Beware of the Unintended Consequence

AT first, it's hard to believe a simple red marker light presents a significant fire risk. More than 80 fires documented since July 2001 prove it, however. What is harder to believe is why these loading dock fires are a recent phenomenon: because enforcement of a U.S./Canadian safety regulation enacted in 1968 finally began four years ago.

The National Highway Traffic Safety Administration requires three red identification lights to be placed, centered, at the top of the rear end of a trailer that is 80 inches wide or wider. Lights available in 1968 weren't easily mounted in this location, so NHTSA didn't force trailer manufacturers to install them. In April 1999 the agency made them mandatory. Burn damage to dock seals and actual fires then increased dramatically, said officials at Frommelt Products Corporation, a Milwaukee manufacturer of loading dock seals. One fire of this type destroyed a food warehouse in Hillside, Illinois. "We're seeing it grow, not going away," Frommelt President Paul Rowlett told me recently.

Frommelt's engineers saw evidence pointing to the ID lights, but how a 14-volt lamp could be responsible for the damage mystified them. Engineering Director Chuck Ashelin and his team investigated the problem as they began developing a fire-resistant dock seal. One factor is dual alternator systems installed on many modern tractor-trailer rigs to power microwaves and other in-cab devices for the drivers. Another is drivers' tendency to leave their lights on while parked, he said.


In their tests, some standard ID lights reached more than 800 degrees Fahrenheit within 30 minutes when compressed into a dock seal's foam pad. Ashelin said the foam begins breaking down because of this heat, releasing flammable gases and more heat; even if the trailer has left the dock, the foam will "auto-ignite" above 800 degrees. "Conditions have to be just right," he said, "but (auto-ignition temperatures) can definitely be exceeded with these low-wattage lamps."

At least 200,000 seals, possibly 250,000, are in use today in the United States with foam head pads vulnerable to this hazard, Rowlett said. Many terminal managers are unaware of it. When they look for heat damage in their facilities' pads, however, they invariably find it. The overall lack of awareness in the industry is the real problem, he said, because dock fires endanger personnel, product, facilities, and productivity.

He said professional firefighters don't believe this hazard is real when they first hear of it. Neither did I. Raising awareness of the threat and of fire-resistant alternative materials may be difficult, but Rowlett and his colleagues are doing their best.


This article originally appeared in the May 2003 issue of Occupational Health & Safety.

About the Author

Jerry Laws is Editor of Occupational Health & Safety magazine, which is owned by 1105 Media Inc.

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