Truck and Track Autumn 2021

Truck and Track Autumn 2021 60 DANGEROUS GOODS As Multimodal 2021 is almost upon us, following the success of September’s CHEMUK 2021 EXPO also hosted at Birmingham’s National Exhibition Centre [NEC] – our dangerous goods columnist Ali Karim FRSC CChem, provides our readers with an insight into supply chain considerations for Managing Risk in the Warehousing and Storage of Chemicals & Dangerous Goods. Previously co-founder and Managing Director of Hazchem Network and Director of UK Operations for Linde Gas – Karim also draws upon his experiences as a young Industrial Chemist at London and Coastal Oil Wharves Ltd [Canvey Island], Chemicals Inspector in the Arabian Gulf, Terminal Manager at TDG Pinnacle Storage [Dagenham] – where he was involved in the storage, measurement [quality and quantity] and warehousing of both bulk liquids and gases as well as packaged dangerous goods. In previous Dangerous Goods Columns at Truck and Track, we have featured information related to the regulatory framework that people and organisations in Europe have to comply with when working in 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 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 such as the Nitrates of Potassium, Sodium and Ammonium away from flammable chemicals. I have 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 class 3 [flammable liquids] and class 4 [flammable solids], as well other restrictions. Risk assessment At the top of the list are what we term the risk assessments, which examine the Hazards posed, and then the associated risks from which countermeasures need to be put into place to manage the risk. When working with dangerous goods you must formally document risk, in a written and periodically reviewed assessment. Risk Assessment is best examined and managed by this matrix. In order to produce a robust risk assessment, it should be carried out by a qualified and experienced team, understanding the product’s chemical and physical properties to begin with, and relate to quantities, managing leakage, spillage, training, environmental issues, personal protective equipment [PPE], managing an incident, and many other factors – input from your Dangerous Goods Safety Advisor/Consultant [DGSA] is vital. Change control Many people do not understand the concept of the ‘law of unintended consequences’ . When you work in Chemical/ Pharma/Nuclear industries robust management of change control is vital; but what is change control? All industries make changes, in process, and in operation for many reasons – but when you do make a change, you have to be mindful of ‘unintended consequences’, so all people and departments need to be consulted. As a result, within highly regulated industries, there is a formal and documented process to manage change. Before any change in an approved process or operation is sanctioned, it needs consultation and ‘sign off’ by all involved [the “stakeholders”] so, collectively, the whole team can have an input to effectively reduce the ‘law of unintended consequences’ when the changes are implemented. Managing Risk in a Multimodal DG Supply Chain by Ali Karim Ali Karim TRUCK & TRAILER SOLUTIONS WELCOME TO ALLPORTS GROUP