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EHS BEST PRACTICE BP/1.11

EHS BEST PRACTICE FOR ROAD TRANSPORT OF PETROLEUM PRODUCTS

JUNE 2016

EHS Best Practice for Road Transportation of Petroleum Products

Contents

1. Introduction .................................................................................8

2. Objective .......................................................................................8

3. Scope ..............................................................................................9

4. Road Transport Safety Management System .......................9

5. RTS Management System .......................................................10

Elements .................................................................................................... 10

Commitment & Awareness of RTS - Policies .................................... 10Management Practice ............................................................................................ 10

Guiding Principles ................................................................................................. 11

RTS Policies ............................................................................................................. 12

Management ........................................................................................................... 12

Supervisors .............................................................................................................. 13

Promoting Safety .................................................................................................... 13

Communications .................................................................................................... 14

Employee/Driver Role .......................................................................................... 15

Performance Metrics .............................................................................................. 15

Awards and Recognition ...................................................................................... 16

RTS Adviser ............................................................................................................ 16

Data, Information & Regulations ........................................................ 17Management Practice ............................................................................................ 17


Carrying and Retaining Documentation ............................................................ 17

Risk Assessment and Reduction .......................................................... 18Management Practice ............................................................................................ 18


Truck Loading ........................................................................................................ 20


Truck Routing and Delivery Site ......................................................................... 20

Delivery Site Considerations ................................................................................ 21

Selection & Monitoring of Transporters ............................................ 21Management Practice ............................................................................................ 21


Contract Provisions ................................................................................................ 22

Subcontractors ........................................................................................................ 23

Driver Recruitment, Selection, Training & Certification ............... 23Management Practices ........................................................................................... 23


Drivers ..................................................................................................................... 24

Selection Criteria .................................................................................................... 24

License and Certification Requirements ............................................................. 25

Induction Training ................................................................................................. 25

Defensive Driving Training .................................................................................. 26

Ongoing and Refresher Training ......................................................................... 27

Routine Driving Skills/Knowledge Training .................................................... 27

Accident Follow-Up (Remedial) Training .......................................................... 27

In-the-Vehicle Driver Observation Training ...................................................... 28

Periodic Performance Appraisal .......................................................................... 28

Driver Risk Assessment ........................................................................................ 28

Driver Health Monitoring ..................................................................................... 28

Drug and Alcohol Testing .................................................................................... 29

Fatigue Management ............................................................................................. 29

Drivers Compensation and Benefits ................................................................... 30

Specification & Maintenance of Equipment ..................................... 30Management Practice ............................................................................................ 30


Transport Unit ........................................................................................................ 31

Incident Prevention Features ............................................................................... 31


Incident Severity reduction Features .................................................................. 32

Vehicles – Marking and Placarding .................................................................... 32

Vehicle Maintenance .............................................................................................. 32

OBC/GPS ................................................................................................................ 33

Training ..................................................................................................... 33Management Practice ............................................................................................ 33


General Training .................................................................................................... 34

Driver Training ....................................................................................................... 34

Driver Monitoring .................................................................................................. 35

Standard Operating Procedures ........................................................... 35Management Practice ............................................................................................ 35


Drivers Handbook ................................................................................................. 36

High Risk Operations ............................................................................................ 36

Standard Operating Procedures .......................................................................... 37

Reporting & Evaluation of Incidents & Accidents ........................... 37Management Practice ............................................................................................ 37


Emergency Response .............................................................................. 39Management Practice ............................................................................................ 39


Management of Change ......................................................................... 40Management Practice ............................................................................................ 40


Process Documentation .......................................................................... 42Management Practice ............................................................................................ 42


Auditing .................................................................................................... 43


Management Practice ............................................................................................ 43


Management Review ............................................................................................. 44

6. References ..................................................................................45


Acronyms

Acronym Description

ADR European Agreement concerning the International Carriage of Dangerous Goods by Road

BP Best Practice

DAFWR Days Away From Work Rate

ERC Energy Regulatory Commission

ERP Emergency Response Plan

GPS Global Positioning System

HERP Highway Emergency Response Plan

HIN Hazard Identification Number

HSE Health, Safety and Environment

HSE BP Health, Safety and Environment Best Practices

HSE MS Health, Safety and Environment Management System

IBC Intermediate Bulk Container

INC Incorporated

IOC International Oil Company

IPO Incident Prevention Observation

KS Kenya Standard

LTI Lost Time Injury

MSDS Material Safety Data Sheet

MVC Motor Vehicle Crash

OBC On-Board Computer

OSHA Occupational Health and Safety Act

PPE Personal Protective Equipment

RPM Revolutions Per Minute

RTS Road Transport Safety

RTS MS Road transport Safety Management system


Acronym Description

SOP Standard Operating Procedures

TRIR Total Recordable Injury Rate

UN United Nations

USA United States of America


1. Introduction

1.1. These Health, Safety and Environment Best Practices (HSE BPs), herein referred as “Best Practices (BPs)”, are guidance to Health, Safety and Environment (HSE) Practices for the Management of Health, Safety and Environment for the Road Transport of Petroleum Products and are produced by the Energy Regulatory Commission (ERC) in consultation with the National Transport and Safety Authority (NTSA), National Environment Management Authority (NEMA), Directorate of Occupational Safety and Health Services (DOSHS) and the Oil Industry in Kenya.

1.2. Oil Marketing Companies have a very strong commitment to Health, Safety, and Environment (HSE).

1.3. OMCs goals in HSE are simply stated – no accidents, no harm to people, no damage to the environment.

1.4. Transporters as important business partners, have a critical role in the achievement of these goals.

1.5. Throughout road transportation of petroleum products, motor vehicle accidents are one of the primary causes of injury to employees, contractors and third parties.

1.6. Significant property damage, disruption of service and product spills also result.

1.7. The HSE BPs describe the guiding principles and management practices for Transporters to specifically focus on providing the right people, equipment and supportive environment so that the driver is an engaged, safe driver, making a difference on the road.

1.8. The benefits that come from improved HSE performance include decreased costs and increased employee satisfaction.

2. Objective

2.1. The HSE BPs on Road Transport is a guidance document describing a comprehensive Transporter HSE Management Program for Fleet Operations.


3. Scope

3.1. The HSE BPs consists of several stages that can enable Transporters to effectively plan and complete work in a way that is consistent with Oil Industry HSE BPs and Expectations.

4. Road Transport Safety Management System

4.1. The information contained in the BPs is not intended to be prescriptive, or to preclude the use of new developments, innovative solutions or alternative designs, materials, methods and procedures, so long as such alternatives provide an acceptable level of risk management.

4.2. The guidelines are provided for information and while every reasonable care has been taken to ensure the accuracy of its contents, the ERC cannot accept any responsibility for any action taken, or not taken, on the basis of this information.

4.3. Transporters need to have a RTS Management Systems in place to ensure that the risks arising from the transport of petroleum products have been fully identified and are being properly controlled and managed.

