Chemical warehousing

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1 Health ad Safety Chemical warehousig The storage of packaged dagerous substaces This is a free-to-dowload, web-friedly versio of HSG71 (Fourth editio, published 2009). This versio has bee adapted for olie use from HSE s curret prited versio. You ca buy the book at ad most good bookshops. ISBN Price 9.50 This fourth editio of Chemical warehousig is aimed at ayoe who has resposibility for the storage of dagerous substaces, regardless of the size of storage facility. It sets out cotrol measures aimed at elimiatig or reducig risks to people at work or otherwise from the storage of packaged dagerous goods. It reflects good practice for the desig of ew storage facilities (ad where reasoably practicable, to existig sites) ad applies to trasit or distributio warehouses, ope-air storage compouds, ad facilities associated with a chemical productio site or ed user. The guidace has bee updated i light of chages to legislatio ad ew sectios have bee added, to reflect chages to idustry practice ad what chemicals warehouses store, coverig: aerosols; itermediate bulk cotaiers (IBCs); storage of hazardous wastes; iformatio, istructio ad traiig; audit ad review; ad process safety performace idicators. HSE Books Page 1 of 65

2 Health ad Safety Crow copyright 2009 First published 1992 as Storage of packaged dagerous substaces Secod editio 1998 Third editio 2004 Fourth editio 2009 ISBN All rights reserved. No part of this publicatio may be reproduced, stored i a retrieval system, or trasmitted i ay form or by ay meas (electroic, mechaical, photocopyig, recordig or otherwise) without the prior writte permissio of the copyright ower. Applicatios for reproductio should be made i writig to: The Office of Public Sector Iformatio, Iformatio Policy Team, Kew, Richmod, Surrey TW9 4DU or licesig@opsi.gov.uk This guidace is issued by the Health ad Safety. Followig the guidace is ot compulsory ad you are free to take other actio. But if you do follow the guidace you will ormally be doig eough to comply with the law. Health ad safety ispectors seek to secure compliace with the law ad may refer to this guidace as illustratig good practice. Page 2 of 65

3 Health ad Safety Cotets Itroductio 4 Who is this guidace for? 4 Objectives 5 Legal requiremets 5 Relevat legislatio 5 Regulators 9 Hazard idetificatio ad risk assessmet 9 Hazards 9 Hazard classificatio 9 Risk assessmet 16 Elimiatio or reductio of risks 18 Itroductio to the hierarchy of cotrol 18 Cotrol measures 19 Mitigatio measures 37 Hazardous area classificatio 44 Emergecy arragemets 47 Overall approach 47 Geeral fire precautios 47 Emergecy procedures 52 Cotrol of off-site risks 53 Escape facilities 54 First aid 54 Iformatio, istructio ad traiig 54 Audit ad review 55 Audit 55 Reviewig performace 56 Refereces ad further readig 57 Refereces 57 Further readig 61 Relevat legislatio 61 Glossary 63 Further iformatio 65 Chemical warehousig Page 3 of 65

4 Health ad Safety Itroductio 1 This guidace book sets out cotrol measures aimed at elimiatig or reducig risks to people, at work or otherwise, from the storage of packaged dagerous goods. 2 This fourth editio of Chemical warehousig reflects chages to legislatio ad ew sectios have bee added to reflect chages to idustry practice ad what chemicals warehouses store. 3 The guidace reflects good practice for the desig of ew storage facilities. It is accepted that it may be iappropriate or impractical to adopt all recommedatios i existig premises. However, the law requires you to make ay improvemets that are reasoably practicable, takig ito accout the risks at the premises ad the cost ad feasibility of the additioal precautios. 4 This guidace is specific to the storage of packaged dagerous substaces. However, there are other legal health ad safety requiremets that you should meet, icludig: the Maagemet of Health ad Safety at Work Regulatios 1999 (as ameded); the Health ad Safety at Work etc Act 1974; ad the Workplace (Health, Safety ad Welfare) Regulatios 1992 (as ameded); so it should be used i cojuctio with other material published by the Health ad Safety (HSE) ad the eviromet agecies, icludig Maagig cotractors: A guide for employers HSG159, 1 Storage & hadlig of drums & itermediate bulk cotaiers PPG26, 2 Gettig Your Site Right: Idustrial ad Commercial Pollutio Prevetio, 3 ad Warehousig ad storage: A guide to health ad safety HSG If your chemical warehouse site falls uder the requiremets of the Cotrol of Major Accidet Hazards Regulatios 1999 (as ameded) (COMAH), you may eed to provide supplemetary measures to cotrol the risks that are listed withi this publicatio to achieve a level of risk that is as low as reasoably practicable (ALARP). For further guidace o the COMAH Regulatios, refer to A guide to the Cotrol of Major Accidet Hazards Regulatios 1999 (as ameded) L Where warehouses are storig large ivetories of dagerous substaces, eg flammable liquids, it may be ecessary to read this book i cojuctio with other guidace such as The storage of flammable liquids i cotaiers HSG51. 6 Who is this guidace for? 6 This book is aimed at ayoe who has resposibility for the storage of dagerous substaces, regardless of the size of storage facility, as well as ispectors resposible for eforcig health ad safety legislatio withi them. This guidace is aimed at elimiatig or reducig risks to people from this type of work activity. There may also be risks to the eviromet from these activities but they are outside the scope of this guidace. Advice o risks to the eviromet should be sought from the Eviromet Agecy i Eglad ad Wales, the Scottish Eviromet Protectio Agecy (SEPA) i Scotlad, or the Norther Irelad Eviromet Agecy i Norther Irelad. These agecies are referred to collectively as the eviromet agecies throughout this book. 7 This guidace provides advice for operators of storage sites for packaged dagerous substaces. It applies to trasit or distributio warehouses, ope-air storage compouds ad facilities associated with a chemical productio site or Chemical warehousig Page 4 of 65

