Even a minor spillage of chemicals can have safety as well as pollution implications. Alan Field explains why response plans are key and the strategies to deploy the right ones for your circumstances.
In some sectors, major spillage of chemicals can occur and response plans are already in place. This article is aimed more at the scenarios where unplanned spillages may be relatively small and proper response plans might not be in place.
Assessing the risk of a spill and its consequences
One key point that is sometimes overlooked is that there needs to be a risk assessment in place to deal with chemical spills. Like everything involving safety and environmental regulation, a risk assessment is essential. This includes the need for a spills kit as part of a spills response.
First, a risk assessment should determine if and where spills might occur and, secondly, the likely scenarios that could arise from this. This could be from the time of delivery of chemicals to the point when they are being used by, say, a service engineer at a business or home address.
Once the business process is understood, the quantities and types of chemicals needed should become clearer. The first port of call once this is understood is to look at the COSHH data sheets and, where necessary, consult the supplier or manufacturer. Whilst many organisations understand the safety information contained within these, they may not give the same attention to the “Ecological Information” section. This will explain the hazards to the environment the chemical poses. This can consequently lead to the risks of regulatory authorities taking action against you if a spill should create a pollution incident, eg egress into drainage or watercourses.
Other than the size of the spill, another determinant of severity of risk is the safety implications to staff and third parties and the likely disruption a spill will cause in stopping work, due to the complexity of clean-up. Indeed, in the USA, terms such as a simple spill and a complicated spill are sometimes used and this approach can sometimes be helpful in determining a response to such an incident.
Consulting staff about the chemicals being stored and moved could be beneficial – there could have been near misses not recorded or ways of doing the process that haven’t been authorised.
This is why buying spills kits is not a matter of just looking at a trade catalogue.
Considerations for a spill response plan
Let us assume the risk assessment is for a small business where relatively small amounts of chemicals are being kept in a warehouse or workshop stock area.
First, always consider if the risk can be reduced or modified by the chemicals being used. Considerations should include the following.
Can smaller stocks be kept on site (ie better “just in time” ordering)?
Can less polluting chemicals be substituted, eg where solvent-based substances are replaced with less harmful alternatives?
Can storage on site be improved to minimise spillage risks? (This could be safer stacking to reduce the need to move drums or boxes of chemicals or thinking about how to minimise the risks of dropping or damaging them during normal site movements, eg fork lift trucks colliding with chemical containers.)
Is there a risk of more than one container or drum being dropped or damaged at any one time? Where dangerous chemical reactions might occur, then these should be kept separately for both storage and movement.
The issues relating to the storage area. If any sudden or accidental spillage would simply run into a sump or interceptor where they could safely remain until emptying, this may minimise the need for a more elaborate response arrangement. The site drainage plan should give a steer on this. However, be cautious with the issue of mixing chemicals and other waste together.
Bunds (both permanent and temporary) can contain many spills and sometimes a specially bunded storage area can be created where all chemicals are stored (if it is safe to keep the chemicals together). Remember, however, that if there is a spill the chemicals will still need to be cleaned up even if they don’t create a pollution incident
Where chemicals have to be taken off site for working purposes, again, these should be minimised as far as possible. This is particularly true with installation or service engineers who can sometimes end up with carrying various chemicals over a number of days that are not required.
Ensure there is a spills procedure and all staff and contractors who come on-site are aware of it. This will be informed by a risk assessment and the controls (or countermeasures) put in place.
Once all these matters are clear, the number and type of spills kit can be decided upon.
Choosing a spill kit
There are many different types of spills kit. Some are very specialised, eg those for cleaning up bodily fluids, or those for spilt battery acids. These are just two examples. The risk assessment should indicate if a specialised spills kit is an option.
Otherwise, spills kits fall into three main options. Universal spills kits (sometimes called general purpose or all purpose kits) do what it says on the tin. They are designed to absorb most types of non-hazardous or low hazard substances in small quantities It can be applied in most scenarios. Then there are chemical spills kits and oil spills kits, again, sometimes known by slightly different names.
The kits will all have slightly different equipment to respond to the type of spill but, essentially, will be preventing the spills escaping further and absorbing the chemical. Remember there are different materials and approaches that can be used in such kits. Always consider what is best for your organisation and take advice from a number of specialist suppliers before making your decision.
Make sure if different types of response for different spills are required then staff are aware of this. We wouldn’t expect staff to use a water extinguisher on an electrical fire — neither should they think one spills kit might cover all situations, unless a universal kit is adequate.
How to create a spill plan
Risk assess chemical spills and pollution as you would any other safety and environmental risk.
Ensure the work areas (including any remote working) have controls and countermeasures in place, eg reducing the amount of chemicals kept on site; improved bunding and not just relying on spills kits.
Review (or create) a spills procedure.
Ensure that staff and contractors are properly trained to deal with spills, knowing what they should do in any such emergency.
Make sure the right type of spills kit is obtained. In some cases, more than one of type of kit might be necessary. Consider the size and complexity of spills kits. Is a small, portable kit the best first response or is a larger kit that can deal with bigger spills the best option?
Decide where kits will be kept and ensure staff are trained to use them.
Establish an audit process to check the content where a number of kits are kept in readiness, rather like first-aid boxes.
Decide who will dispose of the contaminated materials from the spills response if a kit is used. Specialist waste disposal contractors can be used or consult your usual hazardous waste contractor first when a spills procedure is being put together.