4.4. The recommendations on safe management practices contained in these BPs address the different elements of the management systems that petroleum products transporters should have in place in order to ensure that the transport and associated handling of petroleum products is unlikely to have adverse HSE Impacts.

4.5. Implementation of these recommendations should result in a continuous improvement in the safety and environmental performance of the petroleum products transporters.

4.6. These recommendations apply to the transport of petroleum products by the different modes of transport. They also apply to other distribution activities associated with the transport of petroleum products, carried out by transporters, such as storage, loading and unloading and to any subcontractors who are working on a contract basis for transporters.

4.7. This document is intended as guidance for Contractors and may be used as a template in developing Contractor’s RTS Plan.

4.8. The objective of a Contractor’s RTS Plan is to help minimize risk and promote a positive safety culture in road transport operations.


4.9. Implementation of these recommendations on RTS Management Practices will fulfill most of the requirements of the Energy Act 2006 and the Energy (Licensing of Petroleum Road Transportation Business) Regulations 2013, the Traffic Act, and the National Transport Safety Authority Act.

5. RTS Management System

Elements

5.1. Commitment & Awareness of RTS – Policies

5.2. Risk Assessment and Reduction

5.3. Selection and Monitoring of Transporters

5.4. Driver Recruitment, Selection, Training and Certification

5.5. Specification and Maintenance of Equipment

5.6. Training

5.7. Standard Operating Procedures

5.8. Reporting and Evaluation of Incidents and Accidents

5.9. Emergency Response

5.10. Management of Change

5.11. Process Documentation

5.12. Auditing

5.13. The requirements for each of these elements are addressed below.

Commitment & Awareness of RTS - Policies

Management Practice

5.14. Critical to road transport safety, as with safety in any area involving personnel, is management leadership and involvement.

5.15. It is essential that managers and supervisors at all levels actively demonstrate commitment to the Transporter’s RTS Policies and accept and promote HSE Concepts.

5.16. The Transporter should have clear RTS Policies in place, which emphasize the paramount importance of safety and the protection of employees,


customers, the public and the environment from the adverse effects of all logistics operations, whether carried out by or on behalf of the company.

Guiding Principles

5.17. The Transporter is responsible for producing and maintaining his/her RTS Management System, which should contain:

• Road Transport Safety Policies which specifically refer to the requirements regarding road transport safety.

• An Organization Chart, which identifies the persons responsible for management and upkeep of the Management System, and the associated records.

• A process for ensuring that all employees are aware of their responsibilities regarding road transport safety, and the requirements of the RTS MS as relevant to their jobs.

• An audit procedure to be used for regular checks by senior management on the degree of compliance with the RTS MS.

• A document control and record retention system to safeguard the integrity of the RTS MS.

• Detailed procedures for the implementation of each of the RTS MS Elements.

• A Safety Committee Charter. The Charter and the committee’s responsibilities must cover road transport safety matters.

• An emergency response procedure.

• An incident reporting and investigation procedure.

5.18. Prime responsibility should lie with line management who should be required to demonstrate a high level of commitment to safety, health and environmental protection not only in terms of logistic operations but also in terms of personal behavior.

5.19. Management must lead by example in order to influence positively workers attitude and behavior and to continuously improve the safety culture within the company.


RTS Policies

5.20. Transportation companies must have RTS Policies, which indicate the company commitment, RTS targets and safety responsibilities for individuals throughout the company.

5.21. The policies should outline the organization, arrangements and responsibilities for achieving the required results and should be known and understood by all employees.

5.22. The Policies should:

• be signed either by the Chief Operating Executive on the site, or alternatively by the Chairman or Managing Director of the company, reflecting the fact that the overall responsibility for SHE rests at the top of the organization.

• be reviewed at regular intervals, or following any major change in company organization.

• recognize the importance that individuals play in achieving successful implementation.

• be supported with goals and targets.

5.23. RTS Policies provide the starting point for establishing strategic road transportation objectives, which aims are:

• Reduce the number of incidents and fatalities

• Establish driver selection, testing and training programs

• Establish and support safe road transport working procedures and practices and to strive for an incident-free activities

• Ensure that the company will employ only transport assets, facilities and equipment which conform to acceptable standards and that they are maintained in a safe, secure and operational condition; and

• Specify the need to develop and emergency response capability in cooperation with authorities and emergency services.

Management

5.24. An overall management structure for road transportation and its relation to the implementation of the transport policy within the organization should be in place whose have an active responsibility for land transport management, and should state what those responsibilities are.


5.25. All employees who make use of, or are affected by road transport should continually be made aware of their individual responsibilities.

5.26. Management should ensure that adequate resources are made available in a timely manner to fulfill the strategic objectives set out in the company management plan.

5.27. Senior management should establish clear expectations and objectives and ensure the involvement of managers/supervisors at each level of the organization.

5.28. Visible and deliberate efforts should be made to demonstrate management’s strong commitment to safety.

5.29. Top Management must seek to provide both a safe work place and safe working conditions for delivery vehicle drivers.

5.30. On an ongoing basis, managers and supervisors are responsible to ensure that operations are being carried out safely and that all legal requirements are being met.

5.31. Periodic checks should be made and documented to ensure that operating procedures are fully understood and being followed.

5.32. On-site/in the vehicle verifications should be made for all phases of the delivery process, including loading, unloading and on the road driving.

Supervisors

5.33. Road transport safety is a line management responsibility with RTS Advisers assisting in the development, implementation and maintenance of the program.

5.34. Supervisors are key to the effective Fleet Operations and as such must be closely aligned with Top Management’s expectations concerning safety.

5.35. Because their attitudes and actions are highly visible in their daily interactions with vehicle operators, they, as much or more than other management levels, must continually demonstrate commitment to safety.

Promoting Safety

5.36. Promoting a highly motivated safety culture and making progress toward an incident free operation is the responsibility of all positions within the transport organization.


5.37. Critical to this effort is demonstrated commitment by managers and supervisors to RTS Policies and to the concept that no business objective is so important that it takes precedent over safety.

5.38. In addition, there must be firm belief and continuous promotion of the concept that all incidents are preventable.

5.39. Management must visibly demonstrate its commitment to safe working at all times, leading by example and reinforcing the principle that safety is of highest priority.

5.40. All employees involved in road transportation should be made aware of their individual role, accountabilities and responsibilities.

5.41. Management should ensure that personnel performing specific assigned RTS activities and tasks are competent.

5.42. Management should ensure and increase competence through the identification of training needs and the provision of appropriate training for its personnel, both drivers and supervisors.

5.43. Ensure Sub-contractors to operate and have in place a RTS Management System.

5.44. The Energy Act requires that anyone involved in the carriage of dangerous goods by road must:

• act to avoid damage/injury from, and minimize the effects of foreseeable dangers; and

• when there is an immediate risk to public safety, notify the emergency services and give them the necessary information.

5.45. When dangerous goods are being consigned for a third party, the third party has to inform the consignor in writing that the goods are dangerous and make available all the necessary information and documentation.