5 Health ad Safety ed-user. It is limited to the requiremets for safe storage further HSE guidace is available o other topics. No chemical processig activities should be udertake withi a warehouse eviromet to esure there is o icreased risk to people workig withi. Objectives 8 The objectives of this publicatio are to: help you assess ad reduce the risks associated with the storage of packaged dagerous substaces; icrease awareess of the potetial hazards associated with the storage of packaged dagerous substaces; advise o safe maagemet procedures ad precautios to reduce ijuries ad damage caused by icidets ivolvig the storage of packaged dagerous substaces. Risks to health are also importat but this documet does ot cover them i detail; give guidace o the appropriate stadards for the desig ad costructio of storage areas ad buildigs used for storig packaged dagerous substaces at ambiet temperature ad pressure; ad advise o the eed for appropriate precautios, maiteace, traiig ad good housekeepig where packaged dagerous substaces are stored. Legal requiremets 9 There are two types of health ad safety law: those that make specific requiremets detailig what you should do to comply with them ad those that make geeral requiremets, such as the Health ad Safety at Work etc Act HSE publishes guidace to help you to uderstad what you have to do to comply with health ad safety law. You ca fid more iformatio o the HSE website: Relevat legislatio 10 Paragraphs list some of the health ad safety legislatio relevat to the storage of packaged dagerous substaces. Carriage of Dagerous Goods ad Use of Trasportable Pressure Equipmet Regulatios These Regulatios are commoly referred to as the Carriage Regulatios. They act as oe cosolidated piece of legislatio replacig the previous rage of regulatios ad aim to protect everyoe directly ivolved i the carriage of dagerous goods (such as cosigors or carriers) or who may become idirectly ivolved (such as members of the emergecy services ad public). They are eforced by HSE, the Office of Rail Regulatio, the Vehicle ad Operator Services Agecy ad the police. Chemicals (Hazard Iformatio ad Packagig for Supply) Regulatios 2002 (as ameded) (CHIP) 12 These Regulatios, commoly referred to as CHIP, cotai requiremets for the supply of chemicals. They require suppliers of chemicals to: Chemical warehousig Page 5 of 65

6 Health ad Safety classify them accordig to their hazards; give iformatio about the hazards to the people they supply, both i the form of labels ad material safety data sheets (MSDSs); ad package the chemicals safely. 13 Classifyig chemicals accordig to CHIP requires kowledge of physical ad chemical properties, ad of the health ad evirometal effects. 14 As a result of the 2008 CHIP Amedmet Regulatios, chemical suppliers may eed to take accout of ay large quatities of ewly reclassified chemicals they have stored o site at ay oe time to esure that they comply with the Cotrol of Major Accidet Hazards Regulatios 1999 (as ameded). Europea Regulatio o classificatio, labellig ad packagig (CLP) 15 The Globally Harmoised System of Classificatio ad Labellig of Chemicals (GHS) is a Uited Natios system to idetify hazardous chemicals ad to iform users about these hazards through stadard symbols ad phrases o the packagig labels ad through material safety data sheets. These ew regulatios alig existig EU legislatio to the GHS. 16 The CLP regulatios etered ito force o 20 Jauary They replace the curret rules o classificatio, labellig ad packagig of substaces (Directive 67/548/EEC) ad preparatios (Directive 1999/45/EC) after a trasitioal period. The deadlie for substace classificatio accordig to the ew rules will be 1 December 2010 ad for mixtures 1 Jue Cotrol of Pesticides Regulatios 1986 (as ameded) 17 These Regulatios, made uder the Food ad Evirometal Protectio Act 1985, require pesticides to be approved before they may be sold, supplied, used, advertised or stored. I additio, sites storig more tha 200 kg, 200 litres or a similar mixed quatity of a pesticide approved for agricultural use should be uder the cotrol of a perso holdig a recogised certificate of competece. Cotrol of Major Accidet Hazards Regulatios 1999 (as ameded) (COMAH) 18 The COMAH Regulatios implemet Coucil Directive 96/82/EC, kow as the Seveso II Directive, as ameded by Directive 2003/105/EC (Cotrol of Major Accidet Hazards (Amedmet) Regulatios 2005) ad replaced the Cotrol of Idustrial Major Accidet Hazards Regulatios 1984 (CIMAH). The aim of these Regulatios is to prevet major accidets ivolvig dagerous substaces ad limit the cosequeces to people ad the eviromet of ay which do occur. 19 The COMAH Regulatios require dutyholders to itroduce cotrols o establishmets where dagerous substaces are preset above certai quatities. These cotrols may be to a much higher stadard tha is ormally cosidered adequate or good practice. The requiremets placed upo the dutyholder vary depedig o the ivetory of dagerous substaces o site (kow as top tier ad lower tier ). The requiremets are sigificatly icreased for top-tier sites. These Regulatios apply to establishmets rather tha idividual activities. 20 The COMAH Regulatios are joitly eforced by HSE ad the eviromet agecies actig as the Competet Authority. Cotrol of Substaces Hazardous to Health Regulatios 2002 (as ameded) (COSHH) 21 COSHH requires that employers cotrol exposure to hazardous substaces to prevet ill health. Employers should protect employees ad others who may be exposed to these substaces i the form i which they occur i the work activity. Substaces are classified as hazardous uder CHIP. Chemical warehousig Page 6 of 65

