Code of Practice for storage of gas cylinders revised
The British Compressed Gases Association has published a revised Code of Practice which defines the principles of safe practice for the storage of gas cylinders and bundles. What has changed and what do you need to know?
Storage of gas cylinders
Cylinders containing gases are classed as hazardous substances and consequently gas cylinder stores will require relevant land use permission and may require planning and other consents from local authorities.
All cylinders contain gases under pressure and may present a risk of explosion if not safely handled and stored. Applicable legislation includes the Management of Health and Safety at Work Regulations 1999 and the Dangerous Substances and Explosive Atmospheres Regulations 2002, both of which require a site-specific risk assessment for the handling and storage of each gas cylinder.
Tip. Ensure you have adequate insurance to cover your activities. You must ensure that you use the gases and look after your gas cylinders and associated equipment in a safe and responsible way.
Tip. Use our gas cylinder storage checklist to make sure you are following the approved Code of Practice (see The next step).
The Code of Practice
The document updates the principles of safe practice for the storage of gas cylinders and gas cylinder bundles and provides information on the hazards likely to be encountered. It promotes the use of an outdoor store with good natural ventilation, in a secure location which meets the required separation distances.
What does it cover?
This Code of Practice is applicable to the storage of cylinders whilst not in use, cylinders connected
through a supply pipework and in use as the gas source for a gas supply and distribution system, and the storage of a mobile gas supply system, e.g. an oxy-fuel gas welding set mounted on a trolley, whilst not in use. The document stipulates gas cylinders should be stored, used and handled as if they are full of gas.
Tip. Cylinders are never fully empty unless a cylinder is new, de-valved, or following inspection and test where it has not yet been filled.Therefore, cylinders containing a gas, but regardless of the quantity within, should be treated in line with the Code of Practice to avoid incidents.
Safe storage of gas cylinders
Tip. Store cylinders in the open and on concrete in a fenced compound. They should be clearly labelled.
Tip. Oxygen cylinders must be stored at least 3m away/separated by a fire wall from fuel gas such as acetylene, propane, methane, etc.
Tip. Segregate full cylinders and store separately from empties. Don’t store other products in the gas storage area, especially not corrosive liquids, sources of ignition or flammable materials.
Tip. Protect gas cylinders from external heat sources and weather which may adversely affect their mechanical integrity.
Tip. Cylinders should be secured and restrained with straps or a chain connected to a wall bracket or other fixed surface, or by use of a cylinder stand.
The next step
For our gas cylinder storage checklist, visit https:// www.tips-and-advice.co.uk, code TAHS22DA03.
› If poorly handled and stored, gas cylinders can cause catastrophic property damage and injury. Follow the revised Code of Practice by storing your cylinders upright and secured, and in an outdoor, secured space to avoid an incident.
TIPS & ADVICE Health, Safety & Environment 2 16 October 2023 GAS SAFETY
See it, sort it, report it
If you’re looking for a way to involve your staff in near-miss reporting, use our simple form to launch an initiative that rewards your teams for not turning a blind eye. What’s involved and is it expensive to implement?
Near-miss issues
As near misses are an almost accident, it can be tempting to gloss over them and breathe a sigh of relief that no one got hurt or no property was damaged. And if your staff feel that they will be branded a troublemaker for reporting near misses, there may be a lot of incidents that aren’t investigated, leaving your business vulnerable to near misses turning into accidents.
A new form
Use our see it, sort it, report it form as a simple way to encourage your staff to report and correct minor near misses themselves (see The next step). It’s a good way to empower them to think about their own safety and to make a difference.
What’s expected?
If your staff have spotted a hazard (see it) and corrected it themselves (sort it), simply ask them to complete the form (report it) and hand it in to their manager. Add before and after photographs of the hazard to the form if possible to show the improvement. Some examples include:
• Pallet of goods blocking a fire exit. Pallet removed and relocated to a safe position.
• Trailing cables. Cable tidied and secured to avoid a trip hazard.
• Oil leaking from machine. Warning signs placed around the leak and repair request raised.
• Blind corner with risk of pedestrian and vehicle collision. Request raised to install an angled mirror for clear visibility.
• Worn carpet on stair tread. Signage placed to warn others and repair request raised to management.
Tip. This could be a paper-based tool, or if your staff have access to computers go paperless.
Tip. If you have weekly meetings, discuss all see it, sort it, report it forms that have been submitted. It makes safety specific to your particular organisation and shows staff that you are transparent and credible about making safety improvements.
Tip. Keep these forms to show an auditor or inspector. They are evidence of strong communication and co-operation between you and your workforce.
Reward
When launching this tool consider rewarding those who take part to encourage everyone to come forward. If you have a large number of reports you may want to select one per week, or month, for a reward and explain to your workers that that particular one was rewarded as it avoided the most likely and serious accident. We’ve suggested a few safety-related items that could be used as a reward, with the most expensive being only £15. But adapt this to reflect your organisation’s approach to rewarding employees.
Tip. Most of the prizes are for staff to use at home, spreading the safety message beyond your workplace. It’s a great way to make staff feel valued and keep talking safety, even when not at work.
