HSE has issued guidance on the topics that should be addressed by a COMAH safety report, but Occupiers are not obliged to follow the order suggested. In fact it makes more sense to describe a warehouse site first and then the stocks of chemicals held, therefore this is the order of the information presented in this document.
The safety report assessment manual lists all the aspects that should be addressed in the site description. This guidance make reference to the features that are important for a risk assessment:-
Agrochemical warehouses tend to contain substances with risk phrases that span the complete range given in the CHIP Regulations. A safety report must consider the hazards from all substances in a warehouse if the warehouse contains sufficient dangerous substances to bring it under the COMAH top tier regulations.
The aggregation rules, which allow occupiers to test which warehouses meet this criterion are as follows: -
The threshold quantities listed in Schedule 2 Named Substances refer to pure substances. If any one of the listed chemicals is in the form of a solution, it is the mass of pure substance not the mass of the solution that should be compared to the quantities in columns 2&3.
| Class no | Category | Risk phrase number | Risk code letter |
|---|---|---|---|
|
1 |
Very toxic |
R26,R27,R28 |
T+ |
|
2 |
Toxic |
R23, R24, R25 |
T |
|
9 |
Dangerous for the environment |
R50, R51 |
N |
|
3 |
Oxidising |
R8 |
O |
|
4 |
explosive |
R2, R3 |
E |
|
6 |
flammable |
R10, (liquid) |
F |
|
7 |
highly flammable |
R17,R11 (liquid) |
F |
|
8 |
extremely flammable |
R12 (liquid) |
F+ |
|
0 |
Reacts violently with water |
R14, |
|
|
10 |
Releases toxic gas on contact with water |
R29 |
An agrochemical warehouse may store formulated products containing a toxic substance "X" at a concentration of 10%, which is insufficient to cause the them to be classified toxic. If there is another agrochemical in the same warehouse containing "X" at a sufficiently high concentration for it to be classified as toxic, the Operator is obliged to consider both products in his hazard assessment. However, the safety report only needs to provide the following information on the substances that meet the risk phrase criteria. These include:-
If a site stores many tens of toxic substances it is unreasonable for Assessors to insist that the Occupier provides very detailed data on all of them. The most that can be expected is information on the 10 most hazardous inventories and standard data sheets for all other hazardous substance in an appendix.
Since the contents of many chemical warehouses change continually, Occupiers may be unsure how to calculate their total hazardous inventory although the regulations are quite clear on this issue. The quantities that should be aggregated are the greater of:-
(a) The maximum quantity stored for a short period, even if that is less than one day, over a year taking account of seasonal demands and fluctuations in business activity.
(b) The maximum quantity that is liable to be stored in the near future (1 year).
At first sight this information appears unambiguous, but in fact several issues are unresolved mainly because the variation in the stocks of particular chemicals in a warehouse usually has both a cyclic and random component. Some agrochemical stocks peak in the spring while others reach their maximum level in autumn. It would be overly conservative to assume that the inventory of each substance is at its maximum at the time of the accident because this does not happen in practice and the warehouse would not be big enough hold such large stocks. The correct approach should be based on the "worst" inventory for a short period at any time during the year, where worst is defined as the maximum of (peak quantity)/LD50 or any other similar measure of hazard.
The regulations require occupiers to provide data on the analytical methods available to determine the presence of all hazardous substances, or to refer to such methods in the scientific literature. They also demand that the degree of purity of each hazardous substance is given together with a list of the main impurities and their percentages. It is probable that these requirements were included in the regulations with bulk storage or process in mind. They cannot sensibly be applied to a mixed warehouse containing hundreds of different chemicals in small quantities and Assessors should only expect occupiers to know of methods in the literature for detecting broad classes of compound (e.g. organophosphate). They should not insist on lists of impurities and their percentage concentration in every substance.
The Regulations also require occupiers to briefly describe the hazards, which may be created by dangerous substances, but it is difficult to separate out hazards from individual substances in a warehouse. Occupiers are more likely to deal with this requirement by reference to: -
The safety report should describe the conditions, under which hazardous substances are stored paying attention to the following: -
All of the types of packaging for hazardous substances should be described in a safety report even if these are only stored infrequently. Common packaging types include: -
2001
50kg
251
2001
251
20 and 25kg
500ml
11 and 51
101
11
5 and 101
150kg
4001
10001
10kg and 15kg
25kg and 50kg
If safety arrangements are appropriate for a restricted range of packaging types then the safety report should contain unambiguous statements that other types of goods will not be accepted. An example of such statement would be "flammable or combustible liquids in plastic containers are never stored". Handling procedures for different containers should be outlined together with company rules on segregation, policies on loose packets and the breaking open of containers to fulfil special requirements. If shrink or stretch wrapping is employed, the equipment, procedures and safeguards should be described.