7 Health ad Safety Dagerous Substaces (Notificatio ad Markig of Sites) Regulatios The purpose of these Regulatios is to help the Fire ad Rescue Service by esurig the provisio of advace ad o-site iformatio o sites cotaiig large quatities of dagerous substaces. 23 The Regulatios apply to sites cotaiig total quatities of 25 toes or more of dagerous substaces. They require suitable sigs to be erected at access poits ad at ay locatios specified by a ispector, ad otificatio to the appropriate fire ad eforcig authorities of the presece of ay dagerous substace. Notificatio ad markig of sites. The Dagerous Substaces (Notificatio ad Markig of Sites) Regulatios Guidace o Regulatios HSR29 7 gives further guidace. Dagerous Substaces ad Explosive Atmospheres Regulatios 2002 (DSEAR) 24 The DSEAR Regulatios eact the ATEX User Directive (1999/92/EC) ad implemet the Chemical Agets Directive. The Regulatios aim to protect the safety of workers ad others who may be at risk from dagerous substaces that ca cause fire, explosio or ay other similar eergy-releasig evets. 25 The Regulatios require employers to carry out a suitable risk assessmet for work activities ivolvig dagerous substaces, the elimiate or reduce the risks ad if ecessary carry out a hazardous area classificatio exercise. Further guidace is available i the DSEAR ACOP series Electricity at Work Regulatios These Regulatios impose requiremets for electrical systems ad equipmet, icludig work activities o or ear electrical equipmet. They also require electrical equipmet that is exposed to ay flammable or explosive substace, icludig flammable dusts, liquids or vapours, to be costructed or protected so as to prevet dager. 27 Further guidace is available i Memoradum of guidace o the Electricity at Work Regulatios 1989 HSR Equipmet ad Protective Systems Iteded for Use i Potetially Explosive Atmospheres Regulatios 1996 (as ameded) (the EPS Regulatios) 28 The EPS Regulatios eact the ATEX Equipmet Directive (94/9/EC) kow as ATEX 95. These Regulatios are aimed at maufacturers ad suppliers. They apply to equipmet, protective systems, safety devices, cotrollig devices, regulatig devices ad compoets for use i potetially explosive atmospheres. They require that the equipmet is safe, that it meets essetial health ad safety requiremets, has udergoe a appropriate coformity assessmet ad is affixed with CE markig. Fire (Scotlad) Act I Scotlad, this Act ad its various amedmets implemeted the same provisios as the Regulatory Reform (Fire Safety) Order did i Eglad ad Wales (see paragraph 39). Health ad Safety at Work etc Act This Act is cocered with the health, safety ad welfare of people at work ad with protectig those who are ot at work (members of the public etc) from risks to their health ad safety arisig from work activities. The geeral duties i sectios 2 4 ad 6 8 of this Act apply to all work activities that are the subject of this guidace book. 31 The Act is eforced either by HSE or by local authorities as determied by the Health ad Safety (Eforcig Authority) Regulatios Storage operatios are eforced by local authorities uless the mai busiess is the storage of dagerous goods, i which case HSE is the eforcig authority. Chemical warehousig Page 7 of 65

8 Health ad Safety Health ad Safety (Safety Sigs ad Sigals) Regulatios These Regulatios brig ito force the EC Safety Sigs Directive (92/58/EEC) o the provisio ad use of safety sigs at work. They cover various meas of commuicatig health ad safety iformatio. They require employers to provide specific safety sigs wheever there is a risk that has ot bee avoided or cotrolled by other meas, eg by egieerig cotrols ad safe systems of work. The Regulatios apply to all places ad activities where people are employed. However, they exclude sigs ad labels used i coectio with the supply of substaces, products ad equipmet or the trasport of dagerous goods. Maagemet of Health ad Safety at Work Regulatios 1999 (as ameded) (the Maagemet Regulatios) 33 The Maagemet Regulatios require employers ad the self-employed to assess the risks to employees ad others who may be affected by their work activities, so that they ca decide what measures eed to be take to comply with health ad safety law. 34 The Regulatios go o to require you to implemet appropriate arragemets for maagig health ad safety, health surveillace (where appropriate), emergecy plaig, ad the provisio of health ad safety iformatio ad traiig. A Approved Code of Practice L21 14 gives guidace o these regulatios. Notificatio of Istallatios Hadlig Hazardous Substaces Regulatios 1982 (NIHHS) 35 These Regulatios require premises with specified quatities of particular substaces to be otified to the local authority. Followig the Plaig (Cotrol of Major-Accidet Hazards) Regulatios 1999 ad the Plaig (Hazardous Substaces) Act 1990 ad Regulatios 1992, the presece of NIHHS Schedule 1 substaces ad quatities, together with some from COMAH Schedule 1, o, over or uder lad requires coset from hazardous substaces authorities. Plaig (Cotrol of Major-Accidet Hazards) Regulatios These Regulatios eact the lad use plaig cotrols as required i the Seveso II Directive (96/82/EC). They are eforced by local authorities withi the UK. 37 The Regulatios state that where dutyholders have a ivetory of a dagerous substace that exceeds a miimum quatity, they are required to apply for hazardous substaces coset. Oce coset has bee grated, the lad use plaig laws are triggered ad the ivetory of chemicals o the site will be cosidered for plaig applicatios i the viciity. Provisio ad Use of Work Equipmet Regulatios These Regulatios aim to esure the provisio of safe work equipmet ad its safe use. They iclude geeral duties coverig the selectio of suitable equipmet, maiteace, iformatio, istructios ad traiig. They also address the eed for equipmet to cotrol selected hazards. They require employers to esure that people usig work equipmet are ot exposed to hazards arisig from its use. Regulatory Reform (Fire Safety) Order This legislatio, which came ito force i Eglad ad Wales i October 2006, replaces the Fire Precautios Act 1971 ad the Fire Precautios (Workplace) Regulatios 1997 (as ameded) ad revokes the Fire Certificate (Special Premises) Regulatios The Order eshries the priciple of a resposible perso esurig that a fire risk assessmet is carried out ad fire safety duties are complied with. 40 The Order applies to all persos at work plus all persos lawfully o the premises ad those ot o the premises but i its viciity who may be affected by a fire o the premises. Chemical warehousig Page 8 of 65

