One of the most common faults we identify during the safety audits we conduct for clients, are chemicals stores and handling stations that have become a high risk area simply due to poor housekeeping. This blog is about training and supervision: because the money you invest in chemical stores, pallet bunds, and safety cabinets is wasted if your staff don’t know how (or won’t take the time) to put things away correctly.
REMEMBER: Chemical storage and handling areas that are not used and maintained correctly create unnecessary risks to the health of workers and the overall safety of the job site. When your staff use (or are likely to be exposed) to hazardous chemicals you have a duty under Australian WHS legislation to train your staff and provide them with adequate supervision.
Storing and handling chemicals safely
Compliant chemical stores and handling areas have two important elements: first you need to have the correct equipment; and second you need to use it correctly. Don’t assume that when you install new chemical stores or under-pallet spill bunds that your staff will automatically begin using them properly. They’ll need some training, and then enough supervision to ensure they are following safety procedures and aren’t putting themselves or other workers at risk.
We thought the best way to illustrate this was with two real examples.
EXAMPLE 1: bunded chemical stores
Bunds are used to collect spills from IBC stores or drum storage areas where flammable or otherwise toxic liquids are held. Bunds should be able to hold 110% of the maximum capacity of the largest container. Whenever you install a new bunding system for your chemicals, staff should be given full instructions so they understand the importance of using them correctly.
In our audits we frequently see things like:
|Fuel drums sitting on the floor next to the spill bund.||No spill protection.||Staff not receiving sufficient supervision and getting slack with housekeeping.|
|Chemical containers stacked high on bunded pallets||Bund capacity could not contain a possible chemical spill.||Staff don’t understand the capacity of the spill bund and aren’t being supervised properly.|
|Deliveries of IBCs still sitting on the ground outside the chemical store 48 hours after drop-off.||No spill protection.||Inadequate supervision.|
|IBCs of non-hazardous chemicals placed on bunds but other IBCs with corrosives etc left sitting on the ground||No spill protection.||Staff haven’t been trained properly and cannot distinguish hazardous chemicals from non-hazardous substances. OR staff simply can’t be bothered separating the chemicals and storing them properly.|
In many cases the problem is a combination of high staff turnover, lack of remedial training, and inadequate supervision. When a new staff member sees their co-worker leaving fuel drums next to the bunded pallets, they copy this behaviour. Even if they were trained correctly when they commenced employment, without adequate supervision and review training your chemical stores can quickly become a high risk area.
EXAMPLE 2: chemical safety cabinets
Most classes of hazardous chemicals and dangerous goods require dedicated chemical stores constructed according to stringent Safety Standards. But a compliant flammable liquids store offers no fire protection if the cabinet is overloaded or has incompatible substances placed inside.
During our chemical audits we regularly see:
|Mixed classes of hazardous chemicals stored in the one chemical store.||Incompatible substances could cause a dangerous reaction eg, fire/explosion.||Staff don’t understand the hazard classes of the chemicals, or are just being slack.|
|Chemical containers left open or with the lids not completely sealed.||Containers could be knocked over and spill, or escaping vapours can create a fire and exposure risk.||Staff aren’t following procedures and supervisors aren’t checking the chemical stores.|
|Some Safety Data Sheets (SDSs) are missing from the HAZCHEM Register kept with the cabinet.||Staff need emergency first aid information in a hurry. NOTE: this is also a compliance issue.||SDSs were not returned after being used or never obtained in the first place.|
|Chemical containers left sitting on top (or next to) the safety cabinet.||Containers could leak or be knocked over/broken.||Containers won’t fit in the cabinet, or the cabinet is locked and the manager has the key.|
Workers aren’t always being lazy or slack when they put chemical containers in the wrong area. When chemical safety cabinets reach capacity staff will often leave containers on top of a cabinet or look for another cabinet that still has some shelf space. Again, supervision can quickly correct these issues.
LEGISLATION: A person conducting a business or undertaking must provide any information, training, instruction or supervision that is necessary to protect all persons from risks to their health and safety arising from work carried out as part of the conduct of the business or undertaking. WHS Act (Section 19(f))
Supervising staff and enforcing workplace hygiene
Without supervision workplace hygiene deteriorates, and safe work practices become tardy and inconsistent. Many fatal incidents at work occur when workers try to undertake tasks that are largely unsupervised and outside the scope of established procedures.
Effective supervision has a number of essential components including:
Delivering clear and accurate instructions
Assessing the competency of workers while performing their duties
Carrying out routine inspections and audits of work areas
Conducting refresher training and counselling when necessary
Conducting refresher training
Refresher training is an important part of effective supervision and not only required when staff demonstrate substandard performance. You should also conduct training reviews when work procedures change or if staff members have spent time away from their regular duties. You may need to carry out a training needs analysis which should be conducted in consultation with relevant workers and their supervisors.
IMPORTANT: Remedial training is a specific requirement of many Australian Safety Standards including AS4332-2004 - The storage and handling of gases in cylinders and AS1940:2017 - The storage and handling of flammable and combustible liquids.
Staff training and supervision is an administrative control and an important part of your risk management plan. To gain a greater understanding of the steps required to eliminate (or minimise) the chemical hazards at your job site, why not download our free eBook How to manage the risk of Hazardous Chemicals in the workplace. Read it today and get your workplace 100% chemical safety compliant