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ANGLO FATAL RISK GUIDELINE
HAZARDOUS MATERIALS MANAGEMENT
HAZARDOUS MATERIALS MANAGEMENT GUIDELINE AA_AFRG_00000300.doc APPROVED 13 August 2008 Page 1 of 55
This document is intended for Company use only. Reproduction for external use is allowed only under specific authorisation. Anglo American assumes no responsibility for the content and/or the implications of its use by third parties.
CONTENTS
PAGE
1 2 3 3.1 4 5 5.1 5.2 5.3
SCOPE OBJECTIVE APPLICATION DEFINITIONS RECOMMENDED APPROACH REQUIREMENTS OF THE STANDARD PLANT AND EQUIPMENT REQUIREMENTS SYSTEM AND PROCEDURAL REQUIREMENTS PEOPLE REQUIREMENTS
3 3 3 4 7 8 9 28 50 55 55
REFERENCES RECORD OF AMENDMENTS
SCOPE
This guideline refers to the implementation of the Anglo Fatal Risk Standard: Hazardous Materials and should be read in conjunction with that Standard. The guidelines contained in this document are considered as "highly recommended" and deviations are to be documented and justified. Full adherence to these guidelines will not be a factor in determining compliance with the Standards, since alternative methods can be available if justified on a risk basis. In case of conflict with requirements of any other Anglo document or guideline, the following hierarchy will apply: 1. 2. 3. Anglo Safety Way Anglo Fatal Risk Standards Anglo Fatal Risk Guidelines ASW AFRS AFRG
It is important that when implementing Standards the organisation takes cognizance of, and comply with the relevant legal requirements in the country of application.
OBJECTIVE
The purpose of this Guideline is to provide guidance and clarity to assist in implementing the requirements of the Hazardous Materials Fatal Risk Standard. This guideline has been developed to provide more detail and clarification for the implementation of the requirements of the Standard. This should enable sites to be more aligned with each other on what the boundaries are with regards to meeting the requirements. This guideline is by no means exhaustive and will be updated periodically and supported by good practice sharing. It is not intended as a template for achieving compliance.
APPLICATION
Pertinent section in the standard: This Standard applies to all Anglo American Group managed businesses and operations, including contractors and visitors when involved in controlled activities. Controlled Activities or Controlled Sites are those where the Anglo American Group Company has the authority to determine how to manage the operation. It does not include monitored or uncontrolled activities. Monitored Activities are those where Anglo American can exercise some influence but cannot set Policies and/or comprehensive Control Standards and/or directly supervise and enforce their application (i.e. contractor and supplier transporting their goods and/or personnel to or from controlled sites). Uncontrolled Activities are those where Anglo American does not set or influence Policies or Control Standards and does not supervise safety performance. These include services provided by public Companies, activities performed at supplier or manufacturer shops, etc.
Where there is uncertainty over whether the activity is controlled, monitored or uncontrolled, the matter should be referred to the Safety function for determination.
3.1
DEFINITIONS
HAZOP : A HAZard and OPerability study is a useful tool in evaluating any inherent hazards or operational problems. The technique enforces a structured, systematic examination of complex process facilities. A (HAZard IDentification) is high level hazard identification that typically addresses the overall project, not only the process equipment. A Material Safety Data Sheet (MSDS) is a document that contains information on the potential health effects of exposure to chemicals, or other potentially dangerous substances, and on safe working procedures when handling chemical products. Each MSDS must contain a minimum of sixteen sections, as prescribed by international standards. This is a code system developed to provide immediate action advice when dealing with a chemical incident. Chemicals are assigned a code e.g. 3Y on the basis of the hazard that they represent and the required emergency response. Major Hazard Installation that holds a quantity of a hazardous substance which may pose a risk that could fatally affect the health and safety of employees and the public.
HAZID MSDS
: :
HAZCHEM
MHI
Hazardous Material Pertinent Section in the Standard: This Standard applies to hazardous materials in Major Hazard Installations (MHI) that, in one or more of their forms (solid, liquid or gas), have the potential to lead to harm to people, the environment or community (all stakeholders), either in an incident involving loss of control or in normal, controlled activities (e.g. storage, handling, production, transport, recycling and disposal). Where hazardous materials, processes or facilities do not qualify as Major Hazard Installations, some requirements of this Standard may not be practicable. In these cases, a risk-based approach shall be used to determine the level of compliance required. This Standard does not cover handling of explosives or radioactive materials, for which specific procedures shall be in place. A hazardous material is a substance or mixture of substances having properties capable of producing adverse effects on the health or safety of a human. Included are substances that are carcinogens, toxic, irritants, corrosives, sensitizers, asphyxiants and agents which may damage the lungs, skin, eyes, mucus membranes or substances which are subject to the release of large amounts of energy such as explosive gases. Hazardous materials are present at most Anglo sites in activities such as storage, warehousing, processing, distribution, transportation, cleaning, maintenance and waste recycling and disposal. The risk associated with hazardous materials is normally associated with uncontrolled loss of containment or mishandling and they are typically controlled through a Hazardous Materials Register.
Note: for the purpose of Anglos initiative bulk fuels including bulk petrol, diesel and oils and particularly used engine oils are included along with potentially hazardous waste materials. Hazardous materials can present different physical states such as solid, liquid, mists, vapours or gases, pure reagent or mixtures and have the potential to harm human health through the following properties: Nature of Hazard Flammable/ explosive Toxic Corrosive Irritating/ allergenic Sensitising Carcinogenic (cancer inducing) Mutagenic (likely to induce genetic damage) Teratogenic (likely to induce foetal damage) Asphyxiant
Hazardous materials may enter the human body in a number of ways depending on the material, its phase (i.e. solid, liquid or gas) and how it is used. The main routes of concern in industry are via inhalation and absorption. Inhalation is the most common route of entry as many toxic materials are present in an airborne form. Entry via the skin and eyes is through direct contact with a material. Ingestion is not a common route and predominantly occurs through poor hygiene practices. Mode of Assimilation Inhalation (i.e. breathing in the material) Ingestion (i.e. swallowing the material either directly or indirectly) Skin or mucus membrane absorption (i.e. directly or indirectly via contaminated clothing etc.) Injection (i.e. into the body by high pressure jet/hose, puncture by sharp object).
Note: it is worth considering the application of these requirements to materials which, although not hazardous for human health by themselves, may cause damage through indirect effects (i.e. use of gases that displace oxygen and may cause asphyxiation in a confined environment). Exposure Level The level of exposure depends upon various factors including how the material is handled, how much is used and the existing controls such as ventilation and personal protective equipment (PPE). Health effects may be acute, resulting from a short-term (usually high) exposure or chronic, resulting from long-term (often low level) exposure over a period of time. Chronic effects may not occur for many years, are hard to predict in advance and when they do occur it may be hard to identify what caused them.
Occupational health and safety laws in most countries require that the risks associated with Hazardous Materials are effectively controlled and the exposure to hazardous substances is kept below levels at which health effects are known to occur. These laws usually require workplaces to make sure potentially affected personnel know: What hazardous substances are being used; What effects they can have on health; and What has to be done to prevent or minimise exposure to them.
All sites must identify and comply with all relevant local legislation, standards, licenses, permits and other requirements in relation to hazardous materials as well as the requirements of the Hazardous Materials Management Standard. Major Hazard Installation (MHI) is a term used by South African legislation to classify those facilities handling hazardous materials that may represent a significant risk to people in or around the sites. Key considerations for classifying a facility as MHI are: "the Act" means the Occupational Health and Safety Act, 1993 (Act No. 85 of 1993) "major hazard installation" means an installation where any substance is produced, processed, used, handled or stored in such a form and quantity that it has the potential to cause a major incident; "major incident" means an occurrence of catastrophic proportions, resulting from the use of plant and machinery, or from activities at a workplace; "on site emergency plan" means the emergency plan to be followed inside the premises of the installation or part of the installation classified as a major hazard installation. "off site emergency plan" means the emergency plan to be followed outside the premises of the installation or part of the installation classified as a major hazard installation. "risk assessment" means a process of collecting, organising, analysing, interpreting, communicating and implementing information in order to identify the probable frequency, magnitude and nature of any major incident which could occur at a major hazard installation and the measures needed to be taken to remove, reduce or control potential causes of such incident
RECOMMENDED APPROACH
A high proportion of the elements in this standard including Major Hazard Installations are risk based and a standardised approach to risk assessment will be needed to ensure uniformity of application. It is recommended that Anglo Technical Division is consulted for advice on the current techniques of risk assessment where cognisance is taken of the value of both quantitative and qualitative approaches to risk management. To support the risk management approach referred to above a comprehensive document and revision control system is a pre-requisite and again AR/ATD may be consulted for advice in this area.
New Material
Supplier Information & MSDS Refer AFRS Implemetation Guideline for possible hazard types
Risk Assessment Procedures
Possible Hazard? No
Yes
Pending Assessmen t
Management Approval in Safety Document System Enter in Hazardous Material Register

Yes
Low Risk
Baseline Risk Assessment to Identify high risk materials
SHE Document, Standard Operating Proc edure, or Safe Work Practice Doc
PPE, Biological Monitoring, Buddy System etc Reject for us e
Yes
Residual Risk Acceptable?
No
Can the Material or Risk be: Eliminated? Substituted? Process redesigned? Separated? Reduc ed by Training etc?
High Risk
Notes: The application of the material in question must be considered in the environment in which it is to be used. It may therefore require a HAZOP- type RA to evaluate as part of the Baseline RA (the risks associated with the use of this specific material). Any change in the use of the material will have to be reassessed using the change management procedures. Non hazardous substances could become hazardous under certain conditions (e.g. water in contact with molten metals see relevant FRP). Protection systems e.g. gas dumping systems could result in control rooms becoming confined spaces. It is recommended that the users of HAZMAT adhere to the Responsible Care principle, which expects that companies take ownership for the entire life- cycle of hazardous materials.
Responsible Care is the chemical industrys global voluntary initiative under which companies, through their national associations, work together to continuously improve their health, safety and environmental performance, and to communicate with stakeholders about their products and processes. The Responsible Care ethic helps industry to operate safely, profitably and with due care for future generations, and was commended by UNEP as making a significant contribution to sustainable development at the World Summit on Sustainable Development in 2002.
REQUIREMENTS OF THE STANDARD

This section is structured using exactly the same numbering sequence as the Fatal Risk Standard document. Each requirement is repeated in a box, followed by a statement of intent. This is followed by discussion and clarification of that particular requirement. Detail has been added to some, but not all requirements, as some sections were deemed self explanatory. Definition for some of the terms used in these guidelines: ALARP CHAZOP ChemAlert : : : As low as reasonably practicable Computer HAZOP A Windows based chemical hazard management system to assist in the safe usage, handling and waste disposal of hazardous materials through the provision of Facility: Plant, equipment, buildings and civil infrastructure Failure Modes and Effects Analysis Fault Tree Analysis Hazard Identification Hazard and Operability Study Intermediate Bulk Container (a rigid or flexible portable packaging that is typically of a volume between 500 and 3000 litres) Material Safety Data Sheet National Fire Protection Association Process Hazard Analysis Piping and Instrumentation Diagram Personal Protective Equipment Pressure safety Valve
FMEA FTA HazID HAZOP IBC
: : : : :
MSDS NFPA PHA P&ID PPE PSV
: : : : : :
QRA SIL
: :
Quantitative Risk Assessment Safety Integrity Level
5.1
PLANT AND EQUIPMENT REQUIREMENTS

