A brief guide to Safety in the Warehouse

Many businesses have storage and warehouse facilities as an integral and important part of their operation.  These may be very busy places at all times (such as in a logistics operation) or they may be pretty quiet for many hours a day, but have periods of intense activity.  Warehouses are dangerous places and people do get hurt in them in several ways.  Many of the injuries suffered can be avoided by taking some simple steps; all derived from simple risk assessments. In this blog, I have asked two basic questions: "What types of accidents are associated with warehouse operations?" and "What can be done to avoid these accidents?" This blog does not seek to provide in depth answers, but to get the reader thinking. Contact me through the website for further information or assistance.

What types of accidents are associated with warehouse operations?

That depends on the operations carried out in the warehouse.  The main types of accidents in warehouses generally include:

• Slips, trips and falls (on the same level)
• Manual handling
• Falls from height
• Accidents involving vehicles moving in and around the warehouse
• Being struck by moving or falling objects

However, other types of accident will occur in warehouses depends on the type of operations being carried out, such as:

• Mechanical accidents involving the use of conveyor systems
• Exposure to chemicals (from poorly stored items)
• etc

What can be done to avoid these accidents?

Slips, trips and falls

• Ensuring good standards of housekeeping – keep walkways clean. Clear and unobstructed
• Ensure that spillages are cleaned up immediately that they occur or when they are noticed
• Ensure that banding tapes, packaging materials and polythene, etc are not allowed to collect on the floors
• Ensure that leaky roofs are repaired
• Ensure that all staff are provided with (and wear) appropriate safety footwear
• Ensure that the floors are maintained in good condition and that defects are repaired

Manual Handling

• Arrange work such that the needs for manual handling are reduced (such as by the use of fork lift trucks, (powered)-pallet trucks, dock lifts, etc)
• Ensure that the risks associated with all manual handling operations are assessed and minimised, giving consideration to:
• the task
• the load
• the working environment
• individual capability, and
• other factors
• Ensure that there are always a sufficient number of employees to deal safely with the loads that need to be handled
• Arrange suitable training in manual handling for all warehouse staff (including temporary and agency workers)

Work at Height

• Avoid the need to work at height were possible
• Avoid climbing on the top of loads where possible
• Provide suitable, practical protection to areas from which people may fall (such as loading bays, etc)
• Provide suitable means of access  for any elevated work area, such as racking locations, etc
• Arrange for all access equipment to be checked regularly by a competent person
• Instruct workers not to use inappropriate or defective access equipment (avoid the use of the forks on a fork lift truck or the use of a pallet on the truck, etc)
• Provide safe working platforms for accessing the back of vehicles (such as tankers or flat bed trucks) if accessed routinely

Vehicles

• Manage the vehicles accessing the site – where possible, provide delivery drivers with relevant health and safety information about your site (times for deliveries, one-way system information, etc) before they arrive
• Display suitable warning signs and notices
• Consider have safety information available in different languages if regularly dealing with drivers from different countries
• Provide clearly designated vehicle and pedestrian routes (where possible)
• Ensure that areas are adequately illuminated
• Provide warehouse staff with high visibility clothing
• Control the reversing of vehicles (consider the use of CCTV systems on your own vehicles)
• Provide workers with suitable and sufficient vehicle movement awareness training, banksman training, etc
• Implement suitable controls for vehicles on site – such as warning signs, site speed limits, mirrors on “blind” corners and bends, etc
• Ensure that all loads are safe before attempting to unload a vehicle
• Ensure that all loads are secure before allowing a vehicle to leave site
• Implement procedure to prevent vehicles from driving off prematurely (such as a key collection system or chocked wheel system).
• Ensure that the use of fork lift trucks is restricted to trained and authorised users
• Restrict access to the warehouse to authorised persons and display suitable notices to this effect

Falling Objects

• Ensure that all loads stored at height (such as on racking) are secure
• Avoid working under other people
• Assess the safety of loads before attempting to unload a vehicle
• Ensure that all racking systems are adequate for the loads that will be stored on them
• Display the safe loading limit of all racking systems
• Carryout regular inspections of the racking and of the goods stored on the racking
• Check the condition of wooden pallets and do not reused damaged pallets
• Arrange for loose items to be secured (such as by shrink wrapping) before storage