9 Health ad Safety Regulators 41 The Health ad Safety (Eforcig Authority) Regulatios 1998 defie which regulator eforces a workplace. Warehouses are eforced by HSE or the local authority depedet upo use, except those that are subject to the COMAH Regulatios, where eforcemet is by the Competet Authority (see paragraphs 18 20). Hazard idetificatio ad risk assessmet Hazards 42 A umber of hazards may be created whe storig packaged dagerous substaces. These hazards may affect people workig withi the storage site, the emergecy services i the evet of a icidet, the geeral public off site ad the eviromet. 43 I a warehouse, fire is geerally cosidered to be the greatest hazard. This is because may people ca be exposed to dagers such as radiated heat, missiles, harmful smoke ad fumes. There will also be other hazards withi your storage area that you should cosider. I rare cases, certai stored substaces ca udergo violet decompositio whe egulfed i flame, ad a explosio ca result. 44 Commo causes of icidets are: lack of awareess of the properties of the dagerous substaces; operator error, due to lack of traiig ad other huma factors; iappropriate storage coditios with respect to the hazards of the substaces; iadequate desig, istallatio or maiteace of buildigs ad equipmet; exposure to heat from a earby fire or other heat source; poor cotrol of igitio sources, icludig smokig ad smokig materials, hot work, electrical equipmet etc; ad horseplay, vadalism ad arso. Hazard classificatio 45 Packaged dagerous goods have their ow well-defied hazards, ofte detailed o the material safety data sheet (MSDS), ad a specified safe method of storage. Sectio 15 of the MSDS summarises all relevat hazardous iformatio about a product i terms of the CHIP labellig requiremets. However, certai types of packaged dagerous substaces may give rise to additioal hazards withi a warehouse. These differet types of dagerous substaces should therefore be assessed whe cosiderig a risk cotrol strategy to esure there is sufficiet segregatio etc. Iteractio betwee differet dagerous substaces may create additioal hazards. 46 Dagerous substaces should be received ito a chemical warehouse by a competet perso who uderstads all the risks that they pose ad ca decide o where to store them ad how to segregate them, havig regard to their physical ad chemical properties, the quatities cocered ad the sizes of the packages. 47 Most dagerous substaces arrivig o site will be marked with the carriage labellig or markig system laid out i the Carriage Regulatios. These Regulatios Chemical warehousig Page 9 of 65

10 Health ad Safety refer to the system set out withi the ADR 15 regulatory regime. This is based o a global classificatio system, is widely uderstood i idustry ad is simple to operate. Most chemical warehouses use this system to classify dagerous substaces, although it does ot meet the requiremets of DSEAR. However, may dagerous goods, such as aerosols, are trasported i limited quatity packages ad will ot be marked with the carriage labellig system, but with the limited quatity mark. This will ormally cosist of the Uited Natios (UN) umber, or umbers, (idetifyig the type of dagerous goods) withi a framed diamod ad preceded by the letters UN. This is show i black o a white backgroud. Where multiple umbers are required these may optioally be replaced by the letters LQ. Examples of limited quatity marks are show i Figure 1. UN 1950 UN 1133 UN 1950 UN 1263 LQ Figure 1 Examples of limited quatity marks 48 From 2009 a ew Excepted Quatities package is beig itroduced. This is for very small quatities i special packages. These will be marked as show i Figure There is also a secod hazard classificatio system i operatio, kow as CHIP, that is based o iformatio for supply of the dagerous substace. The classificatio tests are comparable to those for carriage, but are ot the same as they serve a differet purpose. A substace may have differet hazard idicators for carriage ad supply. I these cases the competet perso should cosider both hazard classificatio categories. I geeral, if a substace is withi its outer packagig ad this has a carriage label the the carriage system should be used. If the substace is removed from the outer packagig the the CHIP labellig should be used. The itroductio of the classificatio, labellig ad packagig regulatios should make ay differeces betwee the two systems obsolete. COMAH ad COSHH use the CHIP hazard classificatio system. This system does ot ecessarily meet the more specific requiremets of DSEAR. * = positio for Class or Divisio ** = place for ame of cosigee or cosigor (if ot show elsewhere o package) Figure 2 Markig for Excepted Quatities packages Chemical warehousig Page 10 of 65

11 Health ad Safety 50 The CHIP system geerally uses black o orage yellow dager symbols, with associated sigal words as show i Table If goods are i trasit, betwee activities o site, or iteded for dispatch at a later time, the competet perso should collect relevat iformatio from withi the compay to determie the hazard classificatio to allow a storage locatio to be idetified. 52 The hazard classificatio categories are give i paragraphs ad Table 2. Note that Class 1 (explosives), Class 6.2 (ifectious substaces) ad Class 7 (radioactive substaces) are ot cosidered i this book. Table 1 CHIP classificatio system Used with idicatio of dager statemet(s) EXPLOSIVE (E) VERY TOXIC (T+) or TOXIC (T) or [Noe] HARMFUL (X) or IRRITANT (Xi) CORROSIVE (C) DANGEROUS FOR THE ENVIRONMENT EXTREMELY FLAMMABLE or HIGHLY FLAMMABLE OXIDISING Type of hazards covered Explosive ad pyrotechic products Acutely toxic chemicals Carcioges, mutages ad toxic by reproductio (ot ormally dagerous for carriage) Chemicals with a harmful effect (may ot be dagerous for trasport). Also used for ihalatio sesitisers No-corrosive chemicals which may cause iflammatio. Also used for ski sesitisers Chemicals which may destroy livig tissue o cotact Chemicals that may preset a immediate or delayed dager to oe or more evirometal compartmets Liquid substaces with very low flashpoit ad boilig poit, ad flammable gases Chemicals which may become hot ad catch fire OR solids which may readily catch fire after brief cotact with a igitio source OR liquid chemicals with flashpoit below 21 C OR which whe wet give off flammable gas i dagerous quatities Chemicals which give rise to highly exothermic reactio i cotact with other combustible substaces Chemicals that have a flashpoit betwee 21 C ad 55 C are idetified merely by the presece of risk phrase R10 Flammable. Chemical warehousig Page 11 of 65

