Record management is an essential element when it comes to training your employees. Having accurate & efficient record management assists in making your learning management system audit compliant. Defining record management can be vast but capturing and maintaining a foundation for an organisation is crucial. Teams rely on information and data to help them work effectively and to build the knowledge for themselves and the organisation as a whole. Security and GDPR compliance also come into play regarding record management for your LMS. Organisations must ensure the storage of documentation, certification and attendance of employees is secure and easily accessible to platform administration. 

The SAFEWARE Team have compiled a list of benefits of keeping your record management in toe for 2021. 

December 17th 2020

Written by Collette Dunne, Safety Consultant with CMSE Consultancy. 

It might be time to do a review of goods coming and going from your site. Is anything classified as a dangerous good? 

Do you know, transporting dangerous goods, isn’t just the transport on a truck or in a van, but also includes the role of:

• consignor
• packer
• filler
• loader/unloader and
• consignee.

Furthermore, the people involved in these activities have legal responsibilities.

What are dangerous goods?

As well as national legislation on the carriage of dangerous goods, we also have the ADR.  ADR is an agreement between United Nations countries to harmonise transport conditions for dangerous goods, to prevent accidents and reduce risks.  It’s updated every two years and specifies how to classify dangerous goods and also the requirements for their transport.  Dangerous goods are classified into:

Class 1: Explosive

Class 2.1: Flammable Gas, 2.2. Non Flammable, Non Toxic Gas, 2.3 Toxic Gas.

Class 3: Flammable Liquid

Class 4.1: Flammable Solid, 4.2 Spontaneously Combustible Substance, 4.3 Substance which emits flammable gas in contact with water.

Class 5.1: Oxidising Substance, 5.2 Organic Peroxide.

Class 6.1: Toxic Substance, 6.2 Infectious Substance

Class 7: Radioactive Material

Class 8: Corrosive Substance

Class 9: Miscellaneous Dangerous Substances.

How will I know if our goods are dangerous goods?

There are a number of things you can do initially.

• Read the Safety Data Sheet (SDS) for goods being transported off your site – you should have these readily available. Go to Section 14: Transport Information.  If this section is populated, then you are transporting a dangerous good and you are a Consignor.  It’s important to have the most recent revision of the safety data sheet as information may change and something that wasn’t classified before, may now be classified and vice versa.  Different dangerous goods have different requirements for example, the type of packaging you can use, the maximum weight or volume per package and what other products they can be transported with. 
• If you don’t have an SDS for your products, an expert can assess them to determine if they are dangerous goods based on their properties.
• Review materials being delivered to your site. Look at the labels on the outside.  Do they have a diamond shaped, coloured pictogram and a number?  If yes, they may dangerous goods.  If you accept, unload or move them again off-site, then you are involved in the transport of dangerous goods.  All vehicles involved in the carriage of dangerous goods should have orange plates displayed.

Common misunderstandings

• Our chemical waste is collected by a registered company so the ADR/Regulations don’t apply to us.

Waste is not exempt.  Chemical and other waste can be classified as dangerous goods.  If you are delegating some responsibilities to your waste provider, you should have a Contract of Carriage in place.  You can delegate some responsibilities but not all.

• We get chemicals delivered through a chemical supplier so they probably look after it.

If you are accepting, unloading or loading then you are involved in their transport.  You might even have requirements around the transport of empty containers, depending on what material was last in them.

• We only transport very small quantities so the they don’t apply to us.

Even a single package of dangerous goods might fall under the Regulations but you must check.  There are different requirements for limited or excepted quantities with specific conditions.

Why should you learn more?

The cost of a mistake could be huge.  Consider what could happen if you don’t follow the ADR, package something incorrectly, load it with a material that it’s incompatible with or if there was a road accident and no-one knew there was a dangerous good on-board.  You have a moral, financial and legal responsibility to comply. 

So what do I need to do?

