The safety section provide a service to allow the Process and Maintenance sections to complete the required work safely. The service includes issuing of safety equipment from the safety centre , site inspection tours, servicing and monitoring of site based safety equipment and auditing of the safety certificate procedures and associated paper work.
The SPMs are responsible for carrying out regular Planned General Inspections (PGI) of all areas of the site. These are monthly tours of each area to inspect the general condition of the area , cleanliness, condition of safety equipment , and general amenities. It is essential that an operator accompanies the SPM during these tours to ensure that the operator has an input to the report. Each plant area has it’s own specific inspection sheet which should be filled in and then kept. Each item detected must be given a priority rating. Before each tour the previous tour report should be consulted and the SPM and operator ensure that listed defects have been corrected. Maintenance work orders should be generated for any defects found
Planned general inspections are part of the requirements of the International Safety Rating System (ISRS) safety management program. The system is the basis for a number of other “safety” related administration systems. Many of these systems are documented in a green loose leaf folder entitled Health and Safety Manual.
An accident and incident report form is used to record all accidents and incidents on the site. It is essential that the SPM speaks to the people who were involved or present at an incident before completing the report. The form has a space in which immediate actions to prevent occurrence should be recorded. The report forms the basis on any further investigation or initiation of disciplinary action.The form can also be inspected and used by external agencies as part of there investigations into incidents.
Once completed a copy should be stored in the SPM folder, a copy sent to the Work’s Manager’s secretary for filling and the original sent to the relevant process manager. The front of the SPM folder contains a summary of all incidents within the year. The next sequential number should be used for the AIR. A copy of the fully completed AIR should be returned to the SPM for inclusion in the folder.Other administration systems based around the Safety Section are listed below and are detailed in the Heath and Safety manual. The SPM should be familiar with the working of each of these systems and, in particular, his role in them. Details of the systems can be found in the Heath and Safety manual.
- Monthly plant safety tours.
- STOP tours ( Safety training observation tours )
- Safety rules for work groups.
- Plant defect reports.
- Refusal to work on grounds of safety and health hazard.
- Emergency preparedness.
- Colour coding of valves and switches.
- Health control and monitoring surveys.
- Conformance with the requirements for the Control of Hazardous Substances. (COSHH)
The company has a Health and Safety committee with elected workforce representative as required under the H&SWA. The committee meets at about monthly intervals and any member of the work force can ask there elected representative to raise issues at this meeting. The SPM would normally attend the Safety Committee meeting.
A Suggestions Committee meets around once per month. Industrial staff are encouraged to suggest improvements to plant operations or maintenance procedures. These suggestions are then assessed by a panel of people usually including a SPM. Actions arising from the suggestion are normally assigned to the SPM or maintenance manager. The originator of the suggestion will receive a cash award based on the assessment of the panel.
A Duty Manager system is in operation. This provides the SPM with another senior manager who is on call and can be contacted by bleeper or phone at any time. The Duty manager should be contacted whenever there is an on site incident which could have off site consequences or could generate off site interest. In addition the Duty manager is available to deal with off site incidents such as road transport incident.
The safety section are responsible for the running of the site fire service. The site has two fire engines which are stored in the fire station adjacent to the safety centre building. In addition fire fighting equipment is located in sealed boxes at several locations around the site. Each shift have a number of trained fire man who are regularly trained in the operation of the fire station equipment. Members of the section are responsible for the inspection and servicing off all the mobile fire fighting equipment on site.
The compliance manager is responsible for the management of the safety section. He is also responsible for the site emergency plan to deal with fire , chemical release and major emergency. It is essential that the SPM is well versed in the operation of these plans and is confident in his own role.
As part of the emergency plan an automated call in system is available. This should be initiated by the SPM using a pre-recorded voice mail phone based messenger system. Once initiated the system will call a predefined list of employees with a simple menu selected pre-recorded message. The employees nearest to the works are called first to ensure a rapid response to site incidents. The system should be used by the SPM to initiate a test call on the first Thursday in each month.
The safety centre is responsible for the charging and inspection of the site portable gas monitors. These are used to enable work to be carried out in potentially flammable atmospheres or where toxic vapours or low oxygen concentration could become present. The monitors are often issued to contractors or employees and there location should be recorded on the board in the safety centre. They should be returned to the safety centre at the end of each day for charging.
The Safety Centre has a Breathing air compressor which is used to replenish BA cylinders. The system can be used to recharge a number of either normal and light weight cylinders at a time. It is useful for the SPM to know how to operate the recharging system.
