IOSH magazine recently ran a webinar on the segregation and storage of chemicals. Dangerous goods expert Henry Mooney answers your key questions.
What is your advice for an organisation that does not have the physical space required to implement best practices with regards to storage and segregation?
If your organisation does not have physical space to implement best practices, I would advise:
- Keep stock levels to a minimum.
- Reduce the size of containers used to store the chemical products.
- Outsource the storage of the chemicals to a local contractor warehouse/storage facility that can meet the requirements. Only bring the necessary chemicals onsite as required.
- Use bunding where you cannot achieve segregation distances, for example if you have a small quantity of an acid and alkali you could review the option of storing them in the same cabinet if they are kept in separate bunds.
How do you store chemicals that have more than one hazard?
For chemicals with more than one hazard such as Acetic Acid (classified as both flammable and corrosive) you need to consider the control and mitigation measures required for both hazards.
Normally the storage area will be determined by the more hazardous property of the chemical and having assessed the consequences in the event of an accident in the storage area. If a chemical is both flammable and corrosive it would be appropriate for the chemical to be stored with other flammables.
It is important to review sections 7 and 10 of the Safety Data Sheet to ensure that the other chemicals are compatible with each other.
What about storing alcohol hand sanitiser in the workplace?
Hand sanitisers are classified as flammable liquids and therefore must be stored in accordance with HSG 51. Section 223 of HSG provides guidance for the storage of retail flammable liquids in primary containers in less than 500ml where you can store the containers in general storage with appropriate precautions.
I have about 100ml of Sodium Hydroxide (Alkali) and 100ml Hydrochloric acid in the laboratory I work in. Can I store them in the same corrosive chemical cabinet?
I would advise that acids and alkalis are stored in separate cabinets. However, if you have small quantities of acids and alkalis and you have limited space you could review the option of storing them in the same cabinet with the use of bunding.
Can I use steel trays for bunding my chemicals?
The bunding that you use for the storage of chemicals must be compatible with the chemicals to be stored in the bund. Steel bunding would not be suitable for corrosive chemicals because in the event of a spill the corrosive chemical would corrode the bund.
In our catering department we have a chemical storage room with wooden shelving. Are wooden shelves safe?
I do not recommend that chemical products are stored on wooden shelves because in the event of a spill the chemical may absorb into the wood and thus contaminate the wood. Also, in the event of a fire, the wood will contribute as a fuel to the fire.
Will the Safety Data Sheet inform you which DSEARS Hazard classification zone the flammable liquid should be stored in?
No, the Safety Data Sheet will not inform you of the DSEARS Hazard classification zone associated with the storage of flammable liquids. The DSEAR Hazard classification should be completed by a competent person to determine the likelihood of an explosion based on key factors including quantity stored onsite, flashpoint of the chemical products and the current controls and mitigation measure in place.
Our safety data sheets are not kept up to date by the manufacturer and therefore the information regarding the storage of chemicals is not current. What should we do?
The manufacturer has a statutory duty to provide you with a safety data sheet which is compliant with the REACH and GHS regulations. Sections 7 and 10 of the safety data sheet should be populated with information on the segregation and storage. If your supplier/ manufacturer is not providing you with a compliant safety data sheet it may be necessary to consider an alternative supplier.
Are you aware of any plans to review HSG 71 as it is 12 years old?
No, I am not aware of plans by the HSE to update HSG 71. I too would welcome an updated version.
If I have 3 x 200 litre drums on a bund. Should the bund capacity be 220 litres or 660 litres?
The bund capacity should be 110% of the largest container on the bund. In this scenario the large container is 200 litres and therefore the capacity of the bund should be 220 litres.
We use plastic bund trays in our laboratory for chemicals kept on the bench and in cabinets where the chemicals do not have built-in trays. Is it ok to place the chemical containers into the bund tray?
Placing chemical containers in the bund reduces the bund capacity. You need to ensure that the net spill capacity of the bund tray is greater than 110% of the largest container. I often find that the spill capacity is reduced below 110% when the container is place in the bund.
Have you any comments on spill kits in storage areas?
A few key points on spill kits in storage areas:
- Do not keep spill kits in the chemical store / cabinet. In the event of a spill you will not be able to access the spill kit.
- Decide on what size of spill you are going to deal with in each department as part of your risk assessment and above what quantities will be call the emergency services or emergency Response Team.
