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H.S .E
NEWS FROM THE HEALTH AN D SAFETY EXECUTIVE
Statutory Labelling Scheme for Dangerous Chemicals Approved Suppliers of any of about 800 dangerous chemicals - mostly used in industry, but some used in the home - will be legally obliged to put warning labels on their containers, under Regulations laid before Parliament recently. Containers must also be properly designed, constructed and secured to prevent accidental spillage during normal use. The Regulations* drawn up by the Health and Safety Commission and made jointly by the Parliamentary Under Secretary of State for Employment, Mr John Grant, and the Minister of State for Prices and Consumer Protection, Mr John Fraser, implement within Great Britain an EEC Directive on the packaging and labelling of dangerous substances.
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They have been prepared in consultation with the TUC, CBI, trade and consumer organisations, and are the first step towards establishing a standardised scheme the EEC for the labelling of all hazardous substances. Implementation will be in two stages according to container size. Suppliers have until September 1, 1978 to put labels on containers with a capacity of 200 litres or more and, until March 1, 1979 on containers with a capacity of less than 200 litres.
The basic idea of the scheme which covers such chemicals as acetaldehyde, concentrated nitric acid, hydrofluric acid, and mercury compounds, is that byreading a simple label the user of a listed substance will be able to gain quick but important guidance on its main dangers and how to handle and use it safely. *The Packaging and Labelling of Dangerous Substances Regulations (SI 1978 No. 209), HMSO, price £1.00, plus postage.
Label Composition The principal feature of a label is a pictorial symbol accompanied by a key word. A symbol shows, where possible, thelikely dangers of the chemical and is printed in back on a bright orange/ yellow background so that it stands out. Every chemical, listed in a Schedule to the Regulations, is classified according to the hazard or hazards it presents: explosive, highly flammable, toxic, corrosive, flammable, oxidizing, irritant and harmful. Each hazard category has its own symbol: an exploding bomb for explosive substances; a flame over a circle for oxidizing substances; a skull and crossbones for toxic substances; a flame for highly flammable substances; a hand and piece of metal being dissolved by liquid dropping from two test tubes for corrosive substances, and a St Andrews Cross for harmful irritant substances.
In addition the Regulations generally require each label to carry:
- one or more Risk Phrases spelling out in more detail the main dangers, 'Very toxic in contact with the skin' or 'Reacts very violently with water'; - one or more Safety Phrases givinv, advice on sensible safety precautions, e.g. 'Wear suitable protective clothing' or 'Never add water to this product': - the name of the chemical and name and address of the supplier or manufacturer which may assist doctors or first-aid staff in the event of an accident.
The responsibility under the Regulations for labelling the containers will rest with the Supplier. Manufacturers or importers will be required to attach labels before supplying directly to other manufacturers or before wholesale or retail outlets. Wholesalers and retailers will still have an to ensure that products are correctly labelled before selling them to users, but in practice it is expected that manufacturers' labels will remain on containers. Wholesalers or retailers who re-package must attach their own labels.
Minimum sizes are specified for the labels depending on container capacity but there will be room for manufacturers to put brand names and other information elsewhere on the container. Where a substance is required to be labelled under both these Regulations and under existing transport rules, allowance is made for a single label to be used which shows the requirements of the transport rules and certain provisions of the new Regulations.
Enforcement of the Regulations will generally be carried out by health and safety inspectors e.g. Factory Inspectors, of the Health and Safety Executive (the HSC's operational arm). However, in the case of shops and registered
pharmacies the Regulations will be enforced by local authority Weights and Measures Inspectors and the Pharmaceutical Society of Great Britain
The following is a list of some of the chemicals which are covered by the Regulations and used in the home:
- sodium hydroxide, anhydrous (caustic soda for cleaning drains) - formic acid (kettle descaler) - sodium chlorate (weed killer) - sodium hypochlorite (bleach)
EEC Directive
The Packaging and Labelling of Dangerous Substances Regulations implement within Great Britain an EEC Directive which is binding on all nine Member States. The Directive, incorporating the new type of label, applies only to those substances listed in the Regulations. The EEC intends however to gradually extend this form of labelling to products which contain only a proportion of one or more of the dangerous chemicals.