The safety centre also contains equipment as part of our commitment to the Chlor-aid and Brom-aid schemes. These schemes are described later. The equipment allows small leaks of material, maintenance of tankers or response to other incidents to be carried out quickly. The equipment is stored in plastic boxes for easy shipment.
The site has a number of alarm systems. Some of these cover the whole of the site some just specific plants.
The major emergency alarm system can be activated from two positions. One in the SOT control room and a second in the prechlorination hut near to BOT2 pump house. The alarm should be used when there is a risk of off site consequences from some failure of containment on site. The major emergency procedure as listed in Reference 2 should be initiated if the alarm is activated. The alarm is tested monthly.
The site fire alarm can be activated from the SOT control room or gate house. The fire service should be called if there is an on site fire. The site fire procedure should also be activated. See Reference 2.
A site fire and smoke detection system has an alarm panel in the SOT building. The system monitors various areas around the site and will give an indication if smoke or fire is detected. If the local alarm panel indicates smoke or fire has been detected in a particular area , a site fire man and at least one other person should investigate. If necessary the site fire alarm system and procedure should be initiated.
Some areas of the MPBF plant are fitted with fire detection units. Any fire detected will initiate an audible alarm in the control room. In some cases the alarm will also automatically initiate the fire water and foam system.
The site gas alarm should be sounded as a warning to those on site if there is a significant escape of any gas. Everyone on site should following the relevant instructions. The gas alarm is tested monthly.
Automatic bromine detection systems are situated around the SOTs, bromine packing and loading area. A similar system is fitted to the MPBF plant. This equipment gives an annunciated panel alarm. Any alarm should be investigated and if necessary the site gas alarm sounded to warn others. At the moment the system will sound an alarm but take no action. In the future it is possible that the alarm will be used to actuate automatic shut down systems.
Automatic chlorine detection systems are situated in the chlorine house area. This equipment gives an annunciated panel alarm. In some case they also activated trip systems in the chlorine house. Details of the system and trips will be found in the chlorine operating manual.
An ethylene gas detection system is fitted to the vent on the DBE reactor ventilation system. Any alarms should be investigated and if necessary the reactors taken off line and ethylene isolated. In addition BOT2 pumps should be taken off line if ethylene gas is detected outside the LEP perimeter fence.
The liquid ethylene plant is fitted with an automatic flammable vapour detector system. A number of point detectors are located within the LEP. A ring fence detection system is also in operation. The detection of a flammable atmosphere above a threshold limit will activate the detector alarm system.
This results in an audible and visual alarm outside the LEP South gate and also with in the Sot control lab.
A flammable gas detection system is fitted to some areas on the MPBF plant. If the alarm sounds the area should be carefully investigated.
The Chemical Industries Association (CIA) is a umbrella association for all UK chemical manufactures and industries. One of its functions is to provide members with assistance in case of a chemical emergency. This is normally by a local member company offering assistance in any chemical incidents away from the home base of a company. The scheme is called Chemsafe.
Any call to assist in a Chemsafe type incident should be passed on to the Duty Manager who will deal with the incident and arrange for GLC(E) personnel to assist as required. The equipment to enable us to assist is stored in the safety centre.
Chlor-aid & Brom-aid
This is a response system similar to Chemsafe but with the specific knowledge of chlorine or bromine handling run by those companies involved in their production companies.
The Environment Agency
The site has three authorisations under the integrated pollution control ( IPC ) legislation. The authorisations are detailed in the IPC compliance guide. Reference 16 and are contained in a red folder in the SPM bookcase.
The authorisations cover the following processes:-
AL8533 Production of DBE which includes all bromine ,Sulphur dioxide and sulphuric acid processes.
AL8550 Production of DBM and BCM which includes all HBr gas and acid processes.
AT8835 The MPBF process.
The IPC regulations require the company to carry out the processes using the “Best techniques not entailing excessive costs (BATNEEC)
Each of these processes have approved release points for both water and to air. Each of these release points have a release limit and sampling frequency. The Process laboratory are responsible for monitoring these points on a regular basis and for producing monthly and yearly summaries to the Environmental Agency.
Any release which takes place other than from an authorised release point or exceeds the level of material that should be released at that point is a breach of the regulations.
There are clear and unambiguous requirements for formal notification to the Environmental Agency in the event of detection of releases which breach the conditions of the authorisations. In addition it may be necessary to inform them of any malfunctions or breakdowns which have the potential to cause serious pollution of the environment.
