Strategic Actions to Prevent Risks and Accidents

7/30/2019 Strategic Actions to Prevent Risks and Accidents

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Strategic Actionsto Prevent Risks

and Accidents

InvolvingHazardous

Chemicals

Michael J Cowing

August 2012Brasilia

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Content

BackgroundEU Legislative Background and FrameworkEU Organisational FrameworkHandling & StorageTransportationHaz WasteConclusions


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Venezuela Amuay Refinery Explosion


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Venezuela Amuay Refinery Explosion

There was a deadly explosion early on Saturday at the Amuay Oil Refinery innorthern Falcon State, Venezuela, one of the largest such facility in the world.Forty-one people died and dozens were injured in the blast .Firefighters said their work had been slowed down by increasing winds and achange in wind direction.Government officials said the blast occurred at 01:15 local time on Saturdaywhen a gas leak created a cloud that ignited.More than 200 homes and 11 businesses were damaged.Venezuela has the world's biggest certified oil reserves.Critics say under-investment by state oil company PDVSA has led to a declinein production and safety standards.But President Chavez stated that there was no evidence the blast was the

result of poor maintenance.


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BACKGROUND


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Hazardous Substances

By their very nature certain substances can be considered to be a risk to eitherhuman health or the environment - such substances are referred to as

hazardous substances.

In order to ensure the protection of those who come into contact with them andalso the environment into which they may be released it is first necessary to

understand and importantly to communicate the risks associated withdealing with these substances.

Risk is the combination of the probability of occurrence of harm and the

severity of harm.A high risk can be defined as a high likelihood of the hazard occurring.Within the EU the risks associated with the handling of hazardous substances

are captured within laws designed specifically to control all aspects of operation the handling, storage and transportation of hazardous substances and thewastes produced a cradle-to-grave approach.The single and most significant aspect of the legislation relates to the

communication of hazards; this is achieved with the application of consistent

terminology, removing the risks relating to mis-interpretation and harmonizing the

level of expectation required from those who use hazardous substances.


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Background

The growing importance of the chemicals industry to Brazils economyand the associated environmental and public health risks are welldocumented such as within the National Plan of Preparedness andResponse to Environmental Emergencies with Hazardous Chemicals,2009, (P2R2) so do not need to be repeated here in any detail.

But to summarize:In In 2007, the chemicals sector represented 3.2% of the national GNP, ranking 9 inthe world market.

In 2008 some 28 million tons of hazardous chemicals were imported and over 10million tons were exported.

Almost 70% increase in production since over the last ten years.

The chemicals industry is by far the largest producer of hazardous waste.

Further, the legitimate problems are compounded by those related to thegrowing illegal chemicals trade focusing on materials such as agro-chemicals and heavy metals.


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Background

Brazil is a signatory to and has ratified numerous Conventions and Protocolsdealing with themes directly related to the matter of chemicals and chemicalwastes, such as:

The Rotterdam Convention on the Prior Informed Consent Procedure for Certain

Hazardous Chemicals and Pesticides in International Trade;

The Stockholm Convention on Persistent Organic Pollutants (POPs)

The Basel Convention on the Control of Trans-boundary Movements of Hazardous

Wastes and their Disposal

The control of other chemicals which may affect the air and the oceans isequally mentioned in international commitments such as:

The Vienna Convention on the Ozone Layer Protection;

The Montreal Protocol on the Ozone Layer Destructing Substances SDOs,

The Convention on Climate Change;

The Kyoto Protocol on the reduction of gases emission;

The Convention on the Right of the Sea protecting the marine environment.


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European Legislative framework and history


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Eu Legislative framework

and history

Within the EU there are numerous directives and regulations developed to controlthe use of hazardous substances within member states.

A directive is a legislative act of the European Union, which requires member

states to achieve a particular result without dictating the means of achieving thatresult.

These can be It distinguished from regulations which are self-executing and do

not require any implementing measures.

Furthermore there are also agreements that can be considered a form of treaty

and require signatories to enter into the spirit of the agreement.The legal instruments provides overall control of hazardous substances, includingtheir: identification, classification, handling, storage, transportation and eventualdisposal.

There are deliberately transferrable elements between legislative acts.For example: the Waste Management Directive specifically calls on elements ofthe Global Harmonisation System (GHS) (enacted through REACH) andClassification, Labeling and Packaging (CLP) Regulations to ensure thathazardous wastes are treated adopting a legally defined methodology.