• You may be required to appoint a Dangerous Goods Safety Advisor (DGSA).   There are a few exceptions to the rule. It’s a good idea to get professional advice to confirm whether you are exempt or not.  The function of the DGSA is monitor and advise on compliance and prepare an annual report. 
• Confirm who in the organisation is involved in transport activities. These workers may require function specific training.
• Talk to your carriers to confirm that their drivers are competent. Drivers must complete ADR training relevant to the different classifications and the types of packaging (packages, IBCs, drums, tanks).  It’s up to you to inform your carrier of what is to be transported. 

If you would like a review of your activities or other DGSA support, please contact the CMSE Consultancy Team

Chat to us instantly by clicking the chat box in the bottom right-hand corner of your screen. Alternatively, you can click here to email [email protected]

Leadership in COVID-19 time is more important than ever!

While it was unusual to attend the Health and Safety Review Conference online this year, we certainly agreed strongly with the central theme of the event this year – safety leadership is more important than ever.  The event theme focused on the challenges of working during the current pandemic and how it is essential for leaders within an organisation to maintain a positive safety culture. These are indeed strange times for many organisations. Many employees continue to work under infection prevention regimes, while many others work from home, physically isolated from the normal workplace environment and their colleagues. We should not forget people in certain more affected sectors who are concerned about their future as employers face continuing commercial uncertainty.

During the conference Neil Lenehan, HSQE Manager for Irish Water, delivered a presentation on implementing an effective H&S strategy, and provided an insight into the Irish Water journey in safety and the importance of vision, strategy and leadership during the COVID-19 era. Irish Water’s ‘Work Safe Home Safe’ framework is based on 5 key pillars to building a safety culture within an organisation:

1. Leadership and safety culture
2. Safe workplaces
3. Safe ways of working
4. Safe delivery partners
5. Health and wellbeing

These pillars facilitated the organisation to navigate through their COVID-19 journey and the obstacles of the new homeworking situation. When Neil was asked by a participant how an organisation can ensure people will continue to be motivated when working from home, he outlined how an employee’s mental health as the leading concern. He recommended engagement with workers through increased social contact, and not just to discuss work but to simply ask your employees “how are you?”.  

This simple message certainly resonated with us in relation to our own team, who like many have effectively been working from home since early March. While large organisations can have teams, plans and programmes to address safety, mental health and well being for employees, it is key for leaders at all levels, and in organisations and teams of all sizes, to do the small, simple things that will make a difference. This can be as simple as a regular call from a team lead to have a chat and see how things are going and listen to the employee’s concerns. Across organisations there will be a wide range of home circumstances in which employees find themselves. Homeworking for a prolonged period can lead to a sense of isolation or loneliness in employees. There is mounting evidence that there is a drop in the mental and physical health of employees as a whole from prolonged home working.

A duty of care of exists on employers to ensure their employees’ ‘place of work’ is safe and suitable. A good approach to monitoring an employees’ health and safety at home is through a homeworking assessment. The assessment considers both the working environment and work equipment. It examines posture and behaviours to mitigate musculoskeletal discomfort and strain. Employees appreciate the assessments, and it is a clear statement that an employer wants to ensure employees are comfortable and well setup for working at home.

Leadership is about setting people up for success. Employees need the physical tools for effective and productive home working, but they also need an environment that is supportive, where leaders display empathy and where there are supports available when required. Engaging with employees, ensuring that the remote working situation is not negatively impacting their health and wellbeing is a proactive and positive step in the duty of care for employees – it will reap due reward.

During these uncertain times, communication, engagement, and visual commitment in safety leadership is more important than ever. We are working with employers to provide support for their employees in this COVID-19 era and you would like to talk about safety leadership, homeworking assessments or ergonomic programmes please contact the CMSE Consultancy team.

