20110825_ST 018_Minimum_Safety_Instructions_for_Cargo_securing_ENG' Health & Safety Standard Ref.: ST 018 Issue: 25.08.2011 Vers.: 0 Controlled Circulation Name: Minimum Safety Instructions for Cargo securing Drawn up by: Checked by: Approved by: Cargo securing project working teams Cargo securing project steering committee F. Haers The only officially available version of this document is the one that can be found at the following web address: http://www.arcelormittal.com/index.php?lang=en&page=263 The UK English language version of this document shall be the official version Index 0. Legal basis... 1 1. Scope, reference documents and definition... 3 2. Generality... 3 3. Arrival of the truck... 4 4. Loading of the cargo on the truck... 8 5. Securing of the cargo... 9 6. Before departure of the truck (in Long products domain)... 9 7. Detailed check of some trucks (in Flat products and in AMDS domains)... 9 8. After the departure... 9 9. Best practices... 10 Annex... 11 0. Legal basis Loading security is not an end in itself, but is mandatory by law to prevent damages. It is important to remark that liability in case of damages applies in case of (imprudent or reckless) action as well as in case of omission (lack of the required diligence - negligence ). The main principle is that either in the usual course of business, as well as regarding the fulfilment of any contractual obligation, individuals must always act/perform their obligations according to the general legal duty of being as diligent as possible (also including checking by AM that our sub-contractor complies with regulations and has taken all measures to prevent any accident) In case of lost loadings there exists the danger of very severe injuries to persons, even of fatalities, where not only civil liability (monetary indemnification) but also criminal liability (fines, Page 1 of 11
prison, etc.) are involved. In addition, it is not only the people directly in charge of the cargo operations who can be held criminally liable. Such criminal liability can eventually also involve (and this is highly dependent on the specific national criminal law systems) those middle and top management of the ArcelorMittal legal entity who have a relevant role in such operations, and who i) must ensure the availability of all the security means, ii) train the relevant employees about the risks and good practices, iii) is eventually directly in charge of the surveillance of the compliance of all the security processes and of the proper performance of the works. Necessity of loading security The necessity of loading security is put in place by the accident prevention standards, the above mentioned general principles of liability, and many legal standard rules, which range from very detailed laws on specific cargo and loading safety procedures existing in some countries, to just general principles of due diligence and administrative regulations existing in other countries, which apply in general terms to such works. Rules on cargo securing exist in several Member States, but often differ in content and scope, making it very difficult for international transporters to know what the minimum cargo securing requirements are for a given cross-border transport operation. This is why in any event, securing of cargo on a vehicle should be,carried out according to adequate standards to be applied in a uniform manner across Europe, and ultimately, best practice guidelines such as the European Best Practice Guidelines on Cargo Securing for Road Transport, and the European EN 12195-1, are important backgrounds of loading security, no matter the legal specific scenario of the countries concerned. Such guidelines are a relevant reference for all public or private parties directly or indirectly concerned by cargo securing, they represent the accumulated knowledge of European experts in this field, and are designed to lead all the parties involved to the adequate safety level required to perform international transport operations. Important: In view of the general principles of liability mentioned above, such standards should be seen as a "MUST" and not a "CAN". It is the job of the acting persons, the loading employees and the drivers to guarantee In which manner danger will be excluded. Responsibility / Liability for loading security: In brief: Those persons potentially responsible and liable for loading security are: 1. The loader (the person, who puts the load on the truck) 2. His / her supervisor 3. His/her Company 4. The driver 5. His / her supervisor 6. His/her Company Page 2 of 11