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and history

Legislation within the EU has developed over a significant number ofyears and has responded to a number of criteria not least - lessonslearned from accidents and incidents involving the uncontrolled releaseof hazardous substances.This type of development is progressive over time in order to reach the

desired goal the protection of the environment and human health.This can be used to the advantage of countries with less developedlegislative controls; the work has already been done and examples canbe taken from lessons learned previously in other countries.


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and history


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The Globalized Harmonisation System

The GHS is the most widely applied regulatory scheme and forms the

central framework against which European legislation on the control ofhazardous substances has evolved.Developed by the UN (United Nations Economic and Social Council) it providescontrol on the transportation of dangerous goods in the form ofUNRecommendations on the Transport of Dangerous Goods.This forms the basis for most regional and national regulatory schemes and inmany instances the founding steps in more comprehensive hazardoussubstances national programmes, initiatives and more specific acts oflegislation.The new system addresses classification of chemicals by types of hazard andproposes harmonized hazard communication elements, including labels andmaterial safety data sheets (MSDS).It aims at ensuring that information on physical hazards and toxicity from

chemicals is available in order to enhance the protection of human health andthe environment during the handling, transport and use of these chemicals.The GHS also provides a basis for harmonization of rules and regulations onchemicals at national, regional and worldwide level, an important factor also fortrade facilitation.


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Registration, Evaluation, Authorisation

& Restriction of Chemicals

REACH is a European Union Regulation of December 2006.It addresses the production and use of chemical substances, and their potential impacts on both humanhealth and the environment.

Its 849 pages took seven years to pass, and it has been described as the most complex

legislation in the Union's history and the most important in 20 years.

It is the strictest law to date regulating chemical substances and will affect industries throughout the world.REACH entered into force in 1 June 2007, with a phased implementation over the next decade.

When REACH is fully in force, it will require all companies manufacturing or importing chemicalsubstances into the European Union in quantities ofone tonne, or more, per year to register these

substances with a new European Chemicals Agency (ECHA) based in Helsinki, Finland.

Because REACH applies to some substances that are contained in objects ('articles' in REACHterminology), any company importing goods into Europe could be affected.The European Chemicals Agency has set three major deadlines for registration of chemicals. In generalthese are determined by tonnage manufactured or imported:

1,000 tonnes/a. being required to be registered by 1 December 2010,100 tonnes/a. by 1 June 2013; and

1 tonne/a. by 1 June 2018.

In addition, chemicals of higher concern or toxicity also have to meet the earlier 2010 deadline.


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REACH (continued)REACH also addresses the continued use of chemical 'substances of very high

concern' (SVHC) because of their potential negative impacts on human health or the

environment.From 1 June 2011, the European Chemicals Agency must be notified of the presence of

SVHCs in articles if the total quantity used is more than one tonne per year and the SVHC is

present at more than 0.1% of the mass of the object.

Some uses ofSVHCs may be subject to prior authorisation from the European Chemicals

Agency, and applicants for authorisation will have to include plans to replace the use of the

SVHC with a safer alternative (or, if no safer alternative exists, the applicant must work to findone) - known as 'substitution'.

As of January 2012, there are 73 SVHCs throughout the EU.

Using potentially toxic substances (such as phthalates or brominated flame retardants) isdeemed undesirable and REACH will force the use of certain of these substances to be

phased out.

According to the EC, little safety information exists for 99 percent of the tens of thousands ofchemicals placed on the market before 1981.

There were over 100,000 chemicals in use in the EU in 1981, when the last survey wasperformed. Of these only 3,000 have been tested and over 800 are known to be carcinogenic,mutagenic or toxic to reproduction. These are listed in the Annex 1 of the DangerousSubstances Directive (now Annex 3 of the CLP Regulation).In 2006 the REACH proposal came under criticism from a group of nations including the UnitedStates, India and Brazil, claiming that the bill would hamper global trade.


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Classification, Labeling and Packaging (CLP)

Regulations

The European Regulation (EC) No 1272/2008 on classification, labeling

and packaging of substances and mixtures the CLP Regulation

came into force in all EU member states, including the UK, on 20January 2010.The CLP Regulation:

Adopts in the EU the Globally Harmonised System (GHS) on the classification andlabeling of chemicals;

Is being phased in through a transitional period which runs until 1 June 2015.

