Liquefied Petroleum Gas (LPG) Storage

What is LPG?

Liquefied petroleum gas (LPG) is a colourless odourless liquid which readily evaporates into a gas. Normally an odourant has been added to it to help detect leaks.

LPG (either Butane or Propane), is generally stored and distributed as a liquid and it is widely used for process and space heating, cooking and automotive propulsion.  .  It is classified as highly flammable and if it contains more than 0.1%Butadiene, it is also classified as  a carcinogen and mutagen.

LPG is non-corrosive but can dissolve lubricants, certain plastics or synthetic rubbers.

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What are the dangers of LPG?

LPG may leak as a gas or a liquid.  If the liquid leaks it will quickly evaporate and form a relatively large cloud of gas which will drop to the ground, as it is heavier than air.   LPG vapours can run for long distances along the ground and  can collect in drains or basements.  When the gas meets a source of ignition it can burn or explode.

Cylinders can explode if involved in a fire.

LPG can cause cold burns to the skin and it can act as an asphyxiant at high concentrations.

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What are the Regulations?

The regulations are framework in character.  They lay down general requirements but rely for detailed guidance upon codes of practice which may be approved from time to time by the Health and Safety Authority.  These regulations apply in addition to any other requirements under relevant statutory provisions.

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What do the Regulations cover?

The regulations cover storage, loading and unloading, use of LPG and related activities, carried on in the course of any trade or business, involving more than 70kg or a total volumetric storage capacity above 160 litres. The regulations do not apply to fuel tanks of vehicles.

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What other Regulations apply to the storage of LPG?

• The Safety, Health and Welfare at Work (General Application) Regulations
• The European Communities (Control of Major Accident Hazards involving Dangerous Substances) Regulations, 2006, apply to the storage of LPG at inventories of 50 tonnes or greater

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Who must comply?

Obligations are placed upon occupiers, suppliers of LPG, persons present at installations, designers of plant and persons installing plant.

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What are the general requirements?

• LPG must be stored in adequate location wherein vessels or cylinders are suitably positioned having regard to the relevant codes of practice
• LPG  plant must be designed to appropriate standards and be properly installed and commissioned by competent persons
• Plant must be fitted with adequate safety and monitoring control devices and operated by competent persons
• Occupiers must notify the gas supplier of any structural or other changes which might affect the gas installation
• There must be a suitable programme of maintenance and testing by competent persons
• Plant must be identifiable and accessible for maintenance
• Records of maintenance and tests must be kept
• Precautions must be taken to prevent fire and explosion including appropriate protection of storage vessels
• Installations must have appropriate security measures to prevent deliberate interference
• Incidents involving death or hospitalisation, fire or explosion or a significant release of LPG must be reported to the Authority and records of such incidents must be kept

Hazard and Risk

What is a Hazard?

When we refer to hazards in relation to occupational safety and health the most commonly used definition is ‘A Hazard is a potential source of harm or adverse health effect on a person or persons’.

The terms Hazard and Risk are often used interchangeably but this simple example explains the difference between the two.

If there was a spill of water in a room then that water would present a slipping hazard to persons passing through it. If access to that area was prevented by a physical barrier then the hazard would remain though the risk would be minimised.

What is Risk?

When we refer to risk in relation to occupational safety and health the most commonly used definition is ‘risk is the likelihood that a person may be harmed or suffers adverse health effects if exposed to a hazard.’

Categorising Risk

The level of risk is often categorised upon the potential harm or adverse health effect that the hazard may cause, the number of times persons are exposed and the number of persons exposed. For example exposure to airborne asbestos fibres will always be classified as high because a single exposure may cause potentially fatal lung disease, whereas the risk associated with using a display screen for a short period could be considered to be very low as the potential harm or adverse health effects are minimal.

What are Control Measures?

Control measures include actions that can be taken to reduce the potential of exposure to the hazard, or the control measure could be to remove the hazard or to reduce the likelihood of the risk of the exposure to that hazard being realised. A simple control measure would be the secure guarding of moving parts of machinery eliminating the potential for contact. When we look at control measures we often refer to the hierarchy of control measures.

