ANGLO FATAL RISK GUIDELINE
CONTENTS PAGE
1
SCOPE 3
2
OBJECTIVE 3
3
APPLICATION 3
3.1
D
EFINITIONS4
4
RECOMMENDED APPROACH
7
5
REQUIREMENTS OF THE STANDARD
8
5.1
PLANT
AND
EQUIPMENT
REQUIREMENTS 9
5.2
SYSTEM
AND
PROCEDURAL
REQUIREMENTS 28
5.3
PEOPLE
REQUIREMENTS 50
REFERENCES 55
1 SCOPE
This guideline refers to the implementation of the Anglo Fatal Risk Standard: Hazardous Materials and should be read in conjunction with that Standard.
The guidelines contained in this document are considered as "highly recommended" and deviations are to be documented and justified. Full adherence to these guidelines will not be a factor in determining compliance with the Standards, since alternative methods can be available if justified on a risk basis.
In case of conflict with requirements of any other Anglo document or guideline, the following hierarchy will apply:
1. Anglo Safety Way - ASW 2. Anglo Fatal Risk Standards - AFRS 3. Anglo Fatal Risk Guidelines - AFRG
It is important that when implementing Standards the organisation takes cognizance of, and comply with the relevant legal requirements in the country of application.
2 OBJECTIVE
The purpose of this Guideline is to provide guidance and clarity to assist in implementing the requirements of the Hazardous Materials Fatal Risk Standard.
This guideline has been developed to provide more detail and clarification for the implementation of the requirements of the Standard. This should enable sites to be more aligned with each other on what the boundaries are with regards to meeting the requirements.
This guideline is by no means exhaustive and will be updated periodically and supported by good practice sharing. It is not intended as a template for achieving compliance.
3 APPLICATION
Pertinent section in the standard: “This Standard applies to all Anglo American Group managed businesses and operations, including contractors and visitors when involved in controlled activities.”
Controlled Activities or Controlled Sites are those where the Anglo American Group
Company has the authority to determine how to manage the operation. It does not include monitored or uncontrolled activities.
Monitored Activities are those where Anglo American can exercise some influence but
cannot set Policies and/or comprehensive Control Standards and/or directly supervise and enforce their application (i.e. contractor and supplier transporting their goods and/or personnel to or from “controlled sites”).
Uncontrolled Activities are those where Anglo American does not set or influence
Policies or Control Standards and does not supervise safety performance. These include services provided by public Companies, activities performed at supplier or manufacturer shops, etc.
Where there is uncertainty over whether the activity is controlled, monitored or uncontrolled, the matter should be referred to the Safety function for determination.
3.1 D
EFINITIONSHAZOP : A HAZard and OPerability study is a useful tool in evaluating any inherent hazards or operational problems. The technique enforces a structured, systematic examination of complex process facilities.
HAZID : A (HAZard IDentification) is high level hazard identification that typically addresses the overall project, not only the process equipment. MSDS : A Material Safety Data Sheet (MSDS) is a document that contains
information on the potential health effects of exposure to chemicals, or other potentially dangerous substances, and on safe working procedures when handling chemical products. Each MSDS must contain a minimum of sixteen sections, as prescribed by international standards.
HAZCHEM : This is a code system developed to provide immediate action advice when dealing with a chemical incident. Chemicals are assigned a code e.g. 3Y on the basis of the hazard that they represent and the required emergency response.
MHI : Major Hazard Installation that holds a quantity of a hazardous substance which may pose a risk that could fatally affect the health and safety of employees and the public.
Hazardous Material
Pertinent Section in the Standard: “This Standard applies to hazardous materials in Major Hazard Installations (MHI) that, in one or more of their forms (solid, liquid or gas), have the potential to lead to harm to people, the environment or community (all stakeholders), either in an incident involving loss of control or in normal, controlled activities (e.g. storage, handling, production, transport, recycling and disposal). Where hazardous materials, processes or facilities do not qualify as Major Hazard Installations, some requirements of this Standard may not be practicable. In these cases, a risk-based approach shall be used to determine the level of compliance required. This Standard does not cover handling of explosives or radioactive materials, for which specific procedures shall be in place.”
A hazardous material is a substance or mixture of substances having properties capable of producing adverse effects on the health or safety of a human. Included are substances that are carcinogens, toxic, irritants, corrosives, sensitizers, asphyxiants and agents which may damage the lungs, skin, eyes, mucus membranes or substances which are subject to the release of large amounts of energy such as explosive gases.
Hazardous materials are present at most Anglo sites in activities such as storage, warehousing, processing, distribution, transportation, cleaning, maintenance and waste recycling and disposal. The risk associated with hazardous materials is normally associated with uncontrolled loss of containment or mishandling and they are typically controlled through a Hazardous Materials Register.
Note: for the purpose of Anglo’s initiative bulk fuels including bulk petrol, diesel and oils
and particularly used engine oils are included along with potentially hazardous waste materials.
Hazardous materials can present different physical states such as solid, liquid, mists, vapours or gases, pure reagent or mixtures and have the potential to harm human health through the following properties:
Nature of Hazard • Flammable/ explosive • Toxic • Corrosive • Irritating/ allergenic • Sensitising
• Carcinogenic (cancer inducing)
• Mutagenic (likely to induce genetic damage) • Teratogenic (likely to induce foetal damage) • Asphyxiant
Hazardous materials may enter the human body in a number of ways depending on the material, its phase (i.e. solid, liquid or gas) and how it is used. The main routes of concern in industry are via inhalation and absorption. Inhalation is the most common route of entry as many toxic materials are present in an airborne form. Entry via the skin and eyes is through direct contact with a material. Ingestion is not a common route and predominantly occurs through poor hygiene practices.
Mode of Assimilation
• Inhalation (i.e. breathing in the material)
• Ingestion (i.e. swallowing the material either directly or indirectly)
• Skin or mucus membrane absorption (i.e. directly or indirectly via contaminated clothing etc.)
• Injection (i.e. into the body by high pressure jet/hose, puncture by sharp object).
Note: it is worth considering the application of these requirements to materials which,
although not hazardous for human health by themselves, may cause damage through indirect effects (i.e. use of gases that displace oxygen and may cause asphyxiation in a confined environment).
Exposure Level
The level of exposure depends upon various factors including how the material is handled, how much is used and the existing controls such as ventilation and personal protective equipment (PPE). Health effects may be acute, resulting from a short-term (usually high) exposure or chronic, resulting from long-term (often low level) exposure over a period of time. Chronic effects may not occur for many years, are hard to predict in advance and when they do occur it may be hard to identify what caused them.