The CLP Regulation applies to substances from 1 December 2010, and to mixtures(preparations) from 1 June 2015;

Applies directly in all EU member states. This means that no national legislation is

needed;Is overseen by the European Chemicals Agency (ECHA);

Will replace the Chemicals (Hazard Information and Packaging for Supply)Regulations 2009 CHIP from 1 June 2015

It is Europe wide and therefore ensures that harmony exists between member states

on the communication of hazards and subsequent identification of risks.


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Classification Labelling and Packaging (CLP) Regs

This Europe-wide harmonisation is an important and essential aspect thatcreates in itself a standardised form of communication.

Pictures are used as the first critically important visual identification of

the hazard a substance poses.This is essential where there are a number of different languages across

Europe, allowing the user/member state to develop their own responseplans, whether in the workplace or as an emergency service.

Alongside these, the regulations call for the supplier or manufacturers ofhazardous substances to produce material safety data sheets (MSDS)which must accompany the product on its journey from manufacturer tocustomer. These data sheets detail the physio-chemical properties of the

substance and its direct risks.


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Seveso Directive Control of Industrial Major Accident Hazard Regulations

Special consideration should be given to the specific risks associated with the

bulk storage of flammable liquids.

EU Council Directive 96/82/EC known as the Seveso II Directive, as amended

by Directive 2003/105/EC and replaced the Control of Industrial Major AccidentHazards Regulations 1984 (CIMAH) detail the requirements necessary for thecontrol of major installations.In general these regulations apply mainly to the chemical industry, but also tosome storage activities, explosives and nuclear sites, and other industrieswhere threshold quantities of dangerous substances identified in theRegulations are kept or used.


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International Carriage of Dangerous

Goods by Road (amended 2011)

The transportation of hazardous substances is defined in the Act - EuropeanAgreement Concerning the International Carriage of Dangerous Goods byRoad, most recently amended in 2011.The agreement first entered into force in 1968. In its most simple form theagreement states that (with the exception of some exceptionally dangerousgoods) all other dangerous goods may be carried internationally, i.e. between

member states as long as they comply with specific requirements; namely:The conditions laid down in Annex A for the goods in question, in particularas regards their packaging and labeling; and

The conditions laid down in Annex B, in particular as regards theconstruction, equipment and operation of the vehicle carrying the goods in

question


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ROHS and WEEE Directives

The Directive on the restriction of the use of certain hazardous substances inelectrical and electronic equipment (2002/95/E) commonly referred to as the

Restriction of Hazardous Substances Directive or (RoHS) was

adopted in February 2003 by the European Union.

The RoHS directive took effect on 1 July 2006, and is required to be enforced

and become law in each member state.This directive restricts the use of six hazardous materials in the manufacture ofvarious types of electronic and electrical equipment.

It is closely linked with the Waste Electrical and Electronic

Equipment Directive (WEEE) 2002/96/EC which sets collection, recycling

and recovery targets for electrical goods and is part of a legislative initiative to

solve the problem of huge amounts of toxic e-waste


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Waste Management Directive

Hazardous waste control in the EU is implemented in accordance with the Waste

Management Directive 2008/98/ECPrevious to this hazardous and normal wastes were co-mingled increasing both therisks associated with known and unknown exposure on handling and carriage as wellas issues associated with disposal.The properties which render waste hazardous are laid down in Annex III of theDirective 2008/98/EC and are further specified by the Decision 2000/532/ECestablishing a List of Wastes.It provides additional labeling, record keeping, monitoring and control obligationsfrom the "cradle to the grave", i.e., from the waste producer to the final disposal orrecovery.In addition, mixing of hazardous substances is banned in order to prevent risks forthe environment and human health.Moreover, the permit exemptions that may be granted to installations dealing with

hazardous wastes are more restrictive than for installations dealing with other wastes.


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Integrated Pollution, Prevention and Control (IPPC)

Directive

On 21 December 2007 the Commission adopted a proposal for a Directive on

Industrial Emissions.

The Proposal recasts seven existing Directives related to industrial emissions into asingle clear and coherent legislative instrument. The recast includes in particular the

IPPC Directive.

The IPPC Directive has been in place for over 10 years and the EC has undertakena two year review to determine how it can be improved and simplified in so doingcutting unnecessary administrative costs.In essence the implementation plans required for IPPC are designed to control the

activities of plant operators through the use of Best Available Technique(BAT).

Through the application of BAT the regulator can ensure that the appropriatemeasures have been installed to prevent the unauthorized release of contamination.Whilst IPPC has been developed to review and control industrial emissions there

are controlling features and recommendations within the IPPC requirements thatensure that the operator is undertaking best practice.In this way the release of pollution and the actions taken to control, contain andmitigate the impact of its release are mutually compatible between the independentlegislative frameworks of the EU.