1. Process Risk Assessment The basis of design of a facility or process, whether permanent or temporary, which transports, produces, stores, uses or disposes of hazardous materials shall be reviewed (preferably with the vendor), amended as necessary and documented, utilising a process risk assessment tool such as HAZOP, HAZID, etc. As-built design drawings (e.g. process and instrumentation diagrams, process flow diagrams, layout drawings, isometrics, software upgrades, etc.) shall be updated as a result of these reviews. Process risk assessments should be carried out during all phases of a facility life. During the design phase the reviews should start as early as possible and use preliminary hazard analysis techniques. As the design progresses into execution more detailed techniques appropriate to the risk profile should be used. During the operating phase there should be regular reviews at frequencies required by local legislation or as consistent with the risk profile. During operation, process risk assessments should also be part of the management of change system for any modifications to plant and equipment. A variety of process hazard identification and risk assessment tools are available. Some methods are alternatives or are complementary to others. Advice should be sought where necessary to select the most appropriate tool. All methods involving hazard identification should be facilitated by someone competent in the technique and involves a review team selected to represent a wide range of disciplines including production, maintenance, technical and safety. The team should be provided with the necessary information on hazards of materials, process technology, design drawings, procedures, equipment data sheets, instrumentation control logic, incident experience, previous hazard reviews, etc. At the conclusion of the study a report should be issued with a set of recommended actions and queries concerning the design. The following is a brief overview of some of the more frequently used tools. Hazard Identification (HazID) HazID is the name sometimes given to the process of identifying credible hazards for a Quantitative Risk Assessment (QRA). There are a number of generic techniques that can be used including HAZOP, What-if/Checklist, and FMEA. Process Hazard Analysis Process Hazard Analysis is the application of one or more analytical techniques to identify and evaluate process hazards for the purpose of determining the adequacy of or need for control measures. Regulatory authorities in the US (OSHA and EPA) require a hazard analysis for all subject processes. Acceptable methodologies include What-if, Checklist, What-if/Checklist, HAZOP, FMEA and FTA or other appropriate equivalent methodology.
Hazard and Operability Study (HAZOP) HAZOP is a qualitative structured brainstorming technique that identifies the potential hazards and operating issues with the design of processes, plant and equipment and concentrates on how the design will cope with deviations from design conditions. HAZOP studies primarily use P&IDs and systematically question every part of the system being studied on a section by section basis. Deviations from the intent of the design, their causes and consequences are investigated. Deviations are identified using a checklist of standard guide words (pressure, temperature, flow, level, composition, maintainability etc), which also suggest deviations from normal operating conditions (high, low, reverse, etc). When hazard and operability issues are identified, risk assessment is required to determine if the hazards are credible and to recommend actions including design changes to address them. Those actions may be a result of the following resolution methods: Brainstorming: the options to eliminate or control (Terminate, Treat, Transfer of the risk in this order of preference) are to be considered. The effectiveness, cost and residual risk following the implementation of the proposed control measure is then weighed. Experience: individual or collective experience in the review team can identify the control because this situation and solution has been seen before; Codes of Practice: the control is dealt with through some applicable codes of practice, design standards or other industry standards or guidelines; or Hazard Analysis: either the level of risk is uncertain or the control(s) for the risk are not obvious and so further analysis is required (e.g. QRA).

Cost effective resolution by any of the first three methods is preferable to avoid the need for more time consuming qualitative or quantitative risk assessment (see later). The advantages of HAZOP are that it encourages creativity and new ideas and because it is a systematic method it tends to be more thorough and accurate. Limitations are that it assumes that the design has been carried out in accordance with appropriate engineering design codes. It can also be time consuming and success is significantly dependent upon the knowledge and experience of the team members and the capability of the leader. The process requires a trained facilitator, preferably with experience in the process evaluated. What-if/Checklist What-if/Checklist is a qualitative technique that is a combination of the creative brainstorming What If technique and the prescriptive Checklist technique. The purpose of the technique is to identify hazards, consider the types of incidents that can occur in a process or activity, evaluate in a qualitative manner the consequences and determine whether the existing controls are adequate. The study team leader and a sub team first formulate the initial what if questions to be used and also assemble the process specific checklists. The brainstorming technique is then used on subsections of the process guided by the set questions to identify possible deviations and weaknesses in design.
Questions such as: What if the pump stops? and What if the level sensor fails? are used to stimulate discussion. As the study progresses, any new what if questions that become apparent are examined. This is followed by one or more checklists which are used to trigger thoughts about situations that may have been overlooked. Checklists which are specific to the type of industry or process and are based on prior experience are available (references for checklists are provided in Lees: Loss Prevention in the Process Industries). If hazards are identified then recommendations are made as to additional controls to minimise or eliminate the risk (similar to HAZOP). The technique is relatively easy to use, quicker than HAZOP, and is a good mix of creativity and previous experience captured in checklists. Limitations are that it depends upon the knowledge and expertise of the team performing the analysis and on the right questions being asked. It is not particularly effective in identifying new or previously unrecognized hazards and focus can also be lost due to repetition of the checklists. Failure Modes and Effects Analysis (FMEA) FMEA is a qualitative analytical technique which identifies each failure mode, the sequence of events associated with failure and the consequences of failures or malfunctions of individual components (pressure relief devices, valves, switches, pressure vessels, pumps etc) in a system. The technique is oriented towards equipment rather than process parameters. Guidance on FMEA is given in BS 5760 Reliability of Systems, Equipment and Components, Part 5:1991 Guide to Failure Modes, Effects and Criticality Analysis (FMEA and FMECA). For the system that is to be studied questions are asked for each component such as: How can each component fail? What might cause these modes of failure? What would the effects be if the failure occurs? How serious are these failure modes? How is each failure mode detected?
The risk of each is assessed using a risk matrix. A report details the failure modes of components, including recommended risk reduction actions either to reduce the frequency of failure or mitigate the consequences of failure. The limitations of FMEA are that it focuses on single failures of equipment and it may not recognise multiple failures or multiple causes. It also does not focus on hazards caused by human error and can be a laborious and inefficient process unless judiciously applied. Consequently this is best done in combination with HAZOP.
Fault Tree Analysis (FTA) FTA is a predominately quantitative graphical technique that provides a systematic description of the combinations of possible hardware and human failures in a system which can result in an undesirable outcome. The outcomes with the highest risk such as fire, explosion and release of toxic materials are selected as the top event in the fault tree. Such events may have been identified as a result of previous hazard identification studies such as HAZOP, What-if/Checklist, or FMEA. A fault tree is then constructed top down by relating the sequence of events which individually or in combination could lead to the top event. The fault tree is constructed by deducing in turn the preconditions for the top event and then successively for the next levels of event, until the basic causes are identified. The fault tree is graphically developed using AND and OR gates. By ascribing probabilities to each event, the probability of the top event can be calculated. FTA is an effective technique for identifying failures that have the greatest influence on bringing about the top event. If the risk is unacceptable then in order to reduce the risk corrective action should be taken with emphasis on those branches of the tree that have the most effect on the top event. Actions may include adding safety devices, testing safety devices more frequently or improving the design and reliability of devices. FTA focuses on developing the logical links of failures that lead to the top event and is not that effective in identifying the hazards themselves. Preliminary Hazard Analysis Preliminary Hazard Analysis is a qualitative method used to identify hazards with a design in concept and/or pre-feasibility stages. Controls implemented at this early design stage are less costly and easier to implement than in later design stages. Usually this method is driven by a checklist and one method of application is to use hazard guidewords characterised by energy type (electrical, mechanical, chemical, kinetic, potential, pressure, thermal, fire/flammability, explosive, acoustic, biological, radiation, etc). Each process unit or area is then reviewed with these guidewords. Various aspects are reviewed including the effect of these hazards on people, equipment, product, environment, community etc. Hazards identified are treated in a similar way as with other HazID techniques. Preliminary Hazard Analysis is reliant upon the skills and experience of the people involved. Hazards are only assessed singly and the method does not evaluate the combined effect, nor is it a substitute for conforming to applicable design codes, standards and regulations and subsequent use of other techniques such as HAZOP. Variants of this methodology are Concept Hazard Analysis and Screening Level Risk Analysis (SLRA). Procedural HAZOP The procedural HAZOP is similar to HAZOP but is intended to identify specific HAZARDS around the procedures associated with the operation of the systems. It normally follows in the implementation stage once procedures are being developed. Examples of questions are: Not done/ step omitted Done too early/too late Too many repetitive tasks
Computer HAZOP (CHAZOP) This technique is similar to HAZOP but is intended to identify specific hazards associated with computer control systems of processes. CHAZOP is typically only done during the project design phase and if it is done it normally follows on after the project HAZOP. Like HAZOP this technique uses a systematic methodology with guidewords. As well as looking at the hardware design aspects of the system it also reviews the control logic with a question set to investigate control failures. Examples of questions are: Does the failure matter? Will the operator be aware of the failure? What should the operator do?
The input and output signals are each reviewed with guidewords such as: low, high, invariant, drifting and bad. Hazard Indices There are several hazard indices such as the Dow Index and Mond Index. These indices are not hazard identification tools but rather tools for risk ranking of hazards in a particular facility and comparative risk ranking to other similar facilities. Further information is available in Lees: Loss Prevention in the Process Industries. Qualitative and Quantitative Risk Assessment Depending on the site-specific requirements of the process hazard analysis and the hazards identified, the analysis of the risks associated with the hazard can vary from simple intuitive qualitative risk assessments conducted during the HazID, to formal qualitative risk assessments and ultimately to Quantitative Risk Assessment (QRA). QRA is a quantitative method of estimating the magnitude of risk. It provides a degree of objectivity and a facility for ranking risks. It does however involve some degree of subjectivity as it relies to a certain extent on past events and/or experience. QRA uses numerical values for consequences and likelihood using data from a variety of sources. Consequences are evaluated by various modelling techniques. Usually consequence modelling is done using specialist modelling software for evaluating the effects of: Flammable and toxic gas releases Fires (including jet, pool and building / warehouse fires) Explosions Products of combustion / fires including smoke and toxic gases.
Risks that cannot be eliminated should be documented in the sites risk register. Current drawings should be available for all process risk assessment reviews. Drawings which may be required are listed in requirement 18. Affected drawings should be updated at the conclusion of any design changes as a result of implementing engineering controls.
2.
Risk Assessment of Design Specifications All specifications for the location, design and/or modification of hazardous materials facilities shall be subjected to risk assessment that includes materials selection, site conditions, transport, production, storage, handling, use and disposal. Previous incidents shall be reviewed. The design of an entire facility as well as subsystems and individual items of plant and equipment is critical to effective elimination or minimisation of risks. An integral part of the design process for new or modified plant and equipment is the selection of appropriate design codes and standards. In some cases the application of these alone is sufficient; however, where necessary, designers should conduct hazard identification, risk assessment and identification of controls to achieve a design where the risk is ALARP. When conducting risk assessments, previous incidents in similar or related facilities should be reviewed to ensure that the learnings are incorporated. Process risk assessment methods as outlined in requirement 1 generally assume that the design has been carried out in accordance with appropriate engineering design codes and standards. Depending upon the types of hazardous materials involved and the complexity of the process, plant and equipment which handles the hazardous materials and the following aspects of design may also require risk assessment: Process selection (inherently safer design) Plant siting and plot plan layout Storage tanks design (segregation, containment etc) Separation distances Hazardous area classification Ignition sources Fire and explosion analysis Fire protection (passive and active equipment) Vapour cloud dispersion modelling Control building design and survivability to fire and explosion and toxic gas clouds Emergency response equipment Escape route and refuge area survivability Materials of construction selection Pressure equipment Materials handling systems (spillage, stoppage etc) Valves (leakage routes through glands and flanges) Rotating equipment (catastrophic failure, leak routes though glands and seals) Equipment reliability (FMEA) Control system reliability (Safety Integrity Level) Effluent and drain systems Flare and Blowdown systems Waste disposal
HAZARDOUS MATERIALS MANAGEMENT GUIDELINE
AA_AFRG_00000300.doc
APPROVED
13 August 2008
Page 14 of 55
3.
Manual handling of raw materials and products Maintainability (provision for access, decontamination, isolation, vessel entry) Positive isolation requirements (e.g. spool pieces required to all equipment that needs to be isolated. Provision for calibration without exposure to hazardous materials/conditions Provision for sampling of process streams without exposure to hazardous circumstances) Safeguarding and personal protection Human factors analysis (alarm management, mal-operation etc.) Commissioning, start-up and shutdown studies Transport systems including loading and unloading and offsite risks Risks that cannot be eliminated should be documented in the sites risk register.
Emergency Response Facilities All facilities which have a significant risk from hazardous substances shall provide a risk-based emergency response plan which includes: emergency response procedures appropriate to the hazardous materials and the risk emergency equipment/facilities (e.g. oxygen, antidotes, showers, etc.) on location where hazardous materials are stored or used means of escape in an emergency situation clearly marked emergency isolation valves emergency response teams appropriate to the risk appropriate use of safe refuge and assembly areas for people emergency response equipment for spillage containment, fires, explosions, burns, etc. appropriate response arrangements with external emergency services (e.g. ambulance, hospitals, fire brigade, medical personnel, etc.) impact minimisation including spill clean-up and dust suppression recovery procedures and disposal of the hazardous material.
This requirement covers the plant and equipment required for emergency response (the systems for emergency response are covered in requirement 24 and training in requirement 34). The plant and equipment may be fixed equipment such as fire pumps or portable equipment such as fire extinguishers. In many countries, emergency response equipment is specified by legislation, design standards and codes of practice for hazardous industries. The plant and equipment should also be identified as a result of design studies and/or risk assessment in order to be able to respond to credible emergency scenarios and can include: Designated emergency assembly areas and safe refuges Emergency escape and evacuation routes/role of access control Emergency sirens and warning systems Emergency alert equipment such as break glass alarms