Mechanical Accidents

• Ensure that all plant and equipment provided for use in the warehouse (such as shrink wrapping equipment, conveyor systems, etc) is suitable for the task and is in good condition
• Arrange for all equipment to be checked and inspected regularly by a competent person to ensure that it remains in good condition, to ensure that all guards are in place and that all emergency stops and other safety features and controls work
• Restrict the use of plant and equipment to authorised persons only

Exposure to chemicals

• Ensure that all chemical packaging is in good condition
• Ensure that appropriate PPE is provided
• Ensure that suitable washing facilities and emergency arrangements are in place for washing and for emergency eye wash
• Ensure that safety data sheet are available for all substances used and/or stored on site
• Ensure that all chemical packaging display suitable warning symbols

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Health Surveillance

Introduction
It is a sad fact that eery year, many thousands of employees suffer or are made ill by the work that they do.  The harm may come from a range of occupation factors, such as:

• Noise
• Noise induced hearing loss (NIHL)
• Tinnitus
• Vibration
• Hand-Arm Vibration Syndrome
• Exposure to chemicals
• Dermatitis
• Skin sensitization
• Reduced lung capacity
• Occupational asthma
• Respiratory sensitization
• Poisoning (such as by lead)

The HSE estimates that between 1500 and 3000 people in Great Britain each year develop some form of occupational asthma. Many of these illnesses can be identified by the process of health surveillance.  In some cases, they can be identified before too much (irreversible) harm is done.  Health surveillance is about putting in place systematic, regular and appropriate procedures to detect early signs of work-related ill health among employees exposed to certain health risks; and allowing the employer to act on the results.

Health Surveillance and Risk Assessment

It is well established that employers must carry out risk assessments.  These assessments must be suitable and sufficient to identify how employers (and also non-employees) can be harmed and how that harm can be avoided or, if this is not reasonably practicable, minimised.  The Management of Health and Safety at Work Regulations 1999 (MHSW) create this duty in all work situations and other sets of Regulations enforce this requirement in certain circumstances.  Schedule 1 of MHSW details a hierarchy that the employer must follow when considering control measures (i.e. measures to avoid or reduce the harm that people may suffer).  Health Surveillance is at the bottom of this hierarchy.  The main reason for this is:

• Health Surveillance does nothing to protect the employee from harm – it merely allows the employee to determine t he amount of harm of the level of exposure to harmful agents (chemicals, noise, vibration, etc.).

When Health Surveillance should be carried out and by whom
Health surveillance should be carried out when all of the following conditions are satisfied:

• The work being carried out (or the environment in which the work is being carried out) is known to damage health in some particular way
• There are valid and safe ways to detect the disease or condition – It is important to understand that health surveillance is only worthwhile in situation where it can reliably show that damage to health is starting to happen or that there is a likelihood of such damage occurring. It is also important to understand that a particular health surveillance technique is only useful if:
• it provides accurate results,
• it is safe, and
• it is practical.
• It is reasonably likely that damage to health may occur under the particular conditions at work?
• Health surveillance is likely to benefit employees

Health surveillance should also be carried out when it is expressly required by legislation, such as where an employee is engaged in one of the processes listed in Schedule 6 of the Control of Substances Hazardous to Health Regulations 2002 (such as: manufacture involving exposure to vinyl chloride monomer (VCM), pitch, carbon disulphide, potassium or sodium dichromate, auramine, Magenta or several other identified substances) and is likely to receive significant exposure to the substance involved.
 

Procedure	By whom	Examples
Self Checks	The employee	Self checks are suitable for those employees exposed to hazards who have been properly trained in how to look for easily recognisable signs and symptoms of disease.  The employee should know who to go to if they find anything that causes them concern.
Basic (visual) checks for signs of disease	Responsible Person	Skin inspections where people work substances that can cause dermatitis, such as: Detergents metalworking fluids (MWF) shampoos
Enquiries about symptoms, inspection and examination	Qualified person	An occupational health: o   Checking for signs of asthma o   Measuring lung function Audiologist:: o   Measuring hearing
Clinical examinations	Should be carried out by or be supervised by a doctor.   Interpretation of results may also require a doctor.	In some cases this is a legal duty (for example for employees exposed to lead); in others the nature of the tests will require the expertise of a doctor to interpret the results and advise on their significance. Examination by a doctor is also likely to be necessary where health surveillance by a responsible person or an occupational health nurse has identified possible work-related ill health that requires further investigation, diagnosis and treatment.
Biological monitoring and biological effect monitoring	In general, these should be carried out by or supervised by a doctor.   The samples may be taken by a suitably trained person.	Blood testing for: lead mercury carbon monoxide Urine testing for: cadmium fluoride Urine testing for breakdown products of: isocyanates styrene