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EU Organisational framework


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General

There are presently 27 member states within the European Union.Each has a responsibility to ensure that it can create and sustain the

appropriate organizational responses necessary to implementlegislation.There are significant differences between the way countries create the

organizations that are necessary to enact the requirements and thesedifferences are brought about as a result of many aspects, not least ofall the socio-political make up of the country.But also, and significantly, the length of time that the country has alsobeen a member of the EU.Mature members of the EU may have many of the frameworks and

structures in place whilst newer members may be required to overhaulexisting frameworks and even create new ones.


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The UK & Czech Republic

The UK is a mature member of the EU, joining in 1993 whilst the Czech Republic is a new memberjoining in 2004.The two countries have distinct differences in their socio-political composition with the UK having anessentially de-centralised and free market approach to enacting legislation whilst the CzechRepublic retains vestiges of the centralized communist approach significant in its history.The essence of the UK system is one of de-centralisation of the enforcement responsibilities downto the level of local councils and municipalities.

Centralised functions are present at the higher level giving policy guidance and strategic support inareas such as health and safety, innovation, nuclear power etc.At the government level the Secretary of State is ultimately responsible for the success of the Healthand Safety Executive (HSE).In support there is a strong structure of dissemination of communication and expectation downwardsto the enforcers and the users so that elements of uncertainty and doubt are removed as far aspossible.It is absolutely the responsibility of the user to ensure that they follow the guidance and

requirements but it is understood that the user must have access to information in a format that issimple to understand.


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The UK & Czech Republic (2)

The Czech Republic maintains its delivery of legislation through a centrally appointedorganization the Czech Environmental Institute (CEI).The CEI has a wide ranging mode of operation and is required to ensure that a largenumber of legislative acts are enforced, not only those relating to the control andmanagement of hazardous substances.A review of legislation developed by the Czech Government indicates that it is most certainlycreating laws that reflect the expectation of the EU, including Acts relating to the testing of

substances, assessment of risks, control of major installations as well as the use of bestavailable techniques (BAT).Maybe as a reflection of its previous position within the former USSR, the Czech Republichas elected to control the use of hazardous substances from a centralized entity.This does not diminish the effectiveness of the system but it is limited by the resourcesavailable to that entity.As with other members of the EU, accidents still occur but the responses of the authorities

in understanding and reacting to the causes of those accidents as well as the deficiencies inthe protocol for subsequent revision appear to be strong and co-ordinated.


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The UK & Czech Republic (3)

It is important to not draw conclusions from the two examples provided that oneis better than the other.Both have their merits as well as their drawbacks.It would be simple to conclude that the HSE in the UK represent best practiceand therefore can be applied to any society across the globe; the HSE workswell for the UK where de-centralisation is a priority however accidents still

happen.The important factor is that both countries structures have processes to learnfrom their mistakes, this being an essential component of the EU legislation.Furthermore the ultimate responsibility for the control of hazardous substanceslies with the government itself and this is an important and extremely relevantconsideration.

By undertaking to legislate and control from a central authority a clearmessage is sent to the country and those within the country who handlehazardous substances.


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the handling and storage of hazardous

substances


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Handling of Hazardous Substances

Handling of Hazardous Substances is set out within the GHS requirements and

delivered through the CLP and REACH protocols.

Within the UK these regulation sets are enacted specifically through the Control of

Substances Hazardous to Health Regulations, commonly referred to as

COSHH assessments.

The COSHH assessments set out the basic system for managing the risks to

health associated with the handling of hazardous substances it is not intended as a

prescriptive methodology as it is acknowledged under the Regulations that site specificrequirements are required in relation to the process being undertaken.In this way the basic system provides the framework for the generation interpretation

and storage of information and data that allow for a proper assessment of risk so that itcan be avoided or mitigated.

The key aspect ofCOSHH is that by setting the framework for a standardized

approach to information collection but permitting variances in actual operation allows

for the Regulatory body to police the system whilst not constraining the development ofindustry.

COSHH assessments revolve around two managing requirements find out what

the situation is and then decide what to do about it.

The legal requirement is that the collection of information has to be suitable andefficientto permit for an appropriate assessment of risk, the aim being reliableconclusions based on informed judgments.