Communications

5.46. Communications concerning the importance and priority given to safe operation of vehicles must be an ongoing process and involve all employees as participants.

5.47. The mechanisms for such communications should be essentially the same as those used in other areas of personnel and operations safety.

5.48. Regular driver’s forum shall be organized to communicate and engage driver in promotion on safety performance. These include sharing of personal challenges, recognition of best performed driver and etc.


Employee/Driver Role

5.49. While management is responsible for fostering a positive safety culture and providing training, support programs, equipment, and other appropriate tools for safe vehicle operations, success or failure ultimately depends on the vehicle driver.

5.50. It is critical that the driver be highly motivated and committed to performing all aspects of his job in a safe manner, strictly following established procedures, maintaining alertness to potential hazards and observing defensive driving principles at all times.

5.51. Major emphasis must be placed on attaining a high degree of awareness and self-motivation on the part of all vehicle operators. This can be aided by actively involving employees/drivers in a wide range of safety related activities and programs.

5.52. While voluntary employee commitment and involvement are critical to the success of any safety program, the organization must also place upon its employees minimum expectations:

• Full compliance with all safety rules and regulations.

• Immediate reporting of any unsafe condition.

• Not undertaking a task without proper training/instruction.

• Taking the initiative to stop unsafe acts by others.

• Immediate reporting of any incident, occupational injury or illness.

Performance Metrics

5.53. Measures are required to monitor the effectiveness of the RTS Management System.

5.54. As a minimum, the following items shall be monitored:

• Fatalities

• LTIs

• MVCs

• DAFWR (due injuries),

• TRIR

• Product Spills

• Product Mixes/Contaminations


• Number of Man-hours

• Number of Kilometres Driven,

Awards and Recognition

5.55. While the primary reward for safe operation of any vehicle is avoidance of injury to self and others, award and recognition programs can be valuable tools to enhance safety awareness and promote safe behavior.

5.56. Most effective programs utilize both performance and behavioral criteria for awards, coupled with both individual and team recognition.

5.57. Transporters shall set aside incentives as rewards to the drivers on a monthly/ quarterly and yearly basis, based on the driver’s performances and ranking matrix, i.e. (Best driver of the month/ quarterly/ yearly).

RTS Adviser

5.58. It is recommended that Transporters, whose activities include the carriage of petroleum products by road, and related loading (but not unloading), or filling, to appoint one or more RTS Advisers or assign this responsibility accordingly.

5.59. RTS Advisers ensure that carriage of petroleum products and related activities are conducted in accordance with requirements and in the safest possible way.

5.60. They advise on, and ensure compliance with legal requirements for:

• identification of petroleum products;

• equipment used in connection with carriage and loading;

• training of employees and maintenance of training records; and

• Emergency procedures to be taken in the event of any accident or incident that may affect safety.

5.61. RTS Advisers are also responsible for preparing for management a monthly report on relevant aspects of the carriage of petroleum products and for ensuring that an accident report is prepared whenever an incident occurs.

5.62. RTS Advisers have to be capable of performing their duties. They must undergo training, sit an examination and hold a vocational training certificate to become a RTS Adviser.


Data, Information & Regulations

Management Practice

5.63. Current information on the configuration and capabilities of processes and delivery vehicles and facilities, properties and materials handled, potential safety health and environmental hazards, and regulatory requirements is essential to assess and manage risk

5.64. The Transporter requires an effective system in place for the receipt and collection of appropriate technical product data from the shipper for all the products he is handling.

5.65. A system should be in place to ensure that any changes in these technical data are taken into account.

5.66. The Transporter also needs to have a system in place for the interpretation and application of all relevant national and international regulations and industry codes covering transport and related operations, as well as for monitoring and implementing of any changes in these regulations and codes.

Guiding Principles

5.67. Within the organization of any logistics service provider, a qualified person should be designated to interpret and disseminate SHE information relating to all products that are handled. This information should be used as the basis for the selection of appropriate transport equipment, provision of training, safe operating procedures and the labeling of vehicles.

5.68. The data should be reviewed whenever there are changes in regulatory or product technical data, in classification and any consequential changes communicated to relevant personnel.

5.69. It is the task of the RTS Adviser to facilitate by all appropriate means and actions that all the transport activities and related loading or unloading of dangerous goods are carried out in accordance with the applicable rules and in the safest possible way.

Carrying and Retaining Documentation

5.70. The carrier and every vehicle crew member have to make sure that the applicable requirements of the Traffic Act Cap 403 and the Kenya Standards are met:


• ERC petroleum permit and driver certificate

• Vehicle Permit authorising transport operation

• Transport Documents

• Driver’s Training Certificate

• First Responder - Emergency Response Instructions

• HERP

5.71. Driver instructions in writing have to be kept in a readily identifiable form in the driver’s cab, and the carrier has to make sure that the drivers concerned understand and are capable of carrying out these instructions properly.

5.72. In the event of an accident or emergency involving the carriage of petroleum products, the driver of the transport unit has to take all reasonable steps to ensure written instructions are complied with.

5.73. The driver and vehicle crew have to make sure that correct delivery documents are carried on the vehicle, where applicable.

5.74. Those who carry or consign petroleum products by road have to make sure that the transport document accompanies each consignment, and the Transporter must retain a written record of all the information in any transport document for three months after the journey finishes.

Risk Assessment and Reduction

Management Practice

5.75. A thorough and comprehensive hazard identification and risk assessment of road transportation operations should be performed at the earliest opportunity and at suitable intervals thereafter, by experienced and suitably qualified personnel.

5.76. This exercise should cover an assessment of all hazards that could occur within the land transport of personnel, goods or materials in every aspect of the planned operations

5.77. Transport management has the responsibility to ensure that safe vehicle operating practices and procedures are established, that drivers are properly instructed in their use, and that systems are in place to monitor and steward compliance.


5.78. A Journey Risk Management Plan is in place taking into account National and Local Authority on routing of hazardous substances.

5.79. To identify risks and restrictions on the road that might be imposed by tunnels, bridge regulations. Within the constraints imposed above, select the routes that offer the minimum traffic hazards.

5.80. Process in place to identify temporary road hazards, including engagement of the drivers in sharing these hazards and mitigation actions.

5.81. To ensure safe dispatch to all customers, each delivery route and site must be assessed for potential risk.

5.82. Assessments must be performed prior to first delivery to the customer, and whenever this is a significant change in routing or site facilities.

5.83. Persons conducting Risk Assessments must be trained in Risk Assessment Methodology.

5.84. A system should be in place with which it is possible to assess and reduce potential risks in the logistics chain.

5.85. The system should identify, evaluate and continuously reduce potential risks by taking into consideration the hazards of petroleum products during the operations of containing, packing, handling, transporting and storing them.

5.86. The system should take into account all risks of possible accidents, which may cause human and environmental exposure at final customer sites, storage facilities and during transport movements.

Guiding Principles

5.87. As part of the risk assessment process all operations should be classified into groups according to their potential risk to adversely affect people and the environment. The methodologies which are used to assess the risk vary considerably.

