Know Your Requirements for Chemical & Hazardous Material Management

“Healthy Workplaces Manage Dangerous Substances” – European Safety Agency

An EU wide campaign for all member states created by the European Safety Agency in relation to chemical and hazardous materials management has been widely welcomed by member states.

Of note, The HSE have been strong advocates which is welcoming news,  reinforcing the importance for companies from all industries handling Chemicals, Dangerous & Hazardous Materials.

“The HSE are delighted to support the European Safety Agency’s campaign and have taken this opportunity to review chemical safety to provide helpful information and tools for all our colleagues to better manage hazardous chemicals in the workplace.” HSE website

The most important message we can draw from this is that all Safety Managers should be aware of their requirements when it comes to hazardous chemical compliance management in their workplace.

Workers are exposed to dangerous substances in many European workplaces. Such exposures are more common than most people realise and, in fact, may occur in almost all workplaces. This presents major safety and health concerns.

A step by step process has been published by the HSE which details your requirements for chemical management in stages.

1. Review All Chemicals

chemical containers stacked on shelving

A common issue for the workplace is awareness of exactly what chemicals are used and stored in their workplace. It is imperative that a detailed chemical inventory is carried out for chemical management. By knowing what is on-site is the first step and can work as a useful exercise to carry out the long finger task of clearing out the “shelf in the corner” or “locked old storeroom”. It can serve as a housekeeping exercise to reduce over-ordering of materials which is another common issue with Chemicals we discover on site.

There is no greater risk than expired chemicals sitting in storage, It is a catastrophe sitting in wait!

2. Identify Hazardous Chemicals

chemical bottle protection of a hazardous chemical with GHS symbols that indicate toxicity, corrosivity and contamination

Reading container labels is a start;

When purchasing chemicals, it is a legal requirement that all manufacturers issue a Safety Data Sheet for your consultation. You need to have all SDS sheets on file or you can’t possibly know all the risks that exist! It is also a legal requirement that you have these to hand in the event of an accident or emergency.

Another quick note is if there are any hazardous chemical containers on your site with the older CHIP hazard labels, it would suggest this chemical is now at least three years old and you need to consider safe disposal if the expiry dates are approaching. This is an essential element of correct chemical management.

3. Identify & Assess The Risks

Chemical Risk Assessment - Chempli - Methanol

As a manager, have you assessed your staff’s exposure to chemicals?

You are required to fully review all chemicals running a Chemical Agent Risk Assessment fully considering the following factors:

  • The Amount used or Stored
  • Classification of the Chemical
  • Potential Route Of Exposure
  • Physical, Health & Environmental Hazards
  • Dustiness or Volatility
  • Total Employee Exposure
  • SDS Review
  • Severity V Likelihood Evaluation

4. Implement Identified Controls

Hazardous materials White container and blue drums on an industrial storage site

Once you have assessed the risk associated with the use of chemicals, you are required to identify the control measures necessary to reduce the risks to a reasonable level, another essential for proper chemical management

Ensure you have considered the following the “STOP” principle according to the EU’s Chemical Agents Directive (CAD).

  • Substitution: Is there an alternative material available for your process that is deemed less hazardous?
  • Technological Measures: Is your lab/warehouse adequately ventilated to allow enough air changes/hr to remove harmful vapours from chemicals stored or used?
  • Organisational Measures: Are your chemicals stored safely? How can you reduce employee exposure? Have your employees been trained on how to safely use all hazardous chemicals in your facility? What are your emergency procedures? Have you considered the hazard class of the chemicals? Are you storing flammables? Do your chemicals need to be safely segregated to reduce the risk on your site?
  • Personal Protective Equipment (PPE): Wear protective clothing or equipment as identified through risk assessment and where necessary provide appropriate training in its use.

Do you have a Chemical Management System in place currently that you feel addresses your requirements as a manager above? Ask yourself the following questions:

  • Are you prepared for your next audit?
  • Does the thought of it keep you awake at night?
  • Is your office full of paper copies of your Safety Data Sheets, Incident Reports, Regulatory requirements, staff training files and countless other documents?
  • Have you identified all the chemical risks in your workplace?
  • Do you need a chemical management system that works for you?

