“WHAT ARE you going to do to help me out here?” asked the fire department incident commander (IC) from a central Tennessee truck stop parking lot, where a tanker rig was leaking acetone. He had just finished describing the situation, including the defensive actions his department had taken, and he needed to know what was next. As an employee of the company that had sent the cargo tank, I had already spoken to our central dispatch office, and I had a feeling my answer wasn't going to satisfy him.
I told him that we were dispatching two teams of responders, the first of which was due to arrive in minutes. So far, so good. The IC then asked when the rescue tanker would be arriving for offloading. I told him I was waiting for a status update and gave him my best estimate — four hours.
“What do you mean four hours?” the IC asked, along with a few other words I can't repeat. “This stuff might be in the sewer in four hours — we need something now!” While the IC's style may have lacked finesse, his concerns were genuine. My experience at numerous incidents told me to look at it from his perspective: 7,000 gallons of acetone entering the sewer system and placing his firefighters, the community, and the truck stop in danger of leaving the planet.
The cargo tank in question was an insulated MC307 with a little age on it, and according to the chief, it was losing about 20 drops a minute of acetone into a metal bucket. Due to the insulation on the tank and the outer jacket, the source of the leak wasn't visible.
To bring the incident into perspective, I let the IC know that since the leak wasn't the result of an accident and acetone isn't a harsh corrosive, the leak was almost certainly the result of a bad gasket or a stress fracture no thicker than a fingernail and no longer than a finger. I assured him that if we didn't move the tank or allow additional pressure to be applied, then the leak would maintain its rate of 20 drops per minute until we were prepared to offload the acetone.
Evidently, that explanation made enough sense to satisfy the IC's questions. Shortly after our conversation, the cargo company's responders arrived and transferred the product to the rescue tank with little fanfare. Still, this experience made me realize the need for our responders to address the perspective of the fire service. While I considered them to be the best in the business — they were even trained in the Incident Command System to better work with emergency agencies — it was clear that we had some work to do on their communication skills.
Two Cultures
When a fire department responds to a hazmat incident alongside a tank truck carrier, chemical manufacturer, or environmental contractor, the partnership can be compared to an arranged marriage. No one counted on getting married, but circumstances have thrown them headlong into a relationship that must be successful to expedite the response and ensure everyone's safety. Like many arranged marriages, the newlyweds come from very different cultures with their own customs, and while they share the same language, there are bound to be breakdowns in communication and misunderstandings.
Throughout years of service with county hazmat teams, local emergency planning committees, and various other private and public organizations, I've had a unique opportunity to view and participate in both the fire service and transportation community cultures.
Within the fire service, there's an obvious brotherhood of committed individuals who are prepared to wake from a dead sleep and rise to a performance level in seconds that would astonish and amaze the common man. With the exception of mutual-aid responses to other communities, fire districts or townships delineate a department's area of responsibilities. There's also a well-defined chain of command in the fire service and crisis management practiced daily through the incident command system.
Like the fire service, companies in the tank-truck carrier culture range from large to small, and they may consist of a highly sophisticated hierarchy or a small family business. The transportation business is competitive and covers an extensive territory, so a company's offices or terminals usually are spread out across vast distances. Some carriers operate only in a specific area or region, while others are limited only by the roads they travel. Unlike the fire service, a life-threatening crisis isn't a daily event, and most incidents are minor in nature. Although carriers have crisis-management plans in place that may have been tested, their daily implementation is highly unlikely.
In essence, we have two very different cultures that must understand one another to effectively manage a cargo tank hazmat incident. After all, their goals in regard to mitigating the incident will differ very little: Both cultures want the incident concluded efficiently and safely. Therefore, it's in everyone's best interest to get used to putting themselves in the other guys' shoes to gain an appreciation of the other culture's challenges.
For example, if the owner of a small carrier company is notified in the middle of the night that one of his tankers has just been involved in a catastrophic event, he's in the midst of a situation he may have never experienced. Most of the public doesn't spring out of bed, ready to assume true proficiency. Add the deeply personal loss of a friend or employee, and his competency may decline further.
However, an IC can rest assured that the carrier representative will recover and respond according to the company's crisis management plan. Even so, the company's resources may be limited by both distance and equipment. By understanding these factors and the confusion of someone operating in unfamiliar territory, an incident commander can adjust the planning and operations to accommodate logistics and resources.
Back to Basics
You may be wondering how your department can better work with the carrier and shipper to expedite their response and conclude the event safely. If you have a hazmat team or a mutual aid agreement that gives you access to a team, the basics are already in place.
The hazmat team will start by implementing whatever procedures are specified by your department's emergency response plan, including notification of the carrier and shipper through Chemtrec at 800-424-9300. If your department's response plans call for contacting a local office and not Chemtrec, you may not get the full benefit of the carrier's and shipper's response plans.
