Third-party haulers who transport crude oil, condensate and natural gas liquids (NGL) from oil and gas properties to unloading sites such as terminals are a vital logistics link for our industry. Many haulers hire truck drivers who become responsible for manually checking the level and quality of crude oil in storage tanks before they unload the product into their trucks. Known as tank gauging, this activity can be hazardous due to the potential for exposure to oxygen-deficient, hazardous and toxic atmospheres if safety precautions are not followed.
We developed a program to manage the HES&S risks of loading and transporting products at Marathon Oil’s U.S. onshore unconventional resource plays. The program addresses hauler awareness, operational safety management and hazardous material transportation safety/environmental assurance. We share this standard with our oil buyers, transporters and industry peers, and in 2017 applied the program to approximately 50 crude oil transport companies.
Under the standard, Marathon Oil performs initial audits and vets each transporter’s HES&S management system, regulatory compliance status, standard operating procedures (SOP) and Job Safety Analysis (JSA). Audits are repeated every three years. During audits and other leadership engagements, we communicate our safety culture and expectations, go over NIOSH (National Institute for Occupational Safety and Health) findings and recommendations for manual tank gauging, and identify opportunities for improvement. Emphasis is placed on engineering controls, augmented by procedures and personal protective equipment (PPE) to mitigate the risks.
Buyers and transporters must comply with our oil hauler standard and HES&S requirements, and ensure their drivers/tank gaugers have completed a business unit-specific HES&S orientation before first arrival on location. They must further ensure that drivers/tank gaugers dispatched to our sites have been issued a Marathon Oil product safety data sheet and have the training, procedures and equipment to comply with applicable federal and state regulations. A multi-gas personal alarm monitor must be worn continuously while gauging tanks and handling the product.
In addition, drivers/tank gaugers must comply with posted signage and safety rules at our sites, and follow their employer’s SOPs and JSAs for onsite activities. We require that our buyers promptly respond to any unplanned release on or off a Marathon Oil property as a result of their activities.
Buyers and drivers alike have reacted positively to our efforts, and thanked Marathon Oil for making them aware of the potential hazards of their work and how to do it safely.
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