Since the labelling of all dangerous substances is an enormous undertaking, groups of products are being dealt with through individual Council Directives. A directive dealing with paints, varnishes, adhesives and inks was recently approved and Member States have two years to introduce legislation to implement it. Further Directives all cover pesticides, solvents and a wide range of household products such as disinfectants and cleaning agents, some of which can be dangerous in the home if not used properly.
*The Packaging and Labelling of Dangerous Substances Regulations (SI 1978 No. 209), HMSO, price £1.00, plus postage. Fees would be determined in the same way as those applying to explosives generally. For the importation of acetylene these would, under the proposals, be in the region of £14.00.
The Health and Safety Executive are requesting comments on the draft regulations from all interested parties, the period for consultation ending on 23rd June 1978.
Copies of the draft regulations may be obtained from: Mr N.P.W. Watson, HSD A2, Health and Safety Executive, Baynards House, 1, Chepstow Place, London W2 4 TF.
HEALTH & SAFETY
Draft Compressed Acetylene Regulations 1978
Proposals for Regulations to be made under sections 15(1), (2) and (3) and 43 (2) of, and paragraphs 2 and 4 of Schedule 3 to, the Health and Safety at Work etc. Act 1974 (a), as amended by section 116 of, and paragraph 6 of Schedule 15 to, the Employment Protection Act 1975 (b). Citation, commencement and interpretation
1. (1) These Regulations may be cited as the Compressed Acetylene Regulations 1978 and shall come into operation on
(2) The Interpretation Act l889(c) shall apply for the interpretation of these Regulations as it applies for the interpretation of an Act of Parliament.
Importation of compressed acetylene
NEW REGULATIONS PROPOSED ON IMPORTATION OF COMPRESSED ACETYLENE
Draft regulations have been . 1ssued (copy attached by the Health and Safety Commissior. concerning the importation of compressed acetylene.
The proposals are intended to 'd prov1 e for the of acetylene (which at present 1S prohibited except under a procedure requiring an order Signed by the Secretary of State for Employment) to be controlled in the same way as other explosives, by licence issued by the Health and Safety Executive. 2. The provisions of section to (e)of the Explosives Act l875(d) relate to the importation of explosives under licence) shall apply to the importation of compressed acetylene into the United Kingdom as they apply to the importation of an explosive; and for this purpose "compressed acetylene" means acetylene subject to a pressure exceeding 0.62 bar above pressure. 3. Order in Council No. 30 dated 2nd February 1937(e), as amended (f), shall not apply to any acetylene in respect of which a licence has been issued by virtue of Regulation 2 of these Regulations so long as it remains in the container in which it is imported.
4. A fee £12 shall be payable to the Health and Executive on the issue each licence granted by virtue of Regulation 2 above. (a) 1974 c.37. (b) 1975 c.7l (c) 1889 c.63 (d) 1875 c.17 (e) S.R.&O 1937/54(Rev.VII, p.66: 1973, p.729). S.R.&O 1947/805 (1947 I p.7l7).
The statutory potentially hazardous installations to the Health and Safety Executive is proposed in regulations published today by the Health and Commission in a Consultative document*
The proposed regulations arise from the First Report the Advisory Committee on Major Hazards** They would enable the Health and Safety Executive (the Commission's operational arm) for the time to acquire about the activities of installations holding significant quantities of specified hazardous sUbstances and to build up a complete picture of the number of potentially hazardous installations in Britain. The regulations would apply to installations, whether existing or proposed, where speicified quantities .of the substances concerned are stored, manufactured, processed or used. These provisions would also include the transfer substances by pipeline and handling operations in the course road, rail or sea transport.
The proposed regulations set out the substances concerned, the quantities held which would call for and the details what would be included in the notification.