Occupational health and safety laws in most countries require that the risks associated with Hazardous Materials are effectively controlled and the exposure to hazardous substances is kept below levels at which health effects are known to occur. These laws usually require workplaces to make sure potentially affected personnel know:
• What hazardous substances are being used; • What effects they can have on health; and
• What has to be done to prevent or minimise exposure to them.
All sites must identify and comply with all relevant local legislation, standards, licenses, permits and other requirements in relation to hazardous materials as well as the requirements of the Hazardous Materials Management Standard.
Major Hazard Installation (MHI) is a term used by South African legislation to classify
those facilities handling hazardous materials that may represent a significant risk to people in or around the sites. Key considerations for classifying a facility as MHI are: • "the Act" means the Occupational Health and Safety Act, 1993 (Act No. 85 of
1993)
• "major hazard installation" means an installation where any substance is
produced, processed, used, handled or stored in such a form and quantity that it has the potential to cause a major incident;
• "major incident" means an occurrence of catastrophic proportions, resulting from
the use of plant and machinery, or from activities at a workplace;
• "on site emergency plan" means the emergency plan to be followed inside the
premises of the installation or part of the installation classified as a major hazard installation.
• "off site emergency plan" means the emergency plan to be followed outside the
premises of the installation or part of the installation classified as a major hazard installation.
• "risk assessment" means a process of collecting, organising, analysing,
interpreting, communicating and implementing information in order to identify the probable frequency, magnitude and nature of any major incident which could occur at a major hazard installation and the measures needed to be taken to remove, reduce or control potential causes of such incident
4 RECOMMENDED
APPROACH
A high proportion of the elements in this standard including “Major Hazard Installations” are risk based and a standardised approach to risk assessment will be needed to ensure uniformity of application. It is recommended that Anglo Technical Division is consulted for advice on the current techniques of risk assessment where cognisance is taken of the value of both quantitative and qualitative approaches to risk management.
To support the risk management approach referred to above a comprehensive document and revision control system is a pre-requisite and again AR/ATD may be consulted for advice in this area.
Notes:
The application of the material in question must be considered in the environment in which it is to be used. It may therefore require a HAZOP- type RA to evaluate as part of the “Baseline RA (the risks associated with the use of this specific material)”. Any change in the use of the material will have to be reassessed using the change management procedures.
Non hazardous substances could become hazardous under certain conditions (e.g. water in contact with molten metals – see relevant FRP). Protection systems e.g. gas dumping systems could result in control rooms becoming confined spaces.
It is recommended that the users of HAZMAT adhere to the “Responsible Care” principle, which expects that companies take ownership for the entire life- cycle of hazardous materials.
No
Management Approval in Safety Document System
New Material Supplier Information & MSDS Possible Hazard? Refer AFRS Implemetation Guideline for possible hazard types
Enter in Hazardous Material Register
Baseline Risk Assessment to Identify high risk materials
Can the Material or Risk be: Eliminated? Substituted? Process re-designed? Separated? Reduc ed by Training etc? Low Risk PPE, Biological Monitoring, Buddy System etc SHE Document, Standard Operating Proc edure, or Safe Work Practice Doc Risk Assessment Procedures Yes Pending Assessmen t Residual Risk Acceptable? Yes Yes No Reject for us e High Risk
Responsible Care® is the chemical industry’s global voluntary initiative under which companies, through their national associations, work together to continuously improve their health, safety and environmental performance, and to communicate with stakeholders about their products and processes.
The Responsible Care® ethic helps industry to operate safely, profitably and with due care for future generations, and was commended by UNEP as making a significant contribution to sustainable development at the World Summit on Sustainable Development in 2002.
5
REQUIREMENTS OF THE STANDARD
This section is structured using exactly the same numbering sequence as the Fatal Risk Standard document. Each requirement is repeated in a box, followed by a statement of intent. This is followed by discussion and clarification of that particular requirement.
Detail has been added to some, but not all requirements, as some sections were deemed self explanatory.
Definition for some of the terms used in these guidelines:
ALARP : As low as reasonably practicable
CHAZOP : Computer HAZOP
ChemAlert : A Windows based chemical hazard management system to assist in the safe usage, handling and waste disposal of hazardous materials through the provision of Facility: Plant, equipment, buildings and civil infrastructure
FMEA : Failure Modes and Effects Analysis
FTA : Fault Tree Analysis
HazID : Hazard Identification
HAZOP : Hazard and Operability Study
IBC : Intermediate Bulk Container (a rigid or flexible portable packaging that is typically of a volume between 500 and 3000 litres)
MSDS : Material Safety Data Sheet
NFPA : National Fire Protection Association
PHA : Process Hazard Analysis
P&ID : Piping and Instrumentation Diagram
PPE : Personal Protective Equipment
QRA : Quantitative Risk Assessment
SIL : Safety Integrity Level
5.1 PLANT
AND
EQUIPMENT
REQUIREMENTS
1. Process Risk Assessment
The basis of design of a facility or process, whether permanent or temporary, which transports, produces, stores, uses or disposes of hazardous materials shall be reviewed (preferably with the vendor), amended as necessary and documented, utilising a process risk assessment tool such as HAZOP, HAZID, etc. As-built design drawings (e.g. process and instrumentation diagrams, process flow diagrams, layout drawings, isometrics, software upgrades, etc.) shall be updated as a result of these reviews.
Process risk assessments should be carried out during all phases of a facility life. During the design phase the reviews should start as early as possible and use preliminary hazard analysis techniques. As the design progresses into execution more detailed techniques appropriate to the risk profile should be used. During the operating phase there should be regular reviews at frequencies required by local legislation or as consistent with the risk profile. During operation, process risk assessments should also be part of the management of change system for any modifications to plant and equipment.
A variety of process hazard identification and risk assessment tools are available. Some methods are alternatives or are complementary to others. Advice should be sought where necessary to select the most appropriate tool.
All methods involving hazard identification should be facilitated by someone competent in the technique and involves a review team selected to represent a wide range of disciplines including production, maintenance, technical and safety. The team should be provided with the necessary information on hazards of materials, process technology, design drawings, procedures, equipment data sheets, instrumentation control logic, incident experience, previous hazard reviews, etc. At the conclusion of the study a report should be issued with a set of recommended actions and queries concerning the design.
The following is a brief overview of some of the more frequently used tools.
Hazard Identification (HazID)
HazID is the name sometimes given to the process of identifying credible hazards for a Quantitative Risk Assessment (QRA). There are a number of generic techniques that can be used including HAZOP, What-if/Checklist, and FMEA.
Process Hazard Analysis
Process Hazard Analysis is the application of one or more analytical techniques to identify and evaluate process hazards for the purpose of determining the adequacy of or need for control measures. Regulatory authorities in the US (OSHA and EPA) require a hazard analysis for all subject processes. Acceptable methodologies include What-if, Checklist, What-if/Checklist, HAZOP, FMEA and FTA or other appropriate equivalent methodology.
