You’ve carried out a risk assessment on your flammable liquids storage areas and you’ve eliminated a number of chemical hazards. But this doesn’t mean the job is done and you can throw out your paperwork — you still have a legal responsibility to review those elimination controls and make sure the hazard hasn’t re-emerged in another area of the business. In today’s blog we’ll be highlighting 3 essential steps when reviewing hazard control measures to ensure your flammable liquids stores remain safe and compliant.
REMEMBER: All businesses that use, store, handle or generate Class 3 Flammable Liquids have a duty under Section 35 of Australian WHS Regulations to look for ways to stop using the chemicals. These are known as elimination controls.
1. Elimination controls for flammable liquids
Completely removing a hazardous chemical from your inventory is the ultimate risk control measure — because the hazard no longer exists. But eliminating chemical hazards can be very difficult to achieve because you either have to change your business outputs, or find another way of completing the original task. In many cases it’s not even possible.
Here are some examples of elimination controls which we’ll unpack later in the blog:
- Using steam, water pressure, or ultra sound for cleaning instead of flammable solvents.
- Using water-based paints or powder coasting instead of enamel paints.
- Using nails, bolts, clips, or clamps to hold something in place instead of flammable adhesives.
- Using water-based or hot melt adhesives rather than solvent-based adhesives.
- Changing from petrol/diesel powered machinery and appliances to electrical equipment.
These elimination controls look great on paper, but they can be expensive to implement and in many cases, new hazards are introduced. That’s why it’s critically important to regularly review hazard control measures.
2. Reviewing original controls
Let’s imagine you’ve implemented all of the elimination controls listed in the previous section, now you want to carry out a review to make sure the hazard no longer exists. Sometimes elimination controls merely transfer a hazard to another area of the business.
Your review should immediately identify if any of the flammable chemicals are still present on the job site. If the purchasing department hasn’t been properly notified, they may continue to order flammable liquids that are no longer being used. Here are some considerations based on our previous list:
- Have all cleaning processes been changed over to water/steam/ultra sound? If the new cleaning methods are not as effective as the original solvent-based cleaning, line supervisors may order their staff to resume old work practices without informing management.
- Are any enamel paints still present on the job site? If obsolete chemicals aren’t flagged for removal they can sit around the job site for years.
- Have any maintenance workers started using adhesives again instead of bolts, clamps, and clips? Workers who have not been notified of a new process may continue to carry out their work using old methods?
- Are all maintenance crews using the new water based/hot melt adhesives instead of solvent-based adhesives? Workers may be instructed by supervisors to use up remaining batches of flammable adhesives before changing to new work processes.
- Have all petrol/diesel machines been changed over to electrical equipment? Elimination controls can be expensive, and it may not be feasible to change over every vehicle or machine right away.
Now you’ll need to identify if your elimination controls have created any new hazards. Based on our original list this could include:
- Are workers now facing new hazards from the high-pressure water jets, heat from steam, noise, and ejected particles?
- Are workers now exposed to inhalation and respiratory hazards while powder coating?
- Are clips, bolts, and clamps holding materials securely in place? Could they fail and injure someone — or trigger a dangerous event chain?
- Are workers now at high risk of severe skin and eye burns from hot melt adhesives?
- What new hazards have battery powered forklifts created? Manual handling injuries while lifting batteries? Exposure to sulphuric acid contained in the batteries?
3. Supplementary controls
Finally, your review should consider any supplementary elimination controls that could be implemented. In these instances the flammable liquids are still present on the job site, but you eliminate potential contact points. For example:
- Restricting pedestrian and vehicular access to flammable liquids storage areas to eliminate the event of chemical containers being impacted.
- Banning workers from bringing matches, lighters, personal electronics, and tools that could produce a spark into flammable liquids stores.
If Class 3 Flammable Liquids are fundamental to the operations of your business (and unable to be eliminated), we encourage you to download and read our latest eBook Essential Considerations When Storing Flammable Liquids Indoors. Using indoor storage cabinets that have been manufactured to AS1940:2017 – The storage and handling of flammable and combustible liquids is a known engineering control that isolates the chemicals from ignition sources, heat and incompatible substances. Download and read it today, it’s completely free.