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Storage of Hazardous SubstancesAppropriate storage of hazardous substances is the first line of defense in preventing accidents.An appropriate assessment of the risks of storing and handling dangerous substances - including the possibility ofenvironmental damage caused by leaks and spills, needs to be undertaken and communicated to those who may beexposed to the risks.Precautions needed to control risks can include the following:

storing chemicals according to the manufacturer's instructions on the safety data sheet

keeping the minimum quantity of hazardous substances necessary

storing incompatible substances separately

taking steps to prevent release or leakage of dangerous substances

keeping a spill kit near to storage areas, and ensuring staff are trained in what to do in the event of a spill

rapidly cleaning up any leaks or spills that occur

using appropriate precautions when handling substances - for example, wearing protective clothing or ensuringadequate ventilation

ensuring employees who store and handle dangerous substances are properly trained

checking containers used for short-term storage are properly labeled

place stores of liquid above ground where they're unlikely to be damaged, e.g. away from traffic routes

avoid overfilling containers

supervise deliveries

check and maintain gauges, valves and pipework

monitor oil use - unexpectedly high use may indicate a leak

have procedures for dealing with emergency leakages

use a secondary containment system such as a drip tray or bund (a storage area designed to prevent liquids escaping)


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Flammable liquids

Given both the high risks associated with the handling and use of flammable liquids, specific guidance isoffered to minimize risks arising from their use.In the UK and throughout the EU a flammable liquidmeans a liquid with a flashpoint of 55C or below.

The main hazards from the use of flammable liquids are fire and explosion, involving either the liquid orthe vapour given off from it.Fires or explosions are likely to occur when vapours or liquids are released from a controlled environmentto areas where there may be an ignition source, or, alternatively, when an ignition source is introduced intoa controlled environment.Common causes of such incidents include:

lack of awareness of the properties of flammable liquids;

operator error, due to lack of training;hot work on or close to flammable liquid containers;

inadequate design of equipment;

inadequate installation or maintenance;

failure or malfunction of equipment;

exposure to heat from a nearby fire;

misuse of flammable liquids, for example, to burn waste materials or brighten fires;

inadequate control of ignition sources;

electrostatic discharges;

heating materials above their auto-ignition temperature;

Dismantling or disposing of equipment containing flammable liquids.


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Flammable liquids (2)

Incidents involving flammable liquids commonly arise during transfer operations, including:movement from storage;

decanting or dispensing;

movement within premises;

use in processes;

disposal;

emptying vehicle fuel tanks;

Dealing with spillages.

Combustion of liquids occurs when flammable vapours released from the surface of the liquid ignite.The amount of flammable vapour given off from a liquid, and therefore the extent of the fire or explosion hazard,depend largely on the temperature of the liquid, its volatility, how much of the surface area is exposed, how long it isexposed for, and air movement over the surface.

Other physical properties of the liquid, such as flashpoint, auto-ignition temperature, viscosity, lower explosion limit andupper explosion limit, give further information as to how vapour/air mixtures may develop and also on the potentialhazards.The properties of a flammable liquid should therefore be established (for example, from the relevant data sheet) beforethe material is used, so that adequate precautions can be taken.


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COSHH - Summary

The effectiveness of any legislative tool is only as good as its enforcement.

Common themes on application of the requirements of the laws, and theirenforcement, exist across the EU and in many ways should be regarded asbeing good practice.

In their simplistic form the key to this is in communication.

Risks posed by the handling, transportation, use and disposal of hazardoussubstances are required to be communicated from cradle to gravei.e. from theinitial producer through to those charged with their safe disposal.The licensing of activities and the threat of removal of a license for non-conformance is a powerful tool against which a strong enforcement policy canbe created against this threat the requirements of a license can dictate theway in which it is required an operator conducts their business.Minimum requirements for Infrastructure (tanks and containment structures)can be prescribed as can the protection for workers, their training, the use ofsuitable vehicles and finally a safe way of disposing of wastes.


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Case Study Buncefield Oil Storage Depot, UK 2006

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The terminal was the 5th largest oil-products storage depot in UK.Facility owned by TOTAL and TEXACO.Cause appears to be a fuel/air explosion of unusually high strength possiblythe largest of its kind in peacetime Europe.disaster that occurred in Buncefield highlighted a comprehensive failure in theprocedures, protocols and laws operating in the UK and the EU to prevent such

an accident occurring.The accident has resulted in extensive review of both operational andenforcement activities to ensure that lessons are learned and more importantlyrevisions made.On the night of Saturday 10 December 2005, Tank 912 was filling with petrol.The tank had two forms of level control: a gauge that enabled the employees to

monitor the filling operation; and an independent high-level switch (IHLS) whichwas meant to close down operations automatically if the tank was overfilled.The first gauge stuck and the IHLS was inoperable there was therefore nomeans to alert the control room staff that the tank was filling to dangerous levels.Eventually large quantities of petrol overflowed from the top of the tank. A vapourcloud formed which ignited causing a massive explosion and a fire that lastedfive days.