12 Health ad Safety Class 2: Gases, compressed, liquefied, or dissolved uder pressure Figure 3 Labellig for Class 2 53 I additio to the labellig required uder the various regulatios (the Carriage Regulatios, CHIP ad DSEAR), cyliders are ofte colour-coded to provide idicatio of their cotets. Europea stadard BS EN : relates to the colour-codig of trasportable gas cyliders. 54 Mior leaks from cyliders of compressed gases may disperse more readily if the cyliders are stored i the ope air. Cyliders of liquefied gases should be stored i a upright positio so that ay leaks from valves etc will be of vapour or gas rather tha liquid. Cyliders kept i a upright positio should be secured to prevet topplig. 55 Most types of cylider will explode if exposed to itese heat, causig a risk of impact to people i the viciity eve if the cylider cotets are o-hazardous. Acetylee cyliders i particular are liable to explode without warig durig or for some time after exposure to heat, because of the self-decompositio of the product. They may also explode if dropped or struck forcibly. 56 Where flammable, toxic or asphyxiat gas cyliders are stored i buildigs, good vetilatio is essetial to esure that mior leaks will disperse safely. Whe cosiderig storage locatios ad determiig vetilatio desig criteria, your assessmet will eed to cosider whether the gases cocered are heavier or lighter tha air. Class 3: Flammable liquids 3 Figure 4 Labellig for Class 3 57 Uder the Carriage Regulatios, liquids are classified as flammable if they have a flashpoit below 60 C. However, diesel, gas oil ad heatig oil (light) (UN 1202) are classified as flammable up to a flashpoit of 100 C. 58 This defiitio of flammable liquid icludes all liquids classified as flammable, highly flammable ad extremely flammable for supply accordig to CHIP. 59 Flammable liquid fires ca grow rapidly oce the itegrity of the cotaier is breached ad the fire will spread quickly whe escapig liquid flows from the stored material. If the fire comes ito cotact with other flammable or oxidisig materials, it will sigificatly icrease i size ad it will be more difficult to brig uder cotrol. Sealed cotaiers may explode if exposed to itese heat. Depedig o groud coditios at the time, liquids may travel some distace while a leak remais udetected. Chemical warehousig Page 12 of 65

13 Health ad Safety 60 Precautios to be take iclude storig flammable liquids i a cool, dry place away from sources of igitio ad heat, ad i securely closed cotaiers specifically desiged for the purpose. It is preferable for the store to be i the ope air, but i all cases adequate vetilatio at high ad low level will be eeded to disperse ay vapours from leakig cotaiers. You should also cosider meas of cotrollig spillage see The storage of flammable liquids i cotaiers HSG51. 6 Class 4 61 This class cotais materials with a variety of hazards ad physical properties. Some are low meltig poit solids, or solids which are kept uder a protective layer of iert liquid or gas. The types of substace icluded are described briefly i paragraphs 63 68, uder the three recogised divisios of the class. 62 You should obtai advice o each particular type of substace from the supplier. This eeds to iclude iformatio about ay special coditios required for safe storage, eg temperature limitatios, or sesitivity to impact, frictio, impurities or water. Class 4.1: Flammable solids 4 Figure 5 Labellig for Class These are readily combustible solids that ca be igited by brief cotact with a source of igitio, or are sesitive to frictio, ad that will cotiue to bur after removal of the source of igitio. Examples are matches, firelighters, itrocellulose ad sulphur. 64 Self-reactive substaces are icluded i this divisio. These may decompose with the evolutio of heat ad fumes at moderate temperatures. Examples iclude various azo compouds such as AZDN. 65 Also icluded i this divisio are desesitised explosives. These cotai sufficiet water, solvet or plasticiser to suppress their explosive properties. Care should be take to esure that water or solvet-wetted explosives are ot able to dry out through iappropriate storage coditios. Examples of desesitised explosives iclude picric acid ad urea itrate. Class 4.2: Self-reactive ad related substaces 4 Figure 6 Labellig for Class Pyrophoric (spotaeously combustible) substaces have packagig that is desiged to exclude air. If air eters a damaged package the substace may start to bur at room temperature or whe getly heated. Examples iclude yellow phosphorus ad some metal alkyls. Chemical warehousig Page 13 of 65

14 Health ad Safety 67 Oxidative self-heatig substaces may react with the air, raisig the temperature to the poit at which spotaeous combustio takes place. This is ormally a slow process, which ca be cotrolled by restrictig the pack size, limitig storage duratio, moitorig temperatures or excludig air. Examples iclude some types of carbo dust ad oily atural products. Class 4.3: Substaces dagerous whe wet 4 Figure 7 Labellig for Class These substaces react with water ad evolve flammable gases. Fire ivolvig or i the viciity of such materials should obviously ot be tackled with water. Examples iclude calcium carbide, metal hydrides, powders of reactive metals such as magesium or alumiium, ad the alkali metals such as sodium. Class 5: Oxidisig substaces ad orgaic peroxides 69 These are substaces which, although they may ot i themselves be combustible, ca help other materials to bur rapidly eve if air is excluded. Whe heated i a fire, may of these substaces decompose ad give off oxyge, which ca icrease the rate of burig with possible catastrophic cosequeces. It should be oted that orgaic peroxides do bur, ofte explosively see paragraphs There have bee a small umber of icidets where relatively large packaged quatities of these materials, such as ammoium itrate ad sodium chlorate, have bee ivolved i violet explosios whe egulfed i fire. Guidace o the maximum stack size for ammoium itrate is provided i Storig ad hadlig ammoium itrate 17 ad for sodium chlorate i Storage ad use of sodium chlorate ad other similar strog oxidats CS3. 18 Class 5.1: Oxidisig substaces 5.1 Figure 8 Labellig for Class Most substaces classified as oxidisig are extremely reactive. They may be solids or liquids. They eed to be stored away from flammable materials, so prevetig ay cotamiatio or ay possibility of them becomig ivolved i a fire. They may be stored with other similar strog oxidisig agets, provided they are compatible. Chemical warehousig Page 14 of 65

