Storage and handling of hazardous substances- Identity charades
It is surprising how many companies fail to ensure that their workforces can easily identify the various hazardous materials they handle on site, and their associated risks. Natasha Antunes and Howard Wing explain why it is so important that the simple procedures are properly followed.
As many health and safety practitioners will be only too aware, the Control of Substances Hazardous to Health (COSHH) Regulations set out a requirement for companies to ensure chemicals and dangerous substances are stored and handled in a way that minimises the exposure of anyone who has to handle them in the course of their work.
It is important to approach COSHH in a holistic fashion. Companies need to understand how the various elements that comprise the segregation of hazardous materials fit together, and the impact that small changes can have on the whole workforce.
Despite the difference that simple procedures, such as clear, legible and long-lasting labelling, can make to a company’s hazardous substances safety regime, it is still surprising how frequently organisations fail to abide by such basic principles. It is amazing that people still use an ordinary pen and paper to mark the most hazardous of substances. It’s all well and good old Harry knowing that ‘x’ is in the container in the corner, just waiting for a space in the warehouse, but what happens if he’s off work or ill?
Recent changes concerning the reclassification of what constitutes hazardous waste1 creates another potential handling point, as waste must now be separated according to material. This means additional information for handlers is essential.
The good news is that it’s such a simple culture change to implement hazardous substance identification (HSID), and quite low-tech in this supposedly high-tech age.
One company has recently received recognition for a simple streamlining of hazardous waste segregation, in line with European Waste Category (EWC) legislation.2 Using software and a printer, the company has been able to print off as many fully bar-coded and standardised signs as it needs. Each time a skip is collected, for example, a sign needs replacing, but by controlling the output itself, both employees and contractors know exactly where every type of waste has to go. There’s no confusion, and no potential for a problem of combining two incompatible substances. Employees know what they are dealing with, and specialist contractors know exactly how the waste must be treated.
Most companies operate a colour-coding system, which adheres to the internationally recognised codes of blue, equating to oxidising substances; red, representing flammable; green, for inert; and yellow, to highlight toxic or corrosive substances. By maintaining this colour-coding method throughout the tracking process, instant recognition is gained, covering anything from an order book to a lockout valve in a particular area. All documentation can be tracked via the same colour process, including software data sheets for maintenance and usage records.
Contravening basic housekeeping rules can be the precursor to a major incident (see case study), so the segregation of all hazardous materials is key to their safe management. The HSE suggests a number of general principles that should be considered when dealing with the storage and handling of hazardous substances. These include: human factors; poorly-skilled workforces; ignorance of physical and chemical properties of stored substances; unconscious and conscious incompetence; plant lay-out; and plant siting.3
However, companies should always have their own standard operating procedures for handling hazardous materials across a site. This is particularly important when you are dealing with premises that may have more than one type of hazardous material. All staff should therefore attend a mandatory training course, so that they understand the safety and health hazards associated with the chemicals and equipment used.
Separate risk assessments must also be undertaken for each different department, while constant reinforcement of restrictions and the need for PPE makes simple good sense. For example, eating, drinking and applying make-up should be forbidden in areas where hazardous chemicals are used. In addition, the entry to these areas should be clearly signed to restrict access to only those workers wearing the correct PPE, and banning entry to unauthorised staff. A simple swipe-entry system can restrict entry and log visits into restricted areas.
From a housekeeping perspective, exits, aisles and safety equipment must be easily and quickly accessible, and not obstructed by storage or any similar blockages. Similarly, fire extinguishers must be available, charged, and hung in a location that is quickly accessible. By installing safety and protection equipment onto a logging and tracking programme, not only is it easy to keep a record of when checks are due but any room at any given time can be checked via a central log. Every part of the PPE requirement can be maintained on one central database, from fire protection to respirators.
It’s often said that PPE should be the last line of defence once all efforts have been made to reduce the type of contact any employee should have with hazardous materials, but it can still be a problem to continually reinforce this message both at employer and employee level. Safety posters can come in handy in this area, and there are many available from both unions and health and safety bodies if you don’t have the facility to print your own.
Control and containment
Handling spills covers everything from a small leak of diesel oil during routine maintenance to a serious chemical leakage. The biggest concern when dealing with a spill is identification. If you don’t have a positive identification on a material it can be extremely dangerous to try to clean it up, contain it, or dispose of it afterwards. Significant environmental damage can be caused by inefficient disposal of spills, which can then progress to cause much wider contamination.
It’s essential to have the appropriate spill kit and/or spill kit supplies on hand in areas where spills can occur, and be prepared to respond to combat any environmental or health-risk situation. A spill can be hazardous in nature depending on the type of liquid spilled, and according to the classification of the substance.
Oil spill kits, for example, selectively absorb hydrocarbons and other petroleum-based fluids while repelling water. On the other hand, chemical spill kits are designed for more aggressive spills, such as acids and bases usually found in laboratories and other kinds of manufacturing facilities. These spill kits are also known as Hazmat spill kits, and are available in the same configurations as an oil spill kit or general kit for non-aggressive fluid spills.
Preparation of a spill-containment kit consolidates spill-control materials and PPE in one easy location. They tend to be packaged in the appropriate size and configuration to handle a foreseeable spill in such workplaces as laboratories, manufacturing, retail, commercial, and even home workshops. A spill-response kit should be customised to meet the needs of each work area, and PPE must be selected based on the hazardous materials used. Kits should be stored where individuals can quickly gain access to them in the event of a spill. Needless to say, users of hazardous materials should also know how to use the materials contained in each kit.
Of course, while substances are in transit, it is important that a suitable spill kit is accessible at all times. In addition, individual company policy should also make it necessary to carry additional equipment, for example, fire extinguisher, plastic containment material, and a large quantity of sand, to protect waterways and contain the spill.
Every worker who has to handle substances as part of their job needs to understand the exact nature of the material he or she is dealing with. Using an at-a-glance recognition system, setting up a comprehensive training programme, and imposing strict housekeeping rules should all empower workers to maintain correct handling procedures.
1 Environment Agency (2008): Hazardous waste: Interpretation of the definition and classification of hazardous waste, Technical Guidance WM2 (second edition, version 2.2)
2 European Commission (2002), European Waste Catalogue