- Remember that you need to have the Personal Protective Equipment available for dealing with a spill in addition to the spill kit contents. Have the PPE readily available for dealing with a chemical spill.
- Regular checks should be completed on the spill kit contents. Rather than having to check the spill kit contents each time, place a breakable tie on the closure of the spill kit. The check then will only require that you check that that the tie is intact.
What is an IBC?
An IBC is an Intermediate Bulk Container which is used for the safe transport and storage of liquids. The advantage of using IBCs is that they are large and can typically hold quantities up to 1000 litres. They also are cubic in shape and therefore can transport and store more material in the same area than a container that is cylindrical in shape such as a 200 Litre drum.
Can you stack IBCs on top of each other in a warehouse?
On the side of the IBC there is a marking to indicate if you can stack the IBC and also the maximum loading weight. Some IBCs cannot be stacked.
With regards to the risk assessment, if you are a distributor, should you complete a risk assessment for those stored products?
Yes, you should complete a documented risk assessment on the storage of the hazardous chemical products kept at your facility. You may be able to complete one risk assessment taking into account storage of the dangerous substances onsite. You may also decide to complete a risk assessment on the dangerous substances by hazard class, especially if you have dedicated storage areas, for example, storage of flammable substances. Generally, it should not be necessary to complete an individual risk assessment for each chemical product unless the products is a significant hazard such as extremely toxic by inhalation.
Due to Covid and Brexit, we have had to order more stock due to the delivery dates. What are your thoughts on this?
Increasing the stock levels generally will increase the risk of an incident. If you increase your stock levels, I recommend that you review your risk assessment to consider the additional quantities stored onsite. You may need to implement additional control and mitigation measures such as increased bund capacity, provide larger spill kits, review the option of storing externally. I have found that some of our clients have outsourced the storage of additional stock levels of their dangerous substances.
Can 200 litre drums containing hazardous chemicals be stored on wooden pallets?
Yes, chemical products can be transported and stored on wooden pallets. Hazardous chemicals in 200 litre drums are required to be transported in UN approved drums and therefore the likelihood of a spill is low.
Best practice that I have seen is to move the hazardous chemicals from wooden pallets to chemically compatible plastic pallets when they arrive onsite.
How do you deal with the storage of hazardous packaged waste? What additional factors do you need to take into account?
Hazardous packaged waste is primarily disposed of by a licensed chemical waste disposal company. One of the primary factors that you need to take into account for the chemical waste is the primary packaging that will be used for the storage and transport of the chemical waste. Organisations should consult with the waste disposal company prior to deciding on the packaging to be used for chemical waste.
A safety data sheet may state that a chemical must be disposed of in accordance with current national and local regulations. How does this help organisations, especially those that use hundreds of different substances?
I agree that safety data sheets will have quite generic information in section 13 when it comes to Safety Data Sheets. The disposal route should be considered as part of completing the chemical risk assessment (COSHH & DSEAR). Simple steps to address this issue are:
- List all the waste streams.
- Ensure that you have current safety data sheets for the chemical products in the waste streams.
- Engage the services of a specialist Waste disposal contractor to complete an audit of all the chemical waste streams.
- Implement a chemical waste disposal strategy.
Do empty gas cylinders need to be in a cage?
Yes, empty cylinders are classified as dangerous goods because they will contain residual gas and therefore, I would recommend that they are stored in a caged facility. Empty and full cylinders should be stored separately.
What's the difference between SDS and MSDS?
SDS stands for Safety Data Sheet and is the correct term to use. MSDS is the term that was previously used in the United States and stands for Material Safety Data Sheet. In the US the term Safety Data Sheet (SDS) is also now used.
We store significant amounts of highly flammable liquids in an external flammable liquid storeroom remote from the main building, but they need to be protected from frost. How can we provide ventilation without introducing more ignition sources such as heaters?
I recommend that you engage the services of a competent person to complete your hazard plan as required under DSEARS regulations. They will advise on the ATEX rated equipment required for any equipment introduced in the area for heating and ventilation.
Are you required to include the flashpoint of flammable liquids on your internal COSHH risk assessment if the data sheet is also available?
There is no specific requirement to include the flashpoint on your COSHH risk assessment as the COSHH risk assessment relates to the health hazards of your chemical products. The flammable hazards are addressed in the DSEARS regulations. I recommend that you include the flashpoint for your DSEARs Risk assessment or if you have a combined DSEAR and COSHH Risk assessment template.
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