15 Health ad Safety Class 5.2: Orgaic peroxides 5.2 ORGANIC PEROXIDE Figure 9 Labellig for Class 5.2 Old label (acceptable util ed of 2010) 72 Orgaic peroxides are a particularly reactive type of oxidisig substace. They may be solids, liquids or pastes, ad have oe or more of the followig properties: liable to explosive decompositio; bur rapidly ad itesely eve i the absece of oxyge; sesitive to impact or frictio; react dagerously with other substaces; decompose at comparatively low temperatures; ad/or cause spotaeous igitio if spilt oto combustible material. 73 Some orgaic peroxides may eed to be marked with a subsidiary explosio risk label. Orgaic peroxides eed to be stored separately from flammable, corrosive ad toxic materials. Advice is give i The storage ad hadlig of orgaic peroxides CS Specific advice ad iformatio o particular orgaic peroxides ca be obtaied from the material safety data sheets or the supplier. Class 6: Toxic substaces 6 Figure 10 Labellig for Class 6 74 The mai risk from toxic substaces durig storage is failure of cotaimet. Appropriate pre-plaig ca miimise the cosequeces of isolated puctured drums or burst packages. 75 However, i the evet of fire, such protectio is likely to be compromised by the failure of may cotaiers due to the effects of flame ad heat. As well as posig a immediate threat to aybody i the viciity, eg firefighters, the toxic substace ca also be spread large distaces i the plume of smoke or it may be washed ito watercourses by firefightig operatios. 76 The precautios ecessary to cotrol these risks deped o the quatities of toxic substaces ivolved, their degree of toxicity ad their persistece i the eviromet. 77 Toxic substaces vary widely i the hazards they create. Durig storage, the mai hazard is from acute exposure due to loss of cotaimet, rather tha from the chroic effects that arise from low-level log-term exposure. Ay labellig uder the Carriage Regulatios will give basic advice o the primary hazards ad precautios, but material safety data sheets will eed to be cosulted for more detailed iformatio. Chemical warehousig Page 15 of 65

16 Health ad Safety Class 8: Corrosive substaces 8 Figure 11 Labellig for Class 8 78 Dagerous substaces may be classified as corrosive because they bur the ski or otherwise harm ayoe comig ito cotact with them. May corrosive substaces will also react with icompatible or usuitable packagig or metals, eg storage rackig or process plat. Leakig corrosive substaces may damage the packagig of other dagerous substaces, creatig further leaks. Do ot assume that differet corrosive substaces ca be safely stored together. I may cases they ca react with oe aother ad may give rise to greater hazards tha the idividual substaces. Read the available safety data to determie which substaces ca be stored together. Class 9: Miscellaeous dagerous substaces 9 Figure 12 Labellig for Class 9 79 This class icludes such diverse substaces as asbestos ad those that are dagerous to the eviromet (eg PCBs), lithium batteries, ad air bag iflators. You eed to cosider the specific characteristics of ay material i this class before acceptig it for storage. 80 The above classificatios ca be used to assist i segregatig dagerous substaces see Table 2. Segregatio is oe of the most importat risk-cotrol measures i storage. Risk assessmet 81 DSEAR ad the Maagemet Regulatios require employers to assess the risks to workers (ad others who may be affected by their work or busiess) which may arise because of the presece of dagerous substaces withi the workplace. 82 I completig the assessmet, employers should cosider the hazards arisig from their work activity ad the risks to employees (or others) ad take steps to cotrol these risks. 83 This book details issues you eed to cosider whe udertakig your risk assessmet ad helps you idetify cotrol measures to implemet cocerig the storage of dagerous substaces. Chemical warehousig Page 16 of 65

