Tank to Service
Prior to returning a tank to service, employers should
develop, and tank cleaning entry supervisors should implement, procedures for tank
inspection and preparation, including the following:
Inspection (interior and exterior)
De-isolation
Permits
Preparation
Additional Information
After Katrina: Precautions Needed During Oil and
Chemical Facility Startup. U.S. Chemical Safety and Hazard
Investigation Board, Safety Bulletin, (2005, September), 105 KB
PDF, 2 pages. Provides attention to the hazards of oil
and chemical facility startup.
Accessibility Assistance:
Contact the OSHA Directorate of Cooperative and State Programs at 202-693-2200 for assistance
accessing OSHA PDF materials.
Note: These are NOT OSHA regulations. However, they do
provide guidance from their originating organizations related to worker
protection.
American Petroleum Institute
Recommended Practice 2026, Safe Access/Egress
Involving Floating Roofs of Storage Tanks in Petroleum Service. (2006, June).
Tank cleaning entry supervisors should be aware of the
requirements to conduct a thorough formal safety check, inside and outside the
tank, prior to recommissioning a tank, using a written checklist signed by
qualified persons. Employers should develop procedures and assign
responsibilities for recommissioning tanks following tank cleaning operations
and after conducting a tank recommissioning safety check. If it is necessary to
enter the tank to conduct the safety check, entry must be conducted under the
permit-required confined spaces standard (1910.146).
Procedures should address:
Refilling
Atmospheric hazards
Static hazards associated with tank refilling, gauging and sampling
Entry onto floating roofs and fixed roofs
Precautions and requirements
Additional Information
After Katrina: Precautions Needed During Oil and
Chemical Facility Startup. U.S. Chemical Safety and Hazard
Investigation Board, Safety Bulletin, (2005, September), 105 KB
PDF, 2 pages. Provides attention to the hazards of oil
and chemical facility startup.
Accessibility Assistance:
Contact the OSHA Directorate of Cooperative and State Programs at 202-693-2200 for assistance
accessing OSHA PDF materials.
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