Communication systems including both fixed such as public address and telephones and portable such as hand held radios Detection systems such as thermal, fire, smoke, flammable and toxic gas detectors Passive fire protection equipment such as blast walls and thermal insulation Fixed fire fighting equipment including fire water tanks, foam tanks, fire water pumps, fire water and foam monitors, fire hydrants, hoses, deluges and CO2 flooding systems Fire trucks and trailers equipped for both fires and hazardous material incidents Portable equipment including fire extinguishers, breathing apparatus, specific PPE for fires and hazardous materials Portable equipment for responding to spills such as absorbent material, oil containment and absorbent booms, neutralising chemicals and appropriate PPE Medical and first aid response equipment including medical response centres, first aid rooms, first aid kits and fire blankets Safety showers and eye washes Emergency response command centre including all the required contents of communication equipment, maps, manuals etc.

All fixed and portable equipment should be covered by a documented maintenance, inspection and test regime (see requirement 13) to ensure that its technical integrity is maintained. Such programs should also include the routine inspection and testing of emergency alarms, pumps, safety showers and eye washes and fire extinguishers. These systems are to be tested and trained as per section 34. 4. Vents and Drains Provisions shall be made for the safe venting, drainage and containment required during normal operations and in emergency situations, based on a process risk assessment tool such as HAZOP and HAZID. The location and design of vents and drains is normally specified during the design. It is not the intent of this requirement to supplant design standards and codes and good design practice however some points to note for the design and operation of systems which have caused incidents in the past are: Correct Location and configuration Vents and drains for maintenance and operating activities should be located at appropriate high points for vents and low points for drains. Where equipment items or sections of plant and equipment are anticipated to be taken out of service for maintenance (e.g. pumps, compressors, heat exchangers, tanks and vessels) then vents and drains should be appropriately located so that personnel do not have to crack flanges to achieve inventory removal especially of flammable and toxic materials.
The vents and drains should preferably be connected to closed systems (e.g. flare header or closed drain system) where the materials should not be released for health, safety or environmental reasons. Where this is not practical or required then they should be directed to a safe location where the discharge of material will not cause a health, safety or environmental hazard. Atmospheric vents should be discharged to a safe location to avoid sources of ignition for flammable vapours or to safely disperse toxic vapours. Drains should be directed to a safe location where the material can be contained such as inside a bund or into an effluent treatment system rather than uncontrolled discharge to the environment. Liquid hydrocarbons should not be discharged into an open sewer system or large standing pools of water because the hydrocarbon will float on top of any water and can travel significant distances and create a fire/explosion hazard at a distant location. Consideration should be given to segregation of waste streams of totally different composition at their source (e.g. acidic aqueous material from liquid hydrocarbons) so as to minimise the complexity of downstream waste disposal facilities. When not in use, vents and drains should be securely isolated to prevent fugitive leaks and unintended loss of containment. Leaks have occurred when valves have been left open, vibrated open or been accidentally knocked open. Two barriers of isolation should be used where vents and drains discharge into the open environment. The normal method is to have a blank (spade, slip plate, blind) fitted downstream of the vent/drain valve. Inherently Safe Valves used for inventory reduction as part of normal operation (e.g. periodic draining of water from the bottom of a hydrocarbon vessel or purging inert gases from an accumulator drum) should be designed for the frequent use and take account of the potential for human error. Many leaks have occurred when personnel have left open vents, drains and sample valves to purge the stream and then go away and do another task and subsequently return to find hazardous material flowing out. Consideration should be given to spring-loaded ball valves that have to be held open and will close automatically if left unattended. It is preferable for vents and drains, particularly in flammable and toxic material service, to have a primary valve closest to the process which is opened first and a secondary isolation valve that is used for controlling the flow of venting/draining. Thus if the secondary valve starts to leak the primary valve can be closed. Sample points for fluid streams are similar to these vents and drains in respect to the hazard of loss of containment and their design should follow recommended industry practice and use should be covered by standard operating procedures. Automatic valves and devices such as pressure relief valves, automatically controlled overpressure valves and automatic dump valves should all be carefully designed according to applicable design codes and standards and their design reviewed during process hazard analysis. Hazards can occur with these devices in operation when they become partially restricted or blocked with contaminants or inadvertently isolated by spades or valves. Modifications to process conditions, and associated plant and equipment that are protected by these devices should not be
undertaken without review using a management of change system (see requirement 15) to avoid creating hazards. Containment Containment refers to secondary containment as a back up to the primary containment of a storage tank, vessel, container or package. The purpose of all secondary containment systems is to limit the extent and spread of hazardous materials when there is a loss of containment from the primary containment. In most countries, the requirement for secondary containment is covered by legislation, standards and codes of practice which govern storage and handling of hazardous materials of various classes. Such legislation and codes of practice cover not only the design of the primary tanks, but also other aspects such as layout and separation from other storage and facilities, venting and relief, fire protection, safety equipment, signage, and also dictate when and how secondary containment is required. In the absence of any specific requirements Lees (Loss Prevention in the Process Industries, figures 22.20 22.22) provides some guidance in the form of decision trees for flammable, toxic and corrosive materials. Bunds (dike, berm) are one of the more common types of secondary containment. Bunds are normally designed to contain the entire volume (usually at least 110%) of a tank or of the largest tank in a combined storage area. The bund is usually made of concrete or earth lined with impervious material to prevent leakage. The separation distance and height of the bund walls must be designed taking account of crest locus limits. Bulk containers (e.g. IBCs, bulki bins); drums and small volume packages may also be subject to containment. Containment can be provided by fixed facilities or moveable bunds made out of an impermeable membrane. Care should be taken in warehouse and mixed storage areas to ensure that correct segregation is maintained (see requirement 23). Bunds are normally provided with drains to allow discharge of storm water. The drain valves should normally be closed. 5. Vessel and Tank Labelling Labelling shall be in place on all storage vessels, containers and tanks, as per appropriate national or international standards. This labelling shall clearly identify the carried or stored material. Supporting information (e.g. material safety data sheets [MSDS]) shall also be readily available at the point of use and storage to identify appropriate first aid/spill response procedures. The purpose of labelling of storage tanks, containers and packages is to ensure that the contents can be readily identified by product name and provide relevant information including hazards and precautions about the contents for normal operational use and for emergency response. In some countries there is also a requirement where some types of Hazardous Materials (e.g. Dangerous Goods) are stored in sufficient quantities that placarding is required. Placarding ensures that in event of fire, spillage or other incident involving such material that emergency response personnel have sufficient information to respond immediately and
effectively. Placards usually provide information on the class of material (see later) and guidance on how to manage emergency responses. Most countries have specific legislation which identifies types of hazardous materials (dangerous goods, hazardous substances, toxic substances etc) and is specific about the types of labelling and placarding, the size of labels and where they should be affixed at the entrances to facilities and to tanks, containers, packages, warehouses and transport by road and rail. Each site should identify all applicable legislation including any site specific permits and licences and comply with them (refer to Anglo Management Standard). Labels (or placards) may include: The product name UN number (which identifies the material according to a numbering system developed by the UN Committee of Experts on the Transport of Dangerous Goods) HAZCHEM Action Code (see later) Class of material (see later) Relevant health and safety information The word hazardous Telephone number to contact for specialist advice.

