SITE STORAGE, IS YOUR SITE COMPLIANT?
The incorrect storage or poor management of liquids can have far reaching consequences for your business and the environment and although The Oil Storage Regulations are amongst some of the most highly publicised regulation currently in force it’s all too easy to forget that all liquids pose a potential threat to health, safety and the environment if not properly handled and stored. Remember you are responsible for all the liquids on your site and you can be prosecuted for a pollution incident that originates on your site even if it was caused by vandals.
It’s relatively straight forward to ensure that you are protected by using products specifically designed for the task, such as rotationally moulded polyethylene spill pallets for indoor applications, bunded drum & IBC stores with fully seam welded sumps for secure outdoor use and double skinned storage tanks for bulk liquids.
The following information will help you determine the correct system to suit your specific requirements and when used in conjunction with other measures including good housekeeping, spill kits and training, will substantially reduce the risk of an incident
As a starting point the following questions will generate the information required to help you ensure you store products correctly and safely
- What are the liquids?
- Is there a fire, explosion or vapour release risk associated with any of the liquids?
- Is there a requirement to store any of the liquids separately?
- How many litres of each product do you want to store?
- Are you looking to bulk store, or use drums & or IBC’s?
- Will the liquid be stored indoors or out?
- If indoors are there any access issues with regard to the location?
- If outdoors are there surface water drains or a water course in the vicinity?
- How will the liquids be delivered to site?
- How will they be moved around the site?
The MSDS (Material Safety Data Sheet) for the liquids you use will provide much of the detail required to answer questions 1, 2 & 3 but you should also talk to the manufacturer for advice on issues such as segregation of liquids, possible explosion risk and vapour release hazards.
Determining the amounts (litres) of product you have on site and in what types of container (205ltr drums, 1000ltr IBC, bulk tanks etc) is fundamental to ensuring you don’t end up with product stored in a way that will lead to an incident. Don’t forget to include used, empty containers which are likely to have residues in them and must therefore still be stored correctly too.
You must consider the location of the storage area with great care to minimise the risks of damage to the environment, the health and safety of your employees and the public. It must be located somewhere that if liquids leak or spill, you will not pollute the air, land, surface or ground waters.
It goes without saying that your storage containers (bunded stores, spill pallets etc) must be designed with environmental protection in mind. This means that the bund and any storage units or spill pallets must be able to contain at least 110% of the volume of the largest container or 25% of the total volume stored, whichever is greater and you must check that they are made of a material that is compatible with the chemical you are storing. Don’t forget to consider how you protect the drums or IBCs when they are being moved around the site, bunded trolleys or mobile spill pallets are ideal but remember to properly secure the load before setting off.
If your bund is unprotected rainwater will collect in it and reduce its capacity, you must always check the contents before disposal to ensure you don’t cause a pollution incident by discharging contaminated water. It is against the law to discharge anything into the sewer that could harm or interfere with the treatment or disposal of the sewer contents. If you allow rainwater from bunds to enter surface waters or ground waters you must have an Environmental Permit or registered exemption in England and Wales, a discharge consent or groundwater authorisation in Northern Ireland or authorisation under the Controlled Activity Regulations (CAR) in Scotland. If you have an emergency safety showers on your site, ensure that any used water after an incident is disposed of in the appropriate manor as it may be contaminated. You can dispose of this water to the foul sewer, but you will need permission from your water company or water authority first.
You must dispose of all contaminated water as hazardous/special waste.
Don’t forget areas where you have smaller amounts of liquids such as laboratories, test rigs, workshops or vehicles. The same rules apply but you may only require a laboratory cabinet (Flammable liquids must be held in a fire-proof steel cabinet, the current legal requirement in the UK is a single skinned cabinet) to store the liquids in. Remember to consider segregation issues when storing different liquids together and ensure that the cabinet is secured to the floor and/or wall to prevent it toppling over, avoid the temptation to store liquids directly on the floor, even on a temporary basis, and always avoid storing above eye-height, or on top of cupboards or cabinets. Wear/use PPE (Personal Protective Equipment) as appropriate at all times.
Consider if you need to install Emergency showers for the prompt de-contamination of anyone who may have been caught up in an incident. If you already have showers in place; are they fully compliant with the temperature and flow rate over time requirements of the internationally recognised ANSI Z358.1 2009 standards? (Minimum of 75.7ltr per minute of tepid water for a minimum of 15 minutes.
Are they located within 10 seconds “travel time” of recognised hazard areas?