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The gauge had stuck intermittently after the tank had been serviced in August 2005. However, neither site management nor the contractors who maintained the systems responded effectively to its obvious unreliability.The IHLS needed a padlock to retain its check lever in a working position. However, the switch supplier did not communicate this critical point to the installer and maintenance contractor or the site operator. Because of this lack of understanding, the padlock was not fitted.Having failed to contain the petrol, there was reliance on a bund retaining wall around the tank (secondary containment) and a system of drains and catchment areas (tertiary containment) to ensure that liquids could not be released to the environment.Both forms of containment failed. Pollutants from fuel and fire-fighting liquids leaked from the bund, flowed off site and entered the groundwater. These containment systems were inadequately designed and maintained.


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Failures of design and maintenance in both overfill protection systems and liquid containmentsystems were the technical causes of the initial explosion and the seepage of pollutants to theenvironment in its aftermath. However, underlying these immediate failings lay root causesbased in broader management failings:

Management systems in place at HOSL relating to tank filling were both deficient and not properly followed, despite thefact that the systems were independently audited.

Pressures on staff had been increasing before the incident. The site was fed by three pipelines, two of which controlroom staff had little control over in terms of flow rates and timing of receipt. This meant that staff did not have sufficientinformation easily available to them to manage precisely the storage of incoming fuel.

Throughput had increased at the site. This put more pressure on site management and staff and further degraded theirability to monitor the receipt and storage of fuel. The pressure on staff was made worse by a lack of engineeringsupport from Head Office.

Cumulatively, these pressures created a culture where keeping the process operating was the primary focus andprocess safety did not get the attention, resources or priority that it required.

The operating firms were ordered to pay almost 10m in fines.The Judge in charge of the investigation said: "Had the explosion happened during a workingday, the loss of life may have been measured in tens or even hundreds.


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Transportation of Hazardous

Substances


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Transportation of HazardousSubstances

The European agreement concerning the transportation of dangerous goods is updatedregularly reflecting changes in technology and learning from lessons as a result of incidentsand accidents.However the overall structure of the agreement is consistent with that of the:

United Nations Recommendations on the Transport of Dangerous Goods, ModelRegulations, the International Maritime Dangerous Goods Code (of the InternationalMaritime Organization),

The Technical Instructions for the Safe Transport of Dangerous Goods by Air (of theInternational Civil Aviation Organization) and

The Regulations concerning the International Carriage of Dangerous Goods by Rail (ofthe Intergovernmental Organisation for International Carriage by Rail)

The Globalised Harmonisation System (GHS) was developed to combine an effective

mechanism to bring together the various requirements of the agreements and regulations.The UNECE administers regional agreements that ensure the implementation of thesemechanisms as far as transport of dangerous goods by road, rail and inland waterways isconcerned.Whilst member states have the capability of updating or constructively revising the UNECErequirements the fundamental elements of the agreement remain the prescribing aspectsfor regulation and enforcement and are divided into the following categories (as detailed

within Annex A of the regulations;

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General Provisions

This section relates to the overall introduction to the requirements and thelegislative framework for its enactment.

Classifications

The groupings of substances according to their hazards and further sub-divided based on the type of hazard relevant to that group.

A listing of those goods that have already been classified is listed in theAnnexes of the UNECE documentation and as such requires that theproducer and transporter of that substance undertakes to provide the relevantdocumentation in the form of the chemical and hazard data sheets and

signage of the hazard on the transporting vehicle.

For those substances that are new to the market there are prescriptiverequirements for the physio-chemical testing of the substance in order toidentify the hazards associated with its use.

Transportation of Hazardous


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Dangerous Good list, special provisions and exemptions related to limited and exceptions quantities.This section gives details on the proper shipping names, including that of its chemical composition e.g. ETHANOL as well as that of itsphysical state e.g. LIQUID. It also details the elements composing the dangerous goods list and the special requirements for them

Packing and Provisions

Special requirements for the packing of dangerous goods giving special provision to the technical aspects of goods with properties thatcan change during transportation e.g. expansion of gases with temperature variations.