Conclusion: the only way to manage criminal liability is: 1. to do what ever is possible to avoid any risks 2. to be able to show proof of the risk analysis/measures taken This standard has been created by internal and external experts and represents what ArcelorMittal believes to be the most suitable method for cargo securing. Nevertheless this does not exempt the driver, his/her supervisor or his/her company from alerting ArcelorMittal if he/she finds any possible irregularity in our recommendations. Guard/loading place: if ArcelorMittal considers it necessary, its employees will - inspect the condition of the vehicle, the presence of securing devices, individual protection equipment and licences and the securing of the load after the load was picked up. - intervene in case of an accident or misbehaviour on the premises towards the haulier/driver - deny access to persons in case of non-conformity 1. Scope, reference documents and definition This standard concerns loading and transport of products 1 under the responsibility of ArcelorMittal or ordered by ArcelorMittal in Europe. The content of this standard concerns: trucking companies, internal and external warehouses, transport departments within or outside ArcelorMittal. This document must be used as guideline in non European sites of ArcelorMittal. The Group Companies will follow, as a minimum, the prevailing local regulations for all work concerning the product handling. Where this standard is more demanding, then it will apply. The local rules must be established in accordance with risk assessment and the European standard EN12195. This standard is complemented by separate booklets specific to certain types of products; for instance, the BOOKLET minimum requirement for securing of steel flat products before shipment by road ref. ST019 In this standard, the word mill is used for mills of ArcelorMittal but also for other facilities belonging to ArcelorMittal from which our products are shipped. 2. Generality This standard describes the activity to be performed by our own personnel or by the truck drivers during the loading operation: o Arrival of the truck o Loading of the cargo on the truck o Securing of the cargo o Before departure of the truck 1 Scrap material is outside the scope of this procedure, internal transports inside AM facilities are outside the scope of this procedure. Page 3 of 11
3. Arrival of the truck 3.1 The truck drivers The truck drivers must have the following documents and information to gain entrance to the loading location of AM: - Identification, - Company name, - Detailed list of goods to be loaded, - Total weight of the load to be loaded, - Destination after loading, - (ADR 2 permission, loading over 25 t ) Access will be refused when a driver: - uses alcohol or drugs or brings them to the premises - takes passenger or pets, however, a second driver is allowed. Truck drivers are required to show their PPE (Personal Protective Equipment) when asked to do so at the time of request for access. Truck drivers must have and use, as a minimum, the following PPE: Safety helmet Safety shoes and if required by local rules, they also must have and use: Safety goggles Cut-protection safety gloves during stowing/handling operations Clothing to cover the entire body. Ear protection and any other item that may be specified by local rules (e.g. anti-acid protection, fluo-jackets etc.). 2 European Agreement concerning the international carriage of Dangerous goods by Road). Page 4 of 11
General safety rules for truck drivers Priority to the railway traffic, fork lifts, loading carrier Observe and respect the signalisation Stick to the speed limit Stop the engine when in parking position Put in order all objects present in the trailer Respect the environment (use garbage cans, report oil leakage ) It is prohibited to overtake moving vehicles. Respect the general Highway Code (cell phones, seat belt ) Only park at designated parking places Use of designated restroom (shower, restroom, canteen) Also recommended (and even compulsory in some mills) No persons allowed into the cabin during handling 3.2 The vehicles The vehicles must be maintained in such a way that they are safe to work with or on. Loading platform The loading platform should be flat, solid, stable, well maintained (no missing or broken boards), clean, closed, and dry (except for open trailers) Clean means free of dirt and fluids. When the ArcelorMittal dispatcher decides that the trailer is not clean, it will not be loaded. Fig. 1 and 2 Examples of a bad loading platform Headwall: the vehicle shall be equipped with a headwall between the cabin and the loading platform. If the headwall is used for securing the cargo, then it has to be licensed for a certain amount and this amount must not be exceeded by the securing of the load. Page 5 of 11
Attachment points: The cargo securing points, in sufficient number, should be integrated in the vehicle construction. The frame of the trailer is not a securing point (unless this is agreed locally). Each securing point should be equipped with a hook and capable to withstand the prescribed tensile strength on the securing materials. Attachment points must be in good condition (not highly corroded ) Fig. 3 and 4 3.3 Securing devices The use of securing devices is compulsory: depending on the mill these can be synthetic fibre straps, steel chains or cables. (In some sites chains are even prohibited: be informed!). The number of load straps is sufficient to secure the cargo. These load straps are not worn or damaged. This is checked by a visual inspection by truck driver and/or loading staff. When the device is damaged (cuts, knots ) it shall not be used. Fig. 5-1, 5-2, 5-3, 5-4, 5-5 Examples of straps in poor condition Page 6 of 11
The tensioners (ratchets) should be such to make it easy to tighten the lashing and it should be secured against inadvertent loosening. If nylon straps are used they must comply with EN12195-2 If chains are used they must comply with EN12195-3 The use of cables is left to the decision of mills (if cables are used they must comply with EN12195-4) Straps / chains / cables must be labelled and in good condition Fig. 6 Example of securing devices with label Page 7 of 11