Keep an inventory of the liquids you have on site and ensure it is kept somewhere it can be accessed easily out of hours for use by spill responders or outside agencies
It’s important that your staff is trained and know how to deal with any spills that may occur, and that you have a pollution incident response procedure in place. If you store lots of liquids or have a chemical warehouse, you should consider installing a spill alarm so that you can evacuate the building in the event of spill. You may need a major accident prevention policy under the Control of Major Accident Hazards (COMAH) Regulations.
More information on our BSIF accredited First Responder to Liquid Spills Training can be found on: First Responder to Liquid Spills Training
Ensure that you have spill kits, containment equipment and drain sealing products suitable for the type and quantity of chemicals you store and use on your site. Remember it’s always better to try and keep any spill above ground and deal with it there.
Locate your spill response equipment close too and remote from any area that poses a risk and remember to ensure its location is marked on your site plan (again available to staff or outside agencies) and that the equipment is highly visible and not hidden behind anything that will restrict access.
Never hose a spill down the drain you could cause a much worse pollution incident.
Remember if you cause pollution you could be fined and prosecuted.
When considering the storage of flammable liquids, over and above all the previously mentioned there are strict adherences concerning separation distances. This is the distance the flammable liquids must be stored from occupied buildings, boundaries, process units, flammable liquid storage tanks and or sources of ignition.
If you can achieve the relevant distance you can use a standard single skinned, fully bunded storage unit to hold your flammable liquids. If you can’t achieve the relevant distance the storage unit needs to be constructed to provide a minimum of 30 minutes fire resistance to comply with UK legislation.
The safe storage of flammable liquids in process areas, workrooms, laboratories and similar working areas requires additional careful and informed consideration.
The Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) require risks from the indoor storage of Dangerous Substances to be controlled by elimination or by reducing the quantities of such substances in the workplace to a minimum and providing mitigation to protect against foreseeable incidents.
There are 3 elements required for a fire to start:
HEAT — OXYGEN — FUEL
If you eliminate any one of these elements, you eliminate the fire
HEAT can be any ignition source which generates heat, such as a mechanical spark, static electricity, a naked flame such as from welding equipment etc.
OXYGEN is all around us
FUEL can be any flammable or combustible liquid, remember flammable vapours are a significant hazard too.
Store flammable liquids in a separate area in purpose made bins or cupboards that are compliant with UK regulations and when dispensing, ensure there is good ventilation and no sources of ignition. Always keep containers closed when not in use, whenever possible use safety containers with self-closing lids and flame arresters and always have the appropriate spill kit available too.
Flammable dust in the atmosphere can if ignited and or explode violently, so if you handle flammable dusts you need to remember to keep your plant dust-tight and regularly clean the area to keep it dust free. Don’t forget to vacuum any spills as they occur, remember you will need intrinsically safe equipment.
Many types of packaging material (plastic foam, polyester wadding, textiles etc) give off dense black smoke when they burn so remember not to store them close to heaters or electrical equipment which could act as an ignition source.
Gases are often stored at very high pressure and any uncontrolled release can fill a large area quickly, this is particularly true of liquefied gases such as LPG. You should store cylinders in a designated area in purpose built stores and always restrain the cylinders and try to protect the valves from potential impact damage.
Materials that ordinarily burn slowly will burn vigorously in an oxygen rich atmosphere so in the same way that you protect flammable gases you must store any oxygen in a secure and controlled manor and over and above that, remember never use oxygen instead of compressed air, never use oxygen to sweeten the air in a working area or confined space and never use grease or oil on equipment containing oxygen as they can self ignite.
Some products have chemicals such as organic peroxides as part of their composition which can explode if not stored and handled correctly. Whilst other substances can react with incompatible materials or contaminants in an explosive manor, for example oxidising chemicals can cause flammable materials to ignite and some substances such as sodium react violently and can ignite when they come into contact with water. Storage and process temperatures should be controlled in line with recommended levels so check the MSDS or contact the manufacturer’s help desk for information/advice to prevent dangerous decomposition or reactions.
The risk of explosion and or fire from flammable gases, mists, vapours or even combustible dust is ever present in a great many working environments. Once the substance mixes with the air all it needs is a source of ignition to cause an explosion. It goes without saying that this scenario can lead to serious injuries and or a loss of life as well as significant damage to property.
Preventing the releases of dangerous substances, which can create explosive atmospheres, and preventing sources of ignition are critical to reducing the risk of an incident and with the onus for ensuring your products are stored correctly and your handling and use procedures are safe and fully compliant being your responsibility, it is key that you fully understand the hazards associated with those products. Information from Material Safety Data Sheets and manufacturer’s help desks are invaluable sources of accurate facts and manufactures of safety equipment such as fire rated storage units, earthing wires, or flammable liquid transfer containers will of course offer specific advice too. Please don’t forget to consult with your local authority fire brigade and your insurance provider.
