Yes. State the attendance duties that apply to the task. Include them in the written steps and staff training. OSHA 1910.110(b)(14)(i) covers attendance close to the transfer connection. Paragraph (b)(15)(iv) covers attendance during tank-car or truck loading or unloading. Have a qualified reviewer match the steps to your equipment and work.
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Match the task to the correct provision
Do not use one generic attendance line for every job. Check the actual transfer task against OSHA 1910.110 and other rules that apply. The written steps should name the role in charge. A web checklist cannot replace the instructions for your equipment.
Review the work as it happens
As a management check, ask the supervisor about staffing. Can the attendant meet the duty while doing other assigned work? A written role does not help if the person is sent away while the transfer goes on.
Use the manual as part of instruction
OSHA 1910.110(b)(16) also covers training for staff who do the listed work. Have the training lead and qualified reviewer align the steps with that training. This page does not teach loading or unloading. It does not allow untrained staff to do the work.
Sources and scope
Questions and answers
Does a camera alone satisfy the attendance rule?
Do not assume a camera replaces the attendance the rule requires. Have a qualified reviewer check the actual setup.
What should we bring to a manual review?
Bring the current steps and equipment details. Describe staffing and work duties. Protect private site details when you arrange the review.
Prepare for your review
Gather the current procedure and a description of staffing. Arrange a suitable review method before sharing sensitive site details.
Review bulk plant manual scope and request options
General information, not legal advice. Check which rules apply with your regulator and a qualified safety or legal reviewer. You still need training and instructions for your equipment.