After notification, you may be dealing with the shipper or manufacturer of the material, the carrier or transporter of the material, or an environmental contractor who represents the shipper or carrier. It's helpful to keep in mind each of these parties' areas of expertise. The manufacturer will be intimately familiar with the product, the carrier will know the vessel, and the contractor's expertise will need to be clarified. Don't be afraid to ask questions, and never assume that they're god-like beings incapable of making mistakes. Although they may know more than you, they're not perfect.
Regardless of incident type, it's inevitable that the hazardous material will eventually need to be transferred from the damaged cargo tank to a rescue tank. If you want to expedite the incident's conclusion, it's in everyone's interest to confirm specific information about the damaged cargo tank and designated rescue tank as early as possible.
To understand the importance of this step, let's go back to our earlier example. You're talking to a carrier representative who, while operating in an uncomfortable state of mind, is preparing to dispatch a rescue tank and driver to your location. Normally, the dispatching of a driver and tank is a simple process. The shipper places the order, and the carrier processes the order and screens the product to ensure that the tank which will be used to haul the product is authorized under federal regulations, is compatible with the product, and has the capacity to carry all of the product. However, an emergency situation isn't a common order, and the potential to receive an inadequate rescue tank is present.
So how can you help keep tabs on the carrier and guarantee an adequate rescue tank? Each cargo tank is equipped with what's called a specification plate, located on the front third of the trailer. For trailers manufactured after July 1985, the plate will be on the driver's side of the trailer. The specification plate will provide responders with a wealth of information that will assist them in assessing the level of danger present and ensuring that a transfer will be possible. Information on this plate includes:
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Year of manufacture
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Trailer specification, such as MC307, DOT407 or MC312
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Construction materials, such as stainless steel or aluminum
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Temperature rating or maximum allowable temperature
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Design pressure in psi or maximum allowable working pressure (MAWP)
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Compartment capacities in gallons (front to rear, left to right)
If the specification plate isn't accessible, you should note the trailer unit number and ask the carrier to provide you with this key information. Then ask for these same six key pieces of information from the rescue tank. If they match up, all is well. If the information on the damaged vessel and rescue tank don't agree, it's time to start asking questions.
While it may be possible to transfer the product into a tank with a different specification, as a general rule of thumb, it's a good idea to look for a tank with the identical specification, construction materials, temperature rating, and equal or greater capacity. Moreover, putting hazardous material into a tank that isn't designed to hold the product could be disastrous. In any case, don't wait for the rescue tank to arrive before you start comparing specification plates, or your day may get a lot longer.
Other information on the specification plate will give you an idea of what may be occurring on the inside of the vessel. If the tank's MAWP is limited to 25 psi and the pressure gauge on top of the tank indicates that the pressure is very close to the MAWP, this may be an indication that a pressure relief device is about to go off. If the vessel's pressure is rising, it may be the result of the polymerization or self-heating of the product. This is key information that needs to be communicated to the manufacturer of the product, who in turn will be able to advise you on the proper course of action — evacuate now!
Preparation and Planning
The best way to handle any type of hazmat incident is to be prepared. Tank truck carriers are experts in transporting hazardous materials, and they focus on preventing accidents. On the other hand, emergency services providers are experts in crisis management.
That's not a bad thing. If my house catches on fire, I don't want to see a tank truck pull up in the driveway, and I'm not going to call the fire department for my next load of home heating oil. However, I do think it's high time for us to explore each other's cultures and challenges.
During my career, I've seen industry make great strides with Responsible Care and Transportation Community Awareness and Emergency Response (TransCAER) programs, and many bridges have been built. It goes without saying that many of our nation's firefighters have received invaluable training, but it's time for the tank truck industry to raise the bar.
Key personnel within each company should pursue the same awareness and basic operations training as first responders within the fire service. After a few days at the local fire station, tank truck carrier employees, at the very least, are going to make a few friends. Ideally, they'll be better prepared to work with the fire service.
From the perspective of the fire service, I would encourage attendance at any TransCAER programs available in your area. Take a good look at your community and identify any local tank truck carriers who may have local offices. If you're having difficulty finding one, contact the National Tank Truck Carriers at 703-838-1960. Invite local representatives from carriers to sit in on your first responder classes, and let them know that they're welcome. Finally, visit your local carriers and explore their resources and any training opportunities that they may have for you. Some of the most important training that I have ever received was informal and came directly from the mouth of a driver.
Dave Wolfe is a founding partner of Safe Transportation Training Specialists, a Carmel, Indiana-based company that specializes in both tank truck driver training and tank truck emergency response training products and services. He is a 20-year transportation veteran and most recently served as a division safety manager and general manager of training for Chemical Leaman Tank Lines. A member of the Hamilton County (Indiana) HazMat Team, Wolfe is also a member of the Indiana Response Commission's Training Committee and secretary of the Indiana Alliance of Hazardous Materials.