If you are unsure or would like to arrange a free no obligations site compliance assessment with a trained professional, please contact Chemstore by clicking here or by using the LiveChat in the bottom left of your browser.

References:

  • www.hse.ie/eng/staff/safetywellbeing/chemical-management/
  • www.osha.europa.eu/en
  • www.hsa.ie/eng/Publications_and_Forms/Publications/Chemical_and_Hazardous_Substances/Your_Steps_to_Chemical_Safety.pdf
  • www.chempli.com
Numerous Fatal Accidents in China: Chemical Plant Explosion

In this month’s edition of the Hazmat Bulletin, we take a look back at the tragic explosion that occurred in a Chemical Plant located in Yancheng, China which is the worst industrial accident since the explosion in Tianjin back in 2015.

 

The death toll has now been quoted at 78 and the number injured is in the hundreds. Reports have stated that the cause of the blast initiated from a vehicle carrying compressed gas which then caught fire which led to a secondary and more fatal explosion within a bulk chemical storage area containing a large volume of benzene.

“Local press reported that 176 fire trucks and 928 firefighters were initially involved in the incident. The South China Morning Post said the explosion was heard 40km away and China’s earthquake administration reported a tremor equivalent to 2.2-magnitude at the time of the explosion on the afternoon of March 21”

 

Yancheng Satellite Image

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Source: https://www.nytimes.com/2019/03/22/world/asia/china-chemical-plant-explosion.html

 

 

Benzene

Benzene is a volatile and very dangerous material which has many adverse risks and side effects:

Health Hazard Danger Flammable

 

 

 

 

 

H225 Highly flammable liquid and vapour.

H304 May be fatal if swallowed and enters airways.

H315 Causes skin irritation.

H319 Causes serious eye irritation.

H340 May cause genetic defects.

H350 May cause cancer.

H372 Causes damage to organs through prolonged or repeated exposure.

H412 Harmful to aquatic life with long lasting effects.

 

An explosion with such a large volume of Benzene had catastrophic consequences for the primary area with so many people losing their lives. What must also be recognised is the secondary effects of Benzene dispersal which spread into the atmosphere from the flames. Benzene will remain in the atmosphere for a worrying period of time.

“In February 2018, China’s State Administration for Work Safety cited 13 types of safety hazards at the company, including mishandling of tanks of toxic benzene, the source of the explosion.” 

Additional reports have stated that water sources in the locality have been heavily polluted with Dichloroethane and Dichloromethane which by their nature have a high COD (Chemical Oxygen Demand) on rivers and other water sources which will cause serious side effects for aquatic life and also the risk to the human population consuming drinking water.

 

Public and Official Response

“After the Tianjin blasts in 2015, the government expanded inspections and toughened punishments for companies that violated safety standards. But many executives have cut corners under pressure to meet strict production targets, especially as China grapples with an economic slowdown” 

(http://www.hazardexonthenet.net/article/169028/China-pesticide-plant-blast-kills-at-least-78.aspx)

“Public anger over safety standards has grown in China over industrial accidents ranging from mining disasters to factory fires that have marred three decades of swift economic growth.”

President Xi Jinping has exclaimed that all efforts should now be invested to help the injured survivors and the state media are pushing authorities to drastically increase action to prevent disasters like what has happened in Yancheng from doing so again.

 

Safety Regulations for Hazardous Materials Use, Transport & Storage in China

There is no debating that there needs to be a serious change in the approach to safety in Chinese industry. Particularly for Hazardous Materials or there will simply continue to be tragic accidents and innocent lives lost in the country.

Safety Legislation is written in Chinese law, but there seems to be continuous negligence to adhere to these laws and obviously. The penalties for such failures isn’t severe enough for the responsible organisations.

Below is a list of notable existing regulations in China for Hazardous Materials

https://www.chemsafetypro.com/Topics/China/Overview_of_Chemical_Regulations_in_China.html

It remains to be seen how safety culture in the country will change, but it is clear that there is a need for drastic improvements for the people of China.