5.88. The result of the assessment, whatever method is chosen, enables all operations to be ranked according to their risk level. The company should then determine the need for and the application of risk reduction measures.

5.89. Effective risk management should be regarded as a continuous process. The process should be repeated at regular intervals, based on practical experience and incident evaluation, to constantly improve the process. Higher risk activities should receive more frequent reviews.


5.90. A risk assessment should also be carried out each time there is a significant change in the operational activities (e.g. handling of new products, use of new equipment, changes in operating procedures). All new projects should be evaluated at an early stage, to assess the acceptability of the risks compared with regular activities.

5.91. The scope of Risk Assessments shall include a details classroom study of all the routes to customers taking into considering the constraints and risks associated with the routes.

5.92. Once it is decided, that a particular routes are to be used, a physical route assessment shall be carried out, with route cards highlighting the hazards and mitigations actions for these risks.

5.93. The route cards shall also include details on approved rest areas and prominent land mark (fire brigade, hospital and etc along the routes). The details information of the routes and it mitigations actions shall be communicated to relevant drivers through training, toolbox meeting.

Truck Loading

5.94. Critical procedures should be posted in abbreviated or outline form on placards placed at each loading position. They should be easily read from a distance of three meters and drivers instructed to review the procedures prior to commencing each loading

Truck Routing and Delivery Site

5.95. For each delivery site, an authorisedroute for trucks to follow should be established.

5.96. The route should be the most cost efficient (shortest and/or quickest) unless use of that route would significantly increase the potential for a road incident.

5.97. Possible routes should be researched using available computerized tools and/or experienced personnel to help ensure selection of routes, which are optimum from both financial and safety standpoints.

5.98. The route card should also provide the driver with sufficient detail to help ensure safe ingress to and egress from the delivery site and a diagram of the tankage layout.

5.99. A description of any known hazards should be provided along with any specific safety instructions


Delivery Site Considerations

5.100. Transport management should review delivery sites to ensure safe access and positioning for unloading delivery trucks should review the proposed location and layout of storage tanks and fills.

PPE

5.101. Guidance on the minimum protective clothing and safety equipment required to be carried on all heavy goods vehicle transporting company products, and the provision of such equipment.

5.102. It is the responsibility of the Transporter to ensure that all the necessary protective clothing and safety equipment is provided to drivers

5.103. The minimum PPE should comprise: safety shoes, helmets, overall, refelective jackets and gloves suitable for handling petroleum products.

Selection & Monitoring of Transporters

Management Practice

5.104. Due to the risks inherent in road transportation of petroleum products, careful attention must be given to the evaluation and selection of Transporters to transport/deliver products.

5.105. The process should be consistent with evaluation and selection criteria for medium and higher risk services to ensure that Transporters are of sufficient quality to meet expected standards.

5.106. A system shall be in place to ensure all equipment is appropriate for the products to be handled and transported.

5.107. All equipment must comply with the relevant legal requirements and Oil Industry up minimum standard.

5.108. The equipment must be maintained in good conditions and “fit for purpose”.

5.109. Put in place a system to capture and report defective equipment, which include the criteria in correcting these defects.

5.110. This system should emphasize safety and environmental performance, regulatory compliance, equipment maintenance and training. Furthermore it should ensure regular review of safety and environmental performance and the implementation of necessary improvements.


Guiding Principles

5.111. The following is a listing of the general areas that should be addressed:

• Transporter Company Profile.

• Commercial stability of prospective Transporter:

• Reputation

• Standing in the Oil Industry

• Organizational Structure

• Experience, etc.

• Quality of Management (including Fleet/Driver Supervisory Personnel).

• RTS Performance

• RTS Policies.

• Drugs and Alcohol Policy.

• Standard Operating Procedures.

• Driver Training.

• Personal Protective Equipment.

• Vehicle Equipment and Maintenance Requirements.

• Incident Reporting, Investigation and Analysis.

• Emergency Preparedness.

Contract Provisions

5.112. In addition to normal legal, economic and performance stipulations, Transport Contracts should include specific provisions relating to safety.

5.113. The following is a listing of areas which should be addressed:

• RTS Policies, requirements and expectations/standards of performance.

• Drugs and Alcohol Policy.

• Hours of Work

• Compliance with laws and applicable governmental regulations.

• Incident reporting, investigation and follow-up.


• Emergency response planning and availability of support equipment and personnel.

• Minimum safety specifications for vehicles.

• Minimum qualifications and training requirements for drivers.

• Right to audit to verify compliance with safety requirements.

Subcontractors

5.114. When it is allowed, and product delivery is accomplished using sub-contractors, contract documentation shall include a process to sustain and improve motor vehicle safety within the sub-contractor’s organization, working ultimately to the same standards set and achieved by this RTS MS.

5.115. When selecting a sub-contractor, there shall be a mechanism in place to identify companies with existing quality RTS Management Systems and demonstrated road safety performance.

5.116. Transporters shall ensure that the ongoing road safety performance of its sub-contractors is measured, monitored, and reported regularly to ensure timely detection of nonconformities and effective corrective actions

Driver Recruitment, Selection, Training & Certification

Management Practices

5.117. Maintaining fleet operations that protect Safety, Health and Environment and that conform to laws and regulations requires careful selection, placement, ongoing assessment and proper training of all personnel involved in customer service operations

5.118. It is essential that care be exercised in the selection of individuals for transport management roles, that they possess the necessary qualifications, that they receive appropriate training and that their effectiveness be appraised on an ongoing basis.

5.119. Road Transporters shall have a policy and procedure in place to address the requirements in recruiting new drivers and to recruit the best driver available.


Guiding Principles

5.120. Management must visibly demonstrate its commitment to safe working at all times, leading by example and reinforcing the principle that safety is of highest priority.

5.121. Communications that safety is an ongoing process should be directed toward individual employees and groups of employees.

5.122. While management is responsible for promoting a positive safety culture and providing the training, support programs and other tools, drivers ultimately have the fundamental role in maintaining safe operations.

5.123. Successful management of these functions requires a fully integrated process; from driver recruitment and selection through induction, ongoing training and day-to-day coaching and influence by management.

Drivers

5.124. Drivers shall possess ERC certificate in compliance with the Energy (Licensing of Petroleum Road Transportation Business) Regulations, 2013.

5.125. The requirements associated with loading, transporting and unloading petroleum products, coupled with constant interaction with other roads users, customers and others, require drivers to be continually alert to potential hazards, consistently follow safe work procedures and maintain a safe work environment around themselves.

5.126. Maintaining an appropriate complement of employees with the necessary skills and discipline requires considerable attention to be given to the recruiting and selection of new drivers and ongoing training and performance evaluation of incumbents.

Selection Criteria

5.127. Key to driver recruitment is the identification and definition of the personal attributes and characteristics required to meet the job requirements. These attributes and characteristics should be documented in a job specification for reference to help ensure consistency in the selection process over time.