On premises where there are substances in quantities ten times the notifiable level, a nazara survey would be required. This would include such details as diagrams of any plant containing more than the notifiable quantity of any hazardous substance; factors tha"t could cause a catastrophic release of energy or of the substance notified and the measures taken to prevent or control this; factors that could cause a smaller but continuing release of the substances notified; and the measures taken to prevent or control such releases. The hazard survey and any more detailed assessment, 1I,i. ich may be called for in circumstances of exceptional risk, would enable the Executive to identify those installations which could pose a threat to safety, and also to consider any enforcement action that might be necessary.
The proposed regulations would not apply to any notifiable activities at sites licensed under the Explosives Act 1875; to any vehicle, vessel, aircraft or hovercraft which is being used for transporting the substances, nor to any radio-active substance. A draft guidance note, which is part of the document, sets out the framework for the carrying out of hazard surveys.
* "'Draft Hazardous Installations (Notification and Survey) Regulations," HMSO 50p ** "Advisory Com.rnittee on Major Hazards First Report." HMSO £1.00.
CANVEY ISLAND REPORT RECOMMENDATIONS FOR IMPROVEMENTS TO EXISTING AND PLANNED INSTALLATIONS WOULD CUT EXISTING RISK
An investigation of the risks to the people living on and around Canvey Island from existing and proposed industrial activities, the report of which was published recently shows that the picture that emerges should not cause fear and worry amongst people living in the area. The most likely outcome is that nothing should happen in these installations which will hurt anyone outside them. However, the report adds that steps can and should be taken to further reduce the chances major accidents in the installations. If all the recommendations made in the report are carried out, even though additional refineries were authorised, the risk the industrial activities in the area would be substantially reduced, it says.
The report* consists of two selfcontained parts. Part One has been prepared by the Health and Safety . E txecu · l.ve as a summary of the . stigatl.l.nve on , its main results, and suggested action to ensure improvements. Part Two, together with its many appendices, is the detailed technical report of the investigating team, and is based on
information about the existing and proposed installations in the area known to the team up to December 31, 1977. The investigation was carried out by a small team of experts mainly. from the United Kingdom Atomic Energy Authority's Safety and Reliability Directorate.
The Health and Safety Commission asked the HSE, their operational arm, to carry out the investigation after a request from the Secretaries of State for the Environment and Employment. This followed the publication by the Department of the Environment of the report of an exploratory public inquiry into the desirability of revoking the planning permission given in 1973 to United Refineries Ltd to build an oil refinery on the island. The report contained a recommendation by one of the technical assessors that a study of the risks in the area should be made. refining facilities for Mobil Oil Co Ltd and for new refineries for Occidental Refineries Ltd., and United Refineries Ltd) , would further add to the risk, but it is the view of the Executive that changes can be made which would eliminate most of the addi tional risks from the propos'als and "therefore we could proffer no objection to their construction on health and safety grounds;"
- while some incidents involving intercations are foreseeable, the analysis does not suggest there is a possibility for a "domino" effect, one incident progressively setting off a series of hazardous events;
- the eight knot speed limit should be strictly enforced in the Thames estuary by the Port of London Authority to prevent or minimise the effects of ships leaded with toxic or flammable substances being involved in a collision;
The Executive's report asks for improvements both to existing plant and proposed installations which woula substantially reduce the chances of a major accident or minimise the consequences should one occur. The necessary expenditure by the operators is reasonable in relation to the substantial reduction in risk which would be secured, it says. Work has already started on implementing some of the recommendations, with inspectors putting the improvements to the firms concerned. They will, if necessary, .use their enforcement nowers to require the improvements.
"We consider that our prinCiple should be not to permit any new proposals to introduce significant additional risks of a major incident which would injure people. We would propose to use our own powers in the Executive to this end and recommend that other controlling authorities should do the same," say the Executive in a letter of submission of the report to the Health and Safety Commission.
