• Sandra Nieuwoudt
    42
    Good afternoon all,

    The rules around secondary containment vs thresholds in the act are pretty clear.

    But what about secondary containment for chemicals stored on benches within a laboratory area.
    These chemical containers are glass and connected to instruments, they cannot be stored within a chemical safety cabinet due to the type of test and is not practical to connect and disconnect each day.

    Some in our Snr Management team feels that our H&S Reps are overdoing the use of secondary containment, they mentioned it is not practical and want a set criteria when to use secondary containment or not.
    My opinion is we potentially have low probability of spillage/breakage but the consequence is high.

    We also have a 20 liter jerry cans with solutions with the potential of leaking due to the tap on the side not at the top. Changing them to be at the top is not practical due to the weight of the container and the frequency of use.

    We have discussed fire/electrical risk, and we also had incidents where the area had to be locked out due to breakage. I do not know if all the electrical cords/equipment underneath benches have RCDs fitted.

    At this stage I do not have the best response to people that brush off potential risk and don't consider that mitigation in place is better than having nothing. I need your input to have a good conversation about secondary containment.

    Many thanks
  • Steve H
    308
    We also have a 20 liter jerry cans with solutions with the potential of leaking due to the tap on the side not at the top. Changing them to be at the top is not practical due to the weight of the container and the frequency of use.
    You can get tipping trolleys to store these in Sandra, the trolley tilts to allow the contents of a 20Lt container to be decanted off and the container to be stored upright otherwise, or you could look at "bunded decanting stands"

    We have discussed fire/electrical risk, and we also had incidents where the area had to be locked out due to breakage. I do not know if all the electrical cords/equipment underneath benches have RCDs fitted.Sandra Nieuwoudt
    RCDs might not be the best solution to protect leads under benches, perhaps look into the fitting of Arc Detection Devices to protect the outlets supplying these.
  • KeithH
    173
    @Sandra Nieuwoudt, I see three aspects here.
    • Secondary containment of hazardous products in containers below the threshold,
    • 20 litre containers with flammable contents, and
    • Preparation for discussing these items with the SLT.

    With regards secondary containment of hazardous products in containers below the threshold, you mention
    these chemical containers are glass and connected to instruments, they cannot be stored within a chemical safety cabinet due to the type of test and is not practical to connect and disconnect each day.

    Some in our Snr Management team feels that our H&S Reps are overdoing the use of secondary containment, they mentioned it is not practical and want a set criteria when to use secondary containment or not.
    My opinion is we potentially have low probability of spillage/breakage but the consequence is high.
    Sandra Nieuwoudt

    As with all hazards, the first step is to identify the hazard. I personally record a second step based on the activity or action that will create harm from the hazard.

    In your situation, the hazard could be a class 3 liquid stored in an old glass container sitting on a metal stand. The action or activity could be the glass container falling off the metal stand and breaking.

    Once you get to this point, doing a risk assessment becomes straight forward. Documented risk assessments cease to be opinions and head down the path of becoming operating procedures.

    To establish a threshold for smaller containers, you may wish to refer to the SDS of the product and section 4 - Hazardous substance information - of "Working safely with hazardous substances" from the Hazardous Substances Toolbox. Keep in mind that with change, resistance will occur so consider involvement at worker level.


    20 litre containers with flammable contents. You said
    We also have a 20 liter jerry cans with solutions with the potential of leaking due to the tap on the side not at the top. Changing them to be at the top is not practical due to the weight of the container and the frequency of use.

    We have discussed fire/electrical risk, and we also had incidents where the area had to be locked out due to breakage.
    Sandra Nieuwoudt
    From the incident investigations there will be, hopefully, a documented record describing recommended or required improvements. I believe this is your starting point. Should the documentation be lacking in detail or unavailable, consider conducting investigations retrospectively. @Steve H's comments may be included with the recommendations.


    Preparation for discussing these items with the SLT is based, IMHO, on the above. Your relationship and communication channels with the SLT are probably well established. Equally, your methods of working with lab people could also be entrenched. As a suggestion, consider if you are doing health and safety by yourself or co-ordinating the knowledge and efforts of everyone so production goals can be achieved.


    My 2 cents worth. :cool:
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