evatech
Safety Management Services
Nelson, New Zealand
AgriBusiness. March/April 2006. HSNO Series. Bruce Evans
HSNO – breeds a whole new Culture… ‘Change Management’
Share some examples of change through the eyes of a Test Certifier.
What I thought was my last article on HSNO. Change is taking place and nervous insurance companies are prompting some of the process.
This is the last article in my ‘getting ready for HSNO’ series as by the time you read this the agrichemical industry will be in the final few months allowed for transferred substances under HSNO. The following issue of ‘Agribusinness’ will almost certainly be published beyond the cut-off date for HSNO action.
I write this article as ERMA express some concern that there appears to be very few HSNO Location Certificates issued when compared to the potential gauged from Dangerous Goods Licenses issued under the old regime.
There appears to be ten times less HSNO Certificates issued than there should be.
The low compliance uptake in the agrichemical industry could be even more concerning when you consider that very few Agrichemical retailers had or needed Dangerous Goods Licenses in the past. If you didn’t have a Dangerous Goods license then it’s highly likely your business doesn’t even appear on ERMA or enforcement agency radar at this point.
Equally concerning to ERMA:
Is their calculations indicate that there is less than half of the anticipated minimum number of Approved Handler’s actually holding full HSNO Certificates.
Have you engaged a Test Certifier to work through a HSNO compliance timetable for your particular operation and trained the appropriate number of Approved Handler’s? Time for action has all but run out.
A surprising number of managers ask me what If I don’t comply with ‘all this HSNO stuff’? The answer will take a whole new series of HSNO “what ifs”, but I’m sure most of you know the answers are going to be unpalatable. Ask yourself what would happen if you let your vehicles Warrant of Fitness’ expire or would you be able to secure insurance cover for your premises without a Building Warrant of Fitness.
Nervous Insurance Companies:
Talking of Insurance one of the many affects of HSNO induced ‘change management’ is the increasing number of requests I am getting from insurance companies nervous about the cover they have on chemical storage operations. Would I as a Test Certifier please see certain organizations to check out HSNO preparedness and test their likely compliance? A common insurance cover concern is the propensity for people to store wooden pallets and dunage right slap against buildings thereby creating a fire hazard and in the proccess the stack often obscures drains and impairs vehicle access. Insurance companies are not the only ones who take a dim view of piles of wood lying against buildings.
For me this sort of HSNO induced change is one of the desirable effects of the new legislation thus far. Enlightened Managers are starting to work out that HSNO’s frustrating lack of prescription does allow them to find workable solutions inconjunction with Test Certifiers. Examples from my client’s inventiveness abound but a few that spring to mind involve the avoidance of the significant compliance costs involved when the amount of flammable substance being stored is in excess of the HSNO thresholds.
Avoiding Costs:
One customer decided to get someone else better equipped to store flammable liquids to take over the job, thus freeing up their own space and making segregation easier let alone avoiding the significant costs of building a new flammable hazard zone.
Another customer using a 3.1C flammable substance to make another agrichemical was able to source a 3.1D ingredient thus avoiding the costs of building a flameproof system. Yet another subcontracted out the flammable part of the production and finished off the job themselves once the hazardous sector of production had been carried out off their own site.
Similarly with class 5 fertilizers there are some formulations that are not 5.1.1B or 5.1.1C and thus they can be stored in less rigorous or costly stores.
The whole issue of avoiding formulations that attract expensive HSNO compliance controls is beginning to be picked up by sharp-eyed managers with an eye to effective change management.
Secondary Containment as a HSNO control is having all sorts of positive spin-off effects.
Review your processes:
The costs of having to build bunds or to create barriers preventing spillage getting to drain intakes is leading to a thorough review of just how much liquid needs to be stored and where. Major clean-ups and sort outs of redundant stock are leading to a realization that less stock, turned over more frequently is more profitable than building extra high bunds to store everything held prior to a clean-up. Compliance costs then are leading to sharper stock management practices. ERMA has come to the ‘change management’ party as well with changes advised recently through the Gazetted Emergency Management Reg’s 37/38 that are also making secondary containment a less formidable task.
You need to talk to an experienced industry Test Certifier to utilize this and other new ERMA controls to best effect.
HSNO is now upon you for better or for worse and just like your vehicle WOF ignore reminders about expiry dates at your peril.
Know your peak stock levels:
The best tips I can pass on as a result of dealing almost exclusively with agrichemical manufacturers and retailers on HSNO for five years. Know and understand what 3.1B, 3.1C, 5.1.1B and 5.1.1C controls are and know exactly what your peak stock levels actually are and not what’s in front of you on a casual walk around. Then talk to a Test Certifier experienced in your industry about how best to achieve the non prescriptive controls allowed for under HSNO. I conclude this HSNO series with an observation made previously.
NZ needed a new chemical control system but did we need to be the first country in the world to test the full GHS system as HSNO, and create myriads of complications that continue to flow from not getting it right in the first place.