If the company's warehouses are racked, the safety report should demonstrate that the steel work complies with industry standards. Safety precautions and measures the company has introduced to protect the racking and prevent it being overloaded should be described. These could include: -
In warehouses not fitted with racking, goods may be stored in "block stacks" up to 10 feet high. A safety report for these warehouses should describe the measures and procedures used to: -
Companies should carry a supply of oversized metal and plastic drums for dealing with leaking containers. They should also have metal and plastic trays for leaking IBCs and written procedures for dealing with spills and damaged containers. Procedures for decanting and repackaging flammable liquids should give full details of arrangements to control static ignitions e.g. bonding of vessels, anti-static clothing, antistatic FLT tyres etc. Staff who deal with spills should have access to:
Damaged or leaking containers should be stored in a designated area/building well away from the main warehouse that is well ventilated, equipped with appropriate security features and has segregated areas to ensure compliance with the segregation rules for hazardous substances.
Most of the goods arriving at a warehouse site for storage do so on wooden pallets, which remain the property of the customer and are returned at the end of the storage periods. Some companies use non-returnable pallets and these become the property of the warehouse keeper. Due to movements of part loads in and out of warehouses, most sites accumulate a large number of surplus pallets, which are used to replace substandard pallets and to facilitate transport and distribution of stored goods. A safety report should contain a short paragraph describing the storage, inspection, reuse and scrapping of pallets. Storage of large pallet stacks immediately adjacent to the warehouse is not usually acceptable because of the risk of fire spread through the wall - typically following arson.
A COMAH safety report should provide sufficient information on the warehouses used to store dangerous substances that Assessors are able to ascertain if they meet certain minimum standards. This includes: -
Other highly desirable features of warehouses include: -
Three types of fork-lift truck are commonly used in warehouses, diesel, electric and LPG powered. Diesel trucks for use in highly flammable storage areas should be compliant with HSE Guidance Note PM 58S and electric trucks for these areas should comply with AS 3000 manufacturer's standard and shut down automatically if a flammable vapour is detected. Electric trucks should be charged away from warehouses in a purpose built, well ventilated building.
All fork-lift trucks should carry a fire extinguisher and be regularly maintained by a specialist contractor. Insurers usually require a biannual inspection of all trucks and associated attachments and lifting gear carried out by a competent expert. Servicing records should be held on a computer data base. Safe operating instructions should be available for each type of fork-lift truck used at a site and only qualified operators should be allowed to drive them. Staff who have undergone driver training and demonstrated adequate competence to an outside Inspector should periodically attend training and refresher courses.
The company should have a set of written safe operating procedures for fork-lift trucks, which include the following instructions: -
The following checks should be carried out on fork-lift trucks at the start of each working day: -
In this section separation and segregation have the meanings specified in HSG 71. Separation means a distance of 3 metres or one gangway width (whichever is the larger) between two types of goods. Segregation means that two types of goods should not be kept in the same building compartment or storage compound.
The storage of dangerous chemicals should be in accordance with the following guidance notes: -
As a general rule, substances from different hazard groups should be segregated, although this is not always practicable. A key issue in many warehousing operations is the segregation of flammable materials (especially flammable or combustible liquids) from toxic materials. If this is not done the risk of toxic materials being transported by a fire may be significantly increased. This is discussed in more detail later in this guide.
Oxidising materials should be segregated from flammable solids or liquids. Strong acids should not be stored alongside strong alkalis and substances that react violently with water should not be stored with aqueous products. All substances arriving on site should be accompanied by a Chemical Data Sheet and any consignment that arrives without one should be put in a temporary store until its properties have been ascertained and the complete documentation is available on site.
Assessors should expect a safety report to contain information on delivery notes and unloading instructions. Vehicles should not be reversed inside the warehouse and unloading should take place outside using fork-lift trucks irrespective of weather conditions. The report should describe procedures for: -
Shipping-out procedures are usually similar to those for shipping-in stock, with additional checks being carried out on the trailer to ensure that it is:-
Before leaving the site a driver of a loaded vehicle must obtain relevant the TREM cards from the warehouse office.