Some questions worth considering when working with flammable substances are:
Is there good natural air movement in and around where the flammable substances are stored and used?
If not you may have to consider mechanical air changes. Good ventilation will mean that any vapours given off from a spill, leak, or release will be rapidly dispersed.
Have all the obvious ignition sources been removed from the storage and handling areas? You need to think outside the box as an ignition source can be very varied, sparks from electrical equipment, welding or cutting tools, hot surfaces, open flames, static charge etc.
An explosion can even be caused by the simple action of decanting a flammable liquid from one container to another if they have not been earthed.
Are your flammable substances kept in the correct type of container?
Does it need to be fire rated?
Or if there is a spill will it be contained and prevented from spreading?
Dependant on the quantity of product involved and the separation distance you may need a fire rated storage unit.
Can you replace a flammable substance for a less flammable one?
Or can you eliminate it from the process completely?
Processes and products evolve, check with your supplier(s) and see if they can help you redesign yours to make it safer.
Are your flammable substances stored and used in a different area to other processes?
By separating them you will lessen the risk of an incident and improve workplace safety.
For practical purposes where flammable liquids are required in a process, there is likely to be a need for a limited quantity to be stored and available in the workplace. It is the responsibility of the employer / duty holder when carrying out their risk assessment to justify the need to store any particular quantity of flammable liquid within the work room / working area.
However, the guiding principle is that only the minimum quantity needed for frequently occurring activities or an amount required for use during half a day or one shift should be present in the work room / working area. Actual quantities will depend on the work activity and also the arrangements for controlling the fire risks. When not in use, containers of flammable liquids needed for ongoing work should be kept closed and stored in suitable fire resistant cabinets or bins which are also designed to retain spills. They should be located in designated areas that are where possible away from the processing area don’t interfere with any escape route from the working area.
Flammable liquids should be stored separately from other dangerous substances that may enhance the risk of fire or compromise the integrity of the container or cabinet / bin it’s stored in; for example, oxidizers and corrosive materials should be stored separately from each other. Remember other dangerous substances may also be flammable in their own right however, it is still inappropriate to store these in the same cabinet / bin with flammable liquids. For further guidance on energetic and spontaneously combustible substances please consult HS (G) 131 published by the HSE.
The HSE recommends that the maximum quantities that are stored in cabinets / bins are no more than 50ltr for extremely flammable, highly flammable and those flammable liquids with a flashpoint below the maximum ambient temperature 30ºC of the working area; and no more than 250ltr for other flammable liquids with a higher flashpoint of up to 55°C. These quantities are intended to be viewed as recommended maximums and represent good industry safe practice, rather than being taken as the absolute limits. There can be some flexibility with the limits of the quantities stored, where it is understood that the design of the building and or the pattern of work can sometimes make adherence to these quantities difficult. For example in large or open-plan working areas where the employer / duty holder does identify a need to store quantities in excess of the recommended maximum, they must fully demonstrate the need for this requirement and in particular the risk assessment should take into account:
The properties of the materials to be stored or handled (For mixed storage the worst case situation should be applied, i.e. all materials in the storage cabinets or bin should be considered as being as dangerous as the one that has the lowest flashpoint) the size of the workroom / working area and the number of people working in it. The amount of flammable liquids being handled in the working area and the quantities of liquid that may be accidentally released or spilled.
In the event of an incident the objective is to ensure that people can safely escape from the working area and in this context, the purpose of storing Dangerous Substances in the appropriate cabinets / bins is to provide a physical barrier to delay the involvement of the stored materials in a fire and provide sufficient time for people’s safe evacuation and the duty holder’s immediate emergency procedures supporting this to be implemented.
It is the responsibility of the employer / duty holder to ensure that cabinets / bins meet the minimum legal requirements. Equally, the use of cabinets / bins with enhanced fire performance should not be seen as a substitute for the provision of a dedicated store room(s) and outdoor storage areas for the safe keeping of containers which are nominally empty or are not needed for current work.
It’s important not to overlook any aspect associated with the safe handling of flammable liquids such as static discharge during filling / decanting, combustion due to excessive heat build-up, potential ignition sources such as a spark from a tool or electrical component and pressure build-up in a container.
Please remember to consult with your insurance provider and local authority fire brigade as they will have valuable input that could save you time and money going forward.
An outside pair of eyes will often see things that have become commonplace to you, so you might want to consider using the services of an outside company to assess / review your site.
Empteezy® who have more than 25 years experience of manufacturing spill containment and spill response products are the only company within its industry to be accredited to
ISO 9001, ISO 14001 & ISO 18001 offers; free of charge and without onus site assessment service.
Empteezy® - A British Manufacturing Company