Storage of Hazardous Substances
Much has already been said in these pages regarding Fire Risk Assessments but the legal requirements for Risk Assessments in your place of work doesn’t stop there.
Regulations
The Control of Substances Hazardous to Health (COSHH) Regulations 2002, also requires you to ensure chemicals and dangerous substances stored, used or sold from the workplace are stored and handled in a way that minimise the attendant risk to employees and visitors of exposure to these substances. You must also ensure that you also minimize the risk of environmental damage through leaks and spills.
DSEAR (Dangerous Substances and Explosive Atmospheres Regulations 2002) is a further set of regulations concerned specifically with protection against risks from fire, explosion and similar events arising from dangerous substances used or present in the workplace.
Risk assessment
As with Fire Risk Assessments the COSHH and DSEAR risk assessment require employers (and the self employed) to conduct a detailed examination of the work place and working practices to identify any dangerous substances present or liable to be present in the workplace; the work activities involving them and an assessment of any risks (like sources of ignition) that may cause a fire, explosion and similar events that have potential to harm employees and the public.
Conducting a Risk Assessment requires a combination of knowledge of the substances used in the workplace, the hazards they pose and a fairly common sense approach to what constitutes a risk. It is then a case of implementing precautions that minimise this risk. Some typical examples are given below.
Store hazardous chemicals in accordance with manufacturer’s instructions in an appropriate container or cabinet clearly marked with a Hazard warning label. A range of cabinets designed to meet COSHH and DSEAR regulations are available.
Store the minimum quantity of hazardous substances necessary.
Look at the manufacturer’s safety data sheet and store incompatible substances separately.
Keep a spill kit close to storage areas to contain and clean up and leaks or spills that occur. Most approved flammable liquid and COSHH storage cabinets have inbuilt spillage sumps.
Issue staff with appropriate protective clothing (PPE) and ensure adequate ventilation when handling substances.
Make sure that any employees that handle dangerous substances are aware of what to do in the event of a spill or fire.
A risk assessment is required regardless of the quantity of dangerous substance present, and as like the Regulatory reform (fire safety) Order legislation, if you have 5 or more employees you must keep a physical record of the assessment and actions taken.
Finally if your business has oil storage containers, the Control of Pollution (Oil Storage) (England) Regulations 2001 or the Water Environment (Oil Storage) (Scotland) Regulations 2006 may apply.
The oil storage regulations apply if you store oil above ground in containers with a capacity of more than 200 litres. The regulations define Oil to include petrol, heating oil, vegetable and plant oil, and heavy oils such as bitumen and solvents.
You are not affected by the regulations if:
- Your store a maximum capacity of 200 litres and/or it is located in a building or underground (as in a garage)
- Your business is used for refining or distributing oil
- You operate a farm or wholly agricultural business
- You store waste oil
More reading on DSEAR can be found at http://www.hse.gov.uk/pubns/indg370.pdf and
COSHH at http://www.coshh-essentials.org.uk/
Tony
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Welsh boost for the Sprinkler Industry?
In what has been hailed as a landmark decision in Fire Safety the Welsh Assembly members voted on Wednesday 27th Jan this year to make the installation of automatic fire sprinklers compulsory in all new build homes in Wales.
The euphoria amongst the proponents may well be short lived as the Welsh vote is only the first step and now needs to be formally approved in both houses of Westminster before the legislation can receive Royal assent. Allocating parliamentary time this side of the General Election seems highly unlikely and the new incoming Administration may not be so keen on supporting such legislation.
Not that I am in any way against the wider use of automatic sprinklers but I do see some difficulties in enforcing any legislation. The powerful construction industry lobby may well have something to say as it will add a few thousand pounds to building costs. There is also the issue of ensuring regular maintenance and testing which is essential with Automatic Sprinkler Systems and will represent an ongoing annual cost for the householder.
Private and self build home builders could well argue that other equally effective options are available in the form of smoke alarms and the more versatile domestic friendly fire extinguishers like the ABF, that are already reducing the incidence of deaths and injuries from domestic fires. The figures bear this out with official statistics showing sustained year on year falls in death and injuries from domestic fires.
I also think Ronnie King, vice-chairman of the National Fire Sprinkler Network was letting enthusiasm get the better of his judgement in claiming the move would lead to making Wales the safest place in which to live in the United Kingdom. He went so far as comparing Residential Sprinklers to the installation of air bags in cars and added that “in the course of time fire deaths in Wales will be almost eliminated, and the horrific burns injuries reduced by up to 80% because of this wonderful visionary decision taken by the Welsh Assembly government.”
Now the current housing stock in Wales according to the latest Government statistics is 1.4million homes or thereabouts virtually none of which have, or will ever have sprinklers fitted. New house builds are running at around 5000 per year and demolitions at less than 100 a year. You don’t need to do the detailed math’s to see that “in the course of time” to reduce injuries by 80% will take a very, very long time indeed to achieve with sprinklers alone. Centuries in fact. It is akin to saying the World will end on Wednesday without specifying which Wednesday.
With the exception of multi occupancy complexes – where careless or reckless homeowners can put other residents at risk – legislation is arguably not the answer. A continuance of the high profile fire safety awareness campaigns, the free smoke alarm scheme and the low cost of alternative fire safety equipment will continue to make our homes a safer place. Promoting the undoubted benefits of sprinkler systems should obviously continue, but on the basis of choice and affordability rather than law enforcement.
Tony
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Getting to Grips with the new Fire Regulations
The Regulatory Reform (Fire Safety) Order 2005 rumbles on out into the business community and increasingly solicits frantic enquiries as to what it entails and how to conform. Now any small business out there can get hold of a copy and read it.
Visit www.opsi.gov.uk/si/si2005/20051541.htm#53 but be warned it is not an easy read.