Most modern warehousing operations make use of computers for storing information on stock including: -
Under the COMAH regulations companies will have to keep information on the risk phrases of each substance so that their obligations under the regulations (lower tier or top tier), can be determined at any time. The computer used for this purpose should have its own uninterruptible supply of power and be capable of quickly providing hard copy details of all substances in a warehouse in an emergency situation. Stock data should be continually updated and should never be more than a few hours out-of-date. A copy of the stock data should be kept away from the warehouse, so that it can be retrieved quickly in the case of a fire. Hazard data sheets for every substance on site should be kept in a records office, manned by staff who understand the library arrangements and can locate data on any material at a moments notice.
Full details on each warehouse (in addition to chemical inventory) should be available in the event of an emergency. The information should include:-
The above information should be designed to assist fire fighting operations in the event of a major fire, enhance accident management and facilitate mitigation of its consequences, to staff, the public and the environment.
A warehouse site should have a well-defined management structure with responsibilities at each level clearly identified and understood by the relevant post holders. A COMAH safety report should include management organograms and detailed descriptions of the various management functions under normal operation and in the event of a major accident.
Key management personnel as far as general safety is concerned are: -
The general Site Manager/Director should have considerable experience of all aspects of warehousing. In particular he should be very familiar with: -
The Operations Manager will be responsible for day to day warehouse and transport operations. He should have qualifications and experience similar to those of the General Manager, but in addition he should have experience of all transport activities.
The Quality Assurance and Health & Safety Manager are usually one and the same person who has considerable knowledge of chemical safety and general warehousing operations. His knowledge of chemical hazards is usually greater than anyone else on site and he should have at least a good understanding of the major accident hazards and their consequences. In general he is responsible for:-
The Health and Safety Manager is a key member of the site safety committee and should attend meeting/ discussion that have an impact on site safety.
The Site Services Manager is responsible for buildings and equipment on site including fire fighting equipment, sprinkler system, heating and lighting, emergency generator, emergency communications system etc. His experience and qualifications should be commensurate with these responsibilities.
The Administration Manager usually acts as personnel manager and is responsible for accounts, stock administration, secretarial services and computer based records. He may be a designated emergency controller and may also be responsible for staff training including management training.
A Warehouse Manager is often a relatively junior position, but one calling for considerable experience of warehousing and chemical hazards.
Any or all of the above may have designated roles for emergency situations. There are two key positions, which should be identified in a safety report, these are: -
The Incident Controller is the person who assumes complete control of the site in an emergency and directs operations such as: -
The Executive Controller deals with communications with the media (press, radio and television), supervises public relations and liaises with relatives of any casualties. He also liaises with customers who may be worried about their goods. His primary function is to act as a shield for the Incident Controller so that he is not distracted from the task of emergency control/management.
At least two Senior Managers should be trained to assume the role of Incident Controller and two different manager should be trained to assume the role of Executive Controller. Alternatively three Managers should be able to take on either role.
Good emergency management is dependent on well thought out and practised emergency procedures for all eventualities. Warehouse sites should be fitted with break-glass fire alarms in strategic locations. All grades of staff should be instructed to not to hesitate to raise an alarm if a fire has broken out and looks as if it might get out of control. Immediately the alarm sounds the on-site fire fighting team should spring into action and attempt to bring the fire under control. If the fire is in a warehouse, the local fire service should be called immediately and the site fire alarm sounded. The senior member of the site fire fighting team makes decisions on these actions when the fire in not in a warehouse. The staff handbook for the site should discuss these matters at some length.
Once the site major emergency alarm is sounded, the emergency plan should swing into action and the following should be available:-
The site should have written instructions for dealing with potential run-off situations and for contacting and liaising with EA.
Staff movements and holiday rosters should be arranged so that the following members of staff are on site at all times:-
A warehouse COMAH safety report should demonstrate that the site management has in place a comprehensive system of safety rules, equipment and procedures for all foreseeable eventualities. It should therefore contain descriptions of the safety procedures for buildings and equipment including: -
The safety report should also describe the staff, systems and procedures for dealing with emergencies. These include: -
The duties of the site Safety Officer should be described in respect of: -
A section should be devoted to describing the permit-to-work system that is in operation, paying particular attention to: -
The site should have a site safety committee that meets periodically to discuss safety issues, near misses and accidents. All accidents should be investigated and an accident report prepared.