Responsible Person

Anyone trained to identify straightforward signs and symptoms caused by working with certain substances or processes.  A responsible person must not be expected to diagnose the possible cause of symptoms.  Managers, supervisors or first aiders could carry out these checks. An occupational health doctor or nurse should train these people to recognise signs or symptoms requiring further assessment and to know when and how to refer employees.

Qualified person

A qualified person usually means an occupational health nurse checking, for example, for signs of asthma.  It can also be someone with appropriate technical knowledge, for example an audiologist carrying out hearing tests or someone trained to conduct lung function tests.

Typical health surveillance for those working with substances that may cause dermatitis

Skin health surveillance should be considered in cases were workers:

• Have the following occupations: construction work, health service work, rubber making, printing, paint spraying, agriculture, horticulture, electroplating, cleaning, catering, hairdressing, floristry
• Are (potentially) exposed to any of the following substances: epoxy resins, latex, rubber chemicals, soaps and cleaners, metalworking fluids, cement, wet work, enzymes, corrosive chemicals, irritant chemicals, solvents and other similar organic liquids (such as paint thinners, etc.)
• Are (potentially) exposed to any products that are labelled:
• R43 ‘May cause sensitisation by skin contact’
• R42/43 ‘May cause sensitisation by inhalation and skin contact’.

Typical forms that the skin health surveillance could take include:

• Assessing the skin condition of workers as soon as possible after they start (and preferably within six weeks) a relevant job to provide a baseline.
• Implementing regular testing at appropriate intervals (such as monthly, every few months or annually - as advised by an occupational health practitioner)
• The regular testing could involve a suitable questionnaire and skin inspection (hands, forearms and, if these can be contaminated, lower legs) by a responsible person.

Typical health surveillance for those working with substances that may cause (occupational) asthma

Respiratory health surveillance should be considered in cases were workers:

• Have the following occupations: bakers, food processors, beauty service providers, cleaners, painters, repairers (including electronics), welders and woodworkers (including forestry).
• Are (potentially) exposed to any of the following substances: isocyanates (such as in two-pack spray paints), glutaraldehyde, wood dust (hard wood, soft wood, MDF, plywood, etc), latex (such as from powdered natural rubber latex gloves), flour dust, grain dust, rosin-cored solder fume, laboratory animals or glues and resins
• Are (potentially) exposed to any products labelled:
• R42 ‘May cause sensitisation by inhalation’ (may lead to asthma)
• R42/43 ‘May cause sensitisation by inhalation and skin contact’; or
• Have had a confirmed case of (occupational) asthma.

Typical forms that the respiratory health surveillance could take include:

• Assessing the respiratory health of workers before they start a relevant job to provide a baseline.  This could be achieved by a combination of questionnaire and lung function assessment.
• Implementing regular testing (again a combination of questionnaire and lung function assessment) at appropriate intervals (nominally annually or as advised by the health professional.
• Arranging for the results to be explained to the worker by the health professional.
• Arranging for the health professional to report to the employer on the fitness of the worker to work.
• Interpreting the results of the health surveillance (in conjunction with the health professional) and identify whether there is any requirement to revise the risk assessment, and if so in what way.
• Appointing a responsible person (supported by the health professional) to report any symptoms that occur between tests.
• Setting up a simple system to keep and monitor attendance records to identify any patterns in sickness absence.

Making and keeping Health Surveillance Records
All health surveillance programmes should include the keeping of suitable records, including a health record for each individual. These are important as they provide:

• An historical record of jobs involving exposure to substances or processes that require health surveillance;
• A record of the outcome of previous health surveillance procedures
• A demonstration (to enforcing authorities) that health surveillance has been carried out.
• Useful information that may later provide a defence in the event of prosecution or civil proceedings.