Hazard and Operability Study (HAZOP)
HAZOP is a qualitative structured brainstorming technique that identifies the potential hazards and operating issues with the design of processes, plant and equipment and concentrates on how the design will cope with deviations from design conditions.
HAZOP studies primarily use P&IDs and systematically question every part of the system being studied on a section by section basis. Deviations from the intent of the design, their causes and consequences are investigated. Deviations are identified using a checklist of standard guide words (pressure, temperature, flow, level, composition, maintainability etc), which also suggest deviations from normal operating conditions (high, low, reverse, etc).
When hazard and operability issues are identified, risk assessment is required to determine if the hazards are credible and to recommend actions including design changes to address them. Those actions may be a result of the following resolution methods:
Brainstorming: the options to eliminate or control (Terminate, Treat, Transfer of the risk in this order of preference) are to be considered. The effectiveness, cost and residual risk following the implementation of the proposed control measure is then weighed.
Experience: individual or collective experience in the review team can identify the control because this situation and solution has been seen before;
Codes of Practice: the control is dealt with through some applicable codes of practice, design standards or other industry standards or guidelines; or
Hazard Analysis: either the level of risk is uncertain or the control(s) for the risk are not obvious and so further analysis is required (e.g. QRA).
Cost effective resolution by any of the first three methods is preferable to avoid the need for more time consuming qualitative or quantitative risk assessment (see later).
The advantages of HAZOP are that it encourages creativity and new ideas and because it is a systematic method it tends to be more thorough and accurate. Limitations are that it assumes that the design has been carried out in accordance with appropriate engineering design codes. It can also be time consuming and success is significantly dependent upon the knowledge and experience of the team members and the capability of the leader. The process requires a trained facilitator, preferably with experience in the process evaluated.
What-if/Checklist
What-if/Checklist is a qualitative technique that is a combination of the creative brainstorming “What If” technique and the prescriptive “Checklist” technique. The purpose of the technique is to identify hazards, consider the types of incidents that can occur in a process or activity, evaluate in a qualitative manner the consequences and determine whether the existing controls are adequate.
The study team leader and a sub team first formulate the initial “what if” questions to be used and also assemble the process specific checklists. The brainstorming technique is then used on subsections of the process guided by the set questions to identify possible deviations and weaknesses in design.
Questions such as: “What if the pump stops?” and “What if the level sensor fails?” are used to stimulate discussion. As the study progresses, any new “what if” questions that become apparent are examined. This is followed by one or more checklists which are used to trigger thoughts about situations that may have been overlooked. Checklists which are specific to the type of industry or process and are based on prior experience are available (references for checklists are provided in Lees: Loss Prevention in the Process Industries). If hazards are identified then recommendations are made as to additional controls to minimise or eliminate the risk (similar to HAZOP).
The technique is relatively easy to use, quicker than HAZOP, and is a good mix of creativity and previous experience captured in checklists. Limitations are that it depends upon the knowledge and expertise of the team performing the analysis and on the right questions being asked. It is not particularly effective in identifying new or previously unrecognized hazards and focus can also be lost due to repetition of the checklists.
Failure Modes and Effects Analysis (FMEA)
FMEA is a qualitative analytical technique which identifies each failure mode, the sequence of events associated with failure and the consequences of failures or malfunctions of individual components (pressure relief devices, valves, switches, pressure vessels, pumps etc) in a system. The technique is oriented towards equipment rather than process parameters. Guidance on FMEA is given in BS 5760 Reliability of Systems, Equipment and Components, Part 5:1991 Guide to Failure Modes, Effects and Criticality Analysis (FMEA and FMECA).
For the system that is to be studied questions are asked for each component such as:
How can each component fail?
What might cause these modes of failure? What would the effects be if the failure occurs? How serious are these failure modes?
How is each failure mode detected?
The risk of each is assessed using a risk matrix. A report details the failure modes of components, including recommended risk reduction actions either to reduce the frequency of failure or mitigate the consequences of failure.
The limitations of FMEA are that it focuses on single failures of equipment and it may not recognise multiple failures or multiple causes. It also does not focus on hazards caused by human error and can be a laborious and inefficient process unless judiciously applied. Consequently this is best done in combination with HAZOP.
Fault Tree Analysis (FTA)
FTA is a predominately quantitative graphical technique that provides a systematic description of the combinations of possible hardware and human failures in a system which can result in an undesirable outcome. The outcomes with the highest risk such as fire, explosion and release of toxic materials are selected as the “top event” in the fault tree. Such events may have been identified as a result of previous hazard identification studies such as HAZOP, What-if/Checklist, or FMEA. A fault tree is then constructed top down by relating the sequence of events which individually or in combination could lead to the “top event”. The fault tree is constructed by deducing in turn the preconditions for the “top event” and then successively for the next levels of event, until the basic causes are identified.
The fault tree is graphically developed using AND and OR gates. By ascribing probabilities to each event, the probability of the “top event” can be calculated. FTA is an effective technique for identifying failures that have the greatest influence on bringing about the “top event”. If the risk is unacceptable then in order to reduce the risk corrective action should be taken with emphasis on those branches of the tree that have the most effect on the “top event”. Actions may include adding safety devices, testing safety devices more frequently or improving the design and reliability of devices. FTA focuses on developing the logical links of failures that lead to the top event and is not that effective in identifying the hazards themselves.
Preliminary Hazard Analysis
Preliminary Hazard Analysis is a qualitative method used to identify hazards with a design in concept and/or pre-feasibility stages. Controls implemented at this early design stage are less costly and easier to implement than in later design stages. Usually this method is driven by a checklist and one method of application is to use hazard guidewords characterised by energy type (electrical, mechanical, chemical, kinetic, potential, pressure, thermal, fire/flammability, explosive, acoustic, biological, radiation, etc). Each process unit or area is then reviewed with these guidewords. Various aspects are reviewed including the effect of these hazards on people, equipment, product, environment, community etc. Hazards identified are treated in a similar way as with other HazID techniques.
Preliminary Hazard Analysis is reliant upon the skills and experience of the people involved. Hazards are only assessed singly and the method does not evaluate the combined effect, nor is it a substitute for conforming to applicable design codes, standards and regulations and subsequent use of other techniques such as HAZOP. Variants of this methodology are Concept Hazard Analysis and Screening Level Risk Analysis (SLRA).
