Strategic Actions to Prevent Risks and Accidents Involving Hazardous Chemicals

Michael J Cowing August 2012 Brasilia

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Content
Background EU Legislative Background and Framework EU Organisational Framework Handling & Storage Transportation Haz Waste Conclusions

Venezuela Amuay Refinery Explosion

Venezuela Amuay Refinery Explosion

There was a deadly explosion early on Saturday at the Amuay Oil Refinery in northern Falcon State, Venezuela, one of the largest such facility in the world. Forty-one people died and dozens were injured in the blast . Firefighters said their work had been slowed down by increasing winds and a change in wind direction. Government officials said the blast occurred at 01:15 local time on Saturday when a gas leak created a cloud that ignited. More than 200 homes and 11 businesses were damaged. Venezuela has the world's biggest certified oil reserves. Critics say under-investment by state oil company PDVSA has led to a decline in production and safety standards. But President Chavez stated that there was no evidence the blast was the result of poor maintenance.

BACKGROUND

Hazardous Substances
By their very nature certain substances can be considered to be a risk to either human health or the environment - such substances are referred to as hazardous substances. In order to ensure the protection of those who come into contact with them and also the environment into which they may be released it is first necessary to understand and importantly to communicate the risks associated with dealing with these substances. Risk is the combination of the probability of occurrence of harm and the severity of harm. A high risk can be defined as a high likelihood of the hazard occurring. Within the EU the risks associated with the handling of hazardous substances are captured within laws designed specifically to control all aspects of operation the handling, storage and transportation of hazardous substances and the wastes produced a cradle-to-grave approach. The single and most significant aspect of the legislation relates to the communication of hazards; this is achieved with the application of consistent terminology, removing the risks relating to mis-interpretation and harmonizing the level of expectation required from those who use hazardous substances.

Background
The growing importance of the chemicals industry to Brazils economy and the associated environmental and public health risks are well documented such as within the National Plan of Preparedness and Response to Environmental Emergencies with Hazardous Chemicals, 2009, (P2R2) so do not need to be repeated here in any detail. But to summarize:
In 2008 some 28 million tons of hazardous chemicals were imported and over 10 million tons were exported. Almost 70% increase in production since over the last ten years. The chemicals industry is by far the largest producer of hazardous waste.

In In 2007, the chemicals sector represented 3.2% of the national GNP, ranking 9 in the world market.

Further, the legitimate problems are compounded by those related to the growing illegal chemicals trade focusing on materials such as agrochemicals and heavy metals.

Background
Brazil is a signatory to and has ratified numerous Conventions and Protocols dealing with themes directly related to the matter of chemicals and chemical wastes, such as:
The Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade; The Stockholm Convention on Persistent Organic Pollutants (POPs) The Basel Convention on the Control of Trans-boundary Movements of Hazardous Wastes and their Disposal

The control of other chemicals which may affect the air and the oceans is equally mentioned in international commitments such as:
The Vienna Convention on the Ozone Layer Protection; The Montreal Protocol on the Ozone Layer Destructing Substances SDOs, The Convention on Climate Change; The Kyoto Protocol on the reduction of gases emission; The Convention on the Right of the Sea protecting the marine environment.

European Legislative framework and history

Eu Legislative framework and history

Within the EU there are numerous directives and regulations developed to control the use of hazardous substances within member states. A directive is a legislative act of the European Union, which requires member states to achieve a particular result without dictating the means of achieving that result. These can be It distinguished from regulations which are self-executing and do not require any implementing measures. Furthermore there are also agreements that can be considered a form of treaty and require signatories to enter into the spirit of the agreement. The legal instruments provides overall control of hazardous substances, including their: identification, classification, handling, storage, transportation and eventual disposal. There are deliberately transferrable elements between legislative acts. For example: the Waste Management Directive specifically calls on elements of the Global Harmonisation System (GHS) (enacted through REACH) and Classification, Labeling and Packaging (CLP) Regulations to ensure that hazardous wastes are treated adopting a legally defined methodology.

Eu Legislative framework and history

Legislation within the EU has developed over a significant number of years and has responded to a number of criteria not least - lessons learned from accidents and incidents involving the uncontrolled release of hazardous substances. This type of development is progressive over time in order to reach the desired goal the protection of the environment and human health. This can be used to the advantage of countries with less developed legislative controls; the work has already been done and examples can be taken from lessons learned previously in other countries.

