DEVIATION AND VARIANCE
2.0 PROTOCOL 2 – HAZARDOUS MATERIALS
2.1 OVERVIEW
Purpose Communicate and address all potential chemical hazards effectively.
Proper awareness will prevent fatalities, injuries and incidents from the improper storage, handling, production, transport, recycling and disposal of hazardous materials.
Scope This protocol applies to hazardous materials that, in one or more of their
forms (solid, liquid or gas) possess:
n Physical Hazards n Health Hazards
n Environmental Hazards
Risks related to these hazards arise due to loss of control / containment and improper or incompatible use during normal activities such as storage, handling, production, transport, recycling and disposal.
This protocol does not cover handling of radioactive or infectious materials.
Incident causes Hazardous materials have been involved in previous incidents. The root
causes and contributing factors have included:
n Poor understanding of chemical properties and reactions. n Improper handling and storage.
n Insufficient containment systems.
2.2 REQUIREMENTS
Legislation Obey all applicable OH&S, Environment, Explosives and Transportation
legislation, standards and industry codes of practice when involved in hazardous materials operations.
Safety in design Consider product and process reformulation / redesign where technically
feasible, to eliminate or reduce potential exposure for personnel to hazardous materials.
Review the design of a facility or process, permanent or temporary, which transports, produces, stores, uses or disposes of hazardous materials. Update as-built design drawings (i.e. process and instrumentation diagrams, process flow diagrams, layout drawings, isometrics, etc.) in light of these reviews.
Hazard Include Hazardous Material Management activities in the risk register.
assessment Consider the following:
n Use of alternatives to current hazardous materials n Risk associated with the hazardous materials.
n Selection criteria and lifecycle analysis for all hazardous materials,
including the means of disposal.
n Performance requirements (reliabilities and capacities) of specific
equipment and systems included in these controls.
Hazardous Designate a Hazardous Materials Management position at sites where
materials hazardous materials are processed, stored and handled, to:
management
n Identify all critical activities involving hazardous material. n Assess the properties of hazardous materials on site.
n Authorize the introduction, use and disposal of hazardous materials
on site including empty containers.
n Maintain the sites Hazardous Materials Safety Data Sheet (MSDS)
inventory and provide copies when required.
n Develop JSAs and implement any required controls.
n Ensure that required Personal Protective Equipment is provided. n Ensure that StepBack Risk Evaluations are conducted prior to all
work activities involving hazardous materials taking place.
n Document training related to selection, transportation, storage,
handling, and use and disposal of incompatible hazardous substances.
n Ensure that all relevant design documents and drawings associated
with this protocol are up-to-date, controlled and available.
n All tankage and dispensing equipment shall have incorporated
grounding and bonding systems.
n Only allow smoking in designated areas.
MSDS Ensure that MSDS’ from the supplier of the hazardous material are provided and are readily available to all personnel (employees, contractors and other affected parties such as first aiders and medical personnel) involved in the transportation, storage, handling, use and disposal of hazardous materials in the language(s) commonly used at the site.
Ensure MSDS’ are readily available at the point of use and storage locations. Also ensure that they are not more than 3 years old or they are considered to be expired.
Critical Risk Control Protocols
Labeling Place labels on all storage vessels, containers and tanks, as per appropriate
local or applicable standards (WHMIS, TDG, HazCom and / or DOT). Mark piping containing hazardous substances so that the contents and direction of flow is clear.
Storage Minimize the inventory of hazardous materials to only necessary amounts.
Secure and control access to areas where hazardous materials are stored. Ensure there is a site register for all hazardous materials which includes:
n Name
n Identifier (HAZCHEM/UN/CAS code) n MSDS
n Maximum inventory
n Storage requirements and precautions
n Location and physical properties of all materials n Disposal methods
Protect hazardous materials containers from physical damage due to extreme temperatures, moisture, corrosive mist / vapors, and vehicles. Consider ready access for firefighting and emergency response personnel. Ensure adequate segregation of incompatible materials when stored in close proximity (i.e. oxidizer should not be stored near any flammable solvents)
Transporting Implement procedures for transporting hazardous materials. Complete
a manifest and supporting documentation necessary to transport them. Supplier or workplace labels are different than transportation labels and may not be used for this purpose.
Emergency Implement a documented emergency response plan when the risk level
response from hazardous material is high or extreme. Review, revise and test the
plan at least annually. Include external support services such as local ambulance, spill cleanup and fire suppression.
Consider the following:
n Means of escape in an emergency.
n Emergency response teams appropriate to
the risk.
n Theoretical and practical training of personnel. n Appropriate number and location of muster
and assembly areas.
IN THE EVENT OF A MEDICAL OR FIRE EMERGENCY CALL
RADIO USERS CHANNEL
1 State your NAME
2 NATURE of Emergency (fire, medical, spill, risk, other)
3 NUMBER of people involved
4 LOCATION advise landmarks, signs
5 Stand by in a safe location to assist
Remember: Contact your Supervisor ASAP
6846.1-EN-Rev.0
(6846.1 Emergency Contact Poster)
n Emergency response equipment for spillage containment, fires,
explosions.
n Recovery procedure and disposal of hazardous materials.
n Installation of eye wash equipment appropriate to the type and
volume of chemical hazards. Bottle stations can be used or, where 60 second or longer (flushing) flow rates are called for in the site MSDS sheets, hard lined eye-wash stations may be installed.
Short and long- Exposure to Hazardous materials may present health risks. Monitor short
term exposure and long-term exposure of personnel to hazardous materials, including the
potential for immediate, long-term harm and the potential for Immediately Dangerous to Life or Health (IDLH) situations.
If there is a potential to exceed the occupational exposure limit of a hazardous substance, a safe work permit shall be used and the following actions considered to prevent over exposure:
n Replacement of the material or process with a less hazardous option. n Process and equipment isolation.
n Engineering controls such as ventilation, barriers, and exhaust fans. n Proper decontamination of land, facilities, and equipment.
n Use of the correct personal protective equipment.
Training and To ensure workers have the information they need to protect themselves
competency and their worksites from hazardous materials, they must understand the MSDS
and label formats and how this information should be used in job planning. Implement a competency based training program that addresses:
n The format of the MSDS;
n Hazard materials label information;
n The general transportation, storage, handling, use and disposal of,
and emergency response procedures for hazardous materials.
Develop a training matrix to identify required courses and experience. This will serve as a visual tool for readily assessing compliance to this protocol.
Critical Risk Control Protocols
Monitoring Document:
n A procedure for hand-over between shifts that records any relevant
information / changes in operating status.
n Worker training records.
n Evaluations conducted for the introduction of new chemicals. n All industrial hygiene monitoring records.
2.3 RECOMMENDED PRACTICES
Safety in design Conduct a documented risk assessment such as a HAZOP or HAZID study
for the safe venting, drainage and containment of hazardous materials. Conduct a dispersion model for toxic gas releases and ensure it is available for all credible scenarios. Determine the exclusion zones and adequate containment area.
Consider the use of automated project control systems to eliminate the need for operator intervention and maintain operation within the required parameters.