Among the main recommendations and findings of the report are:
- provided the recommended improvements are made to the eXisting plant, the Executive say that they do not consider the situation to be such that any of the existing installations should now be required to shut down; - for some emergencies an additional road from the east of the island could be beneficial, but in the majority of emergencies people might be better advised to stay indoors rather than attempt to leave.
The improvements called for by the Executive· are listed in the report along with a number of potential hazards it identifies requiring very thorough assessment by the firms concerned.
Numerical Assessment of Risks
Numerical assessments of risk are made in the report and are expressed as chances a year of an individual being killed (individual risk) and of killing more than 10 people at a time ("societal" risk). Different assessments of the individual risks for seven regions in the area are contained in an annexe. A further annexe examines the societal risk of a range of accidents at the existing and proposed installations. The report through a long and complex series of analyses concludes that the chance of a person in Canvey and Stanford-le-Hope being killed as a consequence of a major accident at existing installations is on. averaP.'e about the same as the average risk shared by every person in the 25-34 age group in this country in any one year he could die from natural causes. This level of risk, of about
5 chances in 10,000 a year, would be reduced by about two thirds if all the improvements asked for in the report were adopted at existing and proposed plant. The report acknowledges that its figures may be an overestimate of the chances of serious accidents occurring as it feels it proper in an investigation of this kind to err on the side of caution. It adds: "All of the accidents discussed in this report are theoretically conceivable, and some have occurred, although never anywhere in the world in such a way as to result in the large numbers of casualties judged to be possible by the investigating team." Proposed Developments. The report looks at three proposals for further refining facilities in the area. In its view the revised proposals for the Mobil extension not result in any significant increase in risk to persons in the area."
On the accidental and United Refineries Ltd proposals the report says: "Provided the companies were to build their plants in accordance with our requirements and made alternative arrangements for trans-shipment of the LPG (Liquified Petroleum Gas), we consider that the building of the new refineries would not result in a significant additional risk to the residents of Canvey Island and therefore we could proffer no objection to their construction on health and safety grounds,"
First Investigation of its Kind
The investigation was unique, the first of its kind in the UK and probably in the world, says the report. It began in April 1976 and was expected to be completed by the of that year. In fact the task of the investigating team proved to be far more complex than had been expected and it was not until February 1978 that the work was sufficiently comprehensive for the renort to be prepared. Further work needs to be carried out for there remain some uncertainties in the assessment. Some of the issues raised by the investigation have national if not international implications. The expertise of no less than 30 engineers, chemists and other specialists had been utilised at various stages of the appraisal and the cost of the investigation was about £400,000.
"During the preliminary visits to the premises selected for assessment the investigating team were reassured to find that where hazardous materials were being processed, handled or stored, the mangements were generally very responsive to matters of operational safety. Where relevant Codes of Practice were available these had been taken into account in the design and construction of plant and facilities," says the report.
It adds: "However, these visits also established that none of the companies concerned had made a systematic attempt to examine and document those few potentially serious events which might cause accidents among people in the surrounding community."
The Commission, in submitting their report to Ministers, stress that the assessments of activities at any of the sites concerned cannot be applied directly to similar installations or areas elsewhere in the United Kingdom because so much is dependent on individual circumstances and variations in topography, weather, process and layout.
Dealing with the investigation's general approach, the Commission point out the Safety and Reliability Directorate's special techniques of hazard evaluation entailed considering every theoretically possible accident, however unlikely, together with the range of casualties that could possibly result. In addition, the investigating team had been instructed by the Executive to be as realistic as possible in its appraisal and in cases of doubt not to err on the side of optimism. It was recognised that this approach could be controversial and that the results could be misunderstood but it was accepted that this was the most meaningful way of comparing the different risks involved.
*Canvey: "An investigation of Potential Hazards from operations in the Canvey/ Thurrock area". Part One: "A summary by the Health and Safety Executive", Part Two: "Report of the Investigating Team". Part One is available from HMSO price £1; also available are Parts One and Two together, price £10.