Eu Legislative framework and history

The Globalized Harmonisation System

The GHS is the most widely applied regulatory scheme and forms the central framework against which European legislation on the control of hazardous substances has evolved. Developed by the UN (United Nations Economic and Social Council) it provides control on the transportation of dangerous goods in the form of UN Recommendations on the Transport of Dangerous Goods. This forms the basis for most regional and national regulatory schemes and in many instances the founding steps in more comprehensive hazardous substances national programmes, initiatives and more specific acts of legislation. The new system addresses classification of chemicals by types of hazard and proposes harmonized hazard communication elements, including labels and material safety data sheets (MSDS). It aims at ensuring that information on physical hazards and toxicity from chemicals is available in order to enhance the protection of human health and the environment during the handling, transport and use of these chemicals. The GHS also provides a basis for harmonization of rules and regulations on chemicals at national, regional and worldwide level, an important factor also for trade facilitation.

Registration, Evaluation, Authorisation & Restriction of Chemicals

REACH is a European Union Regulation of December 2006. It addresses the production and use of chemical substances, and their potential impacts on both human health and the environment. Its 849 pages took seven years to pass, and it has been described as the most complex legislation in the Union's history and the most important in 20 years. It is the strictest law to date regulating chemical substances and will affect industries throughout the world. REACH entered into force in 1 June 2007, with a phased implementation over the next decade. When REACH is fully in force, it will require all companies manufacturing or importing chemical substances into the European Union in quantities of one tonne, or more, per year to register these substances with a new European Chemicals Agency (ECHA) based in Helsinki, Finland. Because REACH applies to some substances that are contained in objects ('articles' in REACH terminology), any company importing goods into Europe could be affected. The European Chemicals Agency has set three major deadlines for registration of chemicals. In general these are determined by tonnage manufactured or imported: 1,000 tonnes/a. being required to be registered by 1 December 2010, 100 tonnes/a. by 1 June 2013; and 1 tonne/a. by 1 June 2018. In addition, chemicals of higher concern or toxicity also have to meet the earlier 2010 deadline.

REACH (continued)
REACH also addresses the continued use of chemical ' substances of very high concern' (SVHC) because of their potential negative impacts on human health or the environment. From 1 June 2011, the European Chemicals Agency must be notified of the presence of SVHCs in articles if the total quantity used is more than one tonne per year and the SVHC is present at more than 0.1% of the mass of the object. Some uses of SVHCs may be subject to prior authorisation from the European Chemicals Agency, and applicants for authorisation will have to include plans to replace the use of the SVHC with a safer alternative (or, if no safer alternative exists, the applicant must work to find one) - known as 'substitution'. As of January 2012, there are 73 SVHCs throughout the EU. Using potentially toxic substances (such as phthalates or brominated flame retardants) is deemed undesirable and REACH will force the use of certain of these substances to be phased out. According to the EC, little safety information exists for 99 percent of the tens of thousands of chemicals placed on the market before 1981. There were over 100,000 chemicals in use in the EU in 1981, when the last survey was performed. Of these only 3,000 have been tested and over 800 are known to be carcinogenic, mutagenic or toxic to reproduction. These are listed in the Annex 1 of the Dangerous Substances Directive (now Annex 3 of the CLP Regulation). In 2006 the REACH proposal came under criticism from a group of nations including the United States, India and Brazil, claiming that the bill would hamper global trade.

Classification, Labeling and Packaging (CLP) Regulations

The European Regulation (EC) No 1272/2008 on classification, labeling and packaging of substances and mixtures the CLP Regulation came into force in all EU member states, including the UK, on 20 January 2010. The CLP Regulation:
Adopts in the EU the Globally Harmonised System (GHS) on the classification and labeling of chemicals; Is being phased in through a transitional period which runs until 1 June 2015. The CLP Regulation applies to substances from 1 December 2010, and to mixtures (preparations) from 1 June 2015; Applies directly in all EU member states. This means that no national legislation is needed; Is overseen by the European Chemicals Agency (ECHA); Will replace the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 CHIP from 1 June 2015 It is Europe wide and therefore ensures that harmony exists between member states on the communication of hazards and subsequent identification of risks.