Consignment procedures

The processes necessary for marking, labeling and documentation and where appropriate authorizations and advance notifications

Construction and testing of packagingA detailing of the requirements used in packaging it provides observations that packaging can vary from that specified as long asthey are well constructed, tested in accordance with the regulations and have been agreed with the authorities

Carriage, loading, unloading and handling

This section essentially details the requirements necessary to mitigate the risks associated with transportation of dangerous goods.There are a significant number of prescriptive requirements that have been regulated that reflect the stability of the substances beingcarried and their maximum tolerances before the stability is compromised.

Provision concerning transport equipment and transport operators

A list of regulations concerning the documentation to be carried with the goods e.g. driver training certificates and vehicle eligibility,

consignment notes as well as the emergency response kits suitable for dealing with the substance being carried.

Construction and approval of vehicles

The requirements necessary for approval in the form of their construction and type as well as their annual inspection regimes.

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Calculation of Risks from Transportation of Haz

Substances

The guideline document (General Guideline for the Calculation of Risks in the Transport of Dangerous Goods by Road; An introduction to the basic principles of riskassessment for chapter 1.9 ADR reproduced in Appendix 5) aims at meeting the requirements of national characteristics in the transport of dangerous goods byroad.It is a document that all EU Member States are recommended to use despite the fact that major differences exist between Member States. This concerns for examplethe topography (flat or mountainous), the climate (temperature and wind), the national policy on transport and traffic, the combination of goods and passenger trafficor the population density.The risk assessment document and methodology also recognizes that individual countries can also differ greatly with regard to the technical details of the dangerousgoods vehicles used and the infrastructure, for example the state of the road systems.The guideline was developed to provide an independent framework for the analysis and evaluation of risks and for the assessment of corresponding safety measures.It is only intended to define the basic requirements and to recommend basic approaches. Since the acceptance of a risk assessment is largely dependent on the inputdata and the necessary assumptions and restrictions it should be attempted to achieve absolute transparency of all procedural steps.The guideline concentrates on aspects which should be taken into account for a risk analysis, i.e. on basic contents and quality objectives.It is then recommended that any of the various quantitative risk assessment tools can be used.


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Hazardous Wastes



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C t i t d R bbl


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Contaminated Rubble


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What is Hazardous Waste?

The EU has simplified the process of waste definition by undertaking to classifyand publish wastes in the European Waste Catalogue (EWC).Generally, waste is hazardous if it, or the materials or substances it containsare, harmful to human health or the environment.The EWC has a six-digit code for all types of waste. Hazardous waste isidentified in the EWC with an asterisk.

The EWC contains two kinds of hazardous waste entry:'Absolute' entries are always hazardous. Examples include waste from

the manufacture of specified acids, inorganic wood preservatives, andnickel cadmium batteries.

'Mirror' entries are only considered hazardous if they contain a certain

hazardous component, or more than a specified amount of a hazardoussubstance. Examples include some wastes containing arsenic or mercuryor displaying hazardous properties such as flammability.


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What is Hazardous Waste?

It is recognised that almost all businesses will produce some form of hazardous waste. Typical examples includewaste:

asbestos

chemicals, e.g. brake fluid and printer toner

electrical equipment with potentially harmful components such as cathode ray tubes, e.g. computer monitorsand televisions

fluorescent light tubes and energy-saving light bulbs

vehicle and other lead-acid batteries

oils (except edible oils), e.g. engine oil

refrigerators containing ozone-depleting substances

solvents, e.g. aerosols

pesticides

Wastes are listed in the European Waste Catalogue if they are considered to have one or more of the specifiedhazardous properties.Such properties would normally be identified on the chemical data sheets transmitted with the hazardoussubstances used in the manufacturing process these can be directly transferred to the properties that would bepresent within the waste coming from that process.


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Hazardous Waste Advice


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Hazardous Waste - AdviceIn recognition of the importance of the waste hierarchy reduce, re-use, recycle advice is offered acrossMember States to business that have the potential to produce hazardous waste.