Procedural HAZOP
The procedural HAZOP is similar to HAZOP but is intended to identify specific HAZARDS around the procedures associated with the operation of the systems. It normally follows in the implementation stage once procedures are being developed. Examples of questions are:
Not done/ step omitted Done too early/too late Too many repetitive tasks
Computer HAZOP (CHAZOP)
This technique is similar to HAZOP but is intended to identify specific hazards associated with computer control systems of processes. CHAZOP is typically only done during the project design phase and if it is done it normally follows on after the project HAZOP. Like HAZOP this technique uses a systematic methodology with guidewords. As well as looking at the hardware design aspects of the system it also reviews the control logic with a question set to investigate control failures. Examples of questions are:
Does the failure matter?
Will the operator be aware of the failure? What should the operator do?
The input and output signals are each reviewed with guidewords such as: low, high, invariant, drifting and bad.
Hazard Indices
There are several hazard indices such as the Dow Index and Mond Index. These indices are not hazard identification tools but rather tools for risk ranking of hazards in a particular facility and comparative risk ranking to other similar facilities. Further information is available in Lees: Loss Prevention in the Process Industries.
Qualitative and Quantitative Risk Assessment
Depending on the site-specific requirements of the process hazard analysis and the hazards identified, the analysis of the risks associated with the hazard can vary from simple intuitive qualitative risk assessments conducted during the HazID, to formal qualitative risk assessments and ultimately to Quantitative Risk Assessment (QRA). QRA is a quantitative method of estimating the magnitude of risk. It provides a degree of objectivity and a facility for ranking risks. It does however involve some degree of subjectivity as it relies to a certain extent on past events and/or experience. QRA uses numerical values for consequences and likelihood using data from a variety of sources. Consequences are evaluated by various modelling techniques. Usually consequence modelling is done using specialist modelling software for evaluating the effects of:
Flammable and toxic gas releases
Fires (including jet, pool and building / warehouse fires) Explosions
Products of combustion / fires including smoke and toxic gases.
Risks that cannot be eliminated should be documented in the site’s risk register. Current drawings should be available for all process risk assessment reviews. Drawings which may be required are listed in requirement 18. Affected drawings should be updated at the conclusion of any design changes as a result of implementing engineering controls.
2. Risk Assessment of Design Specifications
All specifications for the location, design and/or modification of hazardous materials facilities shall be subjected to risk assessment that includes materials selection, site conditions, transport, production, storage, handling, use and disposal. Previous incidents shall be reviewed.
The design of an entire facility as well as subsystems and individual items of plant and equipment is critical to effective elimination or minimisation of risks. An integral part of the design process for new or modified plant and equipment is the selection of appropriate design codes and standards. In some cases the application of these alone is sufficient; however, where necessary, designers should conduct hazard identification, risk assessment and identification of controls to achieve a design where the risk is ALARP. When conducting risk assessments, previous incidents in similar or related facilities should be reviewed to ensure that the learnings are incorporated.
Process risk assessment methods as outlined in requirement 1 generally assume that the design has been carried out in accordance with appropriate engineering design codes and standards. Depending upon the types of hazardous materials involved and the complexity of the process, plant and equipment which handles the hazardous materials and the following aspects of design may also require risk assessment:
Process selection (inherently safer design) Plant siting and plot plan layout
Storage tanks design (segregation, containment etc) Separation distances
Hazardous area classification Ignition sources
Fire and explosion analysis
Fire protection (passive and active equipment) Vapour cloud dispersion modelling
Control building design and survivability to fire and explosion and toxic gas clouds
Emergency response equipment
Escape route and refuge area survivability Materials of construction selection
Pressure equipment
Materials handling systems (spillage, stoppage etc) Valves (leakage routes through glands and flanges)
Rotating equipment (catastrophic failure, leak routes though glands and seals) Equipment reliability (FMEA)
Control system reliability (Safety Integrity Level) Effluent and drain systems
Flare and Blowdown systems Waste disposal
Manual handling of raw materials and products
Maintainability (provision for access, decontamination, isolation, vessel entry) Positive isolation requirements (e.g. spool pieces required to all equipment
that needs to be isolated.
Provision for calibration without exposure to hazardous materials/conditions Provision for sampling of process streams without exposure to hazardous
circumstances)
Safeguarding and personal protection
Human factors analysis (alarm management, mal-operation etc.) Commissioning, start-up and shutdown studies
Transport systems including loading and unloading and offsite risks
Risks that cannot be eliminated should be documented in the site’s risk register.
3. Emergency Response Facilities
All facilities which have a significant risk from hazardous substances shall provide a risk-based emergency response plan which includes:
- emergency response procedures appropriate to the hazardous materials and the risk
- emergency equipment/facilities (e.g. oxygen, antidotes, showers, etc.) on location where hazardous materials are stored or used
- means of escape in an emergency situation - clearly marked emergency isolation valves
- emergency response teams appropriate to the risk
- appropriate use of safe refuge and assembly areas for people
- emergency response equipment for spillage containment, fires, explosions, burns, etc.
- appropriate response arrangements with external emergency services (e.g. ambulance, hospitals, fire brigade, medical personnel, etc.)
- impact minimisation including spill clean-up and dust suppression - recovery procedures and disposal of the hazardous material.
This requirement covers the plant and equipment required for emergency response (the systems for emergency response are covered in requirement 24 and training in requirement 34). The plant and equipment may be fixed equipment such as fire pumps or portable equipment such as fire extinguishers. In many countries, emergency response equipment is specified by legislation, design standards and codes of practice for hazardous industries. The plant and equipment should also be identified as a result of design studies and/or risk assessment in order to be able to respond to credible emergency scenarios and can include:
Designated emergency assembly areas and safe refuges Emergency escape and evacuation routes/role of access control Emergency sirens and warning systems
Communication systems including both fixed such as public address and telephones and portable such as hand held radios
Detection systems such as thermal, fire, smoke, flammable and toxic gas detectors
Passive fire protection equipment such as blast walls and thermal insulation Fixed fire fighting equipment including fire water tanks, foam tanks, fire water
pumps, fire water and foam monitors, fire hydrants, hoses, deluges and CO2 flooding systems
Fire trucks and trailers equipped for both fires and hazardous material incidents
Portable equipment including fire extinguishers, breathing apparatus, specific PPE for fires and hazardous materials
Portable equipment for responding to spills such as absorbent material, oil containment and absorbent booms, neutralising chemicals and appropriate PPE
Medical and first aid response equipment including medical response centres, first aid rooms, first aid kits and fire blankets
Safety showers and eye washes
Emergency response command centre including all the required contents of communication equipment, maps, manuals etc.
All fixed and portable equipment should be covered by a documented maintenance, inspection and test regime (see requirement 13) to ensure that its technical integrity is maintained. Such programs should also include the routine inspection and testing of emergency alarms, pumps, safety showers and eye washes and fire extinguishers.
These systems are to be tested and trained as per section 34.