The records should contain, as a minimum, the following information:

• Full name
• Gender
• Date of birth
• Employee’s address
• NI Number
• Date of start of current employment
• Brief employment history (of jobs with exposure to hazardous substances, etc.)
• Conclusions of health surveillance

Health surveillance records should be retained for a minimum period of 40 years (or should be passed to the HSE if the company ceases trading).  As with all personal data being held by a company, there are various data protection issues that must be considered.

Summary

Health surveillance is important as a means of demonstrating that the control measures put in place to protect workers from harm are effective.  Health surveillance is, however, ineffective as a control measure in its own right as it can only measure how much, or how little, harm has been done to an individual – it cannot protect them from that harm.  Health surveillance can be carried out in a number of different ways by different groups of people.  Whenever an organisation is considering the introduction of health surveillance, health professionals should be consulted to help to plan and design the service to be provided.  Health surveillance should be carried out at appropriate, regular intervals and suitable records of should be maintained of all health surveillance.

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DSEAR - Dangerous Substances and Explosive Atmosphere Regulations 2002

I have resurrected an older Q&A article about the Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEAR). I trust that thye rteader will find the information useful.

 

What are the aims of the Dangerous Substances and Explosive Atmosphere Regulations 2002 (DSEAR)?

DSEAR enacted into UK law the European Directive ATEX 137 and the safety aspects of the Chemical Agents Directive.  It applies to all dangerous substances at nearly every business in the UK.  DSEAR sets minimum requirements for the protection of workers from fire and explosion risks arising from dangerous substances and potentially explosive atmospheres.  As with other similar legislation, such as COSHH, it complements the requirement to manage risks under the Management of Health and Safety at Work Regulations 1999.  To comply with the requirements of DSEAR, employers must:

• Carry out a risk assessment of any work activities involving dangerous substances;
• Provide technical and organisational measures to eliminate or reduce as far as is reasonably practicable the identified risks;
• Provide equipment and procedures to deal with accident and emergencies;
• Provide information and training to employees;
• Classify places where explosive atmospheres may occur into zones, and mark the zones where necessary.

Can I integrate the DSEAR Risk Assessment with other risk assessments?

As with all modern safety legislations, risk assessment is at the very heart of the Dangerous Substances and Explosive Atmospheres Regulations 2005 (DSEAR).  This does not mean, however, that distinct DSEAR risk assessments are required.  In the event that your current risk assessments (such as those that are required under the Management of Health and Safety at Work Regulations 1999) address adequately all of the issues required under DSEAR, then there is no need to produce new risk assessments to comply with the requirements of DSEAR.  As with all other risk assessments, DSEAR risk assessments must be kept up to date and reviewed in the event of any significant change or if thought to be out of date for any reason.

In the same way, DSEAR assessments may be integrated with COSHH assessments.  It is possible to have one assessment dealing the use, handling and storage of a substance (or range of substances) that addresses the fire and explosion risks as well as the health effects.  In some circumstances, this may be the most appropriate way to proceed as it will have the advantage of reducing the total number of risk assessments and should not compromise health or safety.  Typical examples of where such an approach could work well are in the areas of paint mixing and painting, fuel handling/dispensing, etc.

Are there any special areas that I should consider?

All areas within the workplace where explosive atmospheres may collect must be considered as part of the (DSEAR) risk assessment.  Special consideration should be given to areas where explosive atmospheres may develop due to the collection of solvent vapours, but are not the immediate areas where these substances are used, handled or stored.  Such areas need not be the main work area, but may be adjacent to the work areas and include cellars and vehicle inspection pits, etc.  Similarly, duct work that is used to transport dangerous substances away from the work area (such as local exhaust ventilation systems) may be areas where an explosive atmosphere may form and should be considered as part of the DSEAR risk assessment.  Other areas that should be considered are those in the vicinity of pipe work (especially joins) and pumps used for the transfer of dangerous substances.

Are there any particular training requirements associated with DSEAR?

