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8.2.2 SHARED RESPONSIBILITY
sulfuric acid fill line and Harcros sulfuric acid delivery hoses.
PHMSA’s mission to protect people and the environment by These couplings share the same unusual size and shape, such that
advancing the safe transportation of energy and other hazardous only the correct delivery hose can be connected to the sulfuric
materials is accomplished, in part, by enforcing the HMRs and acid fill line. The couplings are also colored differently from all
issuing guidance. Although PHMSA’s mandate focuses on the other couplings at the Mod B unloading area (Figure 18).
transportation aspect of hazardous materials, PHMSA concludes,
like the CSB, that safe loading/unloading of hazardous materials
203
is a shared responsibility between the carrier and facility. The
PHMSA Guide provides practical applications of best practices
to clarify where facility personnel should play a primary role,
such as in training and evaluation, risk assessment, emergency
response, and operating procedures. The CSB concludes
that facilities also play a vital role in ensuring chemicals are
unloaded safely and that lessons learned and recommendations
in this Case Study will augment PHMSA and other agency

guidance and regulations to prevent similar incidents.

The two-page PHMSA Companion Guide provides questions, Figure 18. New coupling on the Mod B sulfuric acid fill line
mostly geared toward carrier personnel, to ask before loading/ (Source: MGPI).
unloading. Facilities receiving chemicals will benefit from not only
existing PHMSA guidance, but also a shorter reference guide that
facility personnel can refer to before loading/unloading chemicals.
As such, the CSB has developed “Recommended Practices for
Facilities Receiving Chemicals by CTMVs” (Appendix B) that will

be published as a companion document to this Case Study.

9.0 MGPI AND HARCROS
POST-INCIDENT CHANGES

Immediately following the incident, MGPI made some temporary
changes to its transfer equipment and unloading area to reduce
the potential for a similar incident, until more permanent

changes could be made. These included placing dedicated
locks with separate keys on the different fill line caps, replacing Figure 19. Separation of unloading connections with secure cages
the caps on the fill lines with caps that use a different locking around connection points at Mod B (Source: MGPI).
mechanism, placing new (or more securely affixing existing)
pipe markers closer to fill line connection points and elbows, After making the immediate modifications described
placing new color-coded tags on the fill lines, and updating the above, MGPI also made a number of other engineering
chemical unloading procedures. Additionally, Harcros worked and process safety changes at Mod B, including:
with MGPI to select and install new couplings on the Mod B
• Chemical unloading connection adjustments (a

minimum of three-foot separation between each
203 Cargo Tank Motor Vehicle (CTMV) Loading/Unloading Operations: Recommended
Best Practices Guide, pp 13. https://hazmatonline.phmsa.dot.gov/services/ unloading connection with a secure cage around each
publication_documents/CTMV%20Guidelines.pdf (accessed December 7, 2017).
40 CSB MGPI Processing Case Study