4. Vents and Drains
Provisions shall be made for the safe venting, drainage and containment required during normal operations and in emergency situations, based on a process risk assessment tool such as HAZOP and HAZID.
The location and design of vents and drains is normally specified during the design. It is not the intent of this requirement to supplant design standards and codes and good design practice however some points to note for the design and operation of systems which have caused incidents in the past are:
Correct Location and configuration
Vents and drains for maintenance and operating activities should be located at appropriate high points for vents and low points for drains. Where equipment items or sections of plant and equipment are anticipated to be taken out of service for maintenance (e.g. pumps, compressors, heat exchangers, tanks and vessels) then vents and drains should be appropriately located so that personnel do not have to crack flanges to achieve inventory removal especially of flammable and toxic materials.
The vents and drains should preferably be connected to closed systems (e.g. flare header or closed drain system) where the materials should not be released for health, safety or environmental reasons. Where this is not practical or required then they should be directed to a safe location where the discharge of material will not cause a health, safety or environmental hazard.
Atmospheric vents should be discharged to a safe location to avoid sources of ignition for flammable vapours or to safely disperse toxic vapours. Drains should be directed to a safe location where the material can be contained such as inside a bund or into an effluent treatment system rather than uncontrolled discharge to the environment. Liquid hydrocarbons should not be discharged into an open sewer system or large standing pools of water because the hydrocarbon will float on top of any water and can travel significant distances and create a fire/explosion hazard at a distant location.
Consideration should be given to segregation of waste streams of totally different composition at their source (e.g. acidic aqueous material from liquid hydrocarbons) so as to minimise the complexity of downstream waste disposal facilities.
When not in use, vents and drains should be securely isolated to prevent fugitive leaks and unintended loss of containment. Leaks have occurred when valves have been left open, vibrated open or been accidentally knocked open. Two barriers of isolation should be used where vents and drains discharge into the open environment. The normal method is to have a blank (spade, slip plate, blind) fitted downstream of the vent/drain valve.
Inherently Safe
Valves used for inventory reduction as part of normal operation (e.g. periodic draining of water from the bottom of a hydrocarbon vessel or purging inert gases from an accumulator drum) should be designed for the frequent use and take account of the potential for human error. Many leaks have occurred when personnel have left open vents, drains and sample valves to purge the stream and then go away and do another task and subsequently return to find hazardous material flowing out. Consideration should be given to spring-loaded ball valves that have to be held open and will close automatically if left unattended.
It is preferable for vents and drains, particularly in flammable and toxic material service, to have a primary valve closest to the process which is opened first and a secondary isolation valve that is used for controlling the flow of venting/draining. Thus if the secondary valve starts to leak the primary valve can be closed.
Sample points for fluid streams are similar to these vents and drains in respect to the hazard of loss of containment and their design should follow recommended industry practice and use should be covered by standard operating procedures. Automatic valves and devices such as pressure relief valves, automatically controlled overpressure valves and automatic dump valves should all be carefully designed according to applicable design codes and standards and their design reviewed during process hazard analysis. Hazards can occur with these devices in operation when they become partially restricted or blocked with contaminants or inadvertently isolated by spades or valves. Modifications to process conditions, and associated plant and equipment that are protected by these devices should not be
undertaken without review using a management of change system (see requirement 15) to avoid creating hazards.
Containment
Containment refers to secondary containment as a back up to the primary containment of a storage tank, vessel, container or package. The purpose of all secondary containment systems is to limit the extent and spread of hazardous materials when there is a loss of containment from the primary containment.
In most countries, the requirement for secondary containment is covered by legislation, standards and codes of practice which govern storage and handling of hazardous materials of various classes. Such legislation and codes of practice cover not only the design of the primary tanks, but also other aspects such as layout and separation from other storage and facilities, venting and relief, fire protection, safety equipment, signage, and also dictate when and how secondary containment is required.
In the absence of any specific requirements Lees (Loss Prevention in the Process Industries, figures 22.20 – 22.22) provides some guidance in the form of decision trees for flammable, toxic and corrosive materials.
Bunds (dike, berm) are one of the more common types of secondary containment. Bunds are normally designed to contain the entire volume (usually at least 110%) of a tank or of the largest tank in a combined storage area. The bund is usually made of concrete or earth lined with impervious material to prevent leakage. The separation distance and height of the bund walls must be designed taking account of crest locus limits.
Bulk containers (e.g. IBCs, bulki bins); drums and small volume packages may also be subject to containment. Containment can be provided by fixed facilities or moveable bunds made out of an impermeable membrane. Care should be taken in warehouse and mixed storage areas to ensure that correct segregation is maintained (see requirement 23).
Bunds are normally provided with drains to allow discharge of storm water. The drain valves should normally be closed.
5. Vessel and Tank Labelling
Labelling shall be in place on all storage vessels, containers and tanks, as per appropriate national or international standards. This labelling shall clearly identify the carried or stored material. Supporting information (e.g. material safety data sheets [MSDS]) shall also be readily available at the point of use and storage to identify appropriate first aid/spill response procedures.
The purpose of labelling of storage tanks, containers and packages is to ensure that the contents can be readily identified by product name and provide relevant information including hazards and precautions about the contents for normal operational use and for emergency response. In some countries there is also a requirement where some types of Hazardous Materials (e.g. “Dangerous Goods”) are stored in sufficient quantities that placarding is required. Placarding ensures that in event of fire, spillage or other incident involving such material that emergency response personnel have sufficient information to respond immediately and
effectively. Placards usually provide information on the class of material (see later) and guidance on how to manage emergency responses.
Most countries have specific legislation which identifies types of hazardous materials (dangerous goods, hazardous substances, toxic substances etc) and is specific about the types of labelling and placarding, the size of labels and where they should be affixed at the entrances to facilities and to tanks, containers, packages, warehouses and transport by road and rail. Each site should identify all applicable legislation including any site specific permits and licences and comply with them (refer to Anglo Management Standard).
Labels (or placards) may include: The product name
UN number (which identifies the material according to a numbering system developed by the UN Committee of Experts on the Transport of Dangerous Goods)
HAZCHEM Action Code (see later) Class of material (see later)
Relevant health and safety information The word “hazardous”
Telephone number to contact for specialist advice.
Labels should be firmly attached to the storage tank, container, package and be legible and durable. Labelling should be in a language that the workforce understands. Labels should be regularly checked and damaged or illegible labels should be replaced. Labels should also be revised when any of the details change. Materials which arrive at a site insufficiently labelled should be quarantined until the correct labels are affixed or should be returned to the supplier.