17 Health ad Safety How to carry out a risk assessmet 84 Risk assessmet ca be broke dow ito five steps: Step 1 Idetify the hazards Step 2 Decide who might be harmed ad how Step 3 Evaluate the risks ad decide o precautios Step 4 Record your fidigs ad implemet them Step 5 Review your assessmet ad update if ecessary 85 For more iformatio o risk assessmet see Five steps to risk assessmet 20 ad the DSEAR 12 or Maagemet Regulatios 14 Approved Codes of Practice ad Regulatios. 86 The hierarchy of cotrol is discussed i paragraphs ad the preferred optios for cotrollig the risks preseted by dagerous substaces listed. Factors to cosider whe udertakig a risk assessmet 87 Whe assessig risks from dagerous substaces, there are a umber of factors you should cosider. These are specified i regulatio 5(2) of DSEAR ad iclude: the hazardous properties of the dagerous substace(s); safety iformatio provided by the supplier of the dagerous substace, icludig iformatio cotaied i ay relevat safety data sheet; the circumstaces of the work, eg the amout of dagerous substaces ivolved i storage ad trasport activities; particular activities which may preset a high level of risk such as maiteace or movemet of trasport; the effect of ay measures already i place or take as a result of DSEAR; the likely presece of explosive atmospheres ad the eed for hazardous area classificatio; the likelihood that igitio sources, icludig electrostatic discharges, will be preset; the scale of the aticipated effects of a fire or a explosio; ay places which are or ca be coected via opeigs to places i which explosive atmospheres may occur; ad ay other iformatio you may eed to complete the risk assessmet. 88 Employers should regularly review their risk assessmets ad revise them as sigificat chages arise. Such chages would iclude the quatity or ature of substaces o site, or chages to maagemet or work equipmet. 89 Employers who employ five or more people are required, by the Maagemet Regulatios, to record the sigificat fidigs of their risk assessmet. However, it is good practice to record your fidigs i ay case as soo as practicable ad make them available to all relevat employees ad regulators. 90 Employers should ivolve their employees or represetatives or both i the risk assessmet process. They will ofte be i a good positio to help idetify what happes i practice durig a work activity. 91 It is recommeded that the meas adopted to cotrol risks from the storage of dagerous packaged substaces be writte ito the compay safety policy. A periodic review of these matters should be carried out, particularly if storage coditios chage. 92 Further guidace o these factors is available i the DSEAR Approved Code of Practice L Chemical warehousig Page 17 of 65

18 Health ad Safety Elimiatio or reductio of risks Itroductio to the hierarchy of cotrol 93 Sectio 2 of the Health ad Safety at Work etc Act 1974 imposes a geeral duty o employers to esure, so far as is reasoably practicable, the health, safety ad welfare of all their employees. Sectio 3 of the Act imposes similar duties o employers towards those ot employed by them but who may be affected by their activities. 94 The term so far as is reasoably practicable has bee iterpreted by the courts as allowig cost, as well as time or trouble, to be take ito accout as factors to be set agaist the risk. Reasoably practicable meas that you have to take actio to cotrol health ad safety risks i your workplace, except where the cost (i terms of time ad effort as well as moey) of doig so is grossly disproportioate to the reductio i the risk. 95 DSEAR expads o this ad describes a hierarchy of cotrol measures i relatio to dagerous substaces ad explosive atmospheres. This sets out the priority give to risk cotrol measures ad the order i which employers should cosider them. 96 Regulatio 6(1) of DSEAR requires employers to esure that risks to employees (ad others who may be at risk) are elimiated or reduced so far as is reasoably practicable. 97 Regulatios 6(2) of DSEAR requires that preferece be first give to substitutig the dagerous substace with a differet oe, or substitutig a ew or modified work process to elimiate or reduce the risk. Where risks caot be completely elimiated by substitutio, regulatio 6(3) requires employers to use a combiatio of cotrol ad mitigatio measures to esure the safety of employees ad others. 98 The order i which risk cotrol measures should be cosidered the hierarchy of cotrol is therefore: elimiatio; substitutio; cotrol; ad mitigatio. 99 I a chemical warehouse it may ot always be practicable to elimiate or substitute the materials beig stored, although it may be possible with substaces used as part of the storage operatio, such as cleaig materials. Where risks caot be completely averted through elimiatio or substitutio, a employer should use a combiatio of cotrol ad mitigatio measures to esure safety. If the correct storage coditios caot be met for particular dagerous substaces, the they should ot be permitted o the site. 100 Examples of types of cotrol ad mitigatio measures employers may wish to cosider withi the chemical warehousig eviromet are further explaied i paragraphs Operators of chemical storage sites that fall withi the scope of COMAH are required to take all measures ecessary to prevet major accidets ad limit their cosequeces to people ad the eviromet. The priciples of the hierarchy of cotrol may be used to demostrate that this has bee achieved. Chemical warehousig Page 18 of 65

19 Health ad Safety Cotrol measures 102 The measures discussed here are desiged to cotrol the risks from the storage of packaged dagerous substaces. Employers should cosider these optios as part of the risk assessmet required by the Maagemet Regulatios ad DSEAR. Whe assessig the risks they will eed to cosider whether the existig cotrol measures are adequate ad suitable. Similarly they should cosider what measures eed to be icluded i the desig of ay ew istallatio. Risk maagemet 103 At all sites where packaged dagerous substaces are to be stored, the maagemet eed to cosider the risks created ad the meas adopted to cotrol such risks. The storage of multi-hazard goods together is a high-risk activity demadig high-level maagemet cosideratios. 104 It is recommeded that idividual risk maagemet policies be developed for all warehouses or other premises used to store packaged dagerous substaces. The degree of detail i these policies is clearly depedet o various factors, for example: quatities stored; specific hazards of the materials; ad locatio of warehouse(s). 105 A seior member of staff should be directly resposible for safe warehousig operatios. Safety maagemet eeds to be a key resposibility of the positio. It is importat that this perso should be resposible for the idetificatio, assessmet, hadlig ad storage of all the dagerous goods held o site. Clearly this perso (or people) eeds to be competet to do the job, ad should be adequately traied ad have sufficiet kowledge. 106 Writte operatig procedures eed to be developed coverig matters such as selectig storage locatios, dealig with spillages, ad security arragemets etc. Liaiso with the eforcig authorities ad the emergecy services may be appropriate. Remember that arragemets will be eeded for the cotrol of visitors or cotractors. 107 If the quatity of dagerous substaces o site exceeds the qualifyig ivetory for COMAH, the you are required, amog other thigs, to iform the Competet Authority. Operators of COMAH sites are required to take all measures ecessary to prevet major accidets based o the priciple of reducig risk to ALARP. Further guidace may be foud i A guide to the Cotrol of Major Accidet Hazards Regulatios 1999 (as ameded) L Receipt of goods 108 Employers should make sure they kow what materials are beig received ito the warehouse before they arrive o site. Whe materials arrive the cosigmet paperwork should be checked as well as the actual material beig delivered ad the itegrity of the goods ad packagig, eg check for leaks. 109 Ay substaces arrivig o site that caot be idetified, or where other problems exist, should ot be set ito the storage area. You should have procedures i place for hadlig such substaces ad cotactig the supplier for help. You may eed to store the material i a remote place while this procedure is udertake. If a satisfactory respose from the supplier is ot received the material should be removed from site. All staff should be traied ad familiar with these procedures. Chemical warehousig Page 19 of 65