 

For any queries on hazardous materials stored on your site, please don’t hesitate to Contact Chemstore for any advice and guidance you require.

 

Media Sources

https://www.nytimes.com/2019/03/22/world/asia/china-chemical-plant-explosion.html
https://www.bbc.com/news/world-asia-china-47678641
https://www.independent.ie/world-news/death-toll-in-china-chemical-plant-explosion-increases-37940157.html
http://www.hazardexonthenet.net/article/169028/China-pesticide-plant-blast-kills-at-least-78.aspx

Additional Container Explosion

http://www.hazardexonthenet.net/article/169197/Second-China-factory-explosion-in-month-kills-seven.aspx?utm_campaign=NL190403&utm_source=emailCampaign&utm_medium=email&emailaddress=%7B~email~%7D#China

 

 

Court Orders 1.6 million Pay-Outs for Historic Spill

Following a large fine and huge clean-up costs, a dry-cleaning business in Ontario, United States were taught an expensive lesson on environmental protection and compliance following a chemical spill.  The following article will investigate exactly what happened and the lessons that need to be learned going forward for companies.

Ontario Superior Court in March instructed the corporation responsible for the spill of dry cleaning solvents from 1960-1974 to pay compensation $1,632,500 for remediation costs and $201,700 for expert costs. (Huang V Fraser Hillary’s Limited) The court ruled Huang V Fraser Hillary’s Limited (Dry Cleaners adjacent to Mr Huang’s properties) guilty of the spill of dry cleaning solvents which resulted in the damage of neighbouring property.

Mr Huang after learning of the contamination of soils and groundwater in the surrounding area of his two properties, decided to take legal action. Tetrachloroethylene & Trichloroethylenewere the substances identified to have caused this contamination.

The court found that for fourteen years these substances were allowed to seep into the ground through dry cleaning filters and the dry cleaning sump in the basement. Also, the chemicals in question were stored in cardboard boxes at the rear of the property and would remain there until the weekly garbage collection. It was also found that the dry cleaners took no steps to solve this problem. In 1974 Fraser Hillary’s Limited installed new dry cleaning machines. The modern technology in these machines resulted in the elimination for potential spills.

 

Spill Contamination

In 2002, it came to Mr Huang’s attention that his properties had suffered substantial damage. Through an environmental consulting firm Mr Huang ordered a site assessment of one of Fraser Hillary’s Limited properties which he was contemplating on buying. The assessment found moderate to high levels of contaminants.

When testifying Mr Huang claimed that because of the contamination his bank refused to provide him with the required funds and refusal to renew his existing mortgage. Also, he added that due to the damages he was unable to develop the properties in question in their present condition and once the issues are addressed he intends to proceed with development plans.

 

Description of chemicals

Tetrachloroethylene (PCE) & Trichloroethylene (TCE): Both colourless liquid substances which are highly volatile and toxic. The substance is hazardous to the aquatic environment. Both have a risk of explosion when in contact with other chemicals such as alkali metals, aluminium and alkali hydroxide. The main intake pathways for are via the respiratory tract and through the skin.

 

PCE Challenge Spill

 

 

 

 

 

 

 

 

 

 

(Hazardous Material Management)

 

Decision of the court

“Section 99 of the Ontario Environmental Protection Act provides for a civil cause of action between private parties, allowing recovery of any loss or damage incurred as a result of, among other things, the spill of a pollutant, from the owner of the pollutant and the person having control of the pollutant. Both the “owner of the pollutant” and the “person having control of the pollutant” are defined in relation to the time immediately before the first discharge of the pollutant”. (Ontario.ca)

 

Even though there was no existing statutory right to compensation for private individuals at the time during which the spills were occurring, the court held that recovery under section 99(2) was still possible because:

  • It was not clear that its application would constitute retroactivity.
  • The presumption against retrospective application is inapplicable where a provision is designed to protect the public.
  • Any presumption against retroactivity is rebutted in this case by the clear intention of the legislature.