Labelling also applies to hazardous materials that are decanted or transferred to other containers. A container into which a hazardous material has been decanted should also include as a minimum the product name on the container and preferably more detailed relevant information such as class labels. Under no circumstances should food or drink containers be used for decanting either for ongoing use or disposal. If a container is found with an unknown material that is suspected of being hazardous then a label such as “Caution Do Not Use: Unknown Substance” should be affixed and the container removed from the workplace until the contents are identified or disposed of.
Some of the more common types of labels that are used in various countries are:
Class labels
Class labels are based on the international system detailed in the Model Regulations for the Transport of Dangerous Goods prepared by the United Nations Economic and Social Council’s Committee of Experts on the Transport of Dangerous Goods .
The classes (excluding explosives) are: Class 2 - Gases
Class 3 - Flammable Liquids
Class 4 - Flammable Solids
Class 5 - Oxidising Substances and Organic Peroxides
Class 6 - Poisonous (toxic) and Infectious Substances
Class 7 – Radioactive Substances Class 8 - Corrosives
Class 9 - Miscellaneous Dangerous Goods
HAZCHEM Emergency Action Code for Fire and Spillage
The HAZCHEM code (also known as the Emergency Action Code) was developed by the United Kingdom Fire Service to provide emergency services personnel information on how to respond to fire and spill emergencies involving vehicles
transporting dangerous substances. The HAZCHEM Code system has been adopted in other countries not only for transport but also workplaces where such materials are kept.
The HAZCHEM Code provides advice on:
The type of medium to be used in combating an incident involving a material where there has been a loss of containment or fire
The type of PPE to be worn by persons combating the incident Whether a violent reaction or explosion could occur
Whether a spill should be contained or diluted, and If there is a hazard is to the local population.
The code consists of a number followed by one or more letters as shown in the table:
Notes for guidance:
V : Can be violently or even explosively reactive. BA : Use breathing apparatus plus protective gloves.
FULL : Use full body protective clothing with breathing apparatus. DILUTE : Wash to drain with large quantities of water.
CONTAIN : Prevent spillage from entering drains or watercourses. WATER FOG : In the absence of fog equipment, a fine spray may be used. DRY AGENT : Water must not be allowed to come in contact with the substance
at risk.
An example is Liquefied Petroleum Gas (LPG) which has a HAZCHEM Code of
2 W E. This means that in the event of a fire a water fog or fine spray should be
used, full protective clothing with breathing apparatus should be used and evacuation of the surrounding area should be considered.
NFPA Hazardous Materials Identification System
The system is primarily used in the USA and is based on a diamond shaped marking that is divided into 4 regions. Each region is assigned a colour and a numerical rating in each region. The regions depict health hazard, fire hazard, reactivity hazard and a region to indicate reactivity with water, or other specific hazards if water reactivity is not an issue.
The format of the marking is as follows:
The degrees of hazard are ranked according to the potential severity of the exposure in a fire situation. Like the HAZCHEM Action Code the disadvantage of this system is that it does not address the hazard of day-to-day workplace exposure. An example is Liquefied Petroleum Gas (LPG) which has a NFPA Hazard Class of Health (blue) = 2; Flammability (red) = 4; and Reactivity (yellow) = 0.
Transport Placards
Legislation in many countries requires road tankers carrying chemical products to carry a placard. The placard includes the HAZCHEM Code, the correct technical name of the substance being transported, hazard class label, UN number of the substance and telephone number for emergency advice.
A generic example is shown below:
Standard Safety and PPE Signs
Although not usually required by legislation, the use of PPE and other Safety signs that are in addition to the minimum PPE required on a site (i.e. safety helmet, safety glasses, safety shoes, etc) can be posted close to the location where hazardous materials are handled. Standard safety signs are used as an aid to:
Communicate the need for PPE and the type to be used Communicate information on hazards
Communicate the location of safety equipment/emergency facilities Provide guidance and instruction in an emergency.
There are two main types of safety signs referenced in Australian Standard 1319 – 1994: Safety Signs for the Occupational Environment. These are:
Picture signs, which utilise text and symbols to represent the hazard, equipment or process as well as the standard colours and shapes used to convey a message (e.g. PPE signs)
Signs with text only messages which are supplemented by the use of standard colours and shapes (e.g. Stop, Caution, Fire Exit, emergency contact phone number, etc. signs).
Picture signs which are standard in the country of location should preferably be used.
6. Pipe Labelling
Piping containing hazardous substances shall be clearly marked so that the contents and direction of flow can be identified.
Pipelines are an integral part of conveying hazardous materials in process plants; however it is almost impossible to determine the contents from the external appearance of the pipe.
The purpose of providing a system for easy identification of contents and flow direction of piping systems which transport hazardous materials is:
So that personnel who work in the vicinity are alerted as to the contents So that operating personnel can easily identify the relevant valves and other
equipment
So that isolations can be placed on correct pipe line systems for maintenance work
So that information is provided to assist in response in the event of an incident involving the loss of containment
To assist in the training of personnel who need to be able to identify specific systems required for operating or maintenance activities.
Marking may be achieved by a system of colour coding or by labels which can be painted on or affixed and which specify the contents and arrows to indicate the normal direction of flow. Marking should occur in such locations as adjacent to valves, tees, important line fittings, wall penetrations, road crossings, entries and exit nozzles to tanks, vessels, heat exchangers, pumps, compressors and other important plant and equipment items. On piping runs the marking should be typically at uniform separation distances specified in relevant standards.
In addition to pipeline marking additional definition can also be provided by the inclusion of line designation numbers and valve numbers as shown on P&IDs. Refer to BS 1710 Identification of Pipelines and Services or AS1345: Identification of the Contents of Piping, Conduits and Ducts. Whichever system is used, affected personnel should be able to understand the meaning of the colour coding and/or labels and they must be maintained in a relatively clean state in order to be legible.
7. Security and Access Control
Security and access control systems and hardware shall be in place, appropriate to the risk, to manage access to areas where hazardous materials are stored and used.
Each site should review the hazardous materials on site and, depending upon the risks, install appropriate security hardware and/or security systems. Aspects that should be considered when determining what “appropriate” is include:
The hazards and risks associated with the hazardous materials
The likelihood of deliberate and unwanted access by unauthorised persons and vehicles to storage areas (e.g. for sabotage or theft)
The likelihood of unintentional and unwanted access by unauthorised persons and vehicles to storage areas
The integrity of storage and handling systems to inadvertent operation causing loss of containment (e.g. even if someone was able to get to the storage and handling equipment could they cause a loss of containment by opening a valve)
The integrity and reliability of security systems and hardware. Examples of security hardware that should be considered are: Security fence and site access control to perimeter of the site
Security fence or enclosure to the area where individual or collective hazardous materials are stored and/or used
Locks on doors and other access routes to enclosed buildings and compounds Remotely monitored security cameras
Bollards or other vehicle access control devices
Signs prominently posted warning of the storage of hazardous materials and the need for appropriate authorisation before entry into an area.