1. Eliminate the hazard	Elimination of the hazard is not always achievable though it does totally remove the hazard and thereby eliminates the risk of exposure. An example of this would be that petrol station attendants in Ireland are no longer exposed to the risk of chronic lead poisoning following the removal of lead from petrol products sold at forecourts.
2. Substitute the hazard with a lesser risk	Substituting the hazard may not remove all of the hazards associated with the process or activity and may introduce different hazards but the overall harm or health effects will be lessened. In laboratory research, toluene is now often used as a substitute for benzene. The solvent-properties of the two are similar but toluene is less toxic and is not categorised as a carcinogen although toluene can cause severe neurological harm.
3. Isolate the hazard	Isolating the hazard is achieved by restricting access to plant and equipment or in the case of substances locking them away under strict controls. When using certain chemicals then a fume cupboard can isolate the hazard from the person, similarly placing noisy equipment in a non-accessible enclosure or room isolates the hazard from the person(s).
4. Use engineering controls	Engineering Controls involve redesigning a process to place a barrier between the person and the hazard or remove the hazard from the person, such as machinery guarding, proximity guarding, extraction systems or removing the operator to a remote location away from the hazard.
5. Use administrative controls	Administrative controls include adopting standard operating procedures or safe work practices or providing appropriate training, instruction or information to reduce the potential for harm and/or adverse health effects to person(s). Isolation and permit to work procedures are examples of administrative controls.
6. Use personal protective equipment	Personal protective equipment (PPE) include gloves, glasses, earmuffs, aprons, safety footwear, dust masks which are designed to reduce exposure to the hazard. PPE is usually seen as the last line of defence and is usually used in conjunction with one or more of the other control measures. An example of the weakness of this control measure is that it is widely recognised that single-use dust masks cannot consistently achieve and maintain an effective facepiece-to-face seal, and cannot be adequately fit-tested and do not offer much, if any real protection against small particulates and may lead to a false sense of security and increase risk. In such instances an extraction system with fitted respirators may be preferable where the hazard may have significant health effects from low levels of exposure such as using isocyante containing chemicals.

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What is Risk Assessment?

Risk Assessment is where the severity of the Hazard and its potential outcomes are considered in conjunction with other factors including the level of exposure and the numbers of persons exposed and the risk of that hazard being realised. There are a number of different formulae used to calculate the overall risk from basic calculations using high, medium and low categories to complicated algorithms to calculate risks at Nuclear power stations and other high risk work locations.

It is important to ensure that the residual risk following implementation of control measures is ‘as low as is reasonably possible (ALARP). For a risk to be ALARP it must be possible to demonstrate that the cost involved in reducing the risk further would be grossly disproportionate to the benefit gained.

- See more at: http://www.hsa.ie/eng/Topics/Hazards/#sthash.nqmnz7ry.dpuf

Explosives

Uses of Explosives

Explosives are used in a number of industries and locations in Ireland. They are used extensively in underground mining and surface hard rock quarrying operations. They are also used frequently in the construction industry for the development of new roads, excavation of ground for the foundations of buildings or basement areas and in demolition work.

Types of Explosives

There are many types of explosives used in Ireland and these include ANFO, which is a mixture of Ammonium Nitrate and Fuel Oil (Diesel), pumped emulsion which is a liquid explosive, gelignite based cartridge explosives, and shock tube compressed gas explosives. Explosives require initiation and this is achieved through the use of detonators, detonating cord and in rare cases detonating fuse.

Who Can Use and Handle Explosives?

There are strict controls on who can be involved in the transport, storage and use of explosives and explosive products and a qualified shotfirer is always required to undertake blasting operations. In addition to health and safety legislation on the use and storage of explosives there are also legislative requirements enforced by Inspectors from the Department of Justice, Equality and Law Reform.

- See more at: http://www.hsa.ie/eng/Topics/Explosives/#sthash.x53A0ipy.dpuf

Working in confined space

What is a confined space?

