Chemical substances safety measures
An engineering company has been sentenced for safety breaches after two of its workers were burned when they were sprayed with chemicals during chemical cleaning of a pipework system.
In July 2014, two employees of PSL Worldwide Projects Ltd were working at a Hyclone UK Ltd site in Cramlington. They were using Sodium Hydroxide granules to clean a pipe system. A reaction occurred between the chemicals and water in the system that caused the liquid to heat up, building up pressure in the hose. The hose then detached and sprayed the two workers with the solution, causing severe burns.
One worker received life-threatening burns to his back, buttocks, arms, leg, neck and one side of his face. His injuries were so severe he had to be resuscitated on admission to hospital. His colleague received burns to the right side of his head, his neck, back, left arm and behind his right ear.
The HSE launched an investigation, which revealed that:
the task was not adequately risk assessed by the company,
the equipment provided to do the job, in particular the hosing, was not suitable for the solution, and
the company failed to provide adequate personal protective equipment (PPE) to its employees.
The company initially denied breaching Section 2(1) of the Health and Safety at Work Act 1974 breaches but then withdrew from the court process and was found guilty in November 2016 after a trial in the absence of any of its representatives.
The prosecutor told the court that “the company has not engaged in this process whatsoever” and that any compensation for the injured men would now be dealt with by the firm’s insurers. The judge said that “the whole thing must have been traumatic and upsetting for the injured men” and that the conduct of the business representatives since the accident was “regrettable”. She went on: “It seems very regrettable, in a case where people are seriously injured, that the corporate beings have effectively walked away.”
The firm was fined £150,000 but no costs were awarded due to the company being in liquidation.
SDS, MSDS, COSHH, CLP, REACH, hazardous substances, toxic, harmful, corrosive – the list goes on…
Scratching your head? A lot of employers do!
This is one area you really need to come to terms with because it can quite easily kill.
It is not rocket science; it just requires a methodical approach to it and if you require help, ask.
Looking at the prosecution in the case above, for example, what could have been done differently?
It is all too easy for a company to use their usual cleaning procedure (which has probably been risk assessed and used without incident for years) without checking what has been previously been carried or used in the vessel/pipework.
This becomes routine, so any change in the substance that has been carried is assumed to be the same.
The first time a different substance is carried, it can react violently with the normal cleaning products.
All companies working with hazardous substances should consider the following points:
Create a COSHH register listing all the substances they use or come into contact with.
Download Safety Data Sheets (SDS) for the substances from the manufacturers and keep the list up to date.
Staff should know where SDSs are kept so in the event of an incident the documents can be handed to the emergency services to provide vital information when giving treatment.
Ensure a competent person carries out the COSHH assessment.
Don’t forget when completing your first aid risk assessment that you may require additional items to treat contact with the hazardous substance.
Take special care when considering who may be affected e.g. new and expectant mothers, young/old persons, anyone with certain medical conditions.
Look for “risk ratings”. These are codes and give specific phrases of the harm that could be caused in certain conditions.
Communicate the findings of the assessment with anyone who may be involved with the substance e.g. your employees, contractors, customers.
If your hazardous substances will be used where they come into contact with other substances, check with the manufacturer that they will not react.
Also check for any special instructions on the product that warns of substances they should be kept away from (certain domestic cleaning products, if mixed, will create toxic gas).
Train staff and arrange for regular refresher training – keep records.
Always store substances correctly as per the manufacturer’s instructions.
Never, never decant hazardous substances into unlabelled containers (this happens so many times and has been responsible for numerous deaths).
Use method statements when required.
Implement a “Permit to Work” system if safety critical.
If the assessment control measures state PPE/RPE is required, ensure it is the correct type for the hazard and stored correctly. Ensure that staff are shown how to use it and monitor how it is worn and used.
Carry out regular monitoring.
Review and update your H&S policy when required to reflect any changes.