The Court found that section 99(2) was intended to provide for compensation now any spill, not simply those that occur after the legislative provision came into effect, and consequently found the defendant corporation liable to the plaintiff as “the owner of the pollutant and the person having control of the pollutant” immediately before it was spilled. (Lexology)

 

The experts confirmed that the substances found in the ground water and soil were from dry cleaning solvents. The court awarded costs to Mr Huang that involved isolating the source of contamination with a permeable reactive barrier and treating Mr Huang’s properties with injections of zero valent iron over an eight to ten-year period.

 

zero-valent-iron-injection spill

 

 

 

 

 

 

 

 

 

 

(Hazardous Material Management)

 

Recommendations

It is clear that Fraser Hillary’s Limited failed to monitor and inspect the environmental and structural integrity of their properties for an extended period of time. Several steps could have been taken to prevent such an incident.

 

Sump (Bund) Maintenance & Integrity Testing

Fraser Hillary’s Limited should have regularly been testing their sump system to make sure it was holding and draining the waste appropriately.

 

Filter Replacement/Servicing

Filters should have been regularly serviced and replaced when necessary. The appropriate storage units should have been present to house these highly hazardous materials.

 

Housekeeping/Facilities Management

It is imperative that all machinery used in a business is inspected and tested on an annual basis. This would prevent the environmental damage but also as a protocol for the safety and well being of the employees operating the machines daily.

As per the Institute for Occupational Safety and Health:

  • All rooms and equipment have to be cleaned regularly.
  • Use protective equipment while cleaning if necessary.
  • Only conduct maintenance and other work on or in the vessel or closed spaces after obtaining written permission.
  • Only work with vessels and lines after they have been thoroughly rinsed.

 

Risk Assessment

Fraser Hillary’s Limited should have used the following basic steps.

Identify the hazards: In this case Fraser Hillary’s Limited should have identified that the chemicals used on a day to day basis were hazardous. Therefor, should have had the appropriate measures in place to prevent these chemicals from being exposed to the environment.

Determine the level of the risk: Fraser Hillary’s Limited should have estimated how likely the hazard is to cause harm and what the harm is likely to be.

Decide on the control measures: in this case Fraser Hillary’s Limited should have had their sump system tested regularly and filters used should have been regularly serviced and replaced when necessary.(HSA.ie)

If you would like to get more information about how to avoid hazardous chemical spills then contact one of our sales engineers today.

 

 

 

 

 

 

 

 

The expert guide to safe storage of hazardous materials in laboratories.

Introduction

 

From speaking to our existing clients we repeatedly hear of uncertainty and lack of clear information and guidance on how to identify, quantify and alleviate the risks with hazardous materials in the workplace. Without accurate information we understand it makes it difficult to prepare for the risks and to be aware of what hazards are currently in your workplace.

With that in mind, we are here to enable you with the right information and tools to eliminate the risk.

The following guidance document will make it clear what steps you need to take to create a safe and compliant laboratory.

The use of hazardous and volatile materials is part of daily processes in the majority of labs in universities, research facilities and production plants worldwide. It is currently not feasible to avoid the use of hazardous materials and what is often neglected is unsafe storage of these materials. Improper storage of these materials creates a prominent risk to human life, the environment and the business itself.

 

 

 

We have broken down this process down into 4 areas:

 

 

  1. Risk Assessment

  2. Segregation of incompatible materials

  3. Storage of flammable materials

  4. Emergency preparedness and planning

 

 

 

 

1.Risk Assessment

 

Labs across all areas of industry that haven’t undergone an adequate hazardous material storage assessment exhibit common shortcomings. There is often no defined storage system which determines risks with each type of material present in the lab. Such facilities have the following unsafe storage systems and practices:

 

–        Chemicals stored on lab worktops, benches and the floor

–        Materials stored on structurally fragile shelves and above eye level.