Classification Labelling and Packaging (CLP) Regs

This Europe-wide harmonisation is an important and essential aspect that creates in itself a standardised form of communication. Pictures are used as the first critically important visual identification of the hazard a substance poses. This is essential where there are a number of different languages across Europe, allowing the user/member state to develop their own response plans, whether in the workplace or as an emergency service. Alongside these, the regulations call for the supplier or manufacturers of hazardous substances to produce material safety data sheets (MSDS) which must accompany the product on its journey from manufacturer to customer. These data sheets detail the physio-chemical properties of the substance and its direct risks.

Seveso Directive Control of Industrial Major Accident Hazard Regulations

Special consideration should be given to the specific risks associated with the bulk storage of flammable liquids. EU Council Directive 96/82/EC known as the Seveso II Directive, as amended by Directive 2003/105/EC and replaced the Control of Industrial Major Accident Hazards Regulations 1984 (CIMAH) detail the requirements necessary for the control of major installations. In general these regulations apply mainly to the chemical industry, but also to some storage activities, explosives and nuclear sites, and other industries where threshold quantities of dangerous substances identified in the Regulations are kept or used.

International Carriage of Dangerous Goods by Road (amended 2011)

The transportation of hazardous substances is defined in the Act - European Agreement Concerning the International Carriage of Dangerous Goods by Road, most recently amended in 2011. The agreement first entered into force in 1968. In its most simple form the agreement states that (with the exception of some exceptionally dangerous goods) all other dangerous goods may be carried internationally, i.e. between member states as long as they comply with specific requirements; namely: The conditions laid down in Annex A for the goods in question, in particular as regards their packaging and labeling; and The conditions laid down in Annex B, in particular as regards the construction, equipment and operation of the vehicle carrying the goods in question

ROHS and WEEE Directives

The Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (2002/95/E) commonly referred to as the Restriction of Hazardous Substances Directive or (RoHS) was adopted in February 2003 by the European Union. The RoHS directive took effect on 1 July 2006, and is required to be enforced and become law in each member state. This directive restricts the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment. It is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) 2002/96/EC which sets collection, recycling and recovery targets for electrical goods and is part of a legislative initiative to solve the problem of huge amounts of toxic e-waste

Waste Management Directive

Hazardous waste control in the EU is implemented in accordance with the Waste Management Directive 2008/98/EC Previous to this hazardous and normal wastes were co-mingled increasing both the risks associated with known and unknown exposure on handling and carriage as well as issues associated with disposal. The properties which render waste hazardous are laid down in Annex III of the Directive 2008/98/EC and are further specified by the Decision 2000/532/EC establishing a List of Wastes. It provides additional labeling, record keeping, monitoring and control obligations from the "cradle to the grave", i.e., from the waste producer to the final disposal or recovery. In addition, mixing of hazardous substances is banned in order to prevent risks for the environment and human health. Moreover, the permit exemptions that may be granted to installations dealing with hazardous wastes are more restrictive than for installations dealing with other wastes.

Integrated Pollution, Prevention and Control (IPPC) Directive

On 21 December 2007 the Commission adopted a proposal for a Directive on Industrial Emissions. The Proposal recasts seven existing Directives related to industrial emissions into a single clear and coherent legislative instrument. The recast includes in particular the IPPC Directive. The IPPC Directive has been in place for over 10 years and the EC has undertaken a two year review to determine how it can be improved and simplified in so doing cutting unnecessary administrative costs. In essence the implementation plans required for IPPC are designed to control the activities of plant operators through the use of Best Available Technique (BAT). Through the application of BAT the regulator can ensure that the appropriate measures have been installed to prevent the unauthorized release of contamination. Whilst IPPC has been developed to review and control industrial emissions there are controlling features and recommendations within the IPPC requirements that ensure that the operator is undertaking best practice. In this way the release of pollution and the actions taken to control, contain and mitigate the impact of its release are mutually compatible between the independent legislative frameworks of the EU.

EU Organisational framework

General
There are presently 27 member states within the European Union. Each has a responsibility to ensure that it can create and sustain the appropriate organizational responses necessary to implement legislation. There are significant differences between the way countries create the organizations that are necessary to enact the requirements and these differences are brought about as a result of many aspects, not least of all the socio-political make up of the country. But also, and significantly, the length of time that the country has also been a member of the EU. Mature members of the EU may have many of the frameworks and structures in place whilst newer members may be required to overhaul existing frameworks and even create new ones.

