12 august 2019 hazardous chemicals and dangerous goods and … · 2019-10-24 · training 3....

12 August 2019

Hazardous Chemicals and Dangerous Goods and New Australian Standards for Chlorine Gas

Tim Scott

Nathan McCluskey

50th LIWA Conference Presentation 12-13 August 2019 Fremantle WA2

“Hazardous Chemicals and Dangerous Goods

and New Australian Standards for Chlorine

Gas”

Part 1:Chemical Risk Management

Part 2:AS2927:2019

Update

• What is it?• Which chemicals are of interest?• What can happen when it goes wrong?• What should you be doing?

• What has changed?• What are the new requirements for

pools?• What are the new Separation distance

requirements?• What is the road map to compliance?

WHAT IS CHEMICAL RISK MANAGEMENT?


Chemical Risk Management is the process employed, looking at the three key elements of;

1. Chemical Systems

2. Training

3. Emergency Response

To minimise the risk, and mitigate the consequences, to the individual, site, and public presented by the use of hazardous chemicals

Some of this ‘stuff’ is given to us through regulations, codes of practice, and standards…. …..But some of this we need to do ourselves, under broader responsibility and societal requirements

WHICH CHEMICALS ARE USED THAT REQUIRE CONSIDERATION


Chlorine Gas Sodium

HypochloriteCalcium

HypochloriteHydrochloric

Acid Chlorinated

IsocyanuratesSodium

BisulphateAlgaecides

These chemicals can interact with each other to form dangerous by-products or conditions

WHY IS THIS IMPORTANT IN THE POOL INDUSTRY


Effective Chemical Risk Management in the pool industry faces a unique set of challenges not seen elsewhere.

• Itinerant workforce – lifesavers move around

• Public exposure – kids, elderly

• Complacency – we haven’t had a problem

• Lack of support – other priorities can impact

• Access to funding – some of these can be costly

• Awareness of the risks – it may not be part of their job tasks

• Priority – it’s not the most obvious risk in a pool (drowning)

A combination of these aspects requires a considered approach to minimise cost to manage (equipment and human capital)

WHAT HAPPENS WHEN IT GOES WRONG


ABC Report 19 Sept 2018

“Sydney Pullman Hotel gas leak: 30 guests treated after pool chemical mix-up”

“Guests of the Pullman Sydney Hyde Park hotel have been treated for respiratory problems and eye irritations after a gas leak”

Inadvertant mixing of non-compatible chemicals “hydrochloric acid and chlorine”

Fumes entered ventilation system and lift shafts on 22nd floor

A number of fire appliances, HAZMAT respond to the 000 call

30 people impacted, 6 taken to hospital with respiratory problems and eye irritation

Reputational damage to the Hotel

WHAT HAPPENED?


CHEMICAL SYSTEMS


“The hardware and the instructions on how to run and maintain them”

➢ Chemical installations – are they compliant, are they easy to maintain

➢ Procedures – do they clearly lay out the steps required

➢ Policies – do they cover how people are expected to behave

➢ SDS – are they accessible and are they understandable

➢ Labels – do they clearly state the risks

➢ PPE – should be appropriate to the chemical

Getting this element right will give you the best improvement in your risk profile

Some regulations and standards are focused on this area e.g. AS2927 The storage and handling of liquefied chlorine gas

POOL INSTALLATION – 920KG DRUM


TRAINING


“Turning Information into Knowledge”

Training should be done with consideration of the chemicals and the chemical systems employed

➢ It should be specific for the chemicals involved as they have their own risk characters

➢ It should cover the procedures and PPE required

➢ It should have elements of competency to the training to demonstrate understanding

➢ It should be focused on the important elements that keep people safe

➢ It should be delivered by someone with experience with the chemicals

➢ It should be delivered by someone with experience in training or coaching

COMPETENCY IS CRITICAL


The key to effective training is for the learner to demonstrate competence and understanding

Training material should be constructed to allow the learner the opportunity to do this

This can be done via written or oral assessments, and practical exercises

Powerpoint presentations, on their own, do not allow anyone to demonstrate anything

Under the new AS2927:2019 “The training program shall provide for revalidation of skills and knowledge…” – this implies competence needs to be demonstrated.

EMERGENCY RESPONSE PLANS


For when the preventative measures have not been able to prevent an incident, and the incident becomes non-controllable using standard procedures (i.e. it becomes an emergency and assistance is required)

Important to have an ERP that is simple and easy to follow with clearly identified roles and responsibilities, and captures communication lines

It should be tested on a yearly basis – “Your ERP is only as good as your last exercise”

Testing done via two processes

I. Desktop Review – Tests the ERP content and applicability

II. Field Exercise – Tests the human response and communication channels

It should be done in consultation with local Emergency Services

WHY DO YOU NEED TO INVOLVE EMERGENCY SERVICES


Incident at a pool using On-site Electrochlorination – ‘chlorine smell identified, 000 called’

40 Firefighters, 13 Appliances including HAZMAT and Breathing Appliances, plus Police

Local Roads shut-off and traffic re-routed

Is this a ‘Proportionate Response’? [Has the pool been charged for this level of response?]

