Risk Management Strategy

Any health and safety strategy must accommodate these non-risk faults and failures to include:

  • The flammability of the process material;
  • Monitoring the state of reactions - particularly in enclosed vessels - to ensure that they remain within specified limits and do not become dangerous;
  • The effect of loss of containment, leakage or spillage not only on those working in the plant but the wider air pollution issues that might affect the local community;
  • The amount of waste produced by the process - how to minimise it - how to dispose of it; and
  • Measures to ensure that emissions remain within acceptable environmental limits.

The following sections concentrate on those facets of risk management aimed at preventing or minimising the adverse effects of chemicals on the health and safety of the workforce, namely:

(a) preventing exposure

(b) minimising exposure

(c) training and information

(d) monitoring, and

(e) keeping records.

Preventing exposure Many extremely hazardous substances can be employed quite safely in manufacturing processes provided that at all times they are contained within the plant and not allowed to escape into the working environment. This assumed automated bulk handling into storage, thence from storage to process by transfer either in sealed containers or through enclosed and dedicated pipelines. An essential feature of containment is a high level of operating integrity in the plant, instrumentation and control systems. These features in turn demand high standard of plant maintenance.

Minimising exposure For each substance assessed measures must be developed to ensure that under all foreseeable operating conditions no one, whether employee, visitor, contractor or member of the public is exposed to any hazardous substance in a concentration that may injure their health. A number of actions are possible and in order of priority they are:

(1) Substitution by a less hazardous substance or by the same substance in a less hazardous form.

(2) Minimise emissions.

(3) Partial enclosure with local exhaust ventilation.

(4) Local exhaust ventilation.

(5) Personal protective equipment.

In each of these cases a number of aspects need to be considered.

(a) Substitution

This is the best and most effective safeguard but it must be realistic in terms of process need. Therefore:

(i) It is necessary to check with the chemist and process controller that the substitute proposed will produce an end product of the required specification.

(ii) The cost of the substitute must not be such as to make the process uneconomical or commercially unviable.

(iii) The substitute itself must be a safer substance than the original it replaces.

(iv) In the manufacturing process there must be no side effects or daughter products that nullify the benefit of the change.

(b) Minimise emissions The plant, processes and systems of work should be designed to minimise the generation of hazardous dusts, fumes, micro-organisms, etc. The process must also limit the area of contamination in the event of spills and leaks.

(c) Partial enclosure with local exhaust ventilation If the process requires access into parts of the plant so as to prevent total containment, then the enclosure of the plant must be to the greatest degree possible and local exhaust ventilation provided with exhaust vented to a safe place to reduce exposure to an absolute minimum.

(d) Local exhaust ventilation Used where enclosure is not practicable, the design of the capture systems and discharge points must ensure that the greatest amount of the hazardous substance is prevented from escaping into the general workplace and is discharged at a safe height and position outside the normal workplace. In some cases the use of chemical scrubbing should be considered.

(e) Personal protective equipment This is used only as a last resort or in cases of very low risk. It can be effective provided:

  • The equipment is suitable for the hazard to be faced;
  • It is acceptable to and effective on the wearer;
  • It does not interfere with the functions to be carried out by the person wearing it;
  • It is of an approved type, and;
  • The wearing of it does not generate additional but different hazards.

In addition, the equipment must be properly looked after and maintained in good working conditions. Ideally PPE should be issued to an individual, but if this is not possible then adequate sanitary cleaning must be carried out between each use.

Training and information Essential to any strategy is the need to provide those handling or using the substances with information about the substances and training in the techniques necessary to minimise the risks faced. Thus training and instruction should be given in:

(a) Characteristics of the substances to be handled, the hazards they present and the action to be taken if exposure or contamination occurs.

(b) The system of work which must be followed to ensure:

(i) that the substance is correctly used in the process,

(ii) the safe transfer from store to process plant,

(iii) the safe handling of the finished product, and

(iv) safety in the event of a leakage or spillage.

(c) Any special plant or equipment which is to be used, with particular emphasis on recognising deviations from normal operation or performance.

(d) The proper use of PPE, its correct application, cleaning and care, and the reporting of any damage or faults in it.

(e) Understanding the results obtained from monitoring checks - in the quality of the product, on concentrations in the atmosphere and any measured exposures.

Records Because of the long-term effects that exposure to hazardous substances can have on health, it is essential that adequate records are kept of all those working in areas or on processes where they are likely to be exposed, and exposure or contamination that occurs and the results from monitoring of both the plant and the work area. Finally records of health surveillance must be kept for 5 to 40 years depending on the substance involved and the degree of exposure.

Legislative requirements After the Flixborough incident in 1974 the HSE appointed a committee of experts, the Advisory Committee on Major Hazards, to consider the health and safety problems posed by major chemical sites and to make recommendations. This they did in three reports which identified a need for three basic elements of control:

(i) Identification of the site.

(ii) The location of the site.

(iii) An assessment of the potential hazards arising.

It has been the intention to implement these three recommendations through a single set of regulations. However, following two major incidents as Seveso and Manfredonia in Italy in 1976, the European Community adopted a directive on major accident hazards. This resulted in the preparation of two slightly conflicting sets of regulations, the Notification of Installations Handling Hazardous Substances Regulations 1982 (NIHHS) and the Control of Industrial Major Accident Hazards Regulations 1984 (CIMAH) with its amendments. In addition, continuing concern about the effects on workers of substances which they have to handle in the course of their work resulted in, amongst other things, COSHH and the Chemical Hazard Information and Packaging Regulations 1992 (CHIP).

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