The UK & Czech Republic

The UK is a mature member of the EU, joining in 1993 whilst the Czech Republic is a new member joining in 2004. The two countries have distinct differences in their socio-political composition with the UK having an essentially de-centralised and free market approach to enacting legislation whilst the Czech Republic retains vestiges of the centralized communist approach significant in its history. The essence of the UK system is one of de-centralisation of the enforcement responsibilities down to the level of local councils and municipalities. Centralised functions are present at the higher level giving policy guidance and strategic support in areas such as health and safety, innovation, nuclear power etc. At the government level the Secretary of State is ultimately responsible for the success of the Health and Safety Executive (HSE). In support there is a strong structure of dissemination of communication and expectation downwards to the enforcers and the users so that elements of uncertainty and doubt are removed as far as possible. It is absolutely the responsibility of the user to ensure that they follow the guidance and requirements but it is understood that the user must have access to information in a format that is simple to understand.

The UK & Czech Republic (2)

The Czech Republic maintains its delivery of legislation through a centrally appointed organization the Czech Environmental Institute (CEI). The CEI has a wide ranging mode of operation and is required to ensure that a large number of legislative acts are enforced, not only those relating to the control and management of hazardous substances. A review of legislation developed by the Czech Government indicates that it is most certainly creating laws that reflect the expectation of the EU, including Acts relating to the testing of substances, assessment of risks, control of major installations as well as the use of best available techniques (BAT). Maybe as a reflection of its previous position within the former USSR, the Czech Republic has elected to control the use of hazardous substances from a centralized entity. This does not diminish the effectiveness of the system but it is limited by the resources available to that entity. As with other members of the EU, accidents still occur but the responses of the authorities in understanding and reacting to the causes of those accidents as well as the deficiencies in the protocol for subsequent revision appear to be strong and co-ordinated.

The UK & Czech Republic (3)

It is important to not draw conclusions from the two examples provided that one is better than the other. Both have their merits as well as their drawbacks. It would be simple to conclude that the HSE in the UK represent best practice and therefore can be applied to any society across the globe; the HSE works well for the UK where de-centralisation is a priority however accidents still happen. The important factor is that both countries structures have processes to learn from their mistakes, this being an essential component of the EU legislation. Furthermore the ultimate responsibility for the control of hazardous substances lies with the government itself and this is an important and extremely relevant consideration. By undertaking to legislate and control from a central authority a clear message is sent to the country and those within the country who handle hazardous substances.

the handling and storage of hazardous substances

Handling of Hazardous Substances

Handling of Hazardous Substances is set out within the GHS requirements and delivered through the CLP and REACH protocols. Within the UK these regulation sets are enacted specifically through the Control of Substances Hazardous to Health Regulations, commonly referred to as COSHH assessments. The COSHH assessments set out the basic system for managing the risks to health associated with the handling of hazardous substances it is not intended as a prescriptive methodology as it is acknowledged under the Regulations that site specific requirements are required in relation to the process being undertaken. In this way the basic system provides the framework for the generation interpretation and storage of information and data that allow for a proper assessment of risk so that it can be avoided or mitigated. The key aspect of COSHH is that by setting the framework for a standardized approach to information collection but permitting variances in actual operation allows for the Regulatory body to police the system whilst not constraining the development of industry. COSHH assessments revolve around two managing requirements find out what the situation is and then decide what to do about it. The legal requirement is that the collection of information has to be suitable and efficient to permit for an appropriate assessment of risk, the aim being reliable conclusions based on informed judgments.

Storage of Hazardous Substances

Appropriate storage of hazardous substances is the first line of defense in preventing accidents. An appropriate assessment of the risks of storing and handling dangerous substances- including the possibility of environmental damage caused by leaks and spills, needs to be undertaken and communicated to those who may be exposed to the risks. Precautions needed to control risks can include the following: storing chemicals according to the manufacturer's instructions on the safety data sheet keeping the minimum quantity of hazardous substances necessary storing incompatible substances separately taking steps to prevent release or leakage of dangerous substances keeping a spill kit near to storage areas, and ensuring staff are trained in what to do in the event of a spill rapidly cleaning up any leaks or spills that occur using appropriate precautions when handling substances- for example, wearing protective clothing or ensuring adequate ventilation ensuring employees who store and handle dangerous substances are properly trained checking containers used for short-term storage are properly labeled place stores of liquid above ground where they're unlikely to be damaged, e.g. away from traffic routes avoid overfilling containers supervise deliveries check and maintain gauges, valves and pipework monitor oil use- unexpectedly high use may indicate a leak have procedures for dealing with emergency leakages use a secondary containment system such as a drip tray or bund (a storage area designed to prevent liquids escaping)