Training is an essential part of DSEAR risk assessment process and the control measures that are introduced following the risk assessment.  Employees at different levels within the Company will have different training needs.  Those involved in the DSEAR risk assessment and the implementation of the control measures arising from the assessment will require the most detailed training.  There is a requirement to provide suitable and sufficient instruction, information and training to all employees that may be exposed to the risks associated with dangerous substances.  Typically, the information provided to employees should include:

• the identities and locations of dangerous substances;
• associated hazards;
• sources of ignition, including smoking;
• access to copies of any relevant safety data sheets;
• risk assessment factors resulting from relevant risk assessments;
• the control and/or mitigation measures to be used, including safe system of work;
• reporting, accident, evacuation and emergency procedures

Training and instruction should include elements of theory as well as practice. Training in the use and application of control measures and equipment should be carried out taking into account recommendations and instructions supplied by the manufacturer.  The employer should consider how the training, information and instruction are to be delivered in order to deliver that which is the appropriate to their own circumstances.  In most workplaces, options could include: classroom style training sessions; individual training sessions or toolbox talks.

Do I need to provide employees with antistatic overalls and footwear? 

As with many questions, the answer is: it depends.  It depends on the findings of the (DSEAR) risk assessment and the control measures that are required to reduce the risks down to as low a level as is reasonably practicable.  If the risk assessment indicates that anti static personal protective clothing is required to control the risks of ignition of an explosive atmosphere from a static discharge then the employer must provide the employees with suitable antistatic personal protective clothing (such as overalls and footwear).  As with all PPE issued for the purposes of health and safety at work, this equipment must be provided to the employee free of charge.

It should be noted, however, that the effectiveness of antistatic footwear can be reduced, or even nullified, in several ways.  If the footwear is not cleaned on a regular basis, build up of insulating materials (such as resins, paints, etc) will decrease their effectiveness.  Similarly, the floor can become an insulating barrier if it is not kept clean (or is made from an insulating material, such as wood or some resin finishes).  The antistatic properties of footwear may be checked regularly if a suitable instrument is provided, such as a simple, wall mounted conduction to ground monitor.

What has happened to the old Petroleum License?

The Government is modernising petroleum legislation, and part of that process has been brought about by DSEAR.  Historically, petroleum spirits were controlled by licenses issued under the Petroleum (Consolidation) Act 1928, but this requirement have been removed by DSEAR.  Except in cases where petroleum spirit that is being kept for dispensing into vehicles (retail and non-retail), DSEAR has replaced the externally (often local authority) checked and issued Petroleum License with a new internal risk assessment requirement.

What sort of arrangements do I need to make to deal with accidents, incidents and emergencies

The arrangements under DSEAR for dealing with accidents, incidents and emergencies build on those that should already be in place for fire safety and as required under Regulation 8 of the Management of Health and Safety at Work Regulations 1999.  DSEAR requires that the employer makes suitable arrangements to protect employees (and others) in the event of an accident or incident.  Typically, those arrangements should include:

• Suitable warning and communication systems (which may include visual and/or audible alarms);  
• Suitable escape facilities (the need for which will be identified by the risk assessment);
• Emergency procedures to be followed in the event of an incident;
• Provision of information and training on the emergency procedures to employees;
• Equipment and clothing for essential personnel dealing with the incident
• Simulated emergencies and practice drills
• Where appropriate, liaison with the emergency services to advise them that information on emergency procedures is available (and providing them with any information they consider necessary).

The exact scale and nature of the arrangements for dealing with accidents, incidents and emergencies should be proportionate to the risks and, hence, should be determined by the risk assessment. 

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The Storage of Substances Hazardous to Health - Second Part

Many organisations need to store substances that are classified as hazardous to health, sometimes in substantial quantities.  As discussed previously, several sets of Regulations may apply, depending on the exact nature of the substance being store, but in nearly every case, the Control of Substances Hazardous to Health Regulations 2002 (or COSHH Regulations) will apply.  However, consideration needs to be given to the full range of hazards that may be present, including issues such as compatibility with other materials, reaction with air or water, etc.  Many aspects of the safe storage of substances hazardous to health rely on common sense and part of the purpose of the COSHH risk assessment is to formalise the application of this common sense.

Storage of gases

Gases are usually stored under pressure inside metal gas bottles.  These bottles can vary in size from a few millilitres up to several tonnes.   The gas bottles, and associated pipe work, must be colour coded and/or labelled for identification purposes as required by either various pieces of specific legislation (which are outlined in Schedule 7 of the COSHH Regulations) or by Regulation 12(5) of the COSHH Regulations (a requirement that was new in the 2002 Regulations).  Similar rules apply to pipe work systems used for the storage and transfer of liquids and even solids.

