The Deadly Dangers of Transportation Truck Cleaning

When it comes to worker safety, trucking is one of the most dangerous industries—and the world of tank cleaning is no exception. Between 2016 and 2021, there were 36 reported deaths among tank cleaning workers across the region spanning Louisiana, Arkansas, Oklahoma, Texas, and New Mexico. During this same period, more than 160 investigations uncovered over 300 violations, with approximately 20% of the worker fatality investigations involving entry into confined spaces and permit-required confined spaces.

In response, OSHA launched its Regional Emphasis Program for Transportation Tank Cleaning Operations. The initiative, which currently runs through July 2024, aims to curb injuries, illnesses, and deaths within the transportation tank cleaning industry. Through a two-pronged approach involving outreach and enforcement, the Regional Emphasis Program encourages employers to take proactive steps to protect their employees from workplace hazards and penalizes those who fail to comply.

Unfortunately, regulatory measures are not always sufficient when it comes to preventing on-the-job injuries and deaths. Employers must adhere to these regulations, putting worker safety first.

Transportation Tank Cleaning: What It Is & Why It Matters

Regardless of what they’re carrying, all transportation tanks must undergo a thorough cleaning process every single time they are emptied. Prior to being refilled, these tanks must also be adequately inspected. While some tanks can be cleaned externally, others require workers to enter the tanks to remove materials—including hazardous contaminants—from their interiors. This is when workers are most at risk.

The primary goal of transportation tank cleaning is to prevent contamination. There are three main ways in which cargo can become contaminated:

• Cross-contamination with previously held cargo
• Accumulation of organic residue, such as bacteria or mold
• Tank corrosion, leading to rust and other inorganic contaminants

Tanker trucks transport everything from food products to crude oil to toxic chemicals. As such, these tanks must be extensively cleaned to avoid contamination of transported materials. In some cases, cleaning involves manual methods, such as scrubbing, shoveling, and scraping; chemical agents are required in others. Regardless, transportation tank cleaning companies should ensure that their employees receive the appropriate training, tools, and personal protective equipment (PPE) to avoid harmful exposure, injuries, and fatalities.

How Transportation Tanks Are Cleaned

Every tank or trailer—along with any additional equipment used in the hauling of goods or materials—must be thoroughly washed, dried, and inspected before it can be refilled for transport. This process occurs at specialized facilities known as “wash racks.”

Depending on the type of product the tank was hauling, cleaning may be as simple as washing with a detergent-based solution and pressurized water and steam; in other cases, workers may be required to actually go inside the tank and remove materials by hand. With especially difficult-to-remove dry bulk shipments, tanks may need to undergo a conversion wash. This involves removing the pipe that runs along the bottom of the trailer, as well as pipe fittings, to ensure that all stray particles are completely removed.

Additionally, certain circumstances may call for specialized washes. For example, truck tanks used to haul consumable goods may be required to undergo food-grade tank washes, and kosher tank washes must be performed to qualify tanks for kosher certification.

Outside Tank Cleaning: The Safer Option

Outside tank cleaning, in which workers do not have to enter the tank to clean it, is by far the safest option when it comes to transportation tank washing.

Though each situation is different, this process typically involves:

• Fully emptying the tank of all cargo
• Grounding to prevent static electricity buildup (when necessary)
• Applying a detergent-based, chemical, or caustic cleaner to the inside of the tank
• Utilizing highly pressurized water and/or steam to remove debris from the tank’s interior
• Cleaning the outside of the tank/trailer and all applicable equipment with pressurized water
• Drying the tank with hot air

Note that this is a highly simplified overview of the truck tank cleaning process. In reality, tank cleaning is extremely complex, with each wash requiring a custom approach based on the type of cargo being transported, the presence of residue or spills, the degree of cleanliness required, and other factors.

Cleaning Tanks by Hand

Certain transported materials cannot be adequately removed without a worker entering the tank and doing so by hand. For example, some hardened products must be shoveled or scraped from the bottom of the tank before they can be effectively removed and the tank can be thoroughly cleaned. In nearly all cases, this is a much more dangerous scenario than cleaning from the outside.

Transportation tanks are classified as “confined spaces.” Confined spaces include areas not intended for continuous or long-term occupancy and which have limited or restricted entry and exit points.

There are numerous risks associated with entering confined spaces, including:

• Insufficient ventilation
• Toxic, flammable, or combustible atmosphere
• High or low oxygen levels
• Slow entry/exit
• Unsafe temperatures, including excess heat

When a confined space has any type of atmospheric hazard, such as a potentially combustible atmosphere, OSHA classifies it as a “permit-required confined space.” Many transportation tanks meet this requirement, including those carrying hazardous liquids, chemicals, and gases.

The Dangers of Tank Cleaning

Transportation tank cleaners face serious risks on the job, especially when they are required to get inside truck tanks to clean them.

Some of these dangers include:

• Exposure to toxic chemicals, vapors, and other hazardous materials
• Working within a confined space or permit-required confined space
• Lack of sufficient oxygen inside transportation tanks
• Fires and explosions due to flammable or combustible materials
• Restricted movement and/or visibility
• Difficulty accessing entry and/or exit points
• Inability to quickly exit tanks in the event of an emergency

These and other hazards have led to numerous injuries, illnesses, and deaths across the industry. In Louisiana, a man was found unresponsive inside the transportation tank he was cleaning, which had been carrying paralysis gas. The worker, who passed away at the scene, appeared to have been overcome by deadly fumes after entering the tank. In Oklahoma, two workers died after succumbing to hazardous vapors inside a tank transporting natural gas on a railcar, and two others died after being exposed to toxic fumes while cleaning an 18-wheeler tank at a Texas chemical plant.

Negligence in Transportation Tank Cleaning

The tragic events discussed above represent just a small portion of the numerous workplace accidents that take place every year across the tank cleaning industry. But how do these accidents happen, and why do they keep occurring? In many cases, it comes down to negligence.

Strict regulations require tank cleaning employers to ensure the continued safety of their workers. However, everything from PPE violations to permit noncompliance can lead to serious or even deadly accidents.

Examples of employer negligence in transportation tank cleaning include:

• Failing to test atmospheric conditions inside tanks before worker entry
• Failing to provide employees with proper PPE (personal protective equipment)
• Permit-required confined space violations (i.e., failing to complete permits)
• Misusing or failing to use adequate respiratory protection
• Failing to provide adequate worker training, including emergency training
• Mishandling of hazardous substances
• Improper licensing or permitting
• Failing to correct unsafe or prohibited conditions
• Improper bonding, grounding, or degassing of transportation tanks
• Failing to properly isolate confined spaces for safe entry
• Inadequate testing or inspection

When employers cut corners or otherwise fail to uphold critical safety standards, workers are the ones who get hurt. These companies must be held to a higher standard. They must be held accountable for their failures to protect workers' lives. No matter what.