5.128. All qualifications, for the driver position should be classified as either essential or desirable. Essential qualifications are those that are either legal requirements or considered mandatory by the affiliate. Failure to meet an essential qualification should automatically disqualify a candidate from consideration.


5.129. Failure to meet a desirable qualification should not necessarily exclude an otherwise suitable candidate who has offsetting desirable attributes or where training will correct deficiencies.

5.130. A driver recruitment specification should consider such areas as:

• Driver training from a school approved by ERC

• Certificate of good conduct

• Formal Qualifications (Diving License for Class of Vehicle)

• Existing Skills and Experience (min 4 years driving equivalent class of vehicle)

• Driving Record (proven past safety performance)

• Employment Record (reference check)

• Personal Characteristics and Personality (polite/reliable/team)

• Personal Image (pride in appearance and employer’s image)

• Personal Circumstances (distance from work/current earnings)

• Motivation (wants to be best in class)

• Health/Fitness/Physical Abilities (medical assessment)

• Level of Education (minimum KCSE)

• Demonstrated Intelligence (understands job requirements)

• Criminal Record (no criminal convictions)

License and Certification Requirements

5.131. Before any candidate is permitted to drive a company or contract hauler vehicle, accompanied or alone, it will be mandatory that the driver possess and present for inspection by transport management, a valid license for operation of the class of vehicle(s) to be driven.

5.132. Drivers shall possess ERC certificate in compliance with the Energy Act 2006 and Energy (Licensing of Petroleum Road Transportation Business) Regulations, 2013.

5.133.

Induction Training

5.134. A documented system of initial or induction training should be in place to ensure that new drivers are fully trained to meet the responsibilities and


functions of the job, and comply with governmental/regulatory requirements.

5.135. Induction training should include a combination of theory and practical work, requiring a balance between classroom and “on the job” instruction. Reviews, testing and other methods to confirm understanding of content should be incorporated into the structure.

5.136. The following is a listing of items that should receive such attention:

• Oil Terminal Safety Rules and Procedures.

• Emergency Procedures

• Pre-start and Pre-move Checks.

• Trailer Un-couple and Couple.

• Refueling/Lubricants/Water/Air.

• Driving Principles and Techniques.

• Product Loading.

• Product Unloading

Defensive Driving Training

5.137. Developing skill in the use of “defensive driving” techniques (maintaining continuous awareness of the surrounding road environment, planning ahead and avoiding hazardous situations) is a fundamental requirement for safe driving.

5.138. Comprehensive training in defensive driving techniques is an integral part of any driver training program. Initial training should be included as part of the induction training provided for delivery vehicle drivers and refresher training provided every two years.

5.139. Good defensive driving programs are typically based on similar concepts and include a series of interlocking techniques and practices for avoiding hazards and/or preventing accidents.

5.140. The main features typically included are:

• Expanding the driver’s field of observation.

• Continuous visual search.

• Total awareness of the surrounding environment.

• Perceptive anticipation of the actions of others.


• Planning ahead.

• Timely and deliberate actions/reactions.

5.141.

Ongoing and Refresher Training

5.142. Truck drivers must not be allowed to perform work tasks without being properly trained. Ensuring proper training requires that a system be maintained to identify training needs, provide a mechanism to carry out such training and assess its effectiveness.

5.143. All training should be documented and records maintained for each individual driver.

5.144. The need for training may stem from a variety of sources including:

• Induction gap analysis.

• Need for skills improvement identified by supervisors.

• Changes in equipment, procedures, regulations, etc.

• Incident investigation/follow-up (remedial).

• Driver Competency Evaluations

• Refresher training cycles.

Routine Driving Skills/Knowledge Training

5.145. Routine procedures and demonstrable skills should be periodically reassessed and refresher training provided to all drivers.

5.146. This refresher training should be mainly task oriented with Incident Prevention Observations (IPO) being the primary tool used for identifying areas for discussion and improvement.

5.147. This formal training should, as a minimum, be conducted every two years with the duration of training sufficient to provide adequate time for practical tasks and trainee review (typically a full day).

Accident Follow-Up (Remedial) Training

5.148. Training programs may be required to address specific areas of concern following investigations of incidents or from observed trends in incident causes.


5.149. In addition, specific remedial training should be required for drivers involved in any safety or environmental incident. Such training should focus on the root cause of the incident but include adequate review, discussion of other tasks and appropriate testing to confirm that the driver is fully competent.

In-the-Vehicle Driver Observation Training

5.150. Truck drivers should receive regular in-the-vehicle driver skills evaluation training

5.151. Such training should equip drivers to both demonstrate safe driving and/or defensive driving principles from behind the wheel.

5.152. Trained supervisors can in effect make each opportunity to ride with employees a training session, follow up on previous evaluations, isolate problem areas and provide direction to help employees overcome driving weaknesses.

Periodic Performance Appraisal

5.153. Performance of new drivers during the period immediately following completion of induction training should be closely monitored and culminate in a formal performance review after six months of employment.

5.154. Ongoing assessment of driver performance should be an integrated process involving the use of continuous observations, records, measurement against quantifiable parameters, and the Driver Competency Evaluation Program

Driver Risk Assessment

5.155. A procedure shall be adopted for the assessment of the safety risk factors associated with potential and existing drivers.

5.156. This process shall involve a series of tests designed to identify higher risk drivers so that individually focused training packages can be developed.

Driver Health Monitoring

5.157. Pre-employment and ongoing routine health screening is a requirement for all drivers.

5.158. The objectives of driver health screening are:


• To ascertain the driver’s fitness to drive and to perform the associated work activities of a product delivery driver.

• To inform the driver of any health condition which could be aggravated by the driver’s occupation, could impair the driver’s ability to perform driving and associated duties, and/or could endanger others.

• To provide the Company, Contractor and the driver with adequate information to decide whether the driver should commence or continue employment as a driver.

5.159. The frequency of health screening shall be as follows:

• Persons shall be required to undergo health screening before commencing work as a driver by a Designated Health Practitioner (DHP).

• Existing drivers shall undergo health screening every one year by a DHP.

• Existing drivers shall be required to undergo health screening if they develop an injury or illness (whether or not this results in absence from work) that may affect their ability to perform their work as a tanker truck driver safely.

Drug and Alcohol Testing

5.160. There shall be a program of testing drivers for the presence of alcohol and illicit drugs.

5.161. It is recommended that the program include post-incident testing and random testing at the commencement of shift.

Fatigue Management

5.162. Fatigue is a major safety hazard for tank truck drivers, and the maximum allowable driving hours must be controlled.

5.163. Transporter shall ensure compliance with the driver hour requirements of the Management System and the Employment Act 2007.

5.164. Transporter and staff who roster drivers must not allocate work to a driver which may reasonably be expected to involve longer driving periods than allowed.


5.165. In addition to ensuring compliance with the maximum allowed driving and work hours, Transporter shall implement fatigue management and health/lifestyle training for all drivers.