Flammable liquids
Given both the high risks associated with the handling and use of flammable liquids, specific guidance is offered to minimize risks arising from their use. In the UK and throughout the EU a flammable liquid means a liquid with a flashpoint of 55C or below. The main hazards from the use of flammable liquids are fire and explosion, involving either the liquid or the vapour given off from it. Fires or explosions are likely to occur when vapours or liquids are released from a controlled environment to areas where there may be an ignition source, or, alternatively, when an ignition source is introduced into a controlled environment. Common causes of such incidents include: lack of awareness of the properties of flammable liquids; operator error, due to lack of training; hot work on or close to flammable liquid containers; inadequate design of equipment; inadequate installation or maintenance; failure or malfunction of equipment; exposure to heat from a nearby fire; misuse of flammable liquids, for example, to burn waste materials or brighten fires; inadequate control of ignition sources; electrostatic discharges; heating materials above their auto-ignition temperature; Dismantling or disposing of equipment containing flammable liquids.

Flammable liquids (2)

Incidents involving flammable liquids commonly arise during transfer operations, including: movement from storage; decanting or dispensing; movement within premises; use in processes; disposal; emptying vehicle fuel tanks; Dealing with spillages. Combustion of liquids occurs when flammable vapours released from the surface of the liquid ignite. The amount of flammable vapour given off from a liquid, and therefore the extent of the fire or explosion hazard, depend largely on the temperature of the liquid, its volatility, how much of the surface area is exposed, how long it is exposed for, and air movement over the surface. Other physical properties of the liquid, such as flashpoint, auto-ignition temperature, viscosity, lower explosion limit and upper explosion limit, give further information as to how vapour/air mixtures may develop and also on the potential hazards. The properties of a flammable liquid should therefore be established (for example, from the relevant data sheet) before the material is used, so that adequate precautions can be taken.

COSHH - Summary
The effectiveness of any legislative tool is only as good as its enforcement. Common themes on application of the requirements of the laws, and their enforcement, exist across the EU and in many ways should be regarded as being good practice. In their simplistic form the key to this is in communication. Risks posed by the handling, transportation, use and disposal of hazardous substances are required to be communicated from cradle to grave i.e. from the initial producer through to those charged with their safe disposal. The licensing of activities and the threat of removal of a license for nonconformance is a powerful tool against which a strong enforcement policy can be created against this threat the requirements of a license can dictate the way in which it is required an operator conducts their business. Minimum requirements for Infrastructure (tanks and containment structures) can be prescribed as can the protection for workers, their training, the use of suitable vehicles and finally a safe way of disposing of wastes.

Case Study Buncefield Oil Storage Depot, UK 2006

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Case Study Buncefield Oil Storage Depot, UK 2006

The terminal was the 5th largest oil-products storage depot in UK. Facility owned by TOTAL and TEXACO. Cause appears to be a fuel/air explosion of unusually high strength possibly the largest of its kind in peacetime Europe. disaster that occurred in Buncefield highlighted a comprehensive failure in the procedures, protocols and laws operating in the UK and the EU to prevent such an accident occurring. The accident has resulted in extensive review of both operational and enforcement activities to ensure that lessons are learned and more importantly revisions made. On the night of Saturday 10 December 2005, Tank 912 was filling with petrol. The tank had two forms of level control: a gauge that enabled the employees to monitor the filling operation; and an independent high-level switch (IHLS) which was meant to close down operations automatically if the tank was overfilled. The first gauge stuck and the IHLS was inoperable there was therefore no means to alert the control room staff that the tank was filling to dangerous levels. Eventually large quantities of petrol overflowed from the top of the tank. A vapour cloud formed which ignited causing a massive explosion and a fire that lasted five days.