Confined Space refers to any place, including any vessel, tank, container, pit, bund, chamber, cellar or any other similar space which, by virtue of its enclosed nature, creates conditions that give rise to a likelihood of an accident, harm or injury of such a nature as to require emergency action due to

• the presence or reasonable foreseeable presence of:
  -    flammable or explosive atmospheres
  -    harmful gas, fume or vapour
  -    free flowing solid or an increasing level of liquid
  -    excess of oxygen
  -    excessively high temperature
• the lack or reasonably foreseeable lack of oxygen

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What are the key characteristics which define a confined space?

The key characteristics of a confined space are:

• the space must be substantially enclosed
• there must be a risk of at least one of the hazards listed above occurring within the space
• the risk of serious injury from the hazard must be created by virtue of the enclosed nature of the space
• the potential injury must be serious and be such as to require emergency action to rescue the person involved.

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What are the hazards associated with confined spaces?

The hazards associated confined spaces include:

• Toxic Atmosphere
  A toxic atmosphere may cause various acute effects, including impairment of judgement, unconsciousness and death. A toxic atmosphere may occur due to the presence or ingress of hazardous substances. These substances may be present in the Confined Space for various reasons such as:
  -    remaining from previous processing or storage
  -    arising from the disturbance of sludge and other deposits
  -    the presence of a fire or flames within the space
  -    seepage from improperly isolated adjoining plant
  -    formation during the work processes carried out in the space
  -    being released from under scale and in brickwork as a result of the work process
• Oxygen Deficiency
  Oxygen can be lacking a confined space for the following reasons:
  -    displacement of air by another gas
  -    various biological processes or chemical reactions (such as rotting of organic matter, rusting of metals, burning, etc)
  -    absorption of air onto steel surfaces, especially where these are damp
• Oxygen Enrichment
  An excess of oxygen, in the presence of combustible materials, results in an increased risk of fire and explosion. Some materials, which do not burn in air, may burn vigorously or even spontaneously in an enriched oxygen atmosphere.
• Flammable or Explosive Atmospheres
  A flammable atmosphere presents a risk of fire or explosion. Such an atmosphere can arise from the presence in the confined space of flammable liquids or gases or of a suspension of combustible dust in air. If a flammable atmosphere inside a confined space ignites, an explosion may occur, resulting in the expulsion of hot gases and the disintegration of the structure.
• Flowing Liquid or Free Flowing Solids
  Liquids or solids can flow into the confined space causing drowning, suffocation, burns and other injuries.  Solids in powder form may also be disturbed in a confined space resulting in an asphyxiating atmosphere.
• Excessive Heat
  The enclosed nature of a confined space can increase the risk of heat stroke or collapse from heat stress, if conditions are excessively hot. The risk may be exacerbated by the wearing of personal protective equipment or by lack of ventilation

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What are the legal requirements in regard to confined space entry?

The Safety, Health and Welfare at Work (Confined Spaces) Regulations 2001 cover all work in relation to confined spaces.

Regulation 5 states that:

• A person shall not carry out work in Confined Spaces if it is reasonably practical that it could be avoided
• If the work must be carried out Hazard Identification and Risk Assessment must be carried out prior to the work commencing
• A person shall not enter a confined space unless there is a system of work in place that has been planned, organised, performed and maintained so as to render that work safe and without risk to health
• Anyone entering a confined space must be provided with appropriate information, training and instruction appropriate to the particular characteristics of the proposed work activities

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What are legal requirements in relation to Emergency Arrangements for confined spaces?

Regulation 6 of the Confined Space Regulations 2001 states that:

• A person shall not enter a confined space unless there is a suitable emergency arrangements have been made which are appropriate to the confined space in question
• The emergency arrangements shall include:
  -    all practical measures necessary to ensure the health and safety of  those taking part in the rescue
  -    the provision of a suitable and reliable means of raising the alarm in the event of an emergency
  -    having all necessary rescue equipment nearby and in a well maintained, good condition
  -    the provision of information, instruction and training to all involved in rescue procedures
  -    the provision of equipment and training for resuscitation procedures if there is a foreseeable risk that they will be needed.

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What must I look for in a confined space risk assessment?

