Truck and Track Autumn 2023

Truck and Track Autumn 2023 72 DANGEROUS GOODS I work for Adler and Allan where the management of risk is our core purpose in assisting the operations of our clients and customers. We were present at both Chem UK 2023 at the Birmingham NEC as well as Hazmat 2023 in Stratfordupon-Avon this summer. The focus of discussion naturally pivoted on how organisations can manage their own specific business risks, especially those of a safety and environmental nature. This article references where you can gain help in managing the risks associated with the carriage of Dangerous Goods by road and sea, as well as storage. In previous Dangerous Goods Columns at Truck and Track, we have featured information related to the regulatory framework that people and organisations must comply with when working within the Dangerous Goods Supply chain, including ADR/RID regulations for Road, IATA/CAA for Air and IMO/IMDG for Sea – in terms of carriage. Following the Seveso chemical disaster in July 1976, in Italy, strict regulations for the storage of chemicals / Dangerous Goods came into effect, and are referred to as the “Seveso Directives” in Europe, and are implemented in Great Britain through the Control of Major Accident Hazards (COMAH) Regulations. These directives are in place to regulate the storage, warehousing and associated activities for those involved with Dangerous Goods. The Seveso Directives and COMAH regulations are complex instruments that interface ‘the site’, and its surroundings, linking both authorisations for the quantity, as well as the type of products permitted to be stored, thus managing the risk. They include aggregated quantity by risk class, as well as ‘named substances’ (the more problematical products). COMAH regulations are placed in “tiers” – (a) Sub-COMAH – lower risk sites Where quantities and type of products are below the thresholds outlined under the COMAH regulations, but even in this case, risk management protocols have to be deployed where specific regulations apply, such as the 1974 Health and Safety at Work Act and many others specific to the site and activity. (b) Lower Tier COMAH – for medium-high risk sites (c) Higher Tier COMAH – for highest risk sites Like all effective regulations, they are reviewed and updated on a regular basis. New (updated) Control of Major Accident Hazards (COMAH) Regulations came into force in Great Britain on 1st June 2015. There are some important changes particularly on how dangerous substances are classified and information that has to be made available to the public, so your Dangerous Goods Safety Advisor (DGSA) will keep your operation in compliance. Both top tier (now referred to as upper tier) and lower tier operators need to provide public information electronically and keep it up to date. One of the many protocols of the Seveso Directive / COMAH Regulations include having accurate information about the site, and its permitted storage areas for the local authorities and emergency response organisations. As part of this protocol, documented drills and emergency exercises are crucial. Product knowledge and segregation is also critical, such as keeping Oxidising Agents including the Nitrates of Potassium, Sodium and Ammonium away from flammable chemicals. I follow a simple rule - “red and yellow do not mix”, ie one must keep Class 3 (flammable liquids) and Class 4 (flammable / reactive solids) – which are characterised by red ADR diamonds - away from Class 5.1 (Oxidising Agents) and 5.2 (Organic Peroxides) – which are characterised by yellow ADR diamonds. Even with basic warehousing guidelines (below COMAH thresholds) issued by the Health and Safety Executive, there are restrictions on what can be warehoused with what, for instance class 5.2 Organic peroxides are not permitted to be stored in the same warehousing building as Managing Risk in the Dangerous Goods Supply Chainby Ali Karim Ali Karim In this issue, our Dangerous Goods Columnist Ali Karim BSc FRSC discusses ‘the management risk’, to assist those working in the Dangerous Goods Logistics sector TRUCK & TRAILER SOLUTIONS WELCOME TOALLPORTS GROUP