CMSE - Blog | Safety Training & Consultancy

Written by CMSE Safety Consultant Jake Bumpus

According to the Institution of Chemical Engineers (IChemE), a Hazard and Operability (HAZOP) Study is “a detailed method for systematic examination of a well-defined process or operation, either planned or existing.” Commonly accredited to Trevor Kletz while working as a Safety Manager at ICI, it is now a widely used Process Hazard Analysis (PHA) methodology across the process and chemical industries.

In order to undertake a HAZOP, a process or system is broken down into suitable sections, generally referred to as Nodes. An agreed list of Parameters (e.g. Flow, Temperature, Pressure etc.) and Guidewords (e.g No/None, Less, More etc.) are combined and systematically applied to each node, to identify potential Deviations (such as No Flow, More Pressure). For each credible Deviation, the potential causes, consequences, and risk are assessed, and the current controls which are in place are evaluated. If further controls are required, then actions are raised to reduce the risk to an acceptable level.

HAZOP Studies are always carried out by a team of people. A HAZOP Team generally has a chairperson/study leader to guide the discussions, a secretary/scribe to formally record the discussions, as well as number of team members such as engineers, managers, operators, safety representatives and other specialists. As they are a team-based activity, they allow different stakeholders to interact and discuss the process, and the HAZOP Study is often the first place where they have the opportunity to do this in detail, face-to-face. Although very structured, it can also be a creative process, allowing hazards to be identified which would have otherwise not been thought about.

There a number of common pitfalls associated with HAZOP Studies, which require the advice of experienced and competent HAZOP chairs and team members to avoid:

• Ensuring that the documents which underpin the study are of good quality and have the necessary level of information. If too much information is missing or incorrect, then the HAZOP cannot be effective.
• Carrying out the HAZOP at the right stage of the design/modification project – too early and not enough information is available for a good quality HAZOP, too late and there will not be enough time to easily implement recommendations for improvement.
• Selection of the HAZOP team – the competence of the team members is important for a good quality HAZOP, as well as the size of the study team. If too small, hazards might be missed due to a lack of expertise; if too large, the HAZOP may become excessively long and costly.

CMSE Consultancy process safety consultants carry out the full HAZOP Process for our clients. CMSE Consultancy;

• deliver Process experts to attend the Hazop meetings
• provide a chair for the Hazop meetings
• provide a scribe for the Hazop
• provide a detailed systematic process and associated procedures and documentation/checklists, etc
• provide a high degree of practicality and quality to the hazard identification, risk assessment and control process.
• apply the ALARP principle in identifying the appropriate control measures and design changes
• look closely at the full life cycle covering construction phase, validation phase, commissioning phase, operational phase, maintenance activities, foreseeable demolition situations, etc

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Written by CMSE Safety Consultant Jake Bumpus

According to Regulation 173 of the General Application Regulations 2007, there is a legal duty on employers to “ensure that, where required by the explosion protection document… a system of permits to work is applied for carrying out both hazardous activities and activities which may interact with other work to cause hazards”. Carrying out a welding operation in an ATEX-rated area, which creates the potential to ignite a potentially explosive atmosphere, is a typical example of a hazardous activity which would require the use of a Hot Work Permit.

The types of controls which should be considered as part of the Hot Work Permit are:

• Removing or reducing the source of the explosive atmosphere as far as possible, for example by shutting down operations and/or draining storage vessels of any flammable substances.
• When the area is connected to other areas which are still “live”, then the area must be properly isolated. Any isolations should follow a formal lock-out-tag-out process (LOTO) that prevents the re-energisation of the system.
• Similarly, when vessels/tanks have been drained of flammables and washed out, this must be verified before hot work is carried out, e.g. by visual inspection and/or flammable gas detection.
• Additional means of controlling flammable vapours may be installed, such as temporary additional ventilations.
• The area should be cleared of any combustibles which may be ignited by the sparks generated by the welding activity.
• Temporary fire screens could be installed to prevent sparks travelling to a wider area and causing ignition. Research has indicated that welding/grinding sparks can travel as much as 11 m horizontally form the source of the work activity if not contained.
• Workers should wear personal flammable gas (LEL) detectors/alarms at all times while carrying out the work, and should wear suitable PPE.
• Workers should bring portable firefighting equipment (e.g. fire extinguishers, fire blankets) and should be trained in their use.
• A fire watch could be implemented, where workers observe for any early signs of fire (smouldering/smoking etc.) for a suitable period of time after the work has been completed.

At the end of the working period, the Hot Work Permit should be signed off by those carrying out the work that it is complete, or that work is not yet complete and needs to be continued, and returned to the permit issuer. This helps to ensure that area will only be returned to service only once it is safe to do so.

CMSE Consultancy offers top quality ATEX consultancy and support service to our clients nationwide. We have extensive ATEX experience and a proven track record in providing these services across many industrial sectors. Our ATEX consultants have both process and electrical safety expertise which makes our solutions both legally compliant and beneficial from the perspective of potential cost reductions and savings.

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Written by CMSE Safety Consultant Jake Bumpus

Under the Safety, Health and Welfare at Work (General Application) Regulations 2007, there is a duty on employers to ensure the safety of all machinery provided for use at the workplace. However, what actions should be taken by management if a safety guard is reported as being either defective or bypassed?

In the immediate term, it is clear that the machine is not safe to use in its current state, and therefore use of the machine should be prohibited until the safety guard can be repaired and/or replaced. During this time, the machine should be isolated from all sources of energy, any hazardous stored energy released, and then locked out and tagged out.

