Research published by the Health and Safety Executive (HSE) has identified some weaknesses in the control measures at a number of ports and distribution centres in relation to workers coming into contact with hazardous substances when examining or unloading freight containers.
The findings have been published in a new report, RR1178 – Freight containers: potential worker exposure to hazardous atmospheres at ports and distribution centres.
As the HSE notes, freight containers are confined spaces and hazardous atmospheres can build up inside over time as there is limited or no ventilation during its transportation. The severity of risk this poses is influenced by a number of factors, such as the container’s contents, the condition of the contents and the length of time the container is in transit.
Port and distribution centre operators have a duty to put effective control measures in place to protect workers who routinely open and enter freight containers. Some hazardous atmospheres such as fumigants and carbon monoxide or dangerously low oxygen levels pose a significant risk to human health, so the purpose of HSE’s research was to find out the potential for worker exposure by monitoring a number of volunteer sites.
Researchers identified a number of good practice control measures, notably that workers assumed there was a toxic atmosphere inside and waited to enter after opening the doors to let the container air
As part of its research, the HSE undertook some observations and measurements at six ports and two distribution centres between 2017 and 2019. Although it identified predominantly good practice control measures at the ports, the volunteer sites did raise some concerns. Significantly, the HSE researchers highlighted inadequate safe systems of work at the two distribution centres that took part.
According to the report, a wide range of airborne substances were detected during the site visits in containers holding different cargo and these included a range of fumigants, gases and volatile organic compounds (VOCs). Although the HSE acknowledged that it was impracticable for duty holders to monitor for every potential substance, its report notes that unless effective control measures are put in place, workers that examine or unload the containers could be being put at risk.
The findings highlight the importance of applying a safe system of work 'based on specific circumstances on site and any relevant knowledge of the contents of the container'.
From their observations, mainly at the ports, the HSE researchers identified a number of good practice control measures, notably that workers assumed there was a toxic atmosphere inside and waited to enter after opening the doors to let the container air. Workers also employed a progressive system of entry, which identified any cargo that was capable of depleting oxygen and assessing whether they needed to measure oxygen levels and specific hazardous substances.
Although the researchers noted that risk awareness was generally good at the ports visited, they did note down occasions when errors were made in relation to measuring oxygen levels.
In addition, they reported some gaps in training and in some documentation that required updating, revision or clarification. However, overall, the researchers found that risk management and the safe system of work plans at the ports were adequate.
Although gas testing for various substances was routinely undertaken at all of the participating ports, the researchers found that no standard set of substances were tested and port teams used a variety of equipment to undertake the tests. Significantly, none of the direct reduced iron (DRI) systems employed were checked before use to see if they were functioning correctly, which did raise some issues regarding the reliability of test results.
Not all of the ports meanwhile tested for oxygen levels. In cases where the individual port teams did not undertake testing, each site enforced a procedure whereby the doors were left open for a period of time to air the container before staff entered.
The report notes that when the HSE carried out tests during the site visits, they found that the oxygen levels at the front of the containers returned to normal ambient concentrations within a few seconds of the doors opening.
As RR1178 notes, 'The movement of air on opening the doors was shown in clearance tests which were undertaken using empty containers at HSE’s Science and Research Centre. The risk of oxygen deficiency is reduced once the doors are opened, as air will be able to enter the container during this time.'
The researchers found that no gas testing was undertaken, even at one of the centres, which was aware that all products that contained timber had been fumigated
The HSE researchers did highlight some areas where they felt improvements could be made at the ports that volunteered. In particular, they cited the use of PPE, noting that some of the equipment 'may not provide adequate protection from substances encountered'. They also noted that face-fit testing was not undertaken by any of the participating ports and not all of the workers were 'clean shaven', raising questions about the level of protection that the respiratory protective equipment provided.
In contrast, the research highlighted that neither of the two distribution centres had procedures nor control measures in place that would protect its workers from exposure to hazardous substances.
As the report notes: 'The risks in this setting are identical to those in ports, as are the legal duties to conduct a suitable and sufficient risk assessment.'
In particular, the researchers found that no gas testing was undertaken, even at one of the centres, which was aware that all products that contained timber had been fumigated. The HSE noted both distribution centres demonstrated a 'general lack of risk awareness around confined space issues' and neither had put a safe system of work in place.
Although the OSH regulator acknowledges that the small sample size means the report findings cannot be representative of the sector, it is using the report’s publication to remind ports and distribution centres about the risks that hazardous atmospheres pose to workers and to highlight its guidance and approved code of practice so that duty holders can put effective control measures in place.
The HSE notes that around 63.2 million tonnes of goods were handled by UK ports in 2015 in freight containers.
Nicola Jaynes, from HSE’s Transport and Public Services Unit, said: 'This important research looked at the associated systems of work at ports and distribution centres across Great Britain.
'Some hazardous atmospheres have the potential to harm workers if breathed in. For example, they may contain toxic substances such as fumigants and carbon monoxide or have dangerously low oxygen levels. Potential harm includes asphyxiation and ill health.
'The research confirmed there is the potential for exposure to hazardous substances and/or oxygen depleted atmospheres when opening freight containers if effective control measures are not in place. This underlines the need for a suitable and sufficient risk assessment when conducting this type of work.
'It identified a range of good practice control measures at the six ports. Examples of this included training workers about the risks, and workers testing for hazardous substances in the atmosphere inside freight containers before entering them.
'However, the researchers did not find adequate safe systems of work at the two distribution centres. While this was only a small sample size, these findings cannot be considered as representative of the distribution sector. [The] HSE will use the findings to inform and engage with the industry and local authority regulators.'