Drivers Compensation and Benefits

5.166. Drivers should be covered under WIBA as a minimum;

5.167. Driver’s behavior and performances is largely dependent on its remuneration and motivation. As such, the salary package shall not structure in a way encouraging drivers violations, to work or drive beyond the specific hours.

5.168. Individual drivers are monitored and measured and ranked based on safety behavior performance.

Specification & Maintenance of Equipment

Management Practice

5.169. All bulk petroleum delivery vehicles are required to meet statutory requirements for the carriage of dangerous goods and to display all appropriate signage and carry required documents.

5.170. Safety related features should be considered for inclusion on delivery vehicles.

5.171. Such features are segregated into two broad categories, “Incident Prevention” and “Severity Reduction” and further grouped by function and/or equipment type.

5.172. A system should be in place, which ensures that all equipment is appropriate for the petroleum products which are stored, handled and transported.

5.173. All equipment must comply with the relevant legal requirements and must be maintained in proper condition.

5.174. A system should be in place for immediate reporting and prompt correction of any equipment defects.

Guiding Principles

5.175. A system should be in place requiring a written specification for purchase or lease of any transport equipment. These written specifications should take into account the appropriate Kenya Standards.


5.176. Effective maintenance programs should be in place, which require that all transport equipment (owned, leased or subcontracted) is adequately maintained to prevent and detect defects before they cause accidents or breakdowns.

Transport Unit

5.177. Any carrier carrying petroleum products by road has to make sure that the transport unit complies with the relevant requirements of the Kenya Standard:

• A transport unit loaded with petroleum products must not include more than one trailer or semi-trailer.

• Transport units carrying petroleum products have to be placarded and marked

• They must carry appropriate fire-fighting equipment:

5.178. Every transport unit carrying petroleum products has to be equipped with:

• for each vehicle, at least two chocks of a size suited to the weight of the vehicle and the diameter of the wheels

• two self-standing warning signs

• a suitable warning vest or warning clothing for each member of the vehicle crew (high visibility)

• a flashlight for each member of the vehicle crew;

• the personal protection equipment necessary to take the additional and/or special actions required by HERP.

Incident Prevention Features

5.179. Petroleum trucks shall comply with the relevant Kenya Standard.

5.180. Incident prevention features are those which either directly or indirectly aid in the prevention of incidents.

5.181. Included are features which enhance visibility, provide for improved control of both truck and trailer and reduce the potential for driver fatigue and/or distraction.


Incident Severity reduction Features

5.182. Incident severity reduction features are those whose basic purposes are to reduce the severity of injury and/or damage should an incident occur.

5.183. Included are features which lessen the potential for serious injuries to occupants of other vehicles in certain types of collisions, protect against and/or reduce severity of injuries to delivery vehicle drivers and passengers and reduce the potential for spills and resulting fire and/or environmental damage in the event of rollover.

Vehicles – Marking and Placarding

5.184. Every Transporter has to make sure that any vehicle, container, etc displays the appropriate placards, as well as the applicable marks, orange-colored plates, and HINs.

5.185. Placards have to be fixed to the outside surface of vehicles, containers, etc per the UN recommendations on the transport of dangerous goods – model regulations (UN Orange Book).

5.186. Placards not relating to the petroleum products being carried (or to residues of them) have to be removed or covered.

Vehicle Maintenance

5.187. Vehicles shall be maintained in accordance with the manufacturer’s recommendations on a pre-determined schedule.

5.188. Deviations from the schedule must be minimized, and require management approval.

5.189. Documented procedures shall be followed for all routine maintenance and inspection procedures.

5.190. All faults found during vehicle operations and maintenance shall be recorded in a daily fault record, which shall be rectified and signed off by the maintenance staff within an appropriate period.

5.191. Persons completing maintenance checks and inspections shall certify that the vehicle is roadworthy to the limits of the inspection.

5.192. Maintenance shall be carried out in properly equipped workshops which meet local occupational health and safety standards.

5.193. All completed maintenance records shall be maintained on file for a period of five years, or for the life of the vehicle, whichever is the lesser.


5.194. Maintenance staff shall be provided with training appropriate to the tasks they undertake, and records of training shall be maintained.

5.195. Waste oil shall be managed in accordance with NEMA Waste Management Regulations, 2006.

OBC/GPS

5.196. The data outputs from OBC/GPS (driving improvement monitors) are to be regularly reviewed and the information used to improve driving behaviours.

5.197. The parameters reviewed must include harsh braking, sudden acceleration, speed and engine R.P.M.

Training

Management Practice

5.198. Maintaining fleet operations that protect HSE and that conforms to laws and regulations requires careful selection, placement, ongoing assessment and proper training of all personnel involved in customer service operations

5.199. A system is in place to ensure that the training needs of Drivers are identified and satisfied in an appropriate and adequate manner so that operations are carried out competently and safely.

5.200. The driver shall be trained based on the characteristics of the work activities. The training shall be delivered by approved trainer and shall be properly assessed and recorded.

Guiding Principles

5.201. Systems should ensure that the training needs are regularly reviewed so that all employees are competent at all times to carry out the duties for which they are responsible. In particular, it should be reviewed whenever there are significant changes in the work carried out or in the equipment to be used.

5.202. Training must take account of any statutory regulations but should also reflect industry codes or standards relevant to the work.

5.203. A designated person within the company should co-ordinate and manages the provision of training and maintains appropriate training records.


General Training

5.204. Employers involved in the carriage of dangerous goods by road have to ensure that their employees who have any responsibility for such carriage are appropriately trained. Examples include loaders, unloaders and drivers who do not require specialised driver training. The training must include:

• awareness of legal requirements;

• safety training, covering the hazards and dangers presented by dangerous goods and awareness of safe handling and emergency response procedures commensurate with the degree of risk of injury or exposure arising from an incident involving carriage of dangerous goods.

5.205. Competence including evidence of relevant training should be maintained for all staff and verification obtained for new staff.

5.206. Refresher courses must also be arranged to take account for changes in the law.

Driver Training

5.207. An Annual Training Plan and Systems are in place to ensure that the training needs and effectiveness are review on a regular basis. Training should comply with the National Transport and Safety Authority Act requirements.

5.208. A training matrix should be in place to determine what training will be delivered by whom, what is the frequency etc.

5.209. Training must take account of any statutory regulations but should also reflect industry codes or standards relevant to the work.

5.210. A designated person within the company to co-ordinates and manages the provision of training and maintains appropriated training records.

5.211. Truck drivers must hold a valid driving license for the class of vehicle issued by the Kenya Revenue Authority.

5.212. The driver must have attended appropriate training courses and passed an examination for vehicles carrying dangerous goods.

5.213. The main objectives of the training (which must include theoretical courses, individual practical exercises and appropriate refresher and specialist training) are to:


5.214. make drivers aware of hazards arising in the carriage of dangerous goods

5.215. give them basic information to minimise the likelihood of an incident taking place

5.216. enable them to take necessary measures for their own safety and that of the public and the environment, to limit the effects if an incident does occur.