Chat to us instantly by clicking the chat box in the bottom right-hand corner of your screen. Alternatively, you can click here to email [email protected]

You may also be interested in:

• TOP 3 COVID-19 FAQs Read More
• Chemical Agents Risk Assessments Read More
• The Ergonomic Hazard of Prolonged Postures Read More
• Machinery Safety Update from Aisling Hegarty, Health & Safety Consultant Read More

Gary Horgan (CMSE Consultancy Manager at the Chris Mee Group) and his team are outlining the path for companies to ensure they are compliant with Part 8 “Explosive Atmospheres at Places of Work” of the Health, Safety & Welfare at Work (General Applications) Regulation 2007 in a series of focussed blogs.

This is Blog number 3 in the series.

• Blog 1, Explosion Accidents 2020  
• Blog 2, Preparing for an Explosion Protection Document
• Blog 3, Summary of Legal Requirements
• Blog 4, What Are Explosions? 

In the latest of our series of process safety blogs which are taking you through the process of developing an Explosion Protection Document, we will be looking at the key legal requirements relating to explosion safety in Ireland.

As mentioned briefly in our previous blog, the legal requirements for dealing with explosive atmospheres primarily derives from two European directives:

• ATEX Directive 2014/34/EU, or “ATEX Equipment Directive”, is concerned with products that may be supplied for use in potentially explosive atmospheres. The directive is transposed into Irish legislation by SI No 230 of 2017 European Union (Equipment and Protective Systems for use in Potentially Explosive Atmospheres) Regulations 2017.
• ATEX Directive 1999/92/EC, or “ATEX Workplace Directive” deals with the precautions to be taken in workplaces where explosive atmospheres might be present due to flammable dusts vapours or gases (or mixtures of these). This directive is transposed into Irish legislation by Part 8 of the Safety, Health & Welfare at Work (General Application) Regulations 2007.

The term “ATEX” is derived from the French “ATmosphères EXplosives”. Another acronym often encountered in explosion safety is DSEAR; this is an acronym used for the “Dangerous Substances and Explosive Atmospheres Regulations” which is the UK legislation which transposes the European ATEX Workplace Directive.

In this blog we will focus on the essential requirements arising from Part 8 of the Safety, Health & Welfare at Work (General Application) Regulations 2007.

Where and when do these Regulations apply?

In general, the Regulations apply at most workplaces where flammable substances are stored or used, for example, factories where flammable liquids are present or where flammable dusts are produced in the process. Examples include pharmaceutical manufacturing, chemical processing, LPG storage and filling, milk drying, and flour production.

Some specific types of workplace and equipment are excluded (such as appliances which burn gaseous fuels, and transport of dangerous goods) as these areas are covered by separate Directives and Regulations.

Key Requirements of the Regulations

What then are the key requirements of Part 8 of the Safety, Health & Welfare at Work (General Application) Regulations 2007? Overall, the Regulations set out the general requirements to manage fire and explosion risks, and impose some specific requirements, which are described below. Employers and the self-employed must:

• Carry out a risk assessment of any work activities involving flammable substances.
• Record the findings of the risk assessment in a document called the Explosion Protection Document.
• Provide technical or organisational measures so as to reduce the risk of explosions (as set out in Schedule 2 of the Regulations)
• Classify places (according to Schedule 1 of the Regulations) where explosive atmosphere may occur into zones and mark the zones where necessary.
• Select and provide suitable equipment for use in the zones.
• Equipment must be CE marked and in compliance with SI No 230 of 2017 European Union (Equipment and Protective Systems for use in Potentially Explosive Atmospheres) Regulations 2017.
• Provide training to workers who work in places where explosive atmospheres may occur.

In later blogs, we will examine each of these requirements in greater detail.

While the regulations set out the minimum legal requirements, CMSE Consultants continue to assist our clients to meet or exceed these requirements in a practical and pragmatic way. We draw on our experience working in a wide range of sectors and businesses, including Pharmaceuticals, Energy, Medical Devices and Food & Drink Manufacturing.

If you require further information or assistance please contact us via email at [email protected], by phone at 021 497 8100 or start an instant chat with us via the chat box in the bottom right-hand corner of your screen.