–        Not enough storage space for the hazardous material containers

–        Unsafe containers used to store materials e.g. wooden cupboards

–        Gas Cylinders located internally within a lab unnecessarily

–        Flammables not stored in fire rated cabinets

–        Excessive quantities of flammables stored internally within a lab

–        Absence of inventory or stock management system for chemicals in the lab

 

 

 

 

 

 

Tips:

 

  • Planning and forecasting for the exact activities and work that will be carried out in the lab should be documented in advance of the activities beginning. E.g. Distillation, HPLC, GC.
  • Identification of each material that will be used in each process is imperative before the work begins.
  • Quantification of the amount of each material you will require: no more or less than required should be present in the lab at one time.
  • One of the most important checks you need to make is that you have access to the SDS (Safety Data) sheets for each material. The SDS sheets will provide critical information for any material used in your process and the hazards associated.
  • It is a legal requirement under REACH regulations (EC) No. 1907/2006 that the manufacturer/supplier of the materials provide each SDS to you. For best practice you should consult the data sheets for each material before it is stocked in your laboratory.
  •  Once you have identified all of the above it will the enable you to begin assessing the risks that all operators in your lab will be exposed to and how to best mitigate those risks.

 

 

 

2.Segregation of incompatible materials

 

Our team often find when meeting our clients on site that one common practice is forgotten in laboratories. There is often one designated area/cabinet or container for all hazardous materials to be stored internally. Flammables, Oxidisers, Toxic and Corrosive liquids to name a few will be stored together.

Incompatible chemicals need to be segregated according to the hazard classes of each material. This is as important as with an adequate segregation scheme adverse reactions between incompatible chemicals such as oxidisers and flammables can be avoided.

ghs-labels-cut-out

 

Tips:

–  When developing a segregation scheme for chemicals in the lab, your first point to check should be section 2 of the SDS sheets ‘ Hazards Identification ‘

–  Ensure you have adequate space in your facility to allow for safe segregation and storage of each class of material.

– Some materials will have more than one hazard associated. In this case you should always identify the address the most prominent risk first.

e.g. Dimethlychlorosilane is both flammable and corrosive. In this case it would be best practice to address the flammable risk as a priority.sds

 

 

 

 

 

 

 

 

 

 

 

 

 

3. Storage of flammable materials

 

There is no doubt that the biggest area for concern our team always highlight with clients is the lack of awareness when storing flammable liquids internally. When carrying out a risk assessment of your laboratory and the hazardous liquids you are using and storing, you should immediately identify the flammable materials. Once you have documented an accurate list, you should then quantify in litres how much flammable materials you absolutely need to store internally in your laboratory.

It is now a legal requirement that flammables must be stored in safety storage cabinets that satisfy the requirements of EN 14470-1.

We would also like to reiterate that where possible the quantities of flammables be kept to a minimum.

Please watch the following video that will certainly portray how the negligent handling and storage of flammable liquids could have serious consequences. Risk is always present when handling and storing flammable liquids, so be the one to act and not react after it’s too late!

 

 

 

 

4.Emergency preparedness and planning.

 

If you neglect the above safety procedures when handling and storing hazardous materials in your lab that you are exposing your employees, the public and the environment to untenable risks.

 

  • Insurance in many cases will become void if a fire or explosion occurs in your facility.
  • The company and its owners will be liable for any damage to persons, property and the environment.
  • Damage to your facility could cause long downtime and incalculable effects to the company’s reputation.

commercial-emergency-planning

In order to create the safest possible environment in your laboratory the final step you need to take is to create an emergency response plan in the event an accident occurs.This plan should be carefully written and shared with all employees. All tier 1 organisations are legally required produce an emergency response plan to the local    authorities as part of COMAH Regulations 2015.

Emergency response plans need to be prepared addressing all four areas above in detail including accident scenarios with the hazardous materials present in you laboratory.  Once this emergency response plan has been drafted and approved by the certified body in your organisation, an open correspondence should be opened with the local emergency services and the Health & Safety authorities detailing this plan.

Conclusion

 From gathering extensive feedback from our valued client base and extensive research carried out throughout our 23 years in business, we are constantly striving to provide our clients with the tools and knowledge to eliminate the risks associated with hazardous material storage in industry.

A key strength of Chemstore throughout its history has been anticipating and responding to the needs of our clients. Increasing the level of safety in your workplace is where our work begins. We will enable you to reduce risk, liability and downtime on your site. We will take your business beyond the legal requirements for health & safety and social responsibility in your organisation.