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Case Study Buncefield Oil Storage Depot, UK 2006

The gauge had stuck intermittently after the tank had been serviced in August 2005. However, neither site management nor the contractors who maintained the systems responded effectively to its obvious unreliability. The IHLS needed a padlock to retain its check lever in a working position. However, the switch supplier did not communicate this critical point to the installer and maintenance contractor or the site operator. Because of this lack of understanding, the padlock was not fitted. Having failed to contain the petrol, there was reliance on a bund retaining wall around the tank (secondary containment) and a system of drains and catchment areas (tertiary containment) to ensure that liquids could not be released to the environment. Both forms of containment failed. Pollutants from fuel and fire-fighting liquids leaked from the bund, flowed off site and entered the groundwater. These containment systems were inadequately designed and maintained.

Case Study Buncefield Oil Storage Depot, UK 2006

Failures of design and maintenance in both overfill protection systems and liquid containment systems were the technical causes of the initial explosion and the seepage of pollutants to the environment in its aftermath. However, underlying these immediate failings lay root causes based in broader management failings:
Management systems in place at HOSL relating to tank filling were both deficient and not properly followed, despite the fact that the systems were independently audited. Pressures on staff had been increasing before the incident. The site was fed by three pipelines, two of which control room staff had little control over in terms of flow rates and timing of receipt. This meant that staff did not have sufficient information easily available to them to manage precisely the storage of incoming fuel. Throughput had increased at the site. This put more pressure on site management and staff and further degraded their ability to monitor the receipt and storage of fuel. The pressure on staff was made worse by a lack of engineering support from Head Office. Cumulatively, these pressures created a culture where keeping the process operating was the primary focus and process safety did not get the attention, resources or priority that it required.

The operating firms were ordered to pay almost 10m in fines. The Judge in charge of the investigation said: "Had the explosion happened during a working day, the loss of life may have been measured in tens or even hundreds.

Transportation of Hazardous Substances

Transportation of Hazardous Substances

The European agreement concerning the transportation of dangerous goods is updated regularly reflecting changes in technology and learning from lessons as a result of incidents and accidents. However the overall structure of the agreement is consistent with that of the: United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations, the International Maritime Dangerous Goods Code (of the International Maritime Organization), The Technical Instructions for the Safe Transport of Dangerous Goods by Air (of the International Civil Aviation Organization) and The Regulations concerning the International Carriage of Dangerous Goods by Rail (of the Intergovernmental Organisation for International Carriage by Rail) The Globalised Harmonisation System (GHS) was developed to combine an effective mechanism to bring together the various requirements of the agreements and regulations. The UNECE administers regional agreements that ensure the implementation of these mechanisms as far as transport of dangerous goods by road, rail and inland waterways is concerned. Whilst member states have the capability of updating or constructively revising the UNECE requirements the fundamental elements of the agreement remain the prescribing aspects for regulation and enforcement and are divided into the following categories (as detailed within Annex A of the regulations;

Transportation of Hazardous Substances

General Provisions This section relates to the overall introduction to the requirements and the legislative framework for its enactment. Classifications The groupings of substances according to their hazards and further subdivided based on the type of hazard relevant to that group. A listing of those goods that have already been classified is listed in the Annexes of the UNECE documentation and as such requires that the producer and transporter of that substance undertakes to provide the relevant documentation in the form of the chemical and hazard data sheets and signage of the hazard on the transporting vehicle. For those substances that are new to the market there are prescriptive requirements for the physio-chemical testing of the substance in order to identify the hazards associated with its use.

Transportation of Hazardous Substances

Dangerous Good list, special provisions and exemptions related to limited and exceptions quantities. This section gives details on the proper shipping names, including that of its chemical composition e.g. ETHANOL as well as that of its physical state e.g. LIQUID. It also details the elements composing the dangerous goods list and the special requirements for them Packing and Provisions Special requirements for the packing of dangerous goods giving special provision to the technical aspects of goods with properties that can change during transportation e.g. expansion of gases with temperature variations. Consignment procedures The processes necessary for marking, labeling and documentation and where appropriate authorizations and advance notifications Construction and testing of packaging A detailing of the requirements used in packaging it provides observations that packaging can vary from that specified as long as they are well constructed, tested in accordance with the regulations and have been agreed with the authorities Carriage, loading, unloading and handling This section essentially details the requirements necessary to mitigate the risks associated with transportation of dangerous goods. There are a significant number of prescriptive requirements that have been regulated that reflect the stability of the substances being carried and their maximum tolerances before the stability is compromised. Provision concerning transport equipment and transport operators A list of regulations concerning the documentation to be carried with the goods e.g. driver training certificates and vehicle eligibility, consignment notes as well as the emergency response kits suitable for dealing with the substance being carried. Construction and approval of vehicles The requirements necessary for approval in the form of their construction and type as well as their annual inspection regimes.