See requirement 25 for security and access control systems.
8. Process Control
Process control systems shall ensure that the potential for personnel to be exposed to hazardous materials is eliminated wherever possible, or reduced.
Process control systems are a risk control designed to eliminate those activities where personnel are close to the contained materials and can be exposed to hazardous materials in the event of loss of containment. Process control achieves separation from the risk and should be applied both during new plant design and during ongoing risk reduction activities. Examples of activities which occur during the operating phases of start-up, normal operation, equipment changeover, planned shutdown, emergency shutdown and abnormal operating scenarios that should be reviewed include:
Process flow, temperature, pressure, level and composition adjustment through the manipulation of a valve or other device
Charging feed to and discharging products from processes Sampling and analysis
Routine venting and draining, purging and flushing.
9. Automatic Control
Automatic plant control systems should be in place in hazardous material facilities to eliminate the need for operator intervention and to maintain operation within the required parameters. Such systems shall incorporate fail-to-safe systems in the event of emergencies. Where automatic control is not practicable, risk assessment shall be used to identify and implement operational options that reduce the risk. Automatic control is a generic term used in this protocol and refers to what is otherwise referred to as a “trip system” (also referred to as “emergency shutdown system” or “ESD”) and “interlock system” (also referred to as “override system”).
These systems are discrete control actions whereas “process control” in requirement 8 is continuous control action.
Control systems (automated or manual) and associated critical equipment must be given sufficient design attention, appropriately risk assessed and supported by a rigorous maintenance regime and planned inspections.
Trip and interlock systems are automatic protection systems designed to prevent situations where a hazardous condition could occur in a process. Trip systems shut down an entire process or part of a process or one function if a hazardous condition is detected. An interlock system is slightly different in that it prevents an operator or an automatic control sequence from following a hazardous sequence of control action. Trip and interlock systems and their components are normally classified as critical equipment and should be covered by appropriate maintenance inspection and test plans (see requirement 13).
The identification of the hazardous situation may occur during the normal design process or could be revealed during HAZOP. The decision to install a trip or interlock can be a function of the project/facility design philosophy but also should be risk assessed during development of design specifications (see requirement 2). The hierarchy of controls should be used to determine whether it is better to use the “redesign” control and implement a trip/interlock or use the “administrate” control and depend upon personnel to follow procedures when hazardous situations occur. Trip systems can either be single loop (sensor to trip switch to trip valve) or multi loop (sensor to trip processor to switches to trip valves). The logic can be as simple as a single switch, a relay system, PLC or a complex computerised trip system. Examples of trip systems are:
Single Loop: A benzene storage tank that receives benzene supply pumped from a
rail tank car requires an automatic system to prevent overfilling of the tank. A high level switch can be installed on the tank that shuts an actuated valve in the benzene supply line.
Multi Loop: A hydrocarbon gas processing plant has a lot of flanges and valves that
can leak gas with the risk of fire and explosion and requires a system to shut down the plant and prevent ignition if this occurs. Strategically located gas detectors are installed that trigger when a certain level of gas is detected and automatically shut down the supply of gas into the plant and open blowdown valves to depressure the inventory safely to a flare system.
Examples of interlock systems are:
Instrumented: A road tanker which is filled with flammable fuel pumped from a
storage tank via a loading hose system must have a secure electrical continuity system to prevent static electricity discharge (an ignition source) between the fixed loading equipment and the road tanker. An interlock system is built into the loading hose control system which requires connection of the earthing strap before the main isolation valve in the loading line can be opened to start loading.
Non-instrumented: A pressure vessel containing a hazardous gas is protected
from overpressure by two pressure relief valves. The two valves are installed in parallel with one being a standby and manual isolation valves are provided to allow isolation of either valve to allow one of the pressure relief valves to be taken out of service. A manual interlock system is required to prevent isolation of both valves at the same time. A special sequential key system is provided which only allows the manual valves on one of the pressure relief valves to be isolated at any one time. Both trip and interlock systems (or parts of them) require bypassing (disarming, defeating) at various times such as for start-up, calibration and testing. A system should be in place to assess the risk of bypassing of these safety systems. Usually this is covered under an extension of a permit to work system.
Both trip and interlock systems require periodic proof testing to ensure their reliability and capability. This is often referred to as Critical Function Testing (CFT) and should be part of a maintenance inspection and test program on a facility (see requirement 13). Frequency of proof testing should be determined by Safety Integrity Level studies.
Standards for instrumented and electrical/programmable safety systems can be found in:
IEC 61508-1; Functional safety of electrical/electronic/programmable electronic safety-related systems, and
IEC 61511-1; Functional safety – safety instrumented systems for the process industry sector.
10. Detection Devices
Fixed detectors and personal detection devices shall be considered as options in the selection of potential risk reduction measures.
Fixed devices are usually installed to detect the presence of flammable or toxic gases but can also include smoke, thermal, flame and other detection methods including visual. Their purpose should be clearly defined during design. Systems may either be primarily designed to detect fugitive leaks that can lead to adverse but non fatal health effects or detect major loss of containment which can lead to fatalities either directly (e.g. carbon monoxide gas cloud) or indirectly via fire and explosion of flammables.
The justification for fixed devices should be the subject of careful analysis which evaluates the likely leak locations (e.g. flanges), the potential quantity of leaks and dispersion modelling of gas clouds all in relation to where personnel may be located. This may require risk assessment methods such as QRA (see requirement 1). Provision should be made for dealing with large loss of containment scenarios including emergency shut down and blow down of inventory, containment systems, shut down of heating and ventilation systems in habited confined work areas such as control rooms and provision of gas absorption facilities (e.g. activated carbon filtration). Emergency response plans should specifically have procedures for responding to such scenarios and not only include process actions to respond to the loss of containment but procedures for evacuation.
Fixed detection devices are normally classified as critical equipment and require maintenance, inspection and testing to ensure availability and calibration (see requirement 13).
Personal detection devices are normally used for the fugitive leak scenarios and for other activities such as confined space entry and atmosphere testing for maintenance. The selection of the correct type for each relevant hazardous material should be done by qualified personnel such as occupational hygienists. When personal devices are used there should also be an atmospheric and/or health surveillance program depending upon the nature of the hazardous materials (see requirement 27).
The provision of fixed or personal detection devices is not an alternative to prudent design and operation of a facility including but not limited to the correct design of pressure relief systems, vents and drains, suitable workplace ventilation, tightness testing of pressurised systems, correct gasket selection and flange tightening procedures.
