Chemical safety management – going beyond compliance

Daniel Haggarty | Associate Director & Head of Emergency Response

the-ncec.com/emergency-response

Chemical safety – what is it?

Compliance

Risk management

Corporate social responsibility (CSR)

Sustainability?

Poll question

What do you see your chemical safety management programme as being primarily about?

Compliance

1. For compliance with regulations

▪ EU REACH Annex II, subsection 1.4

▪ China SAWS “Order 53”

▪ Transport regulations such as IATA, IMDG, 49 CFR 172.604

▪ Canada - Controlled Products Regulations (CPR) and TDG Regulations

▪ Mexico - NOM-005-SCT/2008

▪ Existing regulations vary in strength, significant gaps in coverage e.g. 24/7 coverage, language, technical competence and poison centres

▪ Staying on the right side of the regulators

2. Risk Management of an incident not being dealt with effectively

▪ Operational / supply chain risk

▪ Financial risk – reducing cost of intervention during an incident

▪ Brand/reputational damage

3. To meet other business objectives

▪ Responsible Care / Product Stewardship

▪ CSR

Compliance headlines

Region CountryEmergency number

required?In country number?

Local language response?

24/7 requirement?

South America

Argentina Y N Expectation N

Brazil Y Y Expectation Y

Chile Y Y Expectation Y

Mexico Y Y Expectation Y

Colombia Y N Y Y

North AmericaUSA Y N Expectation Y

Canada Y N Y Y

Asia Pacific

Australia Y Not specified Y Y

New Zealand Y Y Y Y

India (pending ratification)

Y Not specified Eng. / Hindi Y

South Korea Y Y Y Unspecified

China Y Y Y Y

Malaysia Y Not for imports Y Y

Taiwan Y N Expectation Y

Africa S. Africa Y Not specified Not specified Not specified

EuropeEurope Y + poison centres N Yes / Expectation Hours of operation

UK Y N Expectation N

Risk

Risk

▪ Supply chain confidence

▪ Reputational damage

▪ Financial impacts?

Reputational risk

▪ Supply chain confidence

▪ Reputational damage

▪ Financial impacts?

Typical responses to risk

▪ Denial - incidents only happen to other people

▪ Disavowal - incidents happen, so what?

▪ Idealization - we are too good to be affected

▪ Grandiosity - we are too big to be affected

▪ Transference - we wouldn’t make a mistake

▪ Victimization - someone else is responsible

▪ Intellectualization - statistical dismissal of the risks

▪ Compartmentalization - only a part will be affected

We are too good to be affected

“The set procedures we have in place for handling dangerous

goods shipments, are stringent enough to prevent significant

damage. In the unlikely event of a Dangerous Goods shipment

being damaged, all staff involved with the handling have rigorous

training and sufficient equipment to deal with the incident.”

Before…

Photo c/o Arup

…after

Photo c/o Arup

Poll question

How often do you test your emergency plans?

Responsibility for dangerous goods

Incoterms® (2010)

15

The cost of incidents

Accidents at work cost UK $14billion a year

2010/11 – 175 people killed at work

200,000 reportable injuries (over 3 days off)

Major injuries: fractures, amputations, chemical burns, loss of consciousness

Poll question

What, if any, NEW activities are you planning in the next year within your chemical safety management programme?

Cost of doing nothing

4 x fire trucks for 6 hours = $7,608

12 hours public health agency time = $1,551

36 hours plant shut down = $277,080

Clean up contractor = $18,472

Fine = $38,483

Legal costs = $10,776

TOTAL = $353,970

Cost of a farm incident

TOTAL = $94,274

Somerset – 2nd Feb 2012. Firefighters battled the blaze for seven hours to prevent fire spreading to two other barns

containing 25 tonnes of chemical fertiliser and one tonne of grain.

2 x fire appliances for 3 hours = $1,879

12 hours of environmental agency time =

$1,533

Clean up contractor (6 hours) = $9,120

Fine = $38,000

Legal costs = $11,400

TOTAL = $61,932

What, how often, how severe?

TOTAL= $94,274

2 x fire appliances for 3 hours = $1,879

12 hours of environmental agency time = $1,533

Clean up contractor (6 hours) = $9,120

Fine = $38,000

Legal costs = $11,400

The end result should be a list such as:

▪ 1 in 100 packaged goods shipment by road will result in a minor leak

▪ 1 in 200 bulk shipments by road will result in a major spill

▪ For ever 100 tonnes of finished product made there will be 1 minor

spill on a site

▪ A major spill will occur x time per ton per km

1 in 200 road shipments = major spill

TOTAL= $94,274

2 x fire appliances for 3 hours = $1,879

12 hours of environmental agency time = $1,533

Clean up contractor (6 hours) = $9,120

Fine = $38,000

Legal costs = $11,400

TOTAL = $61,932

Impact category Impact Likelihood Cost

People 1 serious injury, $273,838* 50% $136,919

People30 locals require health check,

$261* per person10% $783

Property Vehicle damage, $33,328** 100% $33,328

Property Total loss of product, $66,657** 50% $33,328

PropertyDamage to infrastructure:

resurfacing of road, $133,315**50% $66,657

Property Road drainage clean-up, $6,665*** 50% $3,332

*From UK department for Transport, cost to society**For illustration only, highly variable parameter***Educated guess

Mitigation

Health benefits $3,072,601

• Health service savings $10,024

• Reduction in lost work days or days lost through restricted activity $8,132

• Reduction of 1 fatality (road, site, home, etc.) $2,493,947

• Reduction in 2 serious medical issues $560,499

Time savings $1,112,395

• Reduction in time spent by emergency services $205,636

• Reduction in time roads closed or heavily congested $906,758

Environmental benefits $103,122

• Avoided Environment Agency involvement 10% of spills, traffic incidents and fires it would normally need to attend

$2,764

• One case of serious aquatic damage avoided $100358

TOTAL $4,288,119

Bromaid scheme

▪ Clear risk to industry

▪ Benchmark for others through standards of

prevention and response

▪ Risk mitigation and sustainability for the industry

▪ First true mutual aid scheme in China (in Europe

for 20 years)

http://www.bromaid-asia.com/en/

Beyond compliance in the supply chain

In practice

▪ Biannual meetings

▪ Awareness raising

▪ Dissemination platforms

▪ Firefighting colleges,

▪ Fire services

▪ Supply chain

▪ Training videos for Fire Services and clients

▪ Implementing high standards for PPE, containers,

storage requirements, site standards etc.

▪ Auditing of customers

Bromaid

Resources

Quality and safetyof logistics partners

Capabilities of spillage remediation providers

Benchmark chemicals management program

Resources

the-ncec.com/resources

Supply Chain Assurance

the-ncec.com/supply-chain-assurance-tool

Summary

Compliance

Risk management

CSR

Sustainability?

References

Slide Reference

8Article and screenshot c/o http://www.capitalgazette.com/news/annapolis/cgnews-parts-

of-maryland-city-under-shelter-after-hazmat-incident-20150530-story.html

11,12 Images c/o Nigel Cann, Arup.

14 Image c/o International Chamber of Commerce

22 Image c/o Albemarle Corporation

The presentation was prepared with thanks to the following sources:

W: the-ncec.com | E: ncec@ricardo.com | T: +44 (0) 1235 753654

Craig Thomson Daniel Haggarty

Name

NCEC, Ricardo Energy & Environment,

The Gemini Building,

Fermi Avenue, Harwell, Oxon. OX11 0QR