In our last article we discussed REACH and CLP regulations and how your business can get ready for the REACH registration process. In this we touch on the spillage of chemicals and their control – what is spill control? how does it impact your employees and your business? how do you prepare for it?
Impact of spills
While certain chemicals, pesticides, oils, sewage and animal slurries are polluting materials that we can readily identify as harmful or hazardous – many materials we don’t perceive of as hazardous can still have a devastating effect on the environment, including beverages, food products, detergents, dairy products, paints and inks.
Hazardous materials can cause significant damage to employees’ health and the environment including air, land and groundwater pollution and damage to fisheries, public water supplies and disruption to recreational and other uses. The impacts may be immediate and long lasting and you may be responsible for fines depending on the severity of any of injuries and the costs of cleanup which can be expensive particularly if groundwater is contaminated.
There may be additional costs too associated with fines, incident response, legal costs etc. as well as the negative impact on your company’s business reputation. Consequently, it is far better (and less expensive) to prevent spills than to clean up afterwards making investment in spill procedures and control measures a sensible way to protect your business.
Requirements for spill response
When any chemical is spilled, be it in a laboratory, warehouse, hospital or a leak from a punctured drum, someone has to clean it up. It might be the person who spilled it or a trained response team but in every case they should know about the hazards and risks posed by the substances involved, have access to the appropriate PPE and equipment and follow a proper plan based on the relevant legal obligations and best practice.
The severity of a spill impact is affected by, among other things, the toxicity of the material spilled, its quantity and concentration, environmental sensitivity of the local area, time of year and weather conditions, availability of pollution control equipment and spill containment facilities, and the speed and effectiveness of your incident response. Even small spills can have a significant impact. Contingency planning is the key to stopping a spill becoming a serious pollution incident.
Workplaces using hazardous chemicals must implement proper controls to ensure the workforce involved in transporting, handling and using chemicals, perform these processes in a safe manner. The Chemical Agents 2001 Regulations is a key piece of legislation which requires hazard identification and performance of chemical risk assessments (CRA) in relation to normal use of hazardous chemicals and emergency situations. Emergency planning is also required under the Safety Health & Welfare at Work Act 2005. The Transportation of Dangerous Goods 2011 (ADR) Regulations, CLP and REACH Regulations may also impose additional obligations.
Spill response planning
The five-steps outlined below is one approach for preparing for spills:
- Produce a chemical inventory and chemical risk assessments: Maintain an up-to-date record of all substances stored on-site, an indication of the maximum quantity likely to be stored, product data and safety data sheets (SDS) and prepare chemical risk assessments for any hazardous substances.
- Gather your Spill Response information: This should include a diagram of the site showing layout and access details, chemical storage locations etc. along with a schematic representation of the site drainage arrangements.
- Develop your Spill Response Plans: Use the information to identify specific spill scenarios and develop supporting emergency procedures to address these if there’s an incident. Don’t forget to consider what could happen on your site as a worst-case scenario and develop procedures to deal with it. Ensure all relevant staff and contractors are aware of these procedures and the plan.
- Get equipped: Ensure you have the right equipment and materials and in sufficient quantity to deal with the spill scenarios you have identified. Locate these in the most appropriate areas i.e. where spills are most likely to occur.
- Staff training: Train your staff so they know what they should and shouldn’t do if there is a spill and train up and drill a Spill Response Team. Test your response to each scenario by drilling (this is a legal requirement).
Remember: you are responsible for the environmental safety from your site and activities. Spills often happen when you’re least expecting them.
If you would like to learn more about hazardous chemicals, best practice for dealing with spill control, how to plan your response, and preparing the spill response team, have a look at our upcoming best practice in hazardous chemical and spill control course or subscribe to our newsletter to receive all our latest articles.