Would this level of response occurred if there had been consultation during the construction of the plan AND involvement in reviews and exercises?

WHY ARE FIELD EXERCISES IMPORTANT?


Emergency Exercise for chlorine gas conducted at a major Qld WWTP

ERP had gone through a Desktop Review process successfully

Involved ‘person-down’ scenario

Orange flare used to substitute for ‘chlorine plume’

Ixom involved in “Observe and Report” capacity

Exercise resulted in 1 casualty becoming 6 due to Human Responses

• Operator rushed in to ‘save his mate’

• Contractors evacuated to safe place through the plume

WHY DOES LOOKING AT ALL THREE ELEMENTS IMPROVE CRM


Chemical Systems

Training

Emergency Response

Improvement in Chemical

Risk Management

WHAT CAN YOU DO?


Some simple actions that can be followed up on;

1. Audit your chemical installations to relevant standards

2. Risk Assessment of the chemicals present on your site

3. Information sharing with similar complexes

4. Talk to LIWA about where to get help

5. Train your people in awareness and operations of the chemicals and systems on site

6. Ensure that the systems are maintained

7. Speak to Emergency Services about what you have and what you’d expect them to do

Over to Nathan….

AS2927:2019


• Current revision of AS2927 was developed in 2001

• Significant changes in small to medium size chlorine technology since this time (vacuum systems)

• Updated standard currently under development, with second draft released

• Expected to be finalised and implemented before the end of 2019

• New chapter specific to pools

• Specific separation distances for pools, along with general separation distance table

REQUIREMENTS FOR POOLS


• Only acceptable configuration is vacuum vapour withdrawal – no pressure pipework

REQUIREMENTS FOR POOLS


• Leak detectors

• Automatic shutoff devices

• Wind direction indicators

• SCBA Required

• Inventory on site to be minimised

ADDITIONAL RISK CONTROL MEASURES


Additional measures to consider (not mandatory)

• Replacing drums with cylinders

• House chlorine in a building designed to significantly reduce the rate of escape from the building

• Limiting deliveries and changeovers to off peak hours

• Linking mechanical ventilation (if fitted) to leak detector systems to isolate in a chlorine leak

• Effective door and ventilation seals to contain leaking chlorine

• Chlorine scrubber

• Containment vessels

POOL SPECIFIC SEPARATION DISTANCES

2250th LIWA Conference Presentation 12-13 August 2019 Fremantle WA

SEPARATION DISTANCES


SEPARATION DISTANCES

24

Hospitals, schools, etc

Houses, apartments under 4 storeys

Factories, offices, shops, sports grounds


SEPARATION DISTANCES – 4 X CYLINDERS

25

Pool

Open Recreational Area

Flammables

Enclosed Public Area

Child Care Centre

Chlorine Room – 4 x Cylinders

3m

15m

15m

15m

Property Boundary

Factory

Public Park

Houses

Hospital

15m*

15m

15m

15m

8m

2m

8m

7m

2m

5m

7m

2m

2m


SEPARATION DISTANCES – 1 X DRUM

26

Pool

Open Recreational Area

Flammables

Enclosed Public Area

Child Care Centre

Chlorine Room – 1 x Drum

3m

25m

25m

15m

Property Boundary

Factory

Public Park

Houses

Hospital

25m*

25m

25m

25m

15m

3m

35m

3m

20m

30m

3m

3m


AS2927:2019 – OTHER CHANGES

• Changes to acceptable ventilation requirements and modes of operation

• Location of chlorine vents

• Design and replacement of flexible vacuum pipework

• Monitoring of leak detector of alarms

• Training requirement – No greater than every 3 years OR if personnel have not completed the task for 18 months

• Regular testing of emergency plans


AS2927:2019 – OTHER CHANGES

• New chapter specific to storage only areas and transit areas

• Management of moisture

• Vacuum regulators are not isolation points

• Use of activated carbon canisters

• Drum lifting equipment – minimum 2 tonnes

• Changes to required gloves

• Flushing of air/chlorine mix from standby regulators

• Regular exercising of valves

• Management of change


ROADMAP TO COMPLIANCE

Audit to AS2927:2019 to determine

gaps

Review required inventory

Review separation distances

Install vacuum systems

Install windsock

Install leak detectors

Install Automatic

Shutoff Devices

Review Staff Training

Review Emergency Procedures & Testing


12 august 2019 hazardous chemicals and dangerous goods and … · 2019-10-24 · training 3....

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