Tank Trucks & Tank Cars – Falls from Height

Concerns, Regulations, Solutions

(Newsletter, Oct., 2023)

Welcome to the October edition of our newsletter, where we delve into the essential topic of tank truck and tank car access and fall protection solutions. Safety is paramount in any industry, and it’s no different when it comes to accessing and working on top of tank trucks and railcars. Falls from these elevated surfaces can lead to serious injuries, substantial financial losses, and regulatory penalties.

In this issue, we will cover key aspects, including OSHA regulations, the hierarchy of fall protection, cost impacts of falls, a common check list and industry solutions that ensure the safety of your employees.

OSHA 1910 Regulations

The Occupational Safety and Health Administration (OSHA) provides regulations for fall protection in General Industry under 29 CFR 1910 Subpart D. These regulations are in place to protect employees who work on tank trucks and rail cars. Key provisions include the requirement for guardrail systems, personal fall protection systems, and fall protection training. It’s imperative for employers to understand and comply with these regulations to ensure a safe working environment.

OSHA Hierarchy of Fall Protection

OSHA follows a hierarchy of fall protection measures, which outlines the preferred methods to prevent falls in the workplace. It starts with eliminating fall hazards wherever possible, followed by using passive fall protection systems such as guardrails and safety nets. If passive measures are not feasible, then employers must provide active fall protection, such as personal fall arrest systems (PFAS). The last resort should be administrative controls, such as warning lines or safety monitoring systems.

Employers must prioritize these measures to minimize the risk of falls from tank trucks and rail cars.

Cost Impacts of Falls

Falls from the tops of tank trucks and rail cars can have significant financial repercussions for businesses. These impacts include:

1.     Lost Time: When an employee falls and gets injured, it often results in time off work for recovery. Lost time can disrupt operations, reduce productivity, and lead to increased labor costs.

2.     Fines: OSHA can issue substantial fines for non-compliance with fall protection regulations. Fines can range from thousands to millions of dollars, depending on the severity of the violation.

3.     Insurance Rates: Frequent falls and injuries can lead to higher workers’ compensation insurance rates, which can substantially increase a company’s operating costs.

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Industry Solutions for Fall Protection

1.     Guardrails and Safety Gates: Installing guardrails and safety gates on tank trucks and rail cars provides passive fall protection. These physical barriers prevent employees from accidentally stepping off the edge.

2.     Personal Fall Arrest Systems (PFAS): PFAS, including harnesses and lifelines, should be used when guardrails are not feasible. Employees must receive proper training to use these systems safely.

3.     Fall Protection Training: Regular, comprehensive fall protection training is essential. Employees should be educated on the dangers of working on top of tank trucks and rail cars, as well as how to use fall protection equipment correctly.

4.     Equipment Maintenance: Regular inspection and maintenance of access equipment are crucial to ensure their reliability and safety. Damaged ladders or railings should be repaired or replaced promptly.

Fall Protection Assessment Checklist

Here’s a checklist that can be used to assess falls from heights risk from the tops of rail cars and tank trucks:

Fall Protection Assessment Checklist

Site Name: ______________________ Date: ______________________

1. General Site Assessment:

  • Are all employees and contractors provided with fall protection training?
  • Are employees aware of OSHA 1910 regulations pertaining to fall protection?
  • Is there a written fall protection program in place?

2. Fall Hazard Identification:

  • Have all potential fall hazards on and around rail cars and tank trucks been identified?
  • Are fall protection systems installed and clearly marked in areas where fall hazards exist?
  • Are there safe access and egress points available for employees working on top of rail cars and tank trucks?

3. Guardrail and Safety Gate Assessment:

  • Are guardrails installed around the perimeters of the rail cars and tank trucks?
  • Do safety gates provide safe access to and from the tops of rail cars and tank trucks?
  • Are all guardrails and safety gates in good condition, free from damage or wear?

4. Ladder and Stairway Assessment:

  • Are caged ladders or stairways installed for safe access to the tops of rail cars and tank trucks?
  • Are all ladders and stairways in compliance with OSHA regulations, including proper rung spacing, structural integrity, and secure anchorage?

5. Safety Grating and Walkways:

  • Is safety grating or walkway material provided to ensure safe footing on top of rail cars and tank trucks?
  • Is the grating or walkway securely attached and free from damage or corrosion?

6. Personal Fall Arrest Systems (PFAS):

  • Are employees provided with PFAS, including harnesses, lifelines, and anchors, when guardrails and other passive systems are not feasible?
  • Are PFAS used correctly and maintained in good condition?
  • Is proper training provided for employees on PFAS usage?

7. Fall Protection Training:

  • Are employees trained in recognizing fall hazards and using fall protection equipment?
  • Is there a documented training program in place?
  • Is refresher training provided at regular intervals?

8. Equipment Inspection and Maintenance:

  • Is there a scheduled maintenance program for all fall protection equipment and structures?
  • Are damaged or worn components repaired or replaced promptly?
  • Are inspection records maintained for all fall protection equipment?

9. Emergency Procedures:

  • Are emergency procedures in place for rescue and first aid in case of a fall?
  • Are employees trained in emergency response procedures for fall-related incidents?

10. Documentation:

  • Are all documents related to fall protection, including training records and maintenance logs, up to date and readily accessible?
  • Are OSHA 1910 regulations and safety procedures clearly posted and communicated to all employees?

11. Continuous Improvement:

  •  Is there a process in place for regular safety reviews and improvements based on lessons learned from incidents or near misses?

Remember to regularly review and update this checklist as needed to ensure ongoing compliance with OSHA regulations and to maintain a safe working environment. Compliance with fall protection regulations is essential for the safety of employees and the avoidance of fines and legal liabilities.


In conclusion, ensuring the safety of employees working on tank trucks and rail cars is not only a moral imperative but also a sound business decision. By complying with OSHA regulations, implementing the hierarchy of fall protection, and investing in fall protection solutions, businesses can significantly reduce the risk of falls and the associated financial burdens.

Thank you for reading our October newsletter on tank truck and tank car access and fall protection solutions. We hope you find this information valuable and encourage you to prioritize safety in your workplace.

Stay safe, stay compliant, and stay informed.

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