Where incompatible gases are being used on a site, there must be a safe system of work in operation that negates the possibility of the accidental mixing of these gases.  In the case of hydrogen and oxygen, these gases have different screw threads on their fittings to prevent accidental connection of the wrong gas to the wrong part of the system (this system is also seen on oxy-acetylene welding/cutting equipment).

Gas cylinders, and the associated supply pipe work, need to be adequately protected from accidental damage (such as from vehicle movements).  They may also need to be protected from heat, including heat build up from sunlight.

Storage of liquids

Bulk storage

Bulk storage of liquids generally takes place is designated bulk storage tanks.  These tanks are usually bunded, to contain accidental releases of materials.  The tanks are usually filled from a delivery tanker.  It is essential that the right material is unloaded into the right tank.  There have been a number of serious industrial accidents when tanks have been charged with the wrong chemical.  Once such incident is described later in the section dealing with acids/hypochlorite solutions and is described in more detail below.

Small/medium scale storage

Small and medium scale storage of solid hazardous substances generally involves intermediate bulk containers (IBCs), drums or bottles.  The size may vary from a few grams up to about 1200 Kg.

Storage of oil

It is not uncommon for water to be polluted by oil.  The requirements for the storage of oil in containers which carry more than 200 litres are set out in the Control of Pollution (Oil Storage) (England) Regulations 2001. These regulations, which do not apply to waste oil or oil stored in a building or wholly underground, require:

• secondary containment (such as a bund):
• with a capacity of not less than 110 per cent of the container’s storage capacity
• positioned to minimise any risk of damage by impact, e.g. by fork-lift trucks
• with its base and walls impermeable to water and oil
• without its base and walls penetrated by any valve, pipe or other opening used for draining the system
• with the base or walls, where they are penetrated by any fill pipe, or draw off pipe, adequately sealed to prevent oil escaping from the system
• any valve, filter, sight gauge, vent pipe, etc to be situated within the secondary containment system
• fill pipes, not within the secondary containment system, to have a drip tray to catch any oil spilled when the container is being filled with oil.

The regulations also include requirements for the storage of oil in fixed tanks, both above ground and underground, which include particular requirements for ensuring that fill, draw-off and overflow pipes are not damaged, and that the tanks are fitted with automatic overfill protection devices.

Storage of solid materials

Bulk storage

Bulk storage of solid materials may take place in several ways:

• Loose, but in defined locations in a yard (e.g. granite or asphalt blocks)
• In large open access bins (sand, etc.)
• In silos (e.g. flour, various process chemicals)
• In “big bags” which generally hold between one and three tonnes (a range of process chemicals)

If powdery or friable materials are stored loosely, the effect of dispersal by wind, leading to airborne contamination, must be considered.

Small/medium scale storage

Small and medium scale storage of solid hazardous substances generally involves bags, sack, drums or bottles.  The size may vary from a few grams up to about 250 Kg.  Materials may also be stored in roll form, such as in the case of glass fibre, or rolls of various fabrics impregnated with resins, etc.

Storage of incompatible or reactive materials

Where there is a risk of accidentally mixing materials that are incompatible, there is a duty to ensure that all reasonably practicable measures are taken to prevent this from occurring.  This will include, amongst other things, the introduction and maintenance of a safe system of work designed to prevent mixing.  Deliveries, including accompanying paperwork, should be checked carefully and all deliveries and transfers should be supervised adequately.

Acids/bases

Acids and bases must be stored separately as significant heat (of neutralisation) may be generated when these materials are mixed.  The storage arrangements for these materials should ensure that they cannot be mixed accidentally, even in the event of spillage.  Ideally, these materials should be stored in separate, bunded locations.

Acids/hypochlorite

Acids and hypochlorite mixtures should be stored separately as toxic chlorine gas is generated when these materials are mixed.  The storage arrangements for these materials should ensure that they cannot be mixed accidentally, even in the event of spillage.  Unfortunately, in premises with swimming pools (where hypochlorite solutions are often used as part of the water treatment) these materials are often stored close to each other.  It is recommended that containers of these two substances are bunded separately to prevent mixing after a spillage has occurred.