The next consideration should be whether it is appropriate to repair the existing safety guard or investigate whether the design/concept of the existing guard contributed to it becoming defective and/or being bypassed by workers. For example:

• If the existing guard was a fixed guard, but workers were required to frequently access that part of the machine to clear dust, then a fixed guard may not be appropriate. Instead, an interlocked access panel which stops the motion of the equipment on opening may be a better option.
• If the existing guard was an interlocked guard, but was of such a design that it was easily defeatable (e.g. non-coded magnetic interlock which could be defeated using a common magnet), then it should be replaced by a different design which is less easy to defeat (e.g. coded safety switch).
• Additionally, we should consider whether the overall design of the equipment is fit-for-purpose. For example, if workers are frequently having to clear dust from the moving equipment, then perhaps additional local extract ventilation that reduces the amount of dust generated at source would be appropriate.

The considerations above are primarily about the suitability and adequate of engineered/technical controls, but the same degree of consideration should be given to the organisational controls and safety culture in the organisation. The fact that an important safety guard was being regularly bypassed by workers is a very poor indicator of the overall safety culture.

A first step to improving this may be to roll out a training programme to workers which highlights the important aspects of machinery safety, including why bypassing safety guards is so dangerous. However, the organisation should also investigate the human factors around why the workers bypassed the guard in the first place, and why this practice was not observed and/or stopped by supervisors/managers.

CMSE Consultancy is a leading provider of Machinery Safety Support to clients nationally. Our specialists provide practical advice, training and machinery solutions to support your particular needs. Our team work to legislative requirements and benchmark against industry best practice. 

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Written by CMSE Safety Consultant Jake Bumpus

The Safety, Health and Welfare at Work (Biological Agents) Regulations defines a “biological agent” as “micro-organisms, including those which have been genetically modified, cell cultures and human endoparasites, which may be able to provoke any infection, allergy or toxicity…”.

Biological agents are classified into 4 risk groups according to their level of risk of infection. A group 3 biological agent is one which can “can cause severe human disease and presents a serious hazard to employees and that may present a risk of spreading to the community, though there is usually effective prophylaxis or treatment available”.

In the event of a spillage or leak of a group 3 biological agent, there is a clearly a potential risk of harm to staff, but also to others present in the facility, and the wider community.

In a facility which has already implemented good biohazard management practices, then in the event of a spillage of a group 3 biological agent there will already be control measures in place to minimise the consequences of such an event. These measures correspond with Containment Level 3 (CL3) in the Code of Practice. For example:

• Access to and from the area where the biological material is being handled will be controlled, and will be via doors which are self-closing and lockable.
• Access to this area will only be for authorised personnel who are suitably competent to work with pathogens (including spill response training).
• These personnel will wear suitable PPE which they will don in a dedicated gowning up area before entering the area, and they will have received any necessary vaccinations.
• The area will be maintained at a negative air pressure compared to surrounding areas, to prevent aerosol migration into other areas.
• Air which is extracted from the area will be filtered by HEPA filtration before release to the environment.
• Surfaces in the area will be impervious to water and easy to clean with disinfectants.

In regard to the procedure for dealing with a spillage of a biological agent, the following actions should occur:

• The area with the spillage should be blocked off, and personnel should call for assistance from the Emergency Services.
• Personnel dealing with the spillage should wear the appropriate PPE while doing so.
• Absorbent materials should be placed on and around the spill.
• An appropriate disinfectant (depending on the material, could be a bleach solution) around the spill working inwards.
• The disinfectant should be left for an appropriate contact time (at least 10 minutes)
• The spill materials should be carefully retrieved and placed in the appropriate waste containers.
• The area should be wiped with disinfectant and finish with a water rinse if necessary.

Following the incident, the relevant risk assessment should also be reviewed and updated if required. 

CMSE Consultancy is a leading provider of professional services for biosafety in the workplace, including biosafety consultancy and biosafety awareness training.

Under the Safety, Health and Welfare at Work (Biological Agents) Regulations it is the duty of every employer to assess the risks arising from the use or presence of biological agents in the workplace and in determining adequate precautions or control measures to safeguard health and safety.

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Written by CMSE Safety Consultant Jake Bumpus

It is not unusual for some workplaces (such as R&D labs) to handle substances which have relatively little health and safety data available; by their nature, these facilities are often handling substances which are novel and so in-depth testing and characterisation has not yet been completed.

However, there are well-established methodologies available to occupational health and safety professionals and occupational hygienists in the pharmaceutical industry to make suitably conservative assumptions about the chemical hazards posed by a relatively novel substance, and hence what type of engineered controls are required to safely handle them.

Variously called “Occupational Exposure Banding” (as described by NIOSH in the US), or “Control Banding” (the term used by the UK HSE), a banding approach can be used with relatively little detailed toxicological information to determine the required controls. Figure 1 below is a useful summary table which relates the methods of containment required to safely handle a substance, the associated Occupational Exposure Band, the Occupational Exposure Limit, Active Pharmaceutical Ingredient (API) potency, and overall hazard posed by the substance.

As an example, if a research and development facility was being used to handle a new API candidate substance, with a potency of 5 mg/day, then this would be classified as requiring an OEB of 3. To handle this substance safely, the types of engineering containment controls would include the use of split valves, downflow booths and continuous liners.

Despite a lack of detailed health and safety information being available, this type of methodology can be used to ensure that worker exposure to hazardous chemical agents is minimised and that the risk is kept as low as reasonably practicable.