Calculation of Risks from Transportation of Haz Substances

The guideline document (General Guideline for the Calculation of Risks in the Transport of Dangerous Goods by Road; An introduction to the basic principles of risk assessment for chapter 1.9 ADR reproduced in Appendix 5) aims at meeting the requirements of national characteristics in the transport of dangerous goods by road. It is a document that all EU Member States are recommended to use despite the fact that major differences exist between Member States. This concerns for example the topography (flat or mountainous), the climate (temperature and wind), the national policy on transport and traffic, the combination of goods and passenger traffic or the population density. The risk assessment document and methodology also recognizes that individual countries can also differ greatly with regard to the technical details of the dangerous goods vehicles used and the infrastructure, for example the state of the road systems. The guideline was developed to provide an independent framework for the analysis and evaluation of risks and for the assessment of corresponding safety measures. It is only intended to define the basic requirements and to recommend basic approaches. Since the acceptance of a risk assessment is largely dependent on the input data and the necessary assumptions and restrictions it should be attempted to achieve absolute transparency of all procedural steps. The guideline concentrates on aspects which should be taken into account for a risk analysis, i.e. on basic contents and quality objectives. It is then recommended that any of the various quantitative risk assessment tools can be used.

Transportation of Hazardous Substances

The prescriptive and advisory elements of these regulations provide the tools necessary to undertake the carriage of dangerous goods in a manner that can be considered as safe. However accidents still occur inevitably where the regulating authorities, or as the operators, have not carried out their own tasks either in accordance with the regulations or mindful of the spirit in which they are written. The role of the regulator is paramount - including: roadside vehicle checks, document searches, certification procedures, training record validation. Emergency response procedures are essential for maintaining both visibility to operators that they are being regulated as well as ensuring that adequate precautions are in place to protect the environment and human health. Without a strong regulator it falls to the operator to self police and whilst intentions may be good, weak points are at times ignored and accidents occur.

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Hazardous Wastes

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Contaminated Rubble

What is Hazardous Waste?

The EU has simplified the process of waste definition by undertaking to classify and publish wastes in the European Waste Catalogue (EWC). Generally, waste is hazardous if it, or the materials or substances it contains are, harmful to human health or the environment. The EWC has a six-digit code for all types of waste. Hazardous waste is identified in the EWC with an asterisk. The EWC contains two kinds of hazardous waste entry: 'Absolute' entries are always hazardous. Examples include waste from the manufacture of specified acids, inorganic wood preservatives, and nickel cadmium batteries. 'Mirror' entries are only considered hazardous if they contain a certain hazardous component, or more than a specified amount of a hazardous substance. Examples include some wastes containing arsenic or mercury or displaying hazardous properties such as flammability.

What is Hazardous Waste?

It is recognised that almost all businesses will produce some form of hazardous waste. Typical examples include waste: asbestos chemicals, e.g. brake fluid and printer toner electrical equipment with potentially harmful components such as cathode ray tubes, e.g. computer monitors and televisions fluorescent light tubes and energy-saving light bulbs vehicle and other lead-acid batteries oils (except edible oils), e.g. engine oil refrigerators containing ozone-depleting substances solvents, e.g. aerosols pesticides Wastes are listed in the European Waste Catalogue if they are considered to have one or more of the specified hazardous properties. Such properties would normally be identified on the chemical data sheets transmitted with the hazardous substances used in the manufacturing process these can be directly transferred to the properties that would be present within the waste coming from that process.