Labels should be firmly attached to the storage tank, container, package and be legible and durable. Labelling should be in a language that the workforce understands. Labels should be regularly checked and damaged or illegible labels should be replaced. Labels should also be revised when any of the details change. Materials which arrive at a site insufficiently labelled should be quarantined until the correct labels are affixed or should be returned to the supplier. Labelling also applies to hazardous materials that are decanted or transferred to other containers. A container into which a hazardous material has been decanted should also include as a minimum the product name on the container and preferably more detailed relevant information such as class labels. Under no circumstances should food or drink containers be used for decanting either for ongoing use or disposal. If a container is found with an unknown material that is suspected of being hazardous then a label such as Caution Do Not Use: Unknown Substance should be affixed and the container removed from the workplace until the contents are identified or disposed of. Some of the more common types of labels that are used in various countries are: Class labels Class labels are based on the international system detailed in the Model Regulations for the Transport of Dangerous Goods prepared by the United Nations Economic and Social Councils Committee of Experts on the Transport of Dangerous Goods .
The classes (excluding explosives) are: Class 2 - Gases
Class 3 - Flammable Liquids
Class 4 - Flammable Solids
Class 5 - Oxidising Substances and Organic Peroxides
Class 6 - Poisonous (toxic) and Infectious Substances
Class 7 Radioactive Substances Class 8 - Corrosives Class 9 - Miscellaneous Dangerous Goods HAZCHEM Emergency Action Code for Fire and Spillage The HAZCHEM code (also known as the Emergency Action Code) was developed by the United Kingdom Fire Service to provide emergency services personnel information on how to respond to fire and spill emergencies involving vehicles
transporting dangerous substances. The HAZCHEM Code system has been adopted in other countries not only for transport but also workplaces where such materials are kept. The HAZCHEM Code provides advice on: The type of medium to be used in combating an incident involving a material where there has been a loss of containment or fire The type of PPE to be worn by persons combating the incident Whether a violent reaction or explosion could occur Whether a spill should be contained or diluted, and If there is a hazard is to the local population.
The code consists of a number followed by one or more letters as shown in the table:
Notes for guidance: V BA FULL DILUTE CONTAIN WATER FOG DRY AGENT : : : : : : : Can be violently or even explosively reactive. Use breathing apparatus plus protective gloves. Use full body protective clothing with breathing apparatus. Wash to drain with large quantities of water. Prevent spillage from entering drains or watercourses. In the absence of fog equipment, a fine spray may be used. Water must not be allowed to come in contact with the substance at risk.
An example is Liquefied Petroleum Gas (LPG) which has a HAZCHEM Code of 2 W E. This means that in the event of a fire a water fog or fine spray should be used, full protective clothing with breathing apparatus should be used and evacuation of the surrounding area should be considered.
NFPA Hazardous Materials Identification System The system is primarily used in the USA and is based on a diamond shaped marking that is divided into 4 regions. Each region is assigned a colour and a numerical rating in each region. The regions depict health hazard, fire hazard, reactivity hazard and a region to indicate reactivity with water, or other specific hazards if water reactivity is not an issue. The format of the marking is as follows:
The degrees of hazard are ranked according to the potential severity of the exposure in a fire situation. Like the HAZCHEM Action Code the disadvantage of this system is that it does not address the hazard of day-to-day workplace exposure. An example is Liquefied Petroleum Gas (LPG) which has a NFPA Hazard Class of Health (blue) = 2; Flammability (red) = 4; and Reactivity (yellow) = 0.
Transport Placards Legislation in many countries requires road tankers carrying chemical products to carry a placard. The placard includes the HAZCHEM Code, the correct technical name of the substance being transported, hazard class label, UN number of the substance and telephone number for emergency advice. A generic example is shown below:
Standard Safety and PPE Signs Although not usually required by legislation, the use of PPE and other Safety signs that are in addition to the minimum PPE required on a site (i.e. safety helmet, safety glasses, safety shoes, etc) can be posted close to the location where hazardous materials are handled. Standard safety signs are used as an aid to: Communicate the need for PPE and the type to be used Communicate information on hazards Communicate the location of safety equipment/emergency facilities Provide guidance and instruction in an emergency.
There are two main types of safety signs referenced in Australian Standard 1319 1994: Safety Signs for the Occupational Environment. These are: Picture signs, which utilise text and symbols to represent the hazard, equipment or process as well as the standard colours and shapes used to convey a message (e.g. PPE signs) Signs with text only messages which are supplemented by the use of standard colours and shapes (e.g. Stop, Caution, Fire Exit, emergency contact phone number, etc. signs). Picture signs which are standard in the country of location should preferably be used.
6.
Pipe Labelling Piping containing hazardous substances shall be clearly marked so that the contents and direction of flow can be identified. Pipelines are an integral part of conveying hazardous materials in process plants; however it is almost impossible to determine the contents from the external appearance of the pipe. The purpose of providing a system for easy identification of contents and flow direction of piping systems which transport hazardous materials is: So that personnel who work in the vicinity are alerted as to the contents So that operating personnel can easily identify the relevant valves and other equipment So that isolations can be placed on correct pipe line systems for maintenance work So that information is provided to assist in response in the event of an incident involving the loss of containment To assist in the training of personnel who need to be able to identify specific systems required for operating or maintenance activities.
Marking may be achieved by a system of colour coding or by labels which can be painted on or affixed and which specify the contents and arrows to indicate the normal direction of flow. Marking should occur in such locations as adjacent to valves, tees, important line fittings, wall penetrations, road crossings, entries and exit nozzles to tanks, vessels, heat exchangers, pumps, compressors and other important plant and equipment items. On piping runs the marking should be typically at uniform separation distances specified in relevant standards. In addition to pipeline marking additional definition can also be provided by the inclusion of line designation numbers and valve numbers as shown on P&IDs. Refer to BS 1710 Identification of Pipelines and Services or AS1345: Identification of the Contents of Piping, Conduits and Ducts. Whichever system is used, affected personnel should be able to understand the meaning of the colour coding and/or labels and they must be maintained in a relatively clean state in order to be legible. 7. Security and Access Control Security and access control systems and hardware shall be in place, appropriate to the risk, to manage access to areas where hazardous materials are stored and used. Each site should review the hazardous materials on site and, depending upon the risks, install appropriate security hardware and/or security systems. Aspects that should be considered when determining what appropriate is include: The hazards and risks associated with the hazardous materials The likelihood of deliberate and unwanted access by unauthorised persons and vehicles to storage areas (e.g. for sabotage or theft) The likelihood of unintentional and unwanted access by unauthorised persons and vehicles to storage areas
The integrity of storage and handling systems to inadvertent operation causing loss of containment (e.g. even if someone was able to get to the storage and handling equipment could they cause a loss of containment by opening a valve) The integrity and reliability of security systems and hardware.
Examples of security hardware that should be considered are: Security fence and site access control to perimeter of the site Security fence or enclosure to the area where individual or collective hazardous materials are stored and/or used Locks on doors and other access routes to enclosed buildings and compounds Remotely monitored security cameras Bollards or other vehicle access control devices Signs prominently posted warning of the storage of hazardous materials and the need for appropriate authorisation before entry into an area.
See requirement 25 for security and access control systems. 8. Process Control Process control systems shall ensure that the potential for personnel to be exposed to hazardous materials is eliminated wherever possible, or reduced. Process control systems are a risk control designed to eliminate those activities where personnel are close to the contained materials and can be exposed to hazardous materials in the event of loss of containment. Process control achieves separation from the risk and should be applied both during new plant design and during ongoing risk reduction activities. Examples of activities which occur during the operating phases of start-up, normal operation, equipment changeover, planned shutdown, emergency shutdown and abnormal operating scenarios that should be reviewed include: 9. Process flow, temperature, pressure, level and composition adjustment through the manipulation of a valve or other device Charging feed to and discharging products from processes Sampling and analysis Routine venting and draining, purging and flushing.
Automatic Control Automatic plant control systems should be in place in hazardous material facilities to eliminate the need for operator intervention and to maintain operation within the required parameters. Such systems shall incorporate fail-to-safe systems in the event of emergencies. Where automatic control is not practicable, risk assessment shall be used to identify and implement operational options that reduce the risk. Automatic control is a generic term used in this protocol and refers to what is otherwise referred to as a trip system (also referred to as emergency shutdown system or ESD) and interlock system (also referred to as override system).
These systems are discrete control actions whereas process control in requirement 8 is continuous control action. Control systems (automated or manual) and associated critical equipment must be given sufficient design attention, appropriately risk assessed and supported by a rigorous maintenance regime and planned inspections. Trip and interlock systems are automatic protection systems designed to prevent situations where a hazardous condition could occur in a process. Trip systems shut down an entire process or part of a process or one function if a hazardous condition is detected. An interlock system is slightly different in that it prevents an operator or an automatic control sequence from following a hazardous sequence of control action. Trip and interlock systems and their components are normally classified as critical equipment and should be covered by appropriate maintenance inspection and test plans (see requirement 13). The identification of the hazardous situation may occur during the normal design process or could be revealed during HAZOP. The decision to install a trip or interlock can be a function of the project/facility design philosophy but also should be risk assessed during development of design specifications (see requirement 2). The hierarchy of controls should be used to determine whether it is better to use the redesign control and implement a trip/interlock or use the administrate control and depend upon personnel to follow procedures when hazardous situations occur. Trip systems can either be single loop (sensor to trip switch to trip valve) or multi loop (sensor to trip processor to switches to trip valves). The logic can be as simple as a single switch, a relay system, PLC or a complex computerised trip system. Examples of trip systems are: Single Loop: A benzene storage tank that receives benzene supply pumped from a rail tank car requires an automatic system to prevent overfilling of the tank. A high level switch can be installed on the tank that shuts an actuated valve in the benzene supply line. Multi Loop: A hydrocarbon gas processing plant has a lot of flanges and valves that can leak gas with the risk of fire and explosion and requires a system to shut down the plant and prevent ignition if this occurs. Strategically located gas detectors are installed that trigger when a certain level of gas is detected and automatically shut down the supply of gas into the plant and open blowdown valves to depressure the inventory safely to a flare system. Examples of interlock systems are: Instrumented: A road tanker which is filled with flammable fuel pumped from a storage tank via a loading hose system must have a secure electrical continuity system to prevent static electricity discharge (an ignition source) between the fixed loading equipment and the road tanker. An interlock system is built into the loading hose control system which requires connection of the earthing strap before the main isolation valve in the loading line can be opened to start loading.
Non-instrumented: A pressure vessel containing a hazardous gas is protected from overpressure by two pressure relief valves. The two valves are installed in parallel with one being a standby and manual isolation valves are provided to allow isolation of either valve to allow one of the pressure relief valves to be taken out of service. A manual interlock system is required to prevent isolation of both valves at the same time. A special sequential key system is provided which only allows the manual valves on one of the pressure relief valves to be isolated at any one time. Both trip and interlock systems (or parts of them) require bypassing (disarming, defeating) at various times such as for start-up, calibration and testing. A system should be in place to assess the risk of bypassing of these safety systems. Usually this is covered under an extension of a permit to work system. Both trip and interlock systems require periodic proof testing to ensure their reliability and capability. This is often referred to as Critical Function Testing (CFT) and should be part of a maintenance inspection and test program on a facility (see requirement 13). Frequency of proof testing should be determined by Safety Integrity Level studies. Standards for instrumented and electrical/programmable safety systems can be found in: 10. IEC 61508-1; Functional safety of electronic safety-related systems, and electrical/electronic/programmable
IEC 61511-1; Functional safety safety instrumented systems for the process industry sector.
Detection Devices Fixed detectors and personal detection devices shall be considered as options in the selection of potential risk reduction measures. Fixed devices are usually installed to detect the presence of flammable or toxic gases but can also include smoke, thermal, flame and other detection methods including visual. Their purpose should be clearly defined during design. Systems may either be primarily designed to detect fugitive leaks that can lead to adverse but non fatal health effects or detect major loss of containment which can lead to fatalities either directly (e.g. carbon monoxide gas cloud) or indirectly via fire and explosion of flammables. The justification for fixed devices should be the subject of careful analysis which evaluates the likely leak locations (e.g. flanges), the potential quantity of leaks and dispersion modelling of gas clouds all in relation to where personnel may be located. This may require risk assessment methods such as QRA (see requirement 1). Provision should be made for dealing with large loss of containment scenarios including emergency shut down and blow down of inventory, containment systems, shut down of heating and ventilation systems in habited confined work areas such as control rooms and provision of gas absorption facilities (e.g. activated carbon filtration). Emergency response plans should specifically have procedures for responding to such scenarios and not only include process actions to respond to the loss of containment but procedures for evacuation.
Fixed detection devices are normally classified as critical equipment and require maintenance, inspection and testing to ensure availability and calibration (see requirement 13). Personal detection devices are normally used for the fugitive leak scenarios and for other activities such as confined space entry and atmosphere testing for maintenance. The selection of the correct type for each relevant hazardous material should be done by qualified personnel such as occupational hygienists. When personal devices are used there should also be an atmospheric and/or health surveillance program depending upon the nature of the hazardous materials (see requirement 27). The provision of fixed or personal detection devices is not an alternative to prudent design and operation of a facility including but not limited to the correct design of pressure relief systems, vents and drains, suitable workplace ventilation, tightness testing of pressurised systems, correct gasket selection and flange tightening procedures.
5.2
SYSTEM AND PROCEDURAL REQUIREMENTS

