By Barry Dyer, chief executive, Responsible Care NZ.
Safely managing chemical inventory continues to exercise business operators, especially major manufacturing sites, 3PL providers and their clients. A combination of stockpiling following the Covid disruption and seeking to postpone the impact of rising prices for commodity chemicals can challenge chemical warehousing and transport providers, transit depots and distributors throughout the supply chain.
Chemical incidents can occur anywhere in the product life cycle, with the majority occurring during the transport and bulk storage phase. Catastrophic chemical fires and subsequent explosions in Tianjin Port, China and Beirut Port killed hundreds of emergency responders and local inhabitants, causing massive damage to critical facilities and disrupting supply chains for years.
The Health and Safety at Work Act (HSWA) 2015, together with the HSW (Hazardous Substances) Regulations 2017, the Land Transport Act 2010 and even the RMA prescribe the obligation of PCBUs to safely manage the risk associated with hazardous substances and dangerous goods (chemicals).
Safe chemical management requirements for all quantities, particularly bulk, include:
• Maintaining an accurate site chemical inventory.
• Readily accessible, compliant safety data sheets (SDS).
• Correct GHS labelling and segregation of incompatible substances.
• Competent workers.
• A regularly practiced chemical site emergency response plan (ERP).
Site emergency plans typically address the possibility of a fire, flood and even an earthquake, whereas a chemical incident can have far-reaching adverse effects unless competently managed. Even minor incidents can quickly become disastrous, endangering emergency responders, the local community and even perhaps major infrastructure such as ports and highways.
Preparing for a chemical incident requires more than a checklist; it must be the product of a comprehensive risk assessment, backed up with specialist training, the provision of appropriate PPE and spill kits, together with engagement with local emergency responders, FENZ, ambulance and Local Authority hazardous substance enforcement officers, through site familiarisation visits and regular joint practices, as appropriate to the risk profile of the site.
Many chemical incidents can be satisfactorily managed in-house by trained and confident staff. The demise of the HSNO approved handler, while often falling short in the performance standard achieved, means PCBUs now scramble to ensure workers are competent to be safely handling workplace chemicals.
Specialist chemical workers must be aware of the hazard profiles for the substances involved, how to maximise self-protection by correctly employing PPE and how to safely respond to an onsite chemical spill. Competent in-house responders may not need external intervention and the resulting disruption, without jeopardising safety.
Responsible Care NZ site SH&E compliance assessments reveal inadequate site ERPs, exacerbated by inappropriate PPE, inaccurate signage, inadequate training and failing to engage with local emergency services. Training must ensure workers understand and accept their ability to avoid or at least minimize possible harm to people and property by satisfactorily dealing with a chemical incident.
Often overlooked by management and certifiers is incorrectly displaying several GHS pictograms on the Hazchem signage required at each entrance to the site. Emergency responders require the major chemical hazard present to be correctly identified with dangerous goods pictograms, complemented by ready access to the ERP, ideally lodged with the local FENZ station.
Successfully managing an onsite chemical incident is complex and resource-poor businesses could benefit from RCNZ’s popular 24/7 ChemCall Chemical Emergency Response Advisory service. ChemCall responders are subject matter experts with access to a subscriber’s SDS and ERP in a secure database.
They manage the response to the point where people, property and the environment are no longer at immediate risk, then discuss any cleanup required by qualified contractors. A comprehensive ‘after action’ report (debrief) enables a thorough investigation of the incident, including appropriate corrective actions.
Subscribers include the ChemCall freecall number on SDS, site entry signage, at chemical workstations, in vehicles and on phones, to quickly access sound, professional advice about safely responding to the incident, without putting workers and property at risk.
Each site ERP is assessed by the compliance certifier, so a copy of the report should be requested when seeking certification. Regular emergency drills with the local FENZ station should be carried out and recorded, especially where bulk quantities are involved.
The successful execution of a sound ERP will protect staff, property and the wider community. Where a business does not have the requisite experience to confidently and successfully respond to a spill, an investment in ChemCall cover provides ‘peace of mind’.
The free calling number for ChemCall is 0800 CHEMCALL (0800 243622).