5.217. Drivers of vehicles carrying dangerous goods must, on request, produce their driving licenses to the police or any goods vehicle examiner.

Driver Monitoring

5.218. The Transporter shall have a formal system and procedures to monitor and promote safe driving Behavior and performance.

5.219. Unsafe Behavior and traffic violations shall be counselled and disciplinary actions taken on repeated offenders.

5.220. Driver Monitoring will be carried out through GPS Data Analysis, Road Surveillance, Driver’ Log, Drug and Alcohol Random Testing, etc.

Standard Operating Procedures

Management Practice

5.221. A key aspect of safe fleet operations is to ensure safe operating practices and procedures are established, that drivers are properly instructed in their use.

5.222. Additionally, it is important to monitor and assess performance of employees in performing these duties to determine refresher-training requirements and/or improvements to procedures are required.

5.223. Systems should be in place to develop and implement SOPs that ensure that day-to-day operations are carried out in compliance with legislation, industry codes and standards, to protect people and to minimize impact on the environment. .

5.224. The system should also define the requirements got periodic review of SOPs.

5.225. Activities, for which the absence of written procedure could result in infringement of the RTS Policies or breaches of legislative requirement or performance criteria, should be identified.


5.226. Documented SOPs should be prepared for such activities, defining how they should be conducted-weather by the company’s own employees, or by others acting on its behalf – to ensure technical integrity and of transfer knowledge effectively.

Guiding Principles

5.227. Transporters should identify and prepare an inventory of all the operations that are carried out.

5.228. Each operation should be broken down into its individual tasks.

5.229. Procedures should be developed for each task and the responsibility for completing that task should be clearly defined.

5.230. The operating procedures should cover the selection of proper equipment for handling the products taking into account their hazards and relevant national or international legislation and the precautions to be taken both in normal and emergency situations.

5.231. Where the operation involves interfaces with third parties, procedures should ensure full alignment.

5.232. Procedures should be updated whenever changes occur in the legislation or in industry codes and standards. Procedures should be regularly reviewed, covering all aspects of the operation.

Drivers Handbook

5.233. Appropriate and meaningful truck operating procedures should be developed for all routine tasks performed by the driver under normal operating conditions.

5.234. These procedures serve as an ongoing detailed instruction reference for drivers.

5.235. Each driver should be issued a copy of the Drivers Handbook that contains specific SOPs during the initial/induction training and receive all revisions and/or updates.

High Risk Operations

5.236. Higher Risk Operations should be identified and have specific procedures developed and approved before undertaking such operations.


Standard Operating Procedures

5.237. Standard Operating Procedures should include the following:

• Start of Shift Procedures

• Safe Loading Procedures

• Safe Unloading Procedures

• Product Custody Transfer Procedures

• Critical Safety Equipment

• Temporary Disarming or Deactivation of Critical Safety Equipment

• Higher Risk Operations

• Interfaces / Shift Relief

5.238. A Journey management system should be operated to ensure each journey is necessary, properly organized and supported.

5.239. The Transporter should maintain procedure to ensure that HSE-critical facilities and equipment which it designs, procures, operates, maintains and inspects are suitable for the required purpose and comply with defended criteria.

5.240. With effective procedures, structured inspection and qualified personnel who consistently execute SOPs and Practices, it is expected that no incidents will occur due to deficiencies in operations procedures.

Reporting & Evaluation of Incidents & Accidents

Management Practice

5.241. Section 117 of the Energy Act, 2006 and OSHA 2007

5.242. The Traffic Act Cap 403 requires a carrier to report accidents involving the carriage of dangerous goods to the Kenya Police Service.

5.243. The primary purpose of an investigation is to improve safety and environmental performance by learning from incidents and using information gained to determine steps to prevent or reduce the potential for recurrence.

5.244. Both the direct and root causes of an incident should be determined by the investigation. It is important for personnel involved in vehicle operations to understand that pinpointing blame is not the purpose of an


investigation, which in fact can be counterproductive if individuals are reluctant to reveal all the facts concerning an incident for fear of reprisals.

5.245. All incidents and reported near misses, regardless of the level of severity, should be investigated. The causes of minor incidents have been found to be the same as for incidents with major consequences.

5.246. A system should be in place for the recording of all accidents, incidents and potentially hazardous situations, and for identifying and implementing preventive measures.

Guiding Principles

5.247. There should be a written reporting procedure to ensure the proper logging of all accidents and incidents, and communication to all parties concerned.

5.248. Ownership and stewardship of the reporting system should rest with a nominated senior manager within the company.

5.249. The system should be well understood by all personnel and by all subcontractors to ensure that all incidents/accidents are reported.

5.250. Each accident or incident should be investigated. In addition to the identification of the immediate cause, the root cause of the accident or incident should also be ascertained. Corrective actions should be identified to prevent a recurrence of similar events.

5.251. Investigations should normally be conducted by a team of not less than three with at least one member having been thoroughly trained in incident investigation techniques.

5.252. The depth and formality of an investigation should be based on the complexity of the incident and the equipment involved. For less complex incidents an in-house investigation team lead by a local supervisor may be sufficient. For more complex incidents adding team members from outside the local operations group can provide additional technical capability and objectivity.

5.253. All accident/incident reports should be periodically analyzed to search for trends and common causes. Identification of trends allows additional improvements to be developed.

5.254. Similar principles apply to the investigation and reporting of potentially hazardous situations.


5.255. Employees and all subcontractors should be encouraged to make use of the reporting system as a means for continuous improvement.

5.256. The immediate benefits of the investigation process are realized when a determination has been made as to what caused and/or contributed to an incident and recommended steps are implemented to prevent or reduce the potential for recurrence.

5.257. A longer range benefit may materialize if collective incident data are analyzed for trends or patterns by such factors as equipment type/features, type incident, shift, time during shift, work activity, location, type roadway, road conditions, etc.

5.258. Results of such analyses may pinpoint problem areas and provide valuable input into equipment selection, maintenance procedures, work practices, training, safety emphasis and communications efforts and other safety related activities.

Emergency Response

Management Practice

5.259. Emergency response plans should be prepared for all major contingencies involving delivery vehicles, including potential incidents involving third parties and facilities located outside terminals.

5.260. Response plans should be reviewed for currency and updated on an annual basis, and when personnel or organizational changes occur.

5.261. A system should be in place to enable a rapid and effective response to any accidents occurring during logistics operations.

5.262. Transporters should link emergency response plans with the HERP

Guiding Principles

5.263. Transporters have the responsibility for emergency response for incidents involving their vehicles.

5.264. The following scenarios should be considered:

• Medical emergency. A serious injury/fatality of driver personnel and/or third party(s).

• Significant road accident.

• Significant product spill or leakage.


• Vehicle fire outside the terminal.

• Incident which could potentially attract media/public attention or could escalate to any of the above.

5.265. The Emergency Response Plan should, as a minimum, provide for the following:

• Clear definition of roles and responsibilities.

• Coverage for all hours of fleet operation.

• action to be taken in case of different types of emergencies.

• arrangements for handling incoming emergency calls.