11. Hierarchy of Controls Management of risk associated with hazardous materials shall be supported by a documented process that incorporates risk reduction using the Hierarchy of Controls, applied in the following order (a number of these options may be considered and applied individually, or in combination): ELIMINATE the complete elimination of the hazard; SUBSTITUTE replace the material or process with a less hazardous one; RE-DESIGN re-design the equipment or work processes; SEPARATE isolating the hazard by guarding or enclosing it; ADMINISTRATE provide controls such as training, procedures, etc. ; PERSONAL PROTECTIVE EQUIPMENT (PPE) use appropriate and properly fitted PPE where other controls are not practicable.
The hierarchy of controls should be embedded in risk based systems relevant to this protocol including: Risk assessment methodologies (requirements 1 and 2) Selection of detection devices (requirement 10) Risk assessment of hazardous materials on site (requirement 12) Introduction of new hazardous materials (requirement 14) Management of change (requirement 15) Permit to work system (requirement 22) Control of simultaneous operations (requirement 23) Emergency response procedures (requirement 24) Security and access control systems (requirement 25)
Examples of application of the hierarchy of controls to hazardous materials are: Eliminate: Where a process or task involves the use of a material that is not essential, the material or the process should be eliminated or the risk associated with the material or process eliminated if practicable. Examples include: Eliminate on site feedstock storage tank by a pipeline supply direct to the process Eliminate potential leak points at flanges by fully welded systems Eliminate the need for sampling by use of non invasive instruments.
Substitute: Using a safer material or process which includes exchanging the material for one that is less harmful, using the same material in a less hazardous form or using the same material in a less hazardous process. Examples include: Substitute a water-based solvent instead of a solvent based material Substitute acetic acid for acid cleaning instead of using hydrofluoric acid Substitute pellets instead of using dusty powders.
Redesign: Using machinery, equipment or processes which minimise workplace contamination by eliminating or reducing the generation of materials, suppressing or controlling the materials or limiting the area of contamination in the event of spills. Examples include: Install local exhaust ventilation to remove hazardous fumes Install containment and bunding systems to limit spread of spills Install automatic fire/smoke detectors and fire suppression systems.
Separate: Separating hazardous materials from the people through using them by distance or barriers. Examples include: Separate operators from hazardous fumes in an air-conditioned control room Use remote controls to operate a process Safe separation distance of hazardous material storage tanks from control rooms.
Administrate: Minimising the exposure through changing the work method and work practices. Examples include: Provision of standard operating procures for safe handling of hazardous materials Reducing the duration of exposure through job rotation Good housekeeping to remove workplace contamination.
Personal Protective Equipment: Wearing PPE should only be used to provide extra protection, or where other control measures are not practicable. PPE should not be depended upon to control risk because it relies upon personnel using it correctly.
12.
Risk Assessment A risk assessment process shall be in place for all hazardous materials to identify: the selection criteria and life cycle analysis for all hazardous materials the level of risk associated with the hazardous materials controls required to manage the risk the performance requirements (reliabilities and capacities) of specific equipment and systems included in these controls.
Risk assessment may be undertaken for hazardous materials either as a stand alone activity or part of a process wide risk assessment (see requirement 1). If the latter is the case then relevant hazardous material data in steps 2 4 below should be used. For risk assessments on new hazardous materials (see requirement 14), steps 4 -7 below can be used. A suggested step-wise risk assessment process is: Step 1: Assemble a team to carry out the risk assessment Risk assessment should preferably be undertaken by HSEC professionals and personnel who may be affected including supervisors, operators and maintainers and if necessary risk consultants or other personnel with subject knowledge (see requirement 30). Such involvement ensures that the risk assessment is based upon a thorough and practical understanding of what currently happens or will likely occur in new facilities. Step 2: Identify all hazardous materials stored, used, transported and disposed This should involve a site wide inspection to locate, identify and list all materials and the type of storage (i.e. tank, vessel, container and packages). Locations should include not only the normal storage and use areas but also workshops, laboratories, warehouses, laundry facilities, waste treatment facilities etc. Labels on containers, inventories, log sheets, purchasing records and existing registers of MSDSs can assist in data gathering. Step 3: Obtain Material Safety Data Sheets Contact the manufacturer or supplier of the materials to obtain the MSDS. Alternatively data bases such as ChemAlert may have the MSDS already registered on them. Step 4: Review Material Safety Data Sheets The four key aspects to be reviewed are: a) Inherent hazards and routes of exposure: Consider for flammable materials the potential for fire and explosion and for toxic materials which of the routes of inhalation, ingestion, absorption and/or injection may be relevant in the activities associated with the hazardous material.
b)
Form of the hazardous material Review the process conditions to determine the phase of the material (solid, liquid or gas) and what is its concentration and any impurities or mixture components. Consideration should be given also as to whether the material is a mist, fume or dust.
c)
Physical and chemical properties Determine properties such as the pH of liquids (corrosive to the skin and eyes), boiling point and vapour pressures (which can cause high airborne concentrations due to evaporation), the flammability limits and flash point of flammable materials (fire and explosion potential), and the nature and concentration of combustion products and odour.
d)
Health effects For each route of exposure consider the adverse health effects (i.e. toxic, harmful corrosive, irritating, sensitising, carcinogenic, mutagenic and teratogenic).
Step 5: Evaluate the nature of work involving Hazardous Materials Determine what tasks are carried out where there is a potential for exposure involving hazardous materials (see requirement 19 for critical activities). For each task this should include identifying who is or might be exposed, how they might be exposed and the nature of that exposure (i.e. quantity, frequency and duration), how the material is used, whether health effects are currently present and the effectiveness of control measures currently in place. Reviewing existing standard operating procedures may provide information and involvement of personnel who carry out the tasks is essential. Step 6: Assess the risk Determine the credible consequences and estimate the duration and frequency of exposure and the exposure level. Use incident reports and the results of atmospheric monitoring and health surveillance programs to help quantify consequences and frequency. It is also important to remember that risks may extend to personnel who have no direct involvement in the work activity by incidents involving fires and explosions and widely dispersed toxic releases. For some hazardous materials on a site the risk profile may be similar for some or all activities and so a generic risk assessment can be carried out rather than duplicating for each activity. Step 7: Identify Risk Controls Controls should be identified and implemented to manage the risk so that it is eliminated or reduced to levels so that after implementation they are ALARP. The hierarchy of controls should be used to determine appropriate controls (refer to requirement 11). The controls should be communicated to those personnel likely to be exposed via documentation such as standard operating procedures, job safety analyses, permit to work documentation, safety alerts and related training programs.
Step 8: Develop performance standards for critical controls Where critical controls (either critical equipment as identified in requirement 13 or critical activities as identified in requirement 19) are identified then performance standards (e.g. availability, reliability and capacity, survivability, functionality) should be identified. Performance should be routinely monitored and reported to measure the effectiveness of critical controls. At the conclusion of this step-wise process, the risk assessment should be documented. As a minimum the documentation should include: Date of the risk assessment and attendees Which hazardous materials were assessed and in what tasks or facility locations they were used (attach or refer to any JSAs or standard operating procedures) The controls already in place Relevant data such as previous incidents or results of workplace monitoring The result of the risk assessment (can graphically show on the HSEC Risk Matrix) Recommended additional controls and responsibility for implementation Attach copies of MSDS as a record of what revision was available at the time. The risk assessment should also be regularly reviewed during the life cycle and revised at a suggested interval of every five years or if significant changes have occurred, including: A new hazardous material is introduced to the site (see requirement 14) The process, plant or equipment is significantly modified (see requirement 15) New information on the hazardous nature of the material becomes available Health surveillance or atmospheric monitoring shows that controls are inadequate Incidents (actual or near miss) occur which indicate that controls are ineffective New or improved practicable control measures become available.

