To finalise our COSHH campaign, Caroline Raine, Principal Consultant from National Chemical Emergency Centre agreed to be interviewed.
We posed five probing questions.
1. What conferences would you highly recommend attending over the coming 12 months?
There are some fantastic conferences coming up, it’s hard to choose! The Chemical Hazards Communication Society (CHCS) and British Association of Dangerous Goods Professionals (BADGP) run events throughout the year that focus directly on chemical hazard identification, communication and transportation of dangerous goods. Chemical Watch also hosts a variety of events focussing on global risk and international regulation in regions across the world, from the USA and Europe to China and the Middle East. So if you are interested in attending a chemical conference, checking out these organisations’ websites is a great place to start.
However the most significant event in the calendar for us and our clients is probably the Global Chemical Congress (GCC) next April. Held in Windsor in the UK, GCC stands out because of the diversity of the delegation in attendance and the breadth of seminars, workshops and activities on offer. The conference provides a unique forum for crisis management, emergency response and regulatory experts to share experience and best practice, and is regularly attended by representatives from across the chemical industry.
2. What facet of health and safety do firms most neglect?
Possibly the most undervalued aspect of health and safety is in the communication of chemical hazards and risks across the chemical supply chain. Information on best practice in handling hazardous substances needs to be transferred effectively between manufactures, suppliers, purchasers, end users and emergency services. Otherwise when accidents occur – and they inevitably do – the impact on business and employee health will be much more severe.
Safety Data Sheets (SDS) and Control of Substances Hazardous to Health (COSHH) assessments are legal requirements and crucial aspects of a company’s risk mitigation strategy and ‘duty of care’ to employees and stakeholders. However, it is not uncommon to see companies with otherwise excellent health and safety procedures falling short in providing the depth of relevant information required for their staff to safely handle chemical materials, particularly in their COSHH assessments. This might be due to the vague nature of the regulations, where the requirements for COSHH assessments simply state that they need to be ‘suitable and sufficient’.
In my experience, deficiencies in safety assessments are rarely deliberate acts of negligence. Instead, many day-to-day chemical users simply aren’t trained to generate COSHH assessments that are fit for purpose. Part of NCEC’s role in industry is to help companies understand their regulatory requirements and how they practically relate to their work place. Ensuring that all staff are comprehensively trained is key to providing a safer working environment, in addition to saving money and reducing the cost of maintaining compliance with legislation.
3. Do you have any horror stories you could sanitise and share?
NCEC provides 24 hour chemical emergency support for a broad spectrum of chemical incidents, from overturned tankers and chemical contamination to suspected meth labs in caravans. However so many of the incidents we have handled could have been avoided through a better understanding of the chemicals being handled…with the possible exception of the meth lab of course!
For example, we recently received a call from a client’s area health and safety manager who returned to work after the weekend to find one of their freezers had exploded. The freezer had been used to store an unstable organo-peroxide, but had inadvertently been switched off on Friday. As the temperature increased, the compound reached its self-accelerating decomposition temperature and exploded, ripping through the freezer and filling the storage facility with fumes.
The building was evacuated and production halted until the managing director arrived on scene, who called the Fire Brigade and a third party waste contractor. It was at this point we were contacted to provide support to the emergency services and clean-up crew. Our expert emergency responders quickly identified that the residual spill and fumes did not pose a significant health risk.
At each stage of this incident, greater understanding of the chemical’s reactivity could have either expedited the response process or averted the incident entirely. If the staff on Friday had fully understood the reactivity of the chemicals then they wouldn’t have turned the freezer off. If the area manager had realised that the resulting vapour wasn’t harmful then clean-up could have been performed in-house, without contacting the Fire Brigade or hiring an external contractor. And of course, the company was fortunate that the building did not catch fire and that no one was injured in the explosion.
4. Are you seeing an increase of awareness in COSHH usage in general and what would you suggest has generated this?
We haven’t seen a particular surge in awareness in industry, however we are seeing greater attention from the Health and Safety Executive (HSE) in monitoring the adequacy of COSHH assessments. Over the past few years, HSE has begun to charge a Fee for Intervention (FFI), where companies are required to reimburse the cost incurred in carrying out regulatory functions if a material breach of health and safety law occurs.
While the increased enforcement from the HSE is applying some pressure on industry, where we see the greatest enthusiasm for COSHH is in individual companies that are keen to demonstrate a proactive approach to product stewardship. We have recently partnered with a number of high profile companies that are driven to increase their COSHH assessment capability out of a desire to provide the highest degree of care possible for their staff.
5. If you could give two Health and Safety tips for our readers, what would they be?
The best health and safety tip I could give to any organisation would be to ensure that it is fully prepared for when things go wrong.
For companies with robust health and safety procedures, it is very easy to believe that just because a serious chemical incident has never occurred it never will. In reality, companies that handle hazardous goods on a daily basis must assume that accidents can occur at any point, and implement robust strategies to minimise the impact when they do. This requires businesses to take a proactive approach to ensuring that all staff are fully trained to handle hazardous substances on a day-to-day basis.
Another important aspect of managing the risk of hazardous materials is to ensure easy access to Safety Data Sheet (SDS) information. Online SDS and safety document managing systems provide an effective way for companies to quickly access chemical safety information and to ensure staff and emergency responders are fully supported in handling hazardous incidents.
Finally when it comes to safety, it is important to go beyond just regulatory compliance and ensure all staff are adequately informed about the potential hazards of their work. The benefits of taking a proactive approach through staff training and external support by far outweigh the financial and, most importantly, the potential human cost of inaction.
Thank you very much Caroline. We appreciate your time in replying.
The UK’s National Chemical Emergency Centre (NCEC) has provided emergency response support for over 40 years, making it one of the most experienced services in the world when it comes to understanding the needs of the chemical industry and emergency responders.
In addition to 24 hour emergency response, NCEC also provides a range of SDS authoring and management services, and courses specifically designed to help companies comply with legislation, ensuring that they have the right skills and knowledge should an incident occur. This includes training for Chemical Spill Response, First Aid for Chemical Exposures, COSHH assessments and a range of bespoke courses tailored to companies’ specific requirements.
For more information on NCEC’s regulatory compliance and training services contact Caroline Raine on +44 (0)1235 753 479 or at [email protected]