Tanker: Tanker Attendance

11 questions in the bank cover this topic. Everything below is drawn from the sources those questions cite.

Sources: 49 CFR 177.834, 49 CFR 177.837, 49 CFR 177.840

What you need to know

177.834(i)(1) requires a qualified person in attendance at all times during loading, and puts the duty to ensure that on whoever is responsible for the loading.

177.834(i)(1) creates two duties, so you cannot discharge it by assuming somebody is watching.

A cargo tank must be attended by a qualified person at all times when it is being loaded. The person who is responsible for loading the cargo tank is also responsible for ensuring that it is so attended.

49 CFR 177.834

177.834(i)(3)(i) sets 25 feet, which is 7.62 m, and adds that the person must be alert with an unobstructed view of both the tank and the delivery hose as far as practicable.

Note this differs from the 100-foot figure in 397.5(d)(1), which covers attending a parked hazmat vehicle rather than a transfer. Alertness and the view of both tank and delivery hose are required so far as practicable.

the qualified person is within 7.62 m (25 feet) of the cargo tank. The qualified person attending the unloading of a cargo tank must be alert and have an unobstructed view of the cargo tank and delivery hose to the maximum extent practicable during the unloading operation

49 CFR 177.834

177.834(i)(3)(ii) permits remote observation by video or instrumentation, but with conditions: unobstructed camera views of all valves, hoses, domes and relief devices, surveillance at least equal to a human observer, and remotely operable shut-off valves.

Both routes carry demanding conditions on what the system must show.

The qualified person observes all loading or unloading operations by means of video cameras and monitors or instrumentation and signaling systems such as sensors, alarms, and electronic surveillance equipment located at a remote control station

49 CFR 177.834

177.834(i)(3)(ii)(C) requires immediate termination.

Remote attendance is only acceptable while the monitoring that substitutes for a human observer is actually working.

Upon loss of video monitoring capability or instrumentation and signaling systems, loading or unloading operations must be immediately terminated

49 CFR 177.834

177.834(i)(2) ends the obligation only when all three conditions are met: delivery complete, the cargo tank placed on the consignee's premises, and the motive power removed from the tank and off the premises.

All three must be true: the removal is of the motive power from both the tank and the premises.

the carrier's obligation to ensure attendance during unloading ceases when

49 CFR 177.834

177.837(d) sets two distances and an observation interval.

The 25-foot figure matches the general hazmat attendance distance in 177.834(i)(3), but the 150-foot and five-minute requirements are specific to this operation. You must also observe both the tank and the receiving container at least every five minutes.

the qualified person attending the unloading operation must remain within 45.72 meters (150 feet) of the cargo tank and 7.62 meters (25 feet) of the delivery hose and must observe both the cargo tank and the receiving container at least once every five minutes

49 CFR 177.837

177.840(o)(2) drops the five-minute observation cycle that smaller tanks get under (o)(1) and instead requires continuous presence within those distances while the valve is open.

A larger tank releases more, faster. The larger tank also loses the five-minute observation alternative, so the distances apply the whole time the internal self-closing stop valve is open.

For a cargo tank with a capacity greater than 13,247.5 L (3,500 water gallons), excluding delivery hose and piping, the qualified person attending the unloading operation must remain within 45.72 m (150 feet) of the cargo tank and 7.62 m (25 feet) of the delivery hose when the internal self-closing stop valve is open.

49 CFR 177.840

25 feet, which is close enough to reach a valve before a spill becomes a release.

The regulation gives it as 7.62 m with the foot figure alongside. None of the figures offered is the one the rule gives.

the qualified person is within 7.62 m (25 feet) of the cargo tank

49 CFR 177.834

Presence is not attendance.

The rule names two things: alert, and an unobstructed view of both the tank and the delivery hose, because the hose is where most failures show first. Of both the tank and the delivery hose, so far as practicable.

The qualified person attending the unloading of a cargo tank must be alert and have an unobstructed view of the cargo tank and delivery hose to the maximum extent practicable during the unloading operation

49 CFR 177.834

177.834(i)(3) allows a human attendant or a remote system, but the remote route is held to a demanding standard: the camera must see every valve, hose, dome and relief device, and instrumentation must match a human observer.

the qualified person is within 7.62 m (25 feet) of the cargo tank

the camera must be mounted so as to provide an unobstructed view of all equipment involved in the loading or unloading operations, including all valves, hoses, domes, and pressure relief devices

the system must provide a surveillance capability at least equal to that of a human observer

49 CFR 177.834

177.834(i)(1) creates two duties rather than one.

A qualified person must attend, and the person responsible for loading must ensure that attendance happens, so you cannot discharge it by assuming somebody else is watching. Two duties, not one.

A cargo tank must be attended by a qualified person at all times when it is being loaded. The person who is responsible for loading the cargo tank is also responsible for ensuring that it is so attended.

49 CFR 177.834

Check yourself

• Who must attend your cargo tank while it is being loaded, and who is responsible for making sure of it?

• How close must a qualified person be to count as attending your cargo tank?

• Can the 25-foot attendance requirement be met remotely?

• What is required when a remote monitoring system fails during unloading?

• When does a carrier's obligation to ensure attendance during unloading end?

• What attendance applies when unloading a combustible liquid from your cargo tank?

• How does attendance differ for your cargo tank over 3,500 water gallons?

• How close must the qualified person stay to your cargo tank during loading?

• Beyond being nearby, an attendant during unloading must be ______.

• What can satisfy the attendance requirement?

• Your cargo tank is being loaded. Who must attend, and who must make sure that happens?

Answers are in the practice test for this topic.