Another approach to risk assessment (steps 3 7) is through Control Banding. Control Banding is a qualitative or semi-quantitative approach to risk assessment that groups occupational risk control strategies into bands based on their level of rigor. The most fully developed Control Banding model comes from the UK Health and Safety Executive, and is known as COSHH Essentials (from Control of Substances Hazardous to Health regulations). The concept is that while there are many chemicals, there are only a few levels of risk management (control bands) available to control exposures to these chemicals. For guidance on this approach go to the web site: COSHH ESSENTIALS Risks that cannot be eliminated should be documented in the sites risk register.
13.
Critical Equipment Maintenance A system shall be in place to identify and document maintenance, inspection and testing schedules and procedures for critical equipment associated with hazardous materials. The identification of critical equipment is necessary to ensure that maintenance, inspection and testing is conducted on that equipment to maintain its technical integrity. A system should describe how critical equipment is identified and that equipment should then be documented in and controlled via a Critical Equipment Register. Once critical equipment is identified, appropriate maintenance, inspection and testing plans for the equipment should be developed and documented in a system (e.g. GSAP PM) taking into consideration: Outputs of risk assessment studies (e.g. FMEA, SIL and HAZOP) Statutory compliance requirements Historical information Manufacturers recommendations Equipment condition.
One method in which Critical Equipment can be identified is by using a process that examines the relationship between hazards, incident causes, consequences and control measures and uses information from risk assessments to determine the overall criticality of the control measure. It is summarised in the figure at right. Hierarchy of Controls: Elimination or prevention of hazards is a better than detection or mitigation of incidents. It is therefore more important that controls on the causal side of the bow tie diagram are functioning correctly than those on the consequential side. Worst Credible Consequences: Greater management attention is required for hazards that have the potential to lead to very severe consequences than for hazards with less severe consequences. The determination of criticality therefore has a bias towards hazards with the most severe consequences. Inherent Risk from Basic Hazards: Basic hazards that occur continuously or frequently require greater management attention than those that seldom or never occur. Also, causal paths along which hazards would travel quickly with little or no warning (e.g. static electricity) are inherently more hazardous than those characterised by slow progression from hazard to incident with obvious warning signs (e.g. corrosion). The assessment is biased towards basic hazards that occur continuously and those causal paths with little or no warning signs. Reliance on Controls to Reduce Risk: When a control measure is the dominant or only layer of protection in a causal path, it is essential that it is effective. Control measures that are common to many hazards may also have a greater impact on overall risk reduction than those that apply to only one hazard. The determination of criticality therefore considers how heavily each control measure is relied upon. The assessment is biased towards highly effective control measures and those that are most heavily relied upon.
14.
Introduction and Disposal of Hazardous Materials A system shall be in place to ensure that the introduction and disposal of hazardous materials, including containers, shall be approved by the site Hazardous Materials Co-ordinator (refer Element 29) prior to introduction or disposal. The system for the introduction of new hazardous materials to the workplace is required to ensure that the risks to health and safety of personnel and the environment have been assessed, are understood and minimised to ALARP and there is appropriate information available. The system should specifically require that new hazardous materials are not introduced into the workplace without the provision of a MSDS and approval by an authorised person. That person should preferably be the Hazardous Materials Coordinator. Documented systems for the introduction of new hazardous materials can be relatively complex with the interaction of various personnel and steps including the potential for acceptance/rejection and the use of forms and checklists. This system can be graphically represented in a flow chart, augmented by explanatory notes. The system should commence with a request form being filled out by the person wishing to introduce a new hazardous material. The application must be accompanied by a copy of the Suppliers MSDS. The form may have details of: Initiators name and date of application Hazardous material name and relevant classifications (dangerous good etc) Supplier details Intended purpose, location and method of use Whether it is for permanent introduction or a short term or trial use Anticipated package/container/tank size and storage location Maximum inventory and estimated usage rate.
A coarse risk assessment can be done based upon a checklist approach to determine some further basic information and may lead to immediate approval without the need for detailed risk assessment because the material is not hazardous or rejection because it is extremely hazardous. An appointed person with the necessary competency such as the Hazardous Material Coordinator or a person with HSEC responsibilities should then coordinate and perform the risk assessment. The review can either be done by a team (see Step 1 in requirement 12) or sequentially by individuals with key roles. The risk assessment can be done using steps 4 6 in requirement 12 above or using the web based method: COSHH ESSENTIALS The application may be accepted, rejected or sent back to the originator for further data. If the application is accepted then controls should be identified as in step 7 in requirement 12.
The application then requires final approval by the Hazardous Materials Coordinator and only then should the material be ordered. The approval should be documented on a form that includes the details of the controls. That form can also have a checklist of other related activities that should be completed before introduction such as: Supply of new PPE Update of the Hazardous Materials Register Update of Emergency Response Plan and associated procedures Supply of new emergency response equipment including for spill and clean up Update of permits and licences for the storage and handling of Hazardous Materials Update of standard operating procedures Update of air monitoring and health surveillance programs Update of maintenance inspection and test plans Update of training programs and training materials and training carried out Labelling and placarding Modification of plant and equipment for fire protection, bunding etc Logging the new MSDS onto data base (e.g. ChemAlert).
The results of the risk assessment, the controls and any other relevant information from this process should be communicated to potentially affected personnel. This may be through being documented such as in standard operating procedures, job safety analyses, permit to work documentation and safety alerts. Affected personnel include not only those who handle the material but also staff in supply receiving and warehousing functions. Once the new hazardous materials have been introduced, the system should include a provision for subsequent follow up to review the effectiveness of control measures. The application of this system to sites where there are large Contractor organisations can be problematic and liable to be bypassed. Where possible, Contractors should use products which have already been risk assessed and approved for use at sites. As an alternative Contractors can have in place their own Introduction of New Hazardous Materials systems that as a minimum, meet the requirements of the sites system including requirement for their employees to follow the identified controls. Contractors should maintain a hazardous materials register on site that includes MSDS for all hazardous materials they use. The Hazardous Substances Coordinator should periodically audit the Contractors system. A system should also be documented so that wastes generated at sites are correctly identified, safely stored, transported and disposed of and should include provision for: Responsibility: definition of system responsibility Regulatory requirements: clear understanding of legislation, permits and licences
15.
Waste minimisation: attempt to reduce, reuse and recycle before disposal Information: MSDS and other documents such as composition analyses available Classification: characterise and classify according to solid, liquid, level of hazard etc Containers: ensuring containers are fit for purpose and will not leak or degrade Labelling: identification of container contents with appropriate labels and placards Storage: housekeeping and security of on site waste storage Regulatory documentation: as required by regulatory agencies Transport accreditation: select approved transport contractors Receiving facility accreditation: select approved waste disposal facility Documentation: retaining records of all wastes transported from site.
Management of Change A system shall be in place for the management of change of equipment and/or processes for transportation, storage, handling, use and disposal of hazardous materials. The system shall include specific steps to assess the impact of changes on the risks associated with hazardous materials. A management of change system should be documented to define the methodology used for the initiation, risk assessment, checking, approval and implementation of change associated with processes, plant and equipment involving hazardous materials. The system should ensure that all required engineering checks are completed prior to implementing a modification, and that plant documentation is updated and training conducted prior to the use of a modification in operations. This requirement can be part of an overall management of change system that deals with change to all aspects at a site consistent with ASW. Change (or modification) should be defined and should include any temporary or permanent change or alteration in specification to the process, plant or equipment which could affect safety or the integrity in any foreseeable way. Such changes may be: A change to the existing piping and instrumentation of the plant A change in material of construction, size or shape of any component A change in the physical support of plant and equipment A repair which represents a departure from the existing engineering design An alteration to the process flow, temperature, pressure or composition A change to alarm, trip or interlock settings A change to control system logic, instrument configurations, sequence tables Any change in use or alteration in layout of the site, building, or roadways A change to the frequency of scheduled checks of safety related systems.
Prior to effecting the modification there should be a check list of actions that must be completed. Examples of such actions are: Is the implementation of change in accordance with the approved proposal? Are there any potential, previously overlooked, hazard or operability risks? Has the modified equipment been tested (e.g. hydro testing)? Have vessels, flanges, valves etc been leak tested? Have training and operation manuals been updated? Has a new or revised standard operating procedure been issued? Has sufficient training of affected personnel been completed? Have the requirements of relevant legislation, codes etc. been met? Is adequate personal protection, first aid and fire protection equipment available? Have all relevant drawings (P&IDs, electrical line diagrams etc) been updated? Has relevant technical integrity documentation such as pressure vessel and PSV registers, maintenance inspection and test programs been updated? Has risk management documentation such as risk registers been updated? Has the Emergency Response Plan been updated? Has the hazardous materials register been updated? Have all process risk assessment risk reduction controls been implemented? Is the modification approved for use?
The system should require an authorised person to confirm that all actions have been completed or a monitored action plan is in place to complete them and that the modification is safe to use. 16. Site Register A site register shall be in place for all hazardous materials and include the following: name HAZCHEM / United Nations code MSDS summary of maximum inventory storage requirements and precautions location and physical properties of the materials when they are in use inventory of special emergency items held for handling of spillages, fires, etc. (e.g. reagents to neutralise spillages and accidental releases, fire fighting foam, etc.) approved disposal methods.
A step-wise process should be used to develop the register. Step 1: Identify all Hazardous Materials stored, used, transported and disposed This should involve a site wide inspection to locate, identify and list all materials and the type of storage (i.e. tank, vessel, container and packages). Locations should include not only the normal storage and use areas but also workshops, laboratories, warehouses, laundry facilities, waste treatment facilities etc. Labels on containers, inventories, log sheets, purchasing records and existing registers of MSDSs can assist in data gathering. Step 2: Obtain Material Safety Data Sheets Contact the manufacturer or supplier of the materials to obtain the MSDS. Alternatively data bases such as ChemAlert may have the MSDS already registered on them. Step 3: Set up a Hazardous Materials Register The register is a list of all the hazardous materials at the site and as a minimum includes a copy of the MSDS for each of the materials. The MSDS for hazardous materials will contain a statement that the material is hazardous. The register can also include non hazardous materials (i.e. the register becomes a chemicals register). In this case the register should indicate which of the materials are hazardous (e.g. with H next to the product name). Note: ChemAlert can produce this register based on all MSDS entered for a site. A system should be in place to ensure that the register is maintained and when new materials are introduced to site or if unused materials are removed from site that the register is updated. At regular intervals a review should be conducted to ensure that all materials being used are listed on the register and MSDS are available and also an inspection of the site to check that the materials on site are in fact listed on the register which should be an approved document in terms of the site document control system. 17. Material Safety Data Sheets A system shall be in place to ensure that MSDS are available to all personnel (including emergency response, first-aid and medical personnel) involved in the transportation, storage, handling, use and disposal of hazardous materials on site. MSDSs should be checked to ensure they are legible, clearly laid out, less than 5 years old, in language used at site and conform to legal content requirements. MSDS content requirements vary depending upon country; however an international standard was published by the International Organization for Standardisation, Safety Data Sheet for Chemical Products - Part 1: Content and order of sections (ISO 11014-1), which defines: The general layout of an MSDS; The 16 headings with standardised wording; The numbering and order of these headings; and
The information items required to complete an MSDS.
Suppliers should be required to send an updated MSDS if changes are made. MSDS should be accessible to site personnel who could be exposed such as operators, maintainers, warehouse personnel, truck drivers, and emergency response crews and also external emergency response personnel such as fire fighters. MSDSs should be available near the location of the materials so that personnel have immediate access to them. This means either at the point of use (e.g. at a storage tank, loading/unloading point etc) or within a very short distance (e.g. an adjacent control room or warehouse). MSDS can be made available in either or both hard copy or electronic data base format. Where personnel rely solely on electronic format (e.g. ChemAlert) then they should be trained in accessing the data base and be able to print off a hard copy. 18. Design Documents A system shall be in place to ensure that all relevant design documents and drawings associated with this Standard are up to date, controlled and available. The system should ensure that design documents and drawings associated with hazardous materials management are controlled and that the latest revisions are available to all relevant personnel (e.g. supervisors, operators and maintainers). This requirement can be part of an overall site document control system for all documents consistent with HSEC Standard 10 requirements. Relevant documents and drawings may include: 19. Design basis and equipment specifications Original equipment manufacturer and vendor manuals Heat and Mass balances P&IDs Process Flow Diagrams Electrical line diagrams Instrument data sheets and loop schematics Cause and effect diagrams and alarm and trip setting schedules Piping isometrics Layout, civil and underground drawings Safety equipment drawings and layout plans.
Critical Activities Critical activities, which involve hazardous materials and have the potential for immediate or long-term harm, shall be identified and safe operating procedures shall be documented, including transportation, storage, handling, use and disposal of incompatible hazardous substances. The activities associated with start up, normal operation, shut down, abnormal situations and emergency shutdown (including response to loss of utilities such as power, instrument air, cooling water, relief and blowdown etc) should be reviewed to determine which are critical. Each site should determine what is defined as critical
APPROVED
13 August 2008
Page 39 of 55
activities, consistent with the criterion that activities are critical where a loss of containment could cause a fire, explosion or release of toxic material. A process analogous to that used for identifying critical equipment as described in requirement 13, can be used to identify critical activities. Critical activities should be documented in standard operating procedures which should: 20. Be prepared, checked and approved by technically competent personnel Be kept up to date and controlled Be readily available to personnel who are involved in performing those activities Include identification of the hazards and controls associated with the task Include information of applicable exposure standards and the PPE to be used.
Safe Operating Limits Safe operating limits for plant and equipment handling hazardous materials which have the potential for immediate or long-term harm, shall be clearly defined, documented and available to operations and maintenance personnel. Safe operating limits are the approved safe envelope of operation normally developed by designers of the plant and equipment. These limits are not to be confused with design limits (e.g. the design pressure of a pressure vessel) but are the safe limits to which the equipment can be operated to during normal operation. They are set to avoid loss of containment of hazardous materials through overfilling, overpressure, run-away reactions, corrosion/erosion and other such non intended operating modes. Examples are: Safe fill level of a storage tank Maximum operating pressure of a boiler steam drum Maximum operating temperature of a chemical reactor Maximum flow rate of a fluid in a pipe susceptible to erosion Minimum pH of a fluid in a metal subject to acidic corrosion.
Safe operating limits should be clearly defined and readily available to those personnel who have the ability to adjust and/or monitor those parameters. Methods that can be used to define these limits are: Marked on the side of equipment (e.g. safe fill level of a tank painted on the tank) Operating manuals Standard operating procedures P&IDs Alarm and trip schedules Log sheets (usually as a column indicating the maximum/minimum limit).
In some facilities where the design may not have been very well documented, the safe operating limits may not be known or documented. In this case, the first step
should be to identify all the critical plant and equipment (see requirement 13) which is used in the storage, handling, and production of hazardous materials (vessels, tanks etc). Safe operating limits may then be able to be collated for that equipment from a review of all available documentation such as design documentation, drawings, vendor operating and maintenance manuals, process risk assessment (as per requirement 1) and information sources such as site engineers and process and equipment vendors. If limited data or no data at all is available then it will be necessary to start from first principles. This can be done by determining for each equipment item whether a loss of containment is feasible (overfill, overpressure, corrosion, flange leak etc) and if it is feasible, would it result in immediate or long term harm to personnel. To assist in this, take account of the volume and conditions (phase, pressure, temperature, flow, concentration etc) that the material is stored or used at. Consider what would be the consequences of a loss of containment to personnel by using relevant MSDS to determine what happens when people come in contact via inhalation, absorption and ingestion exposure routes. Example: A 5000 litre tank of 48 wt% caustic soda is heated to 60 C and is filled from a road tanker. There is a high level overflow which discharges into a bunded area. If the tank was overfilled then it is possible that an operator could get splashed with significant quantity of hot caustic soda and result in immediate or long term harm - the safe fill level of the tank is thus a safe operating limit. 21. Monitoring and Handover Monitoring systems for hazardous materials shall be in place to ensure that the status of operation is understood and shown clearly at all times. These monitoring systems shall include the procedure for a documented hand-over to the next shift, recording any relevant information/changes in operating status. Monitoring includes the activities of surveillance and formal documentation in log sheets of observations of the status of plant and equipment handling hazardous materials. Control panel operators should at routine intervals review all the remote data available to them either on computerised screens or discrete panel gauges and instruments. Operators in the field should also conduct routine and thorough patrols of the relevant plant and equipment looking for leaks and other defects as well as gathering key operating information (pressures, temperatures, levels etc) from local instrumentation and gauges. The routine inspections should also check that hazardous materials are being used and stored as required by the risk assessments and that control measures are in place and effective. Log sheets or log books should be regularly filled out with the value of critical parameters, changes made to set points and other operating variables and operating and maintenance events that have occurred during the period of work. Handover is a system that should ensure critical information concerning the status of the plant and equipment handling hazardous materials is communicated by one group of personnel on one shift to the oncoming personnel so that they have a thorough understanding and are briefed of the status of the plant and equipment. Normally this is relevant for 24 hour operations which are covered by shift systems. The content of the handover should include a review of the relevant monitoring log sheets covering the critical operating parameters (levels, pressures, temperatures etc), status of permits to work, incidents and events that have occurred, visitors and contractors in the area etc. The personnel involved in handover should include
o
supervisors and operation and maintenance crews who have a key role in determining the status of operation. The handover is normally done by one individual to the counterpart taking over that role. Sufficient time should be allowed for in work routines for this handover to occur. 22. Permit to Work A permit-to-work system, in line with the definition in the Isolation Standard, shall be in place to ensure proper decontamination of plant and equipment, isolation, use of the correct personal protective equipment, and any special requirements or precautions (e.g. requirements for testing, venting, clearing of piping or when using naked flames) where the occupational exposure limit to a hazardous substance could be exceeded. The permit to work system should be documented and define the types of work involving hazardous materials including all plant and equipment maintenance work and other non-routine operating tasks carried out by both employees and contractors. This requirement can be part of an overall site permit to work system which is consistent with the Isolation AFRS. Refer to the Permit to Work Guideline in the Isolation AFRS for further details. In many countries the increased risks associated with confined space entry are recognised and there are often specific legislative requirements controlling such activities. The risks are generally associated with hazardous materials in relation to the toxicity of residual contaminants and/or asphyxiation. Particular care is required for isolation of the confined spaces, ventilation, decontamination, atmospheric testing, and provision of standby personnel, the wearing of correct PPE and rescue plans. 23. Simultaneous Operations A system shall be in place to control simultaneous operations involving hazardous materials to avoid mixing of incompatible materials. This requirement involves the hazards associated with uncontrolled chemical reactions which have the potential to release heat, pressure or toxic products in quantities which exceed the containment ability of the equipment (e.g. a pressure vessel) or environment (e.g. a tank bund) which holds the materials. This loss of containment can result for example in fire or explosion of flammable materials and boil over or toxic gas cloud of non flammable materials. The actual materials which are reactive may not in themselves be reactive or even hazardous but in combination with others create the chemical reaction hazard. The main causes of incidents involving uncontrolled chemical reactions are: a) b) c) d) e) f) Failure to identify the hazards through a lack of knowledge of the particular chemical reaction dynamics Lack of safe standard operating procedures Lack of training in the specific hazards and controls Poor equipment design Poor process and automatic control system design and/or inadequate maintenance Poor protective systems design and/or inadequate maintenance
g)
Poor inventory control.
There are two generic categories where these risks can occur and each site should determine if they are applicable and if so asses the risks. Those categories are continuous or batch processes and storage and warehousing facilities. The following provides some guidance on hazard identification and risk assessment principles for those categories. CONTINUOUS OR BATCH PROCESSES The key system for determining if chemical reaction hazards exist is through integration with process risk assessment (see requirement 1). However, it is because of the first issue above (i.e. lack of chemical reaction knowledge) that during assessments such as HAZOP, the hazards are not identified and consequently appropriate controls are not implemented. Specialist expertise should be sought from personnel such as process engineers, chemists, process technology vendors (see requirement 30) where it is thought that chemical reaction hazards may exist. In new projects this input is required in the early stages such as during the concept phase in order to try and eliminate the hazards altogether. Detailed information on the chemistry of the process is required including reaction equilibrium, kinetics and heat release data and the envelope of intended process operating conditions. During process risk assessment specific questions should be asked of the reactions and the materials involved including: Are any reactions highly exothermic and liable to thermal runaway? Are any of the materials strongly oxidising? Can explosive decomposition reactions occur? Can spontaneous combustion reactions occur? Are there any hazardous by-product reactions? Can any of the materials thermally decompose? Are any of the materials unstable?
Which ever process risk assessment method is used (e.g. HAZOP or What-if/check list) deviations should be specifically reviewed to determine the effect of: Unwanted heat ingress Loss of cooling Loss of power Loss of inert atmosphere (e.g. nitrogen blanket) in flammable atmospheres Loss of indication and control system sensors Loss of mixing and agitation in composition sensitive reactions Reactant impurities Contaminants (air, water, rust, lubricants etc) which may catalyse reactions Change in process conditions Inadvertent mixing or agitation.
When controls are being developed the following options should be considered: Inherent Safety (Eliminate/Substitute) Eliminate or reduce the hazard through: Choosing an alternative reaction which is less or not exothermic Choosing materials which are less hazardous Reducing the inventory in batches or contained in process equipment Using a heating medium with a temperature below the thermal decomposition temperature of reactants/products.
Process and Automatic Control (Redesign) Prevent uncontrolled reactions occurring through safe control the process using: Process control loops Alarms Trips and interlocks.
Protective Devices (Redesign) Mitigate the effect of out of control reactions using: Pressure relief valves Emergency cooling systems Reactant dump systems.
During early stages of a project, hazard indices such as the Dow Index and Mond Index can also provide a means of ranking the hazards associated with a particular process involving reactive materials (see Lees: Loss Prevention in the Process Industries for a detailed description of each). Further information on chemical reaction hazards is available at: http://www.hse.gov.uk/pubns/indg254.htm, and http://www.aiche.org/ccps/pdf/CCPSAlertChecklist.pdf . During operation the effectiveness of the controls must be maintained though safe standard operating procedures, clear understanding of safe operating limits, operator training, monitoring of the process, maintenance of the technical integrity of the plant and equipment, management of change and appropriate security. Emergency response plans and procedures should also specifically address the hazard scenarios. STORAGE AND WAREHOUSING This type of operation is characterised by bulk storage and small volume containers and packages either in warehouses and other storage areas. Often the storage of a variety of materials can occur in close proximity. Many incidents have occurred with storage of incompatible materials and the major hazards usually arise from: Storing incompatible substances adjacent to each other Direction of leaks to common sumps and sewers where mixing occurs