20 Health ad Safety Figure 13 A goods receipt area 110 With the exceptio of those trasported i limited quatities, dagerous goods should arrive with either carriage labellig as described i paragraph 47 or supply labellig as described i paragraph 49. The former will be the simplest guide to how the goods should be stored but the latter may also be used as a guide. 111 Substaces that have bee trasported should comply with the Carriage Regulatios. Materials that have come ito the coutry from the EU will be labelled usig the ADR scheme, 15 which uses the same classificatio system as the Carriage Regulatios. ADR is a Europea system, so goods eterig the chemical warehouse may be marked i this way. 112 However, the specific rules of the Carriage Regulatios oly require the outer cotaier of packaged goods to be marked up accordig to this classificatio system. For packaged goods, the iteral packages will ormally be marked usig the CHIP Regulatios, uless beig imported from outside the EU i which case they will have to be re-labelled to the CHIP system upo receipt. CHIP requires that: the hazard of the substace has bee classified; the substace is suitably labelled with specific risk ad safety phrases, ad packaged accordigly; ad iformatio, i the form of a material safety data sheet, is available. Although a material safety data sheet is oly required to be available to the ed user, i practice it could be used by a itermediary to iform storage coditios. 113 Duties uder COSHH ad COMAH are based o the classificatio system arisig from CHIP, so this should be take ito accout whe udertakig COSHH assessmets or determiig whether the COMAH Regulatios apply. Sometimes packages arrivig oto site will be marked usig a combied labellig system for both CHIP ad the Carriage Regulatios. Separatio ad segregatio of dagerous goods 114 Before goods arrive o site they should be assessed as part of a receipt procedure to determie the hazards they pose. From this a decisio ca be made as to where they should be stored withi the chemical warehouse i accordace with local segregatio policies. Icompatible materials should where practicable be Chemical warehousig Page 20 of 65

21 Health ad Safety Figure 14 Chemical drum store segregated i the receptio area, eve if they were delivered together, ad moved to the storage area as soo as possible. Where ecessary iterim storage areas should be assiged. 115 Your segregatio policy should cover the potetial for igitio or escalatio of a icidet. Ofte it is ot the dagerous substace that is the first material to be igited i a fire; i may cases it is other materials, such as discarded packagig, pallets or rubbish, igited by a discarded cigarette or a spark from poorly cotrolled hot work. Such materials should be removed from the warehouse or placed i a suitable separate compartmet. Pallets outside the warehouse should ot be stacked agaist the wall uless it is fire-resistig. Similarly, dagerous substaces iappropriately stored withi geeral storage ca sigificatly icrease the severity of a fire. This the icreases the dagers to o-site persoel, the emergecy services ad people off-site, as well as to the eviromet. Areas should be clearly marked to show the types of substaces that ca be stored i them. 116 The itesity of a fire, or its rate of growth, may be icreased if icompatible materials are stored together. For example, oxidisig agets will greatly icrease the severity of a flammable liquid fire, or the storage of packaged free-flowig flammable powder, especially stored at height, ca icrease the fire spread if the packagig fails. Furthermore, a fire may grow ad ivolve dagerous substaces which, i themselves, are ot combustible. I this way, toxic materials ca be widely dispersed i the smoke plume or carried i the firefightig water, leadig to potetial cosequeces off site to people or the eviromet or both. To avoid such escalatio dagerous substaces should be stored i dedicated warehouses or suitable compartmets of warehouses. 117 Your segregatio policy should be used to prevet such escalatio. If you store a large rage of multi-hazard stock, it may ot be feasible to assess each substace idividually ad store it accordigly. The various classificatio ad labellig systems described earlier ca be used to greatly simplify the assessmet. Chemical warehousig Page 21 of 65

22 Health ad Safety Figure 15 Storage of packaged dagerous goods i rackig 118 Where a substace is likely to degrade durig storage, you will eed to cosult the suppliers cocerig the possible hazardous effects of such degradatio. Ask them to provide you with: the remedial actios to be take; the recommeded storage coditios; maximum storage times; ad ispectio frequecies. 119 Table 2 gives recommedatios for the segregatio of dagerous substaces accordig to their hazard classificatio. It uses the classificatio system described withi the Carriage Regulatios. This system is globally recogised, relatively simple to operate ad well uderstood by idustry. It uses ie classes ad where a material has more tha oe classificatio there is a agreed hierarchy to determie the most appropriate classificatio. The table excludes Class 1 (explosives), Class 6.2 (ifectious substaces) ad Class 7 (radioactive substaces). 120 The segregatio advice set out i Table 2 does ot take accout of chemical icompatibilities. I some cases, differet substaces that are show as compatible i the table may react together. You should also cosult the material safety data sheets ad other available sources for reactivity data to determie whether it is safe to store them together. This particularly applies to may corrosive substaces i Class 8, which may react together to produce heat or toxic gases. Examples are: acids/hypochlorites geerate chlorie gas; acids/cyaides geerate hydroge cyaide gas; acids/alkalis geerate heat; ad acids/sulphides geerate hydroge sulphide. Chemical warehousig Page 22 of 65

23 Health ad Safety Table 2 Geeral recommedatios for the separatio or segregatio of differet classes of dagerous substaces Chemical warehousig Page 23 of 65

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