Case study: - The danger from the accidental mixing of acids and hypochlorites was shown in the following case study:

In September 2002, a lorry driver from AE Costins Limited delivered an IBC of hypochlorite solution to site on behalf of the supplier and distributor (Tennants Distribution Limited).  The lorry driver then accidentally connected the IBC to a hydrochloric acid bulk storage tank instead of the hypochlorite bulk storage tank.  When the hypochlorite was pumped into the wrong tank the two chemicals reacted, generating a cloud of chlorine gas.  26 employees were taken to hospital for examination, though only one was detained overnight.  This accident was blamed onto the inadequate training of the lorry driver and the failure of Tennants Distribution Limited to ensure that driver of vehicle contracted to the Company to and transfer sodium hypochlorite solution were competent to do so.  Tennants were fined £12,000, with costs of about £5,500.

Acids/(poly)sulphides

Acids and sulphides (including polysulphides) must be stored separately as toxic hydrogen sulphide gas is generated when these materials are mixed.  In July 2001, a load of waste alkali that was contaminated with polysulphides reacted with some waste acids at Park Environmental Services Limited, liberating hydrogen sulphide gas.  One employee was overcome by the gas and was further injured by falling down steps.  Although often underrated as a toxic gas, hydrogen sulphide is more toxic than hydrogen cyanide.  The Company was fined a quarter of a million pounds under S2 (1) of the Health and Safety at Work Etc Act 1974, with costs of about £20,000.

Fortunately, its smell is unpleasantly noticeable well below its toxic level.  The storage arrangements for these materials should ensure that they cannot be mixed accidentally, even in the event of spillage.  

Acids/cyanides

Acids and cyanides must be stored separately as toxic hydrogen cyanide (cyanide gas) is generated when these materials are mixed.  The storage arrangements for these materials should ensure that they cannot be mixed accidentally, even in the event of spillage.  More is said on the storage of cyanides in the section on highly toxic substances (below). 

Oxidising agents/organic materials

Oxidising agents include a wide range of commonly used substances, including peroxides (such as methyl ethyl ketone peroxide, or MEKP, used in the manufacture of glass reinforced plastics, or GRPs, and chromic acid (used in the certain electroplating processes).  Fires may be initiated by the action of oxidising agents on organic materials.  This may include the organic materials often associated with packaging and storage, such as paper, cardboard and wooden pallets.  Naturally, consideration needs to be given to the safe storage of oxidising agents.  The area should be clearly identified and organic materials (including packaging and process chemicals) must be excluded from this area.

Materials that react with water 

Many substances react violently with water.  Some produce explosive gases, such as the release of acetylene from the reaction of calcium carbide with water, or the release of hydrogen from the reaction of alkali metals (such as potassium or sodium) with water.  Sodium also generated enough heat to ignite the released hydrogen).  Other materials react violently with water to generate heat, known as the heat of dilution (such as in cases of pearl caustic soda, concentrated sulphuric acid, oleum, etc.).  The dilution of these materials needs to done correctly, usually with stirring and cooling as well as consideration to the order of addition, etc.  

Materials that react with air 

Some materials (such as Raney nickel catalysts) react violently (or even pyrophorically) with air.  Typically, these materials are stored under water, such as in the form of a slurry.

Storage of highly toxic substances

With highly toxic substances, it is recommended that these are stored in a secure location, such as a locked storage area.  It is also recommended that an inventory of stored materials is maintained, including records of usage.

As with all substances hazardous to health, consideration must be given to reducing the amount of these substances used and/or stored as well as giving consideration to the use of these materials at all.  Regulation 7(2) of COSHH 2002 creates a duty to consider safer alternatives.

Storage of waste materials

Consideration needs to be given to the hazardous nature of stored waste materials.  Consideration needs to be given to the toxic, corrosive or otherwise harmful nature of the substance, as well as any incompatibilities. 

Application of COSHH to storage

As stated at the start of the first article, COSHH applies as much to the storage of substances hazardous to health as it does to their use.  The COSHH Regulations require employers to prevent exposure to hazardous substances to both employees and non-employees where it is reasonably practicable to do so.  Where it is not reasonably practicable to avoid exposure, then exposure must be adequately controlled.  COSHH assessments must consider the storage of substances as well as their use.

Michael Ellerby

LLB BSc CMIOSH MIIRSM MIFSM CChem MRSC CSci

Director

LRB Consulting Limited

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