5.2 SYSTEM
AND
PROCEDURAL
REQUIREMENTS
11. Hierarchy of Controls
Management of risk associated with hazardous materials shall be supported by a documented process that incorporates risk reduction using the Hierarchy of Controls, applied in the following order (a number of these options may be considered and applied individually, or in combination):
- ELIMINATE – the complete elimination of the hazard;
- SUBSTITUTE – replace the material or process with a less hazardous one; - RE-DESIGN – re-design the equipment or work processes;
- SEPARATE – isolating the hazard by guarding or enclosing it;
- ADMINISTRATE – provide controls such as training, procedures, etc. ;
- PERSONAL PROTECTIVE EQUIPMENT (PPE) – use appropriate and properly fitted PPE where other controls are not practicable.
The hierarchy of controls should be embedded in risk based systems relevant to this protocol including:
Risk assessment methodologies (requirements 1 and 2) Selection of detection devices (requirement 10)
Risk assessment of hazardous materials on site (requirement 12) Introduction of new hazardous materials (requirement 14)
Management of change (requirement 15) Permit to work system (requirement 22)
Control of simultaneous operations (requirement 23) Emergency response procedures (requirement 24) Security and access control systems (requirement 25)
Examples of application of the hierarchy of controls to hazardous materials are:
Eliminate: Where a process or task involves the use of a material that is not
essential, the material or the process should be eliminated or the risk associated with the material or process eliminated if practicable. Examples include:
Eliminate on site feedstock storage tank by a pipeline supply direct to the process
Eliminate potential leak points at flanges by fully welded systems Eliminate the need for sampling by use of non invasive instruments.
Substitute: Using a safer material or process which includes exchanging the
material for one that is less harmful, using the same material in a less hazardous form or using the same material in a less hazardous process. Examples include: Substitute a water-based solvent instead of a solvent based material Substitute acetic acid for acid cleaning instead of using hydrofluoric acid Substitute pellets instead of using dusty powders.
Redesign: Using machinery, equipment or processes which minimise workplace
contamination by eliminating or reducing the generation of materials, suppressing or controlling the materials or limiting the area of contamination in the event of spills. Examples include:
Install local exhaust ventilation to remove hazardous fumes Install containment and bunding systems to limit spread of spills Install automatic fire/smoke detectors and fire suppression systems.
Separate: Separating hazardous materials from the people through using them by
distance or barriers. Examples include:
Separate operators from hazardous fumes in an air-conditioned control room Use remote controls to operate a process
Safe separation distance of hazardous material storage tanks from control rooms.
Administrate: Minimising the exposure through changing the work method and
work practices. Examples include:
Provision of standard operating procures for safe handling of hazardous materials
Reducing the duration of exposure through job rotation Good housekeeping to remove workplace contamination.
Personal Protective Equipment: Wearing PPE should only be used to provide
extra protection, or where other control measures are not practicable. PPE should not be depended upon to control risk because it relies upon personnel using it correctly.
12. Risk Assessment
A risk assessment process shall be in place for all hazardous materials to identify: - the selection criteria and life cycle analysis for all hazardous materials - the level of risk associated with the hazardous materials
- controls required to manage the risk
- the performance requirements (reliabilities and capacities) of specific equipment and systems included in these controls.
Risk assessment may be undertaken for hazardous materials either as a stand alone activity or part of a process wide risk assessment (see requirement 1). If the latter is the case then relevant hazardous material data in steps 2 – 4 below should be used. For risk assessments on new hazardous materials (see requirement 14), steps 4 -7 below can be used.
A suggested step-wise risk assessment process is:
Step 1: Assemble a team to carry out the risk assessment
Risk assessment should preferably be undertaken by HSEC professionals and personnel who may be affected including supervisors, operators and maintainers and if necessary risk consultants or other personnel with subject knowledge (see requirement 30). Such involvement ensures that the risk assessment is based upon a thorough and practical understanding of what currently happens or will likely occur in new facilities.
Step 2: Identify all hazardous materials stored, used, transported and disposed
This should involve a site wide inspection to locate, identify and list all materials and the type of storage (i.e. tank, vessel, container and packages). Locations should include not only the normal storage and use areas but also workshops, laboratories, warehouses, laundry facilities, waste treatment facilities etc. Labels on containers, inventories, log sheets, purchasing records and existing registers of MSDSs can assist in data gathering.
Step 3: Obtain Material Safety Data Sheets
Contact the manufacturer or supplier of the materials to obtain the MSDS. Alternatively data bases such as ChemAlert may have the MSDS already registered on them.
Step 4: Review Material Safety Data Sheets
The four key aspects to be reviewed are:
a) Inherent hazards and routes of exposure:
Consider for flammable materials the potential for fire and explosion and for toxic materials which of the routes of inhalation, ingestion, absorption and/or injection may be relevant in the activities associated with the hazardous material.
b) Form of the hazardous material
Review the process conditions to determine the phase of the material (solid, liquid or gas) and what is its concentration and any impurities or mixture components. Consideration should be given also as to whether the material is a mist, fume or dust.
c) Physical and chemical properties
Determine properties such as the pH of liquids (corrosive to the skin and eyes), boiling point and vapour pressures (which can cause high airborne concentrations due to evaporation), the flammability limits and flash point of flammable materials (fire and explosion potential), and the nature and concentration of combustion products and odour.
d) Health effects
For each route of exposure consider the adverse health effects (i.e. toxic, harmful corrosive, irritating, sensitising, carcinogenic, mutagenic and teratogenic).
Step 5: Evaluate the nature of work involving Hazardous Materials
Determine what tasks are carried out where there is a potential for exposure involving hazardous materials (see requirement 19 for critical activities). For each task this should include identifying who is or might be exposed, how they might be exposed and the nature of that exposure (i.e. quantity, frequency and duration), how the material is used, whether health effects are currently present and the effectiveness of control measures currently in place. Reviewing existing standard operating procedures may provide information and involvement of personnel who carry out the tasks is essential.
Step 6: Assess the risk
Determine the credible consequences and estimate the duration and frequency of exposure and the exposure level. Use incident reports and the results of atmospheric monitoring and health surveillance programs to help quantify consequences and frequency. It is also important to remember that risks may extend to personnel who have no direct involvement in the work activity by incidents involving fires and explosions and widely dispersed toxic releases.
For some hazardous materials on a site the risk profile may be similar for some or all activities and so a generic risk assessment can be carried out rather than duplicating for each activity.
Step 7: Identify Risk Controls
Controls should be identified and implemented to manage the risk so that it is eliminated or reduced to levels so that after implementation they are ALARP. The hierarchy of controls should be used to determine appropriate controls (refer to requirement 11). The controls should be communicated to those personnel likely to be exposed via documentation such as standard operating procedures, job safety analyses, permit to work documentation, safety alerts and related training programs.
