evatech
Safety Management Services
Nelson, New Zealand
AgriBusiness. Issue 72 Nov/Dec.2008. HSNO-Series. Bruce Evans
Clarity the aim, more confusion the result
Confusion exists between Class 9 Dangerous Goods and Class 9 Ecotoxicity. Sample pictograms help explain transport issues.
In the last issue of this column a diagram showing the two class 9 labels was used to try and provide clarity on the issue of differing labels being required for transport and HSNO. The sub editors cropping of the original picture for space saving reasons may have lead to more confusion by wrongly swapping the captions. Check out the correct labels below to clarify that there are two ‘Class 9’ product labels, one for Dangerous Goods and one for HSNO. Could this be the type of confusion referred to in Phil Taylor’s New Zealand Herald story on the 27th September? about the cause and effects of the April Tamahere fire and explosion that led to a fireman’s death and seven colleagues being injured.
Legislation blammed for death at Tamahere fire:
The NZ Herald story is titled “Cause of death: Legislation” and subtitled “ a convoluted set of regulations lit a fuse that exploded with the Tamahere cool store fire”. The article further argues “ the immediate cause was the explosion and fire…..the root cause is the confusion caused by the very badly put together legislation” .
Lest we forget that 24 years earlier firemen were also killed and injured in the ICI chemical store fire at Mt Wellington also caused by a major fire. The HSNO legislation came out of that fire and its aftermath with the express desire of providing clarity to a convoluted legislative scene with huge holes in.
The Department of Labour has laid several charges regarding the explosion against several unspecified parties alleging breaches of relevant legislation. These court cases will eventually provide the missing details and presumably lessons but meantime it behoves industry to heed the signals we know about both fires and examine ones own state of preparedness.
We know from both chemical disasters that fires start easily and the downstream effects can be catastrophic. The VJ chemical store fire in Hastings in recent times also led to DoL prosecutions after directives to minimize flammable liquid volumes being stored, were not heeded.
Is the Agrichemical industry better prepared now?
Could we hope that our agrichemical industry is better prepared for and aware of the risks as after all we have had longer than most to get our minds around the new HSNO legislation that aims to prevent disasters like these ? I’m told that as industries go, ‘we’ in agriculture are better off than most in HSNO compliance terms as we have 35,000 odd Approved Handlers trained and that our manufacturing and supply companies have had longer to get compliant than other chemical industries. ERMA signed off on our Agrichemical industry Code of Practice NZS 8409 in 2004 way ahead of other industries, many of whom are still waiting for their Codes of Practice to be developed. Many agrichemical suppliers are now on their third annual renewal of their HSNO Location Certificate’s and thus one could assume that all is well in terms of compliance preparedness in the agriculture chemical industry.
I really wished I could report on a glowing report card but visits to suppliers in recent times to check on renewals and train staff provide some stark reminders that new legislation in itself does not provide safe and effective hazard free workplaces. The common denominator in these non-compliant and prevalent hazardous situations is poorly coordinated work practices that seem to be occurring in spite of HSNO Approved Handlers being on site.
Class 5 Oxidisers still stored incorrectly !
How can we explain situations where Class 5 oxidisers are repeatedly stored alongside incompatible substances. Glycerine and bloat oils are incompatible with Class 5 and if they come together a fire could easily result just like the ICI fire 24 years ago. Flammable solvents being used to make an agrichemical formulation are no less flammable just because they have not come with Safety Data Sheets providing details on flashpoint etc. Ignorance of relevant hazards is not a suitable defence in a court of law or more importantly the ignorance leading to a highly flammable substance being used in an area where ignition is possible. Isn’t this one of the factors in the Tamahere coolstore fire? Workpractices that were okay 12months ago have somehow fallen into disarray in the intervening times as new or untrained staff is introduced to the workplace.
Are tracked substances always sold to an Approved Handler?
Class 6 Toxic products have their own compliance requirements. I struggle to understand why trained Approved Handlers do not appear to be helping their untrained work colleagues deal with compliance and ensure that systems are in place to ensure that toxic tracked substances are not supplied to customers who are not Approved Handlers.
Compliance with Class 6-9 substances is not subject to the annual checks that Class 3-5 substances are as a result of the Location Cert renewal. Thus there is more onus on the person in charge to take all practical steps to make sure that Class 6-9 compliance is managed without outside checks from ERMA Test Certifiers.
Which brings us back to the need for comprehensive training and the need for that training to cover a wide range of compliance issues including transport. A point that Richard Bean the Senior Engineer with Land Transport NZ has made in the latest “Novachem Agrichemical Manual”. His recommendation: if you consign agrichemicals as part of your job, complete the National Certificate in Agrichemical Supply course sometimes called the Growsafe Distributors Accreditation course. Many Approved Handler courses do not address all the significant consignor duties required to be compliant with legislation.
Have a great Xmas break, be careful how you start the Xmas BBQ.