• Adequate availability and positioning throughout the operating area of oil recovery/product transfer equipment.

• Emergency response team(s) to attend emergency situations, e.g., product transfer/recover following major road incident.

• Ninety percent of locations where incidents may occur reachable by a response team within 4 hours traveling time.

• training requirements of the responsible personnel.

• Exercises should be held at appropriate intervals to test communications and practical response.

5.266. Ownership of the Emergency Response Plan should rest with a nominated person, who should be responsible for ensuring that the plan is kept up to date, that individuals are trained as required, that training records are kept, that emergency equipment is regularly checked for completeness and continued suitability and that exercises are held at appropriate intervals.

Management of Change

Management Practice

5.267. Any changes in the personnel, vehicles, processes and procedures of land transport in the company have the potential for adverse effects on health, safety and the environment.

5.268. All changes should be considered in this light. Changes which may be critical to the management of safety of road transportation should be reviewed prior to implementation.


5.269. Changes, which have safety, health or environmental implications, should be controlled through the Management of Change Process. This is required due to the root cause of many accidents can be traced to activities and operations that were being performed in a non-standard way, or by people that had temporarily and recently been assigned to a job or task.

5.270. Whenever personnel, equipment, delivery routes or site conditions cannot be done by in a normal and routine manner, by trained personnel that are familiar with the operation and locations, then Management of Change should be applied.

Guiding Principles

Change Categories

5.271. To initiate any change, the initial step is to complete a change request form.

Key Personnel Change

5.272. Changes to key Personnel should be managed to ensure that appropriate training and hand over of key responsibilities is completed prior to the completion of change.

Transporter Change

5.273. Mobilizing a New Transporter as a result of Fleet Procurement activities to ensure that the procurement and qualification requirements are identified in advance, have received the appropriate reviews and approvals, and are strictly adhered to during the change process.

Truck/Equipment Change

5.274. Changes of trucks, associated equipment or facilities should be managed to ensure that minimum standards and requirement are identified in advance, have received the appropriate review and approval, and are strictly adhered to during the change process.

Delivery Route Change

5.275. Changes of approved route segments to each customer should be managed to ensure that acceptable alternate routes are identified in advance, have received the appropriate review and approval, and are strictly adhered to during the change process.

Procedural Change

5.276. Changes of trucks loading or unloading procedures should be managed to ensure that minimum safety risks are identified in advance, have received


the appropriate review and approval, and mitigative steps are strictly adhered to during the change process.

Facility Change

5.277. Changes of facilities should be managed to ensure that minimum standards are identified in advance, have received the appropriate review and approval and are strictly adhered to during the change process.

Process Documentation

Management Practice

5.278. Current information on the configuration and capabilities of processes and delivery vehicles and facilities, properties and materials handled, potential safety health and environmental hazards, and regulatory requirements is essential to assess and manage risk

5.279. All RTS documents and records for Fleet Operations should be current, available and maintained in accordance with defined intervals.

5.280. Documentation must be kept to demonstrate a fleet's compliance with all laws and regulations.

Guiding Principles

5.281. On an ongoing basis, transport managers and supervisors are responsible to ensure that operations are being carried out safely and that all legal requirements are being met.

5.282. Periodic checks should be made and documented to ensure that operating procedures are fully understood and being followed.

5.283. Transport management must seek to provide both a safe work place and safe working conditions for delivery vehicle drivers.

5.284. Process Documentation will include the following:

• Truck Design Details

• Route Card-Delivery Site Layouts

• Database containing all the relevant licenses for drivers

• Copies of insurances for trucks

• A Re-certification Program for drivers and trucks

• Settings for Safety Valves/Pressure Relief Valves


• Occupational Exposure Limits

• MSDSs

• Tank truck regulated weight limitations

• Regulations limiting driver working hours

• Rejection criteria for tank truck discharging hoses

• Critical Equipment Inspection and Maintenance

• PPE

• Axle load Limits

• Hours of Work

• Licenses and Permits

• Maintenance Records

5.285. Management must ensure the database is kept current

5.286. Truck safety features must be kept and updated as necessary.

Auditing

Management Practice

5.287. Regular assessment of the RTS MS should be of paramount importance to organizations engaged in delivery operations.

5.288. The assessment process is to monitor performance, set action plans for correcting deficiencies, and ensure that lessons learnt lead to further improvement in RTS Management.

5.289. Planned and systematic audits of the RTS MS together with management reviews of performance should be established and maintained as an integral part of the land transport operations.

5.290. Deficiencies observed during audits should be recorded, their implications assessed, and remedial actions prioritized and implemented.

Guiding Principles

5.291. The objectives of auditing can be summarized as follows:

• to review the implementation of company HSE Policies.

• to verify compliance with legislation, industry codes and standards.


• to promote awareness of HSE protection.

• to assess the RTS Performance.

5.292. Auditing is an integral part of the management process. The responsibility for auditing and implementing remedial measures rests with line management, although specialists can assist in developing audit procedures and in auditing.

5.293. The audit plan should identify specific areas to be audited, the frequency of those audits and the responsibilities for auditing specific activities/areas.

5.294. Audit frequency should be determined by the degree of risk and the results of previous audits and inspections.

5.295. Audit protocols should be established which ensure that adequate resources, personnel requirements and methodologies are in place for the audit, together with procedures for reporting audit findings and tracking the implementation status of audit recommendations.

5.296. The internal audits should be carried out quarterly by people trained in auditing and evaluating techniques. A significant portion of auditing can be carried out by the local management.

5.297. On occasion, it may be appropriate to have external audits by auditors who are independent of the location or even of the company to be audited.

5.298. Based on the recommendations of the audit report, there should be an action plan with follow up to which line management is fully committed.

Management Review

5.299. Management shall carry out review on the RTS Management System at appropriate intervals to ensure its continuing suitability and effectiveness for the ongoing operations.

5.300. The review should include audit findings and the status of audit recommendations as well as report from incident investigations.

5.301. It should also consider the continuing suitability of land transport policy, any changes in recognizing hazards and assessing risks and any changes to the system or procedure since the last review.

5.302. The management review should be recorded.


6. References

6.1. Traffic Act Cap 403

6.2. Kenya Standards – KS 2180, 2223 and 2270

6.3. OSHA 2007

6.4. Chevron Corporation – Road Transport Safety Management Plan

6.5. Shell Global – Haulier Standards

6.6. BP – Road Transportation Management Guidelines

6.7. Exxon Mobil – Vehicle Safety Management Guidelines

6.8. Total – Patrom Hydrocarbons Management System

6.9. ADR - European Agreement Concerning the International Carriage of Dangerous Goods by Road

6.10. Kenya Standards:

6.11. KS 2180 – Petroleum Road Tanker Standard

6.12. KS 2223 – LPG Road Tanker Standard

6.13. KS 2270 – LPG Road Tanker Accessories Standard

6.14. UN Recommendations on the Transport of Dangerous Goods - Model Regulations Seventeenth Edition, 2011