When carrying out a risk assessment it is important to ensure that all risks associated with the hazards above are evaluated and controlled. When carrying out a risk assessment the following questions should be asked:

• What could be inside the space that would pose a risk?
  -    Contents?
  -    Oxygen Deficiency?
  -    Previous Contents?             
  -    Oxygen Enrichment?
  -    Residues?                            
  -    Structure and Layout?
  -    Contamination?
• What will be created due to the work carried out in the space?
  -    Sources of Ignition?            
  -   Flammable Substances?
• What‘s outside the space that might pose a risk during the proposed work?
  -    Inadequate Isolation?
  -    Inadvertent Operation Of Plant?
  -    Nearby Work Activities?

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Are there any exemptions from the Safety, Health and Welfare (Confined Spaces) Regulations 2001?

Yes. The regulations do not apply to any place below ground in a mine (as defined by the Mines and Quarries Act 1965) or to any diving operations.

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What are the key elements of a safe system of work for a confined space?

The key elements to be considered when drawing up a safe system of work are:

• Competence, training, supervision and suitability
• Permit-to-work procedure
• Gas purging and ventilation
• Dangerous residues
• Testing and monitoring of the atmosphere
• Mechanical, electrical and process isolation
• Respiratory protective equipment
• Other personal protective equipment
• Safe use of work equipment
• Communications
• Access and egress
• Flammable or explosive atmospheres
• Combustible materials

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What is a permit-to-work procedure?

A permit to work procedure is a means of achieving effective control of a system of work through formal written documentation known as a permit to work form.  The essential components of a permit-to-work system include:

• A written procedure, which sets out how the system is to operate and clearly defines who may authorise particular jobs and who is responsible for specifying and implementing the necessary precautions
• A form, known as the "permit-to-work form", which becomes a written and signed statement ensuring both the establishment of safe conditions for the work to commence and the maintenance of safe conditions for the duration of the work, including the provision of emergency arrangements
• A method of informing the persons carrying out the work of the exact identity, location, nature and extent of the job, the hazards involved and the precautions to be taken, and
• A system for ensuring the safe hand-back of the workplace after the job is completed and, in the case of confined space entry, after the space is vacated

Working at Height

These are briefing notes on the Work at Height Regulations - and some of the things you should be doing about them.

What is work at height?

Work at height is work in any place, including a place at, above or below ground level, where a person could be injured if they fell from that place. Access and egress to a place of work can also be work at height. 

Examples of work activities that are classified as working at height:

• Working on trestles
• Working on a flat roof
• Erecting false work or formwork
• Working on a ladder
• Working at ground level adjacent to an excavation;
• Working on formwork within an excavation
• Working near or adjacent to fragile materials

Our key messages 

• Carry out risk assessments for work at height activities and make sure that all work is Planned, Organised and carried out by a competent person
• Follow the  General Principles of Prevention for managing risks from work at height – take steps to avoid, prevent or reduce risks
• Chose the right work equipment and select collective measures to prevent falls (such as guard rails and working platforms) before other measures which may only reduce the distance and consequences of a fall (such as nets or airbags) or may only provide fall-arrest through personal protection equipment. 

Requirements for employers

The Work at Height Regulations require employers to ensure that:

• All work at height is properly planned and organised
• A risk assessment is carried out for all work conducted at height
• Appropriate work equipment is selected and used
• People working at a height are competent
• Equipment used for work at height is properly inspected and maintained
• Risks from fragile surfaces are properly controlled 

The risk assessment should include a careful examination of what harm could be caused from working at height with a view to taking the effective steps to reduce the likelihood of this harm occurring, either through avoiding the activity or, where this is not reasonably practicable, by carrying it out in a safe manner using work equipment that is appropriate to the task and the level of risk.

Exceptions

Examples of where these regulations do not apply would include:

• Walking up and down a staircase in an office
• Working in an office on the upper floors of a temporary accommodation building
• Sitting in a chair
• Work carried out by private individuals on their own homes where this is not for the purpose of business or trade

- See more at: http://www.hsa.ie/eng/Topics/Work_at_Height/#sthash.NNrYMBm7.dpuf