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5.1.3.2.2 Training

The CSB also examined Harcros’ training program and determined
that it was deficient in effectively communicating the importance
of the critical safety steps that did not align with work practices
on the day of the incident. As part of its training program, Harcros
requires drivers to complete various tasks included on a tanker
training log; the driver’s trainer must observe and initial that
they have been completed. Two of these tasks include ensuring

“customer’s piping is to the correct storage vessel” and “constant
monitoring of the connections and tanker during the unloading
process to abate leaks or any other malfunction that might
arise.” Although training records indicate that the truck driver Figure 16. Harcros CTMV (right) and emergency shutoff switch (left)
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was current on all Harcros training requirements, he did not (Sources: Harcros and CSB).
mention when interviewed by the CSB that the procedure
called for checking to ensure a correct connection. and 49 C.F.R. § 172.704(c)(2). Accordingly, drivers should be

Nor did he mention that he was responsible for intimately familiar with the location of emergency remote
continuously monitoring the unloading process. shutoffs, as well as with how they function. Had Harcros
provided adequate training, such as by requiring its drivers to
In reviewing Harcros’ training documentation, the CSB identified practice locating and triggering the emergency remote shutoff
another area that may have contributed to the incident: in simulations, the driver might have attempted to trigger the
the tanker training log indicated that the driver was aware emergency shutoff switch, rather than attempt to close the
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of the location of a pneumatic emergency shutoff switch valve at the back of the trailer. Without adequate training, no
for the internal valve that would stop the flow of product, at amount of reading or checking would be likely to produce
the front of the trailer ; however, the CSB found that the the appropriate response reliably in a real emergency.
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driver did not trigger the emergency shutoff switch, despite
being in the cab at the time of the incident (Figure 16). 5.1.3.3 COLLABORATION IN PROCEDURE DEVELOPMENT
The CSB determined it is critical for facilities and chemical
U.S. Department of Transportation (DOT) regulations for driver distributors to identify and assess risks associated with unloading
training require, in part, that for the operation of cargo tanks operations and collaborate to develop and/or agree upon
or vehicles with portable tanks with a capacity of 1,000 gallons procedures that address those risks. Such collaboration ensures
or more, training include “operation of emergency control that responsibilities are clearly defined. For example, on the

features of the cargo tank or portable tank.” This training day of the incident, the truck driver opened the valve to the fill
82
must occur once every three years per 49 C.F.R. § 177.816(d) line although, according to MGPI’s procedures, the operator
was supposed to. This action conflicted with Harcros’ procedure.
79 The driver had most recently completed his training in 2016, as indicated on
the tanker training log. The CSB also found that the driver was current with his Had the procedures been
Facilities and developed together,
Commercial Driver’s License hazmat and tanker endorsements.
80 Pneumatic means containing or operated by air or gas under pressure. or agreed upon by
81 The Harcros tank trailer was a Department of Transportation 412 version, which is chemical distributors
required to have stop valves capable of closing the tank outlet within 30 seconds of should collaborate both parties, the roles
actuation and of being remotely actuated. 49 C.F.R. § 178.345 and 178.348 (2017).
According to Harcros, four devices on the Harcros cargo tank could have stopped the to develop, or agree might not have been
flow of material from the trailer: (1) a manual external main valve located at the rear switched. Procedures
of the cargo tank; (2) a manual internal valve located at the rear of the cargo tank; (3) upon, procedures for
the pneumatic emergency shut off at the front of the cargo tank; and (4) a manual should also establish
valve on top of the cargo tank, near the dome. chemical unloading
82 49 C.F.R. § 177.816(b)(1) (2017). a process that requires
22 CSB MGPI Processing Case Study