Operational Excellence

29_Operational-Excellence Every day, companies involved in the storage and distribution of liquid commodities work to achieve the highest levels of operational excellence through the safe and responsible handling of the products in their care. By using management systems and established processes and procedures, ILTA members are reducing risks, enhancing safety and reliability, and delivering continuous improvement in environmental and operational performance.

While state and local agencies also regulate the design and operation of liquid terminal facilities, some of the key federal agencies include:

Department of Labor

Occupational Safety and Health Administration

OSHA requires that tank and terminal operators follow about two dozen general, and industry-specific regulations on everything from walking and working surfaces, stairways, construction, personal protective equipment, egress and fire alarms. OSHA also conducts enforcement inspections and has some specific regulatory requirements when companies handle hazardous chemicals.

Key rules include:

29 CFR 1910 Subpart H. Hazardous materials
29 CFR 1910.106 Flammable liquids
29 CFR 1910.119 Process Safety Management (PSM)
29 CFR 1910.1200(g) Hazard Communication Standard (HCS)

U.S. Environmental Protection Agency

All terminals are subject to regulation by the EPA including its 10 regional offices. EPA regulates air and water quality around facilities under the Clean Air and Clean Water acts and the proper handling and disposal of waste. Some of these programs are delegated to and enforced at the state level. EPA administers other programs that affect terminal operations, including several related to spill prevention, mitigation and risk management if a terminal handles certain chemicals or hazardous substances.

Department of Transportation

Pipeline and Hazardous Materials Safety Administration PHMSA regulates the design, construction and inspection of certain above-ground storage tanks, under 49 CFR Part 195. The agency also regulates the pipelines that often connect to facilities. In addition, PHMSA regulates the safe and secure transportation of hazardous materials via other modes of surface transportation, like rail and truck.

Army Corps of Engineers

The United States Army Corps of Engineers is a U.S. federal agency under the Department of Defense. USACE regulates some aspects of terminal construction and maintenance, including dredging permits.

On Capitol Hill, key committees that oversee operational issues are:

ILTA members are committed to continuous improvement and have developed many ways to share information to learn from each other and share best practices. One example is:

Terminal Operating Practices Symposium (TOPS)

Held every year since 2018, this symposium is designed exclusively for ILTA terminal member companies. This well-attended event allows for the sharing of information, experiences and knowledge relating to safe operating practices at terminal facilities.