The rules governing smoking, housekeeping, site security should also be described in this section.
The safety report should describe in detail the measures and procedure that are in place to deal with spills of dangerous chemical, contamination of an employee, minor accidents, small fires and major emergencies. Inspectors should expect to see a short paragraph on the following: -
The major incident control section should include statements on liaison with the emergency services and the EA. The potential impact of a major accident on the environment should not be overlooked.
The Operator of a COMAH site should provide comprehensive training programs for all levels of staff from the most junior warehouse operator to the site director. All new employees should undergo induction training, details, of which should be given in the safety report. The principal areas covered should include: -
In addition to induction training, all staff should receive instruction on the COSHH Regulations, basic fire fighting and security. There should be at least one full-scale fire drill and one practise site evacuation annually.
Fork-lift Truck Drivers should pass a competence test set by an outside organisation before being allowed to drive fork lift trucks. Warehouse sites can train new drivers provided they have a qualified Instructor. All drivers should undergo periodic refresher courses and competence tests.
Certain supervisory staff should receive more extensive chemical safety training covering, chemical hazards, risks to individuals, the effects of chemicals on the human body, hazard sign recognition, dealing with leaks and spills and evacuation in the event of a major emergency.
Some warehouse personnel may receive training under the British Agrochemical Standards Inspection Scheme (BASIS). Ideally several warehouse keepers should hold a Nominated Storekeeper Certificate of Competence.
The Fire Team should train for 1-2 hours each week in order to ensure a permanent state or readiness and competency. Training courses should include: -
The first aiders on site should, from time to time, take part in simulated exercises with the site fire team, and practise recovery of "casualties" with specific injuries.
Managers should receive two types of training, the first to improve their proficiency and enhance their management skills and the second to practise their emergency management roles. This second type of training is particularly important and should include an annual full- scale practise major emergency lasting up to 3 hours. At these exercises, which ideally are organised by specialists, different managers should practise their roles.
The COMAH Regulations require occupiers to describe the measures taken to prevent, control and minimise the consequences of major accidents.
Companies are obliged to take all necessary measures to reduce the probability of accidents particularly those, which have major consequences for people and/or the environment. This section of the safety report should summarise the measures that are in place to minimise the probability of an accident caused by an off-site event and then go on to discuss minimisation of on-site accident initiators.
The most common causes of fires in warehouses are arson, mal-operation of equipment, poorly controlled hot-work, static ignition of flammable liquids, poor electrical installation and smoking. A site should therefore be reasonably well protected against malicious fire raisers by: -
The safety measures and procedures designed to reduce the probability of on-site accidents that are described under potential sources of major accident should be summarised here. Below are some typical examples of the summaries Assessors should expect to see.
All fork-lift trucks used inside the warehouses are maintained and regularly serviced by specialist contractors working on-site. All new drivers undergo a period of training on joining the company and periodically attend refresher courses on stacking/loading techniques and safety. The vehicles are approved for the areas, in which they work in order to reduce the probability of one of them causing a fire due to poor driving or mal operation.
The probability of a heavy goods/delivery vehicle initiating a fire in one of the warehouse is kept very small by not allowing them to enter a warehouse. Each warehouse is equipped with an excellent array of fire fighting equipment, which can be used to quickly extinguish any vehicle fire. Smoking in warehouses is strictly forbidden.
Warehouses have few electrical fittings other than the lights. The wiring should be inspected regularly and all electrical equipment in warehouses storing flammable liquids should be flame proof. Fork lift trucks operating in the warehouses storing flammable liquids should be designed for use in Zone 2. In the event of a diesel fork lift truck stalling, tests and checks, detailed in written guidance notes, should be carried out before connecting the batteries and restarting the unit.
Processes involving a risk of ignition are not carried out in the warehouse or are subject to rigorous controls. These processes include shrink wrapping, transferring flammable solvents, hot work (i.e. grinding or welding).
The section dealing with the control of major accident hazards should summarise the precautions and measures that have been implemented to extinguish/control fires. These include: -
Top tier sites should have a battery of measures and systems to minimise the consequences of a major accident. These tend to be described in the early sections of the safety report, but are summarised here. They include:-
This section should paint a convincing picture that everything that is reasonably practicable has been done to prevent, control and mitigate the consequences of major accidents: -