Hazardous Waste - Advice

In recognition of the importance of the waste hierarchy reduce, re-use, recycle advice is offered across Member States to business that have the potential to produce hazardous waste. Whilst this advice is fairly self explanatory and much of it good business sense it is strengthened through a charging mechanism that provides a financial dis-incentive for disposing of hazardous wastes. Such advice however is good practice and should be considered taking the form of the following series of high level actions; Know what you are handling train personnel to understand the risks Avoid using hazardous substances - see if they can be substituted by a non hazardous substance Keep the minimum volume in correct storage storing chemicals according to the manufacturer's instructions on the safety data sheet store incompatible substances separately prevent release or leaks storing flammable substances in suitable containers away from sources of ignition, such as boilers and heaters place stores of liquid above ground where they're unlikely to be damaged, for example away from driveways maintain gauges, valves and pipework using a secondary containment system such as a drip tray or bund (a storage area designed to prevent liquids escaping) monitoring oil use - unexpectedly high use may indicate a leak Have an emergency plan with adequate response materials spill kit

Storing Hazardous Waste

Most member states prescribe the length of time and volume that can be stored on site before a license is required (this is to avoid un-licensed premises acting as a waste carrier or disposer; a licensable activity). However in acknowledgement of the need for business to be able to store hazardous wastes a series of guidelines and operating practices are produced giving advice on best practice; such as the following; If you keep hazardous waste on your premises, even for a short period of time, you must: ensure that it is stored safely and securely to prevent pollution ensure that it is packaged and labelled correctly keep different types of hazardous waste separate keep hazardous and non-hazardous waste separate keep liquid hazardous waste in a dedicated area, with a bund or barrier to contain spills and leaks regularly check storage areas for leaks, deteriorating containers or other potential risks display written instructions for storing and disposing of each type of hazardous waste maintain an inventory of the hazardous wastes kept on your premises, and where they are stored - this will help the emergency services to deal with any incident effectively and safely

Hazardous Waste
Given the almost universal presence of hazardous substances in the manufacture of goods, and the subsequent hazardous wastes that are produced, the regulations concerning the handling, movement and disposal of hazardous wastes conform in a large part to the expectations for dealing with hazardous substances. Many countries have established frameworks that are similar in nature to those for dealing with hazardous substances, following the same high level strategic implementation elements; Know what the hazards of the waste are (the same types of waste can be mixed together e.g. waste oils, food products, however wastes cannot be co-mingled) Communicate the hazards within the delivery mode GHS/ADR requirements. Ensure that the wastes are received at a facility that has the ability to store them, process them (e.g. recovery or recycling) and then dispose of them in accordance with the legal framework for protection of human health and the environment. Most countries adopt a licensing system to ensure compliance of carriers with aspects of the GHS requirements and also for places of disposal this latter is an important aspect in that the enforcement of requirements can be maintained through the licensing system as well as allowing for the creation of a national database of disposal sites. The use of consignment and delivery notes ensures that the hazardous wastes are transported in full transparency from cradle to grave.

Moving hazardous waste

Make sure all hazardous waste is: transported by a registered or exempt waste carrier accompanied by a consignment note (there are only a few exceptions where consignment notes are not required) sent to a facility that holds a suitable environmental permit or a registered exemption that authorises them to take that type of waste for the activity they intend

Conclusions

Conclusions
The development of European legislation follows the lifetime of hazardous substances from their manufacture to their disposal cradle to grave. A number of EU wide directives are passed to Member States for them to create their own legislative framework for enactment but importantly provide the unifying terminology and requirements that provide parity across borders (reducing ambiguity caused by cultural and language restrictions). There are of course differences in the way each Member State enacts its duties, some are robust, others less so, however the intent remains the same to reduce the risks posed by hazardous substances to the population and the environment. There re a number of examples frameworks have been provided against which legislation has been developed and then cascaded down into the operating protocols. A centrally controlled function whose mandate is to ensure that the control of hazardous substances is communicated at the highest governmental level. Harmonisation of the communication of hazards it is absolutely essential that the risks posed by hazardous chemicals are communicated through the chain of users who may be exposed to those risks. A strong regulator with the power to enforce and penalize nonconformance A system of licensing across all those who store, move, use and dispose of hazardous substances The creation of an educational base (in the form of advisory notes) to inform those who handle hazardous substances on their legal requirements and expectations for best practice training of staff is key to the enactment of these advisory notes and vocational training qualifications help ensure that the correct level of training is enacted. Emergency response plans that reflect the capabilities of the local and regional civil emergency responder and the agreement of those response plans with the civil authorities.

Thank You