4. Loading of the cargo on the truck The loading of the cargo is managed by ArcelorMittal employees. The truck driver has the duty to give advices on how to place the cargo on the truck. The maximum weight of the cargo per destination has to take into account national legislations. Behaviour of the truck drivers The truck drivers are supposed to work in a safe way and behave according to the standard on the loading and unloading areas. Drivers must: Always remain polite and co-operate Before the loading begins, the driver must uncover the lorry in safe conditions and check that the floor of the trailer is clean and dry Wear the adapted PPE Strictly follow the safety regulations in the loading areas Always remain in the direct surrounding of the vehicle In case of emergencies follow the consignments of the site: in any case the driver must leave his vehicle in such a way that it will not obstruct access by emergency vehicles. Secure the load as described in additional booklets provided by ArcelorMittal or, if such information is lacking, as described in European standard. Use the available means (mobile stairs, platform etc.) if provided by ArcelorMittal, to access the platform of the truck. Drivers must not (non-exhaustive list): Open or close the roof in an unsafe way Be on the trailer during the loading Exception: to un-tighten the product from the crane, access to the trailer is only permitted according to local risk assessment and safety measures Touch the load or the hoist, or guide these by hands Climb on the side edge in an unsafe way Jump out of or off the trailer Operate installations belonging to ArcelorMittal (fork-lift trucks, cranes ) 3 Pass underneath the load Move himself or stand between the load and a fixed point 3 Mills may allow the truck drivers to use these, but only after training such as the one followed by ArcelorMittal employees. Page 8 of 11
5. Securing of the cargo After loading, the securing of the cargo is managed by the truck driver in accordance with the European standard and with other documents referenced in 1 of the present standard. Each driver: Must use (securing) material in good condition. Must use equipment in good and safe condition (e.g.: ladder, etc.) depending on local conditions (We expect ladders to be in good condition, see 9) Is in charge of the distribution of the load on the platform of his vehicle Securing and tensioning shall always be done before the transport starts (Before the truck leaves the plant), even if the journey is short. No material (for example groove covers, stanchions, pallets, lashings, etc.) shall remain unsecured on the trailer 6. Before departure of the truck (in Long products domain) Before the departure of the truck, an AM employee and the truck driver, should perform together a quality audit on the result of loading and securing of the cargo. (Example: see annex). They sign a common document with, as a minimum, the following information: The date, Company name, Truck driver s name, Registration number of the truck, Pictures of the securing load (with date and driver s signature). 7. Detailed check of some trucks (in Flat products and in AMDS domains) Checks shall be done on trucks according to stipulated rules set out below. Frequency of checks: All the mills shall carry out regular spot checks at least 5% 4 (compulsory) 10 % (recommended) on monthly basis (daily basis recommended) before the truck leaves the mill. Spot checks must be oriented especially on new transport companies, new truck drivers, or when there is a doubt (e.g. if, from the past, the haulier company has not always been reliable). There should be frequent reporting of non-conformity to the haulier (by each mill) This reporting is a part of the evaluation of the haulier within mill's evaluation procedure. Hauliers who systematically fail to follow the rules must be placed on an ArcelorMittal black list 8. After the departure Each driver: Is in charge of the retightening of the securing devices during transport Handling of goods Prohibition for the haulier/driver to handle the goods, during or after the transport 4 This compulsory minimal limit may be increased in the booklets relative to specific products or upon decision of local sites. Page 9 of 11
9. Best practices 9.1. Example of adapted platforms to open (close) the roof of the truck (see below), Fig. 7 9.2. To make the access to the trailer easier and to avoid falls, some fixed or mobile ladders can be used, Fig. 8-1 and 8-2 9.3. If applicable, an anti-slip mat must be used under the goods to minimise the risk of sliding. The use of an anti-slip mat is compulsory for certain products (see booklets or local rules) Fig. 9 Page 10 of 11
Annex Audit after truck loading Date: Transport company name: Registration number of the truck: Registration number of the trailer: Truck driver s last name: Type of goods: Order #: Destination after loading (customer): Total weight: Pictures: - general view of loading - general view of cargo securing - detailed view of cargo securing Signatures: Truck driver AM auditor Page 11 of 11