Here’s a typical clause from the section explaining the “Duties under the Order”.
(3) Any duty imposed by articles 8 to 22 or by regulations made under article 24 on the responsible person in respect of premises shall also be imposed on every person, other than the responsible person referred to in paragraphs (1) and (2), who has, to any extent, control of those premises so far as the requirements relate to matters within his control. ”
Simples!!!
You should also be mindful of the virtually limitless powers afforded the fire inspectors under the act. I quote from article 27 “Powers of inspectors” where ” (1) Subject to the provisions of this article, an inspector may do anything necessary for the purpose of carrying out this Order and any regulations made under it into effect and in particular, so far as may be necessary for that purpose, shall have power to do (so) at any reasonable time.”
This was driven home in no uncertain manner when this July the authorities prosecuted the Church of the Mountain of Fire and Miracles Ministries International (I could not have made this up) who they “raided”, no better word for it, during a Church Service for 1200 penitent souls, and threw the book at them for breaches of the RRO to the tune of a £30000 fine. A case of too much fire and damnation no doubt.
To help clarify the key provisions I will post a series of tips that will guide you through. To start with you must conduct a formal fire risk assessment. A fire risk assessment helps you identify all the fire hazards and risks in your business premises. The Act does not apply to domestic residences.
You can then decide whether any risks identified are acceptable or whether you need to do something to reduce and or control them. A risk assessment should be carried out by someone who has reasonable experience or knowledge of fire safety. In the RRO’s parlance this could be the Responsible Person or a trained member of staff or external consultant.
There are five basic steps to complete a Risk Assessment.
1. Identify the fire hazards - smokers, machinery, fuel stores, hot plates, heaters, electrical equipment etc
2. Identify people at risk - employees, customers, visitors
3. Evaluating the risks - decide how best to minimise and or control a fire and safeguard those at risk should it occur - typically staff training, means of escape, fire warning bells, fire fighting equipment , signage etc.
4. Record your findings - and put in a safe place with you other health and safety documentation. The inspectors will home in on this as a first step in assessing compliance. The requirement to record your assessment technically applies to businesses employing 5 or more people but I advise you do it anyway.
5. Review and revise - revise the Risk Assessment to record fire equipment maintenance schedules, changes to office layouts, training sessions, new fire safety equipment and added fire risks.
Having completed the Risk Assessment you must then take appropriate actions in line with your findings, putting in place safety management procedures, fire prevention and fire control measures. If you have a particular concern or question regarding the interpretation of the RRO post it here and we will try and help.
Tony
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Shell Shocked
The news that Shell International that pillar of the industry and one of the world’s largest companies was fined a record £300,000 over deficiencies in fire safety at the Shell Centre in central London should strike a warning bell to all businesses large and small.
I raised this issue here some months ago to warn that the enforcement of the Regulatory Reform (Fire Safety) Order 2005 (RRO) was moving up the agenda with our Fire and Rescue Services.
London Fire Brigade (LFB) brought the prosecution following two small fires in three weeks at the Shell Centre on York Road, Waterloo following which Fire Officers found extensive breaches of the new legislation, including blocked escape routes and fire exits, defective fire doors and excessive fire loading. Shell pleaded guilty at the Inner London Crown court to three breaches of the RRO. It was the largest fine imposed thus far under the measure. The company was also ordered to pay £45,000 in costs.
If you are unlucky enough to have a fire incident on your premises that requires the attendance of the Fire Services you can expect them to put out the fire, but also be prepared for them to scrutinise your fire safety provisions with a fine tooth comb for non conformance with the RRO. And at just the moment when you think things can’t get worse!!
If any of you out there are saying to yourself “what the blazes is the RRO” (pun intended) take a look at http://www.opsi.gov.uk/si/si2005/20051541.htm It’s a great URL and a great read.
Of course the prospect of exacting juicy fines is bound to encourage the enforcers and those that enforce the enforcers, however I think more central investment in communicating the key RRO provisions to the mass of small business owners out there without a degree in Government speak would be an appropriate quid pro quo. If only.
Tony
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Fire Training College on fire
In an unusual if not ironic twist of fate a large fire on Saturday last at the Fire Service College in Moreton in Marsh, Gloucestershire destroyed 11 fire engines valued at £1.3m and the workshop they were kept in.
The fire was discovered at around 9.15am in the single storey building housing a workshop at the College - a building that also contained 1200 litres of diesel and 500 litres of hydraulic oil. Fourteen appliances drawn from Gloucestershire, Oxfordshire and Warwickshire Fire and Rescue Services, as well as a damage control unit and environmental protection unit were drafted in to help tackle the fire.
Fire crews managed to contain the fire and stop it from spreading to an adjacent bay housing even more fire appliances. The incident was brought under control by around 2.30pm with no reports of injury.
Just goes to show that fire has no respect for anything or anyone, and in what may be an embarrassment for the Fire Service College, we have yet to learn what caused the fire.
By the way figures out this week show that fire related deaths rose for the first time in many a year, up 5% to 476 in the 12 months to 30th June 2008. This despite the fact that overall the number of actual fires continues to fall in all categories. This worrying reversal of a long downward trend comes on the back of a separate report from the Institute of British Insurers confirming that the cost of fire damage in the UK last year rose by 16% to a record £1.3 billion.
Begs the question really how we end up with more deaths and more losses from fewer fires? Are we seeing the consequences of the Government’s “rationalisation” of the Fire and Rescue Services, reducing both the number of local Stations and Appliances and forcing them to cover huge geographical areas form centralised locations? Mitigating arguments are already being circulated for example blaming the recession for increases in arson related incidents. Fires are fires and large fires start as small fires - but increased average attendance times - a direct consequence of centralisation - give more time for large fires to develop. Seems logical to me!
Tony
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