The conditions of the authorisations are a combination of concentration limits and mass flow limits. The need to inform the Environmental Agency must be checked out very carefully if a breach of consent is suspected.
Health and Safety Executive.
One of the main functions of the H&SE is to ensure that the conditions of the Health and Safety at Work Act (H&SAW) and the regulations that follow it are up held. Their inspectors make regular visits to the site during normal hours.
The Compliance manager is responsible for the formal reporting of significant incidents and accidents to the HSE under the terms of the Reporting of injures, diseases and dangerous occurrences regulations. (RIDDOR). However the SPM may become involved with initial reporting to the HSE of reportable occurrences “with out delay”.
The following is a brief summary only the official regulations should be consulted before making a report.
The following are reportable accidents:-
- A death or major injury on site. Major injures are defined in the booklet and include fractures or amputation of limbs. Dislocation of large joint. Loss of sight and eye injures. Injuries following electric shock or causing unconsciousness.
- A member of the public is killed or taken to hospital.
The HSE must be notified by telephone or fax without delay. Within 10 days a completed official report form (F 2508) must be sent to the HS&E.
The following are dangerous occurrences which could occur on our site. These must be reported on the official form but do not require an immediate notification.
- Failure or collapse of load bearing parts of lifting equipment.
- Bursting or collapse of any closed vessel.
- Plant or equipment coming into contact with overhead power lines.
- Electrical short or overload causing fire or explosion.
- Any unintentional explosion.
- Malfunction of breathing apparatus during use or on test immediately before use.
- Collapse of scaffold over 5 metres.
- A road tanker carrying a dangerous substance overturns or substance is released.
- Certain collapse of building or structures.
- Explosion or fire causing suspension of normal work for 24 hours.
- Certain releases of flammable material.
- Accidental release of any substance which may damage health.
- Certain reportable diseases.
Whenever we make a report to the environmental agency of the release we should also consider making a report to H&SE. This would include any significant use of the on site gas alarm.
The Amlwch site has a number of hazardous materials on site which bring it under the requirements of The Control of Industrial Major Accident Hazard Regulations 1984 ( CIMAH).
The purpose of the regulations is to demonstrate that the major hazards associated with the site have been identified and that activity is being carried out safely. The site occupier is also required to submit a written safety report to the HSE , to prepare an on-site emergency plan and provide certain information to the public.
The Amlwch site has two materials which exceed the minimum inventory and which therefore bring us within the regulations. We have more than 50 tonnes of DBE on site and also carry more than 25 tonnes of Chlorine. Under our Hazardous Substances Consent we can store a maximum of 250 tonnes of Chlorine.
We carry other stocks of materials on site which are listed in the CIMAH regulations , however our inventory is below the trigger level.
The other substances include H2SO4 , Liquid sulphur , Bromine ,DBM ,BCM , DCM , HBr acid , liquid HBr , hydrogen and SO2. In addition some of the chemicals used and made on the MPBF plant may be listed in the CIMAH list.
It is considered that a major spill of liquid DBE would end up in the marine environment within the confines of the area affected by acidic discharges from the BOTs. There would therefore be no long term environmental damage from a spill of DBE.
The main effect on the environment from a release of chlorine is considered to be short term.
The report contains detailed calculations on the effects of a release of DBE or chlorine from the site would have and the management structures in please to prevent such a release.
Under the terms of the CIMAH authorisation we have to inform local residents of the hazards on this site and their response to them on a regular basis. This is done by the issuing of a telephone directory and short video.
All employees are required to have an annual medical. For shift operators this is normally carried out during working time. The short term manning down of a plant may be necessary during this period. It is important that another competent operator on the shift monitors the plant during the period of absence.From time to time additional urine samples may be needed to monitor the bromide level of employees.
Additional biological sampling may be required for personnel who work on the MPBF plant when BCP is being produced. The Medical centre will provide a list of authorised personnel at the start of each BCP campaign. All SPM should under go the required testing to enable them to work on the MPBF plant during BCP campaigns.
A nurse is available in the medical centre during normal hours and for extended times during major pre planned shutdowns. Each shift has a number of trained first aiders. These are required to receive refresher training at least once per year and have a re-assessment every three years.
For incidents out side normal hours the first aiders should be the first contact point. The nurse should then be phoned. The final back up is the local doctor’s surgery which has a 24 hour call out system in operation. All injures must be reported on an accident and incident report form.