Whilst this advice is fairly self explanatory and much of it good business sense it is strengthened through acharging mechanism that provides a financial dis-incentive for disposing of hazardous wastes.Such advice however is good practice and should be considered taking the form of the following series of highlevel actions;

Know what you are handling train personnel to understand the risks

Avoid using hazardous substances - see if they can be substituted by a non hazardous substance

Keep the minimum volume in correct storage

storing chemicals according to the manufacturer's instructions on the safety data sheet

store incompatible substances separately

prevent release or leaks

storing flammable substances in suitable containers away from sources of ignition, such as boilers andheaters

place stores of liquid above ground where they're unlikely to be damaged, for example away from driveways

maintain gauges, valves and pipework

using a secondary containment system such as a drip tray or bund (a storage area designed to preventliquids escaping)

monitoring oil use - unexpectedly high use may indicate a leak

Have an emergency plan with adequate response materials spill kit

Storing Hazardous Waste


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Storing Hazardous Waste

Most member states prescribe the length of time and volume that can be stored on site before a license is required(this is to avoid un-licensed premises acting as a waste carrier or disposer; a licensable activity).However in acknowledgement of the need for business to be able to store hazardous wastes a series of guidelines

and operating practices are produced giving advice on best practice; such as the following;If you keep hazardous waste on your premises, even for a short period of time, you must:

ensure that it is stored safely and securely to prevent pollution

ensure that it is packaged and labelled correctly

keep different types of hazardous waste separate

keep hazardous and non-hazardous waste separate

keep liquid hazardous waste in a dedicated area, with a bund or barrier to contain spills and leaks

regularly check storage areas for leaks, deteriorating containers or other potential risks

display written instructions for storing and disposing of each type of hazardous waste

maintain an inventory of the hazardous wastes kept on your premises, and where they are stored - this will helpthe emergency services to deal with any incident effectively and safely


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Hazardous Waste

Given the almost universal presence of hazardous substances in the manufacture of goods, and thesubsequent hazardous wastes that are produced, the regulations concerning the handling, movement anddisposal of hazardous wastes conform in a large part to the expectations for dealing with hazardoussubstances.Many countries have established frameworks that are similar in nature to those for dealing with hazardoussubstances, following the same high level strategic implementation elements;Know what the hazards of the waste are (the same types of waste can be mixed together e.g. waste oils,food products, however wastes cannot be co-mingled)

Communicate the hazards within the delivery mode GHS/ADR requirements.Ensure that the wastes are received at a facility that has the ability to store them, process them (e.g.recovery or recycling) and then dispose of them in accordance with the legal framework for protection ofhuman health and the environment.

Most countries adopt a licensing system to ensure compliance of carriers with aspects of the GHS

requirements and also for places of disposal this latter is an important aspect in that the enforcement ofrequirements can be maintained through the licensing system as well as allowing for the creation of anational database of disposal sites.The use of consignment and delivery notes ensures that the hazardous wastes are transported in fulltransparency from cradle to grave.


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Moving hazardous waste


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Moving hazardous waste

Make sure all hazardous waste is:transported by a registered or exempt waste carrier

accompanied by a consignment note (there are only a few exceptionswhere consignment notes are not required)

sent to a facility that holds a suitable environmental permit or a registered

exemption that authorises them to take that type of waste for the activitythey intend


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Conclusions

Conclusions


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ConclusionsThe development of European legislation follows the lifetime of hazardous substances from their manufacture totheir disposal cradle to grave.

A number of EU wide directives are passed to Member States for them to create their own legislative framework

for enactment but importantly provide the unifying terminology and requirements that provide parity acrossborders (reducing ambiguity caused by cultural and language restrictions).There are of course differences in the way each Member State enacts its duties, some are robust, others lessso, however the intent remains the same to reduce the risks posed by hazardous substances to the populationand the environment.There re a number of examples frameworks have been provided against which legislation has been developedand then cascaded down into the operating protocols.

A centrally controlled function whose mandate is to ensure that the control of hazardous substances iscommunicated at the highest governmental level.Harmonisation of the communication of hazards it is absolutely essential that the risks posed by hazardouschemicals are communicated through the chain of users who may be exposed to those risks.

A strong regulator with the power to enforce and penalize nonconformanceA system of licensing across all those who store, move, use and dispose of hazardous substancesThe creation of an educational base (in the form of advisory notes) to inform those who handle hazardoussubstances on their legal requirements and expectations for best practice training of staff is key to theenactment of these advisory notes and vocational training qualifications help ensure that the correct level oftraining is enacted.

Emergency response plans that reflect the capabilities of the local and regional civil emergency responder andthe agreement of those response plans with the civil authorities.


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Thank You

Strategic Actions to Prevent Risks and Accidents

Documents

Transcript of Strategic Actions to Prevent Risks and Accidents