Incorrect or absent labelling of raw materials, intermediates and products Ignition sources in areas containing flammable and combustible substances Use of non-intrinsically safe equipment within intrinsically safe zones Poorly managed inventory control Poor house keeping Knock-on effects from incidents (e.g. thermal radiation from fires).
In storage and warehousing the main control to avoid mixing of incompatible materials is by segregation which means keeping incompatible materials apart from one another using a barrier or intervening space. Some hazardous materials must be segregated when transported to ensure they do not mix in case of spillage.
Segregation charts exist to provide this information for storage and transport (see requirement 28) such as the following:
CLASS 2.1 2.2 3.1 3.2 3.3 3.4 4.1 4.2 4.3 5.1 5.2 6.1 8 9 Flammable gases Non Flammable, Non Toxic gases Flammable liquid Flammable liquids Flammable solids Spontaneous flammable Flammable if wet Oxidizing substances Organic peroxides Poisonous Corrosive Miscellaneous dangerous goods The two classes are prohibited in the same storage area. The two classes must not be stored in adjoining areas which are attached to each other. The two classes must be stored in separate areas at least 10 meters apart The two classes must be fire separated The two classes must be separated from each other by a distance of at least 3 meters Separation or segregation is not applicable to the two classes, and they may be stored in the same area. 2.1 2.2 3.1 3.2 3.3 3.4 4.1 4.2 4.3 5.1 5.2 6.1 8 9
Charts such as this should be prominently displayed in storage and warehouse areas so that personnel involved in the receiving, storage and distribution are aware of the segregation controls applicable to classes of materials which are stored on site.
24.
Emergency Response Plan Emergency response plans for incidents involving hazardous materials shall be in place and reviewed, tested and documented annually. These shall include external support services such as local ambulance and hospitals, as appropriate to the risk. The site wide emergency response plan should have procedures covering all hazardous materials on site. It should be aligned to credible scenarios, and consideration should to be given to fire, explosion and toxic release events that may affect personnel on site and also impact beyond the site perimeter. Adjacent properties and the public may be affected and the plan and procedures should include notification of local authorities. Specific procedures for loss of containment and other emergency scenarios should be in place for those materials in large quantities and/or where the consequences and risk from incidents is significant. For small quantities where the consequences and risk is low then it may be more appropriate to develop generic response procedures. Emergency response procedures for scenarios that include loss of containment of hazardous materials should cover warning systems; muster and evacuation, PPE to be worn by response personnel, containment and spill clean up equipment and procedures. Specific aspects associated with hazardous materials that should be included are: An inventory of hazardous materials on site (can be by reference to the hazardous materials register or other similar summary listing) Procedures for responding to hazardous materials incidents Infrastructure and facilities likely to be affected by the incident (on and offsite) Description of controls which are designed to control or mitigate the consequences of an incident (e.g. fire, smoke and gas detectors, fire fighting equipment etc) Arrangements for obtaining external resources including specialist expertise Procedures for decontamination and clean up after an incident.

Included in the program for simulated exercises and other training for the site wide emergency response plan should be exercises involving hazardous materials. The frequency of such exercises involving hazardous materials should be determined on the overall site risk profile for hazardous materials. 25. Access Control and Monitoring A system shall be in place to control and monitor access to areas where hazardous materials are stored and handled. This shall also identify process areas where hazardous materials may be released under certain operational circumstances (e.g. vent opening during process upset, infrequent discharge points) and what restrictions are placed on access to those areas. The security risk review of hazardous materials on site (see requirement 7), may identify that the security hardware should be augmented by some systems to ensure the integrity of the security or that hardware is not required and systems alone can provide the appropriate level of security.
If systems are required they may include: Continuous or periodic surveillance of an area by operations, warehouse or other relevant personnel such as security staff Visitor and contractor induction programs highlighting the need for approval to enter areas where hazardous materials are stored and used and restrictions on what such personnel can carry out with or without authorisation Control of vehicle access and route control on site to avoid inadvertent access into an area and vehicle collision with plant and equipment Permit to work system which includes access control for work.