Gary Horgan (CMSE Consultancy Manager at the Chris Mee Group) and his team are outlining the path for companies to ensure they are compliant with Part 8 “Explosive Atmospheres at Places of Work” of the Health, Safety & Welfare at Work (General Applications) Regulation 2007 in a series of focussed blogs.

This is Blog number 2 in the series.

• Blog 1, Explosion Accidents 2020  
• Blog 2, Preparing for an Explosion Protection Document
• Blog 3, Summary of Legal Requirements  
• Blog 4, What Are Explosions? 

In our second process safety blog in this series, I want to talk about the type of information you need prior to preparing for the generation of an Explosion Protection Document (EPD), as required in Ireland under Part 8 “Explosive Atmospheres at Places of Work” of the Safety, Health & Welfare at Work (General Application) Regulations 2007. It is also fair to say that some clients are not aware of this regulation and the requirement for an EPD, and request us to complete an ATEX Report.

The word ATEX comes from the ATEX 137 Directive 99/92/EC, or ATEX Workplace Directive, which deals with the precautions to be taken in workplaces where explosive atmospheres might be present due to flammable dusts vapours or gases (or mixtures of these). This directive is transposed into Irish legislation as stated above or below in the UK.

In the UK, our clients request the equivalent DSEAR Report, coming for the Dangerous Substances Explosive Atmosphere Regulations 2002. The prepared Explosion Protection Document, ATEX Report or DSEAR Report often very similar in construction i.e. at a simple level it outlines how you manage your explosion hazards (gases, vapours or powders) at your facility.

It is important to note also that the requirement of an EPD is addition to any other Process Safety Reports and Legislation that may be applicable to your facility; Seveso III or COMAH i.e. dealing with potential Major Accident Hazards.

As a starting point, when CMSE Consultancy are appointed to prepare an Explosion Protection Document for a client, and prior to a site visit, we prepare a list of information we require to start the project. This information (non-exhaustive list) includes the following (Please note we will also cover these in greater detail in later blogs):

• Overview of the company & activities (it is important to note that we are not just talking about manufacturing facilities, it could be warehousing, R & D, utilities, processing, fuel storage, petrol stations, energy generation, waste generation, process waste water treatment)
• Are there any previous EPD, ATEX explosion safety reports available?
• List of the potential flammable substances; gases, vapours & powders
• Copy of relevant Safety Data Sheets (SDS) or Dust explosion testing reports
• History of any explosion related incidents?
• Process description in each potential area where flammable use is foreseen
• Activities involving flammables (raw material, intermediate products, finished products) to consider including the receipt, storing, transporting, handling, processing from raw material in to finished product or hazardous waste.
• Have you considered how you may end up with the formation of an explosive atmosphere i.e. normal operation, abnormal operation, maintenance, and emergencies?
• Have you classified work areas into the likelihood of a potential explosion atmosphere existing?
• Have you completed specific ignition risk assessments in potential flammable areas?
• If a company already has a level of explosion safety compliance, what do you have in place in each potential classified area?
  • Basis of explosion safety controls – engineering
  • Basis of explosion safety controls – organisational
• Do you have a schedule of Ex-rated equipment in your flammable areas?
• What emergency procedures/ resources are in place to deal with potential flammable atmospheres?
• What Preventative Maintenance Programs are in place?
• What relevant standard operating procedures are in place?
• What Permit to Work systems are in place?
• What control of contractors procedures are in place?
• What Explosion Safety Training was completed?
• What type of Personal Protective Equipment is used?
• Are potential flammable areas clearly indicated?

CMSE Consultancy  provide a professional Health, Process, Explosion & Fire Safety Services.

If you require further information or assistance please contact us via email at [email protected], by phone at 021 497 8100 or start an instant chat with us via the chat box in the bottom right-hand corner of your screen.

Some useful references that may assist in gathering information on the explosion properties of dust/ powders include;

• GESTIS Substance Database; dguv.de/ifa/stoffdatenbank
• BIA Report 13/97; dguv.de/ifa/publikationen/reports-download/bia-reports-1997-bis-1998/bia-report-13-97