When reviewing the areas of storage and use of hazardous materials, the locations where infrequent and particularly unannounced (and often automatic) discharges could occur should be considered. Such discharge locations may affect personnel such as contractors or visitors who are in the vicinity and not aware of such events occurring. Those discharges may be as a result of process or tank venting to atmosphere, process blowdown or draining to sewers and drains. Such discharges should be routed to safe locations (e.g. elevated vents, closed flare headers and drain systems) to eliminate the potential for unintended personnel contact. If such isolation is not feasible then personnel should be prevented from unauthorised access. 26. Training A system shall be in place to authorise and control the training of appropriate personnel in normal transportation, storage handling, use and disposal of, and emergency response procedures for hazardous materials. At each site there should be a training system in place which: Identifies personnel involved with hazardous materials who require training Identifies those aspects of their roles which are safety critical and require training Documents training requirements in a training matrix, spreadsheet or database Identifies responsibility for managing training Identifies appropriately trained trainers or training providers Develops/obtains the competency based training material and assessment tools Monitors the progress and effectiveness of training and maintains records.
The appropriate personnel who require training should be identified and could include any personnel who may be exposed to hazardous materials at the site as a consequence of being involved in the transportation, storage, handling, use and disposal of hazardous materials. This may include employees, contractors or visitors. A training needs analysis should be carried out which reviews those activities and systems that personnel have a key role in (see requirement 19) or areas where they may be expected to work and hence be potentially exposed to hazardous materials.
The need for retraining at regular intervals to ensure competence should be evaluated. For hazardous materials management there are many good sources of training materials in MSDS, PPE and other generic requirements. Training programs can include: Applicable legislation and duties and responsibilities of parties in a workplace Hazard identification, risk assessment and development of risk controls for hazardous materials Requirements for labelling and placarding and segregation of hazardous materials How to read and interpret MSDS and hazard warning labels How hazardous materials can enter the body and possible health effects Selection and use of personal protective equipment Specific task related training and the specific control measures contained in standard operating procedures, job safety analyses etc. Emergency response and first aid procedures to hazardous materials incidents.
The training requirements for personnel should be documented and approved by a responsible person. This can be done in a spreadsheet or database (i.e. a training matrix). Training can be conducted by in house resources or contracted out. Trainers should be competent in their subject matter (and in some countries require accreditation). Each training course should have a training plan which not only outlines the content but the expected competency outcomes. Training should be actively managed to ensure workforce competence and someone should be responsible for the ongoing conduct of training, scheduling of personnel and evaluation of training programs to ensure that they are effective. Whether this is carried out by someone in a central resource role such as Human Resources or a line supervisor is for each site to determine. Records should be kept of training dates, attendance, whether competence has been achieved and the requirement for retraining. 27. Exposure Monitoring A system shall be in place to monitor short and long-term exposure of personnel to hazardous materials which have the potential for immediate or long-term harm. This system shall ensure that any potential for a fatality is also addressed. Exposure to hazardous materials should be monitored through atmospheric and/or health surveillance depending upon the nature of the hazardous materials and assessed by properly qualified people. This should be conducted in accordance with Health Exposure Assessment Guidelines (refer to the Anglo Occupational Health Way).
28.
Transportation The following procedures shall be in place to protect communities and the environment during the transport of hazardous materials: establish clear lines of responsibility for safety, security, release prevention, training and emergency response in written agreements with producers, distributors and transporters require that hazardous material transporters implement appropriate emergency response plans and capabilities, and employ adequate measures for hazardous material management where required, a hazardous material manifest and supporting documentation shall be completed and shipped with the hazardous material. This documentation shall comply with local legislation
There should be a documented system for transport of hazardous materials both to and from a site including transport of hazardous waste. Most countries have legislation that covers such transport activities which should be complied with. The common theme of most legislative requirements is: A manifest which describes what is being transported, including proper shipping name, UN Number, Transport Hazard Classes, packaging group, number and type of packages, quantity and supplier/consignor. MSDS available Labelling of individual containers with class of material Placarding of the vehicle with information including shipping name, UN Number , Hazchem Code and emergency contact details (usually front and rear of vehicle) Appropriate segregation (see requirement 23) Containers and packaging approved and fit for purpose Emergency response plan/guide providing contact number in event of an incident Emergency response equipment (e.g. fire extinguisher) Training of personnel involved in transport (in particular truck drivers)

For further information refer to UN Model Regulations. 13th rev. ed. (files)
5.3
PEOPLE REQUIREMENTS
29. Hazardous Materials Coordinator A person shall be assigned as the site Hazardous Materials Co-ordinator at those sites where hazardous materials are processed, stored and handled. This person shall be trained and competent to understand and evaluate the risks associated with a wide variety of substances, and be able to identify where additional expert advice can be sourced. The site Hazardous Materials Co-ordinator shall be responsible for assessing the hazardous properties and disposal requirements of materials used, monitoring the consumption and management of inventory, and providing an as needed service to supply, warehousing, operational and the Safety, Health, Environment and Community (SHEC) personnel.
The Hazardous Materials Coordinator should be formally appointed by site management and be provided with a job description or appointment letter with details of the role and responsibilities. The incumbent may perform the role as part of a wider role or be solely responsible for this role. The incumbent should be competent for the role and competency may be acquired through training, education, experience or a combination of these. Suggested roles and responsibilities, some of which may be appropriate for inclusion in a job description are: Lead and/or participate in risk assessments of hazardous materials Participate and/or lead process risk assessments Coordinate the process of introduction and approval of new hazardous materials Provide technical guidance on storage, handling and use of hazardous materials Maintain the Hazardous Materials Register Maintain the data base and filing of MSDS and ensure accessibility Contribute to the development of emergency response procedures Contribute to the development of standard operating procedures Conduct self assessments of this protocol and systems to ensure compliance Provide hazardous materials safety training for employees and contractors Provide training in the selection and use of personal protective equipment Participate in the investigation of hazardous materials related incidents Analyse significant incident reports for learnings and make recommendations Inspect emergency response equipment such as of eyewashes and safety showers Conduct routine inspections of storage tanks, containers, packages and piping for their condition including status of vents, drains, bunds, labelling and access control Participate in behaviour based observations Participate in audits Provide technical assistance to emergency response personnel during incidents Coordinate with occupational hygienists on atmospheric monitoring and health surveillance Engage consultants where necessary to provide advice.

Suggested Skills and Competencies are: Ability to read and interpret MSDS and use the data base (e.g. ChemAlert) Ability to conduct risk assessments for the introduction of new hazardous materials

Understand the hazardous materials labelling requirements of plant and equipment Ability to provide advice on the selection and use of personal protective equipment Knowledge of basic principles of chemistry related to hazardous materials on site Knowledge of relevant legislation and codes of practice Knowledge of the basic design principles for the safe storage, handling, transportation, and disposal of hazardous materials including hazardous wastes.
30.
Risk Assessment Expertise The risk assessment process shall include people with appropriate expertise. Consideration should be given to the inclusion of external people (e.g. suppliers technical officers) in the risk assessment process. The relevant subject knowledge of risk assessment participants should include: Hazardous material properties Process configuration and dynamics Design standards Standard operating procedures and techniques Maintenance practices and equipment reliability issues Previous incidents at site and similar installations.
The selection of participants depends upon the complexity of the risk assessment and may include: 31. Risk assessment leader (preferably independent) Operations supervisors Operators and Maintainers Technologists and/or chemists Process and/or mechanical engineers Hazardous Materials Coordinator Occupational hygienists and SHE professionals Plant and equipment and process system vendor representatives Hazardous material supplier representatives.
Competency Based Training A competency based training system shall be in place for operational, maintenance and emergency response roles involving hazardous materials. Use should be made of supplier expertise to supply this training with annual refresher courses if required.
Competency based training should develop the skills, knowledge and behaviours required for those involved with hazardous materials handling to achieve defined competency standards (see requirement 26). Competency Based Training Assessment should ensure each trainee is capable of consistent application of the obtained knowledge and skills to the standard of performance required. Assessments can be conducted as a mixture of some or all of written evaluation, oral evaluation and demonstrative evaluation of competency. Training materials should be aligned to the defined competencies. Suppliers of hazardous materials and hazardous material plant and equipment systems should be used where relevant to provide training materials or deliver the training where they have specific knowledge and skills. 32. Behaviour Based Observation Behaviour based observations shall include the operation of equipment and systems handling hazardous materials. Any need for additional specific retraining shall incorporate the results of these observations. Behaviour based observation systems minimise risk by reducing the at risk behaviours that cause incidents by targeting critical behaviours. Critical behaviours are those behaviours essential for performing jobs safely and can be identified through analysis of incident reports, audits, job safety analyses, standard operating procedures and by discussion with workers on what is safe and at-risk behaviour. Once site specific critical behaviours associated with hazardous materials handling are identified they should be included in the standard operating procedures and training programs. Critical behaviours involving hazardous materials may include: 33. Obtaining MSDS to understand material properties, hazards and controls Conducting risk assessments (e.g. job safety analysis) before commencing work Obtaining approval to conduct non routine work via permit to work system Checking the contents of vessels, pipes and containers before commencing work Selection and use of correct personal detection equipment and devices Following the requirements of task specific standard operating procedures.
Risk Awareness All personnel shall be trained to understand the potentially hazardous effects on health of their working conditions and the materials handled. Training schedules shall be developed to enable individuals to recognise the signs and symptoms resulting from exposure to hazardous materials and enable them to take appropriate action. As with the requirements of paragraph 26 those involved with hazardous materials handling shall achieve a defined level of competency. A Competency Based Training Assessment should ensure each trainee is capable of consistent application of the obtained knowledge and skills to the standard of performance required. Assessments can be conducted as a mixture of some or all of written evaluation, oral evaluation and demonstrate competency. Training materials should be aligned to the defined competencies. Suppliers of hazardous materials should be consulted where relevant to provide training materials or deliver actual training where specific knowledge and skills are available.
APPROVED
13 August 2008
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34.
Regular Emergency Drills Regular appropriately staged emergency drills shall be held and lessons learnt shall be incorporated into the emergency response plan. Emergency exercises shall be conducted at frequent intervals to enable individuals and teams to practice the response to exposure to hazardous materials and enable them to take appropriate action in accordance with the Emergency Response Plan. Assessments may be conducted independently and where appropriate observations included in the respective safety improvement plans. Documentation should be reviewed and updated where appropriate. Professional teams could be included in such drills Note: Site personnel are to be trained in terms of their reaction and requirements which in case of hazmat is only to make immediately safe (cordon off and prevent entry) and call in the appropriate reaction teams.
REFERENCES The Anglo Safety Way Safety Management System Standards- Ver.2 December 2007 The Anglo Occupational Health Way Anglo Fatal Risk Standard Molten Materials Management Anglo Fatal Risk Standard Isolation Anglo American Golden Rules Dept of the Environment and Tourism (RSA) "Minimum Requirements for the Handling and Disposal of Waste" RECORD OF AMENDMENTS Issue 0 : New document (M. Karberg / S. Batchelor ; August 2008)

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AA_AFRG_000003 ISSUE 0

ANGLO FATAL RISK GUIDELINE

HAZARDOUS MATERIALS MANAGEMENT

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1 2 3 3.1 4 5 5.1 5.2 5.3

REFERENCES RECORD OF AMENDMENTS

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Risk Assessment Procedures

Management Approval in Safety Document System Enter in Hazardous Material Register

Baseline Risk Assessment to Identify high risk materials

PPE, Biological Monitoring, Buddy System etc Reject for us e

Residual Risk Acceptable?

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REQUIREMENTS OF THE STANDARD

FMEA FTA HazID HAZOP IBC

MSDS NFPA PHA P&ID PPE PSV

Quantitative Risk Assessment Safety Integrity Level

PLANT AND EQUIPMENT REQUIREMENTS

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The classes (excluding explosives) are: Class 2 - Gases

Class 3 - Flammable Liquids

Class 4 - Flammable Solids

Class 5 - Oxidising Substances and Organic Peroxides

Class 6 - Poisonous (toxic) and Infectious Substances

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SYSTEM AND PROCEDURAL REQUIREMENTS

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The information items required to complete an MSDS.

Poor inventory control.

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