Tip. Make sure that that the near misses are genuine and haven’t been set up just because there is a reward. It’s up to you to determine who is genuine and who is trying to pull the wool over your eyes.
The next step
For our see it, sort it, report it form, visit https:// www.tips-and-advice.co.uk, code TAHS22DA03.
› Encouraging staff to fix an issue themselves is an effective way to engage them and raise safety awareness in your workplace. Rewarding staff with safety products up to a value of £15 will encourage them to deal with situations and avoid future accidents.
TIPS & ADVICE Health, Safety & Environment 3 16 October 2023 NEAR-MISS REPORTING
Quickly read, print, share our advice online tips-and-advice.co.uk H&S BASICS
Are safety data sheets a risk assessment?
You’ve heard of safety data sheets (SDS) and chemical risk assessments. But are they the same thing and how should you manage chemicals used by your business to avoid accidents, ill health and enforcement action?
What is a safety data sheet (SDS)?
An SDS is a technical document issued by the producers of chemicals. It includes information about each chemical, covering the physical and environmental hazards, precautions for safe handling, storage, and transportation of the chemical, and more. It is a legal requirement under the REACH regulations Note. REACH stands for registration, evaluation, authorisation and restriction of chemicals and regulates chemicals placed on the market in Great Britain. Note. An SDS used to be known as a material data sheet, but the phrase has become outdated due to the Global Harmonized Standards
How you should use an SDS
An SDS structures and makes available the relevant data required to keep people safe from harm. It proposes appropriate safety measures for the workplace and the environment and contains the information necessary to allow employers to do a risk assessment. It is not an assessment in itself but should be used to help you assess your risks.
What is a COSHH risk assessment?
Regulation 6 Control of Substances Hazardous to Heatlh 2002 (COSHH) requires you to undertake a suitable and sufficient assessment of the risk created by the work and should include steps to reduce exposure. The chemical manufacturer has no idea how you are going to use its product, the quantities, frequencies, etc. so this is why you need to assess it for your workplace.
How to do a COSHH risk assessment
The first step in the process is to identify hazardous
substances. Don’t forget that these might not be limited to chemical use, such as cleaners and solvents, but may be generated in other areas, e.g. fumes from exhausts, paint and welding.
The next step is to identify people at risk. Don’t focus on just the operator who is handling the chemical. You need to consider anyone who is in the vicinity who may be exposed by inhalation, absorption, etc.
Next evaluate the risks by considering the likelihood of exposure and the severity (or outcome) if that risk is realised. Tip. Use our COSHH assessment record (see The next step).
Controls
Then you need to determine control measures, applying the hierarchy of control. Consideration must be given to eliminating the hazard if feasible. Next you should try to substitute the chemical for a less hazardous one or reduce the amount and frequency of handling. If this can’t be achieved you should consider isolating the chemical, e.g. spraying paint in a booth with local exhaust ventilation. Then you need to review your management system controls including good housekeeping, training, safe systems of work, welfare facilities, etc. Finally, as a last resort, you should consider issuing PPE.
Record keeping
You must record COSHH assessments and make them available to your staff. They should be reviewed regularly to pick up on any changes.
The next step
For our COSHH assessment record, visit https:// www.tips-and-advice.co.uk, code TAHS22DA03.
› An SDS and a chemical risk assessment are two separate things. The former details the properties of the chemical. The latter shows how you are going to use it whilst protecting your staff from harm. Record and review your assessment regularly.
TIPS & ADVICE Health, Safety & Environment 4 16 October 2023
CHEMICALS
Managing psychosocial hazards
Psychosocial hazards are an emerging risk which left unchecked could lead to significant business interruption. Taking the time to understand and manage them will have less of a detrimental impact. What’s involved and could this affect you?
What’s a psychosocial hazard?
This is anything at work that may cause an adverse impact leading to work-related stress, exacerbated non-work-related stress or affect individual workers’ health and wellbeing, including their ability to participate with other people in a work environment. The risks are increased by the way work is designed and managed, the working environment, or behaviours including bullying, harassment, discrimination and violence.
Tip. A stress response is a physical, mental and emotional reaction that occurs when a worker’s perceptions of the demands of their work exceed their ability to cope. It’s important to remember that stress itself does not constitute a physical or psychological injury.
Emerging psychosocial hazards
An emerging health and safety risk is any occupational risk that is both new and increasing. In a recent EU survey the five most important cateogories of emerging risk identified were:
• new forms of employment
• contracts and job insecurity
• risks for the ageing workforce
• high emotional demands at work
• poor work-life balance.
How does this impact your business?
Work-related psychological injuries have longer recovery times, higher costs, and require more time away from work when compared with physical injuries. In Australia they have seen an increase in compensation claims.
Duty of care
A business has a duty of care to do everything reasonable to prevent exposure to psychosocial hazards and risks. But if you manage psychosocial risks it can protect workers, decrease staff turnover and absenteeism, and may improve broader organisational performance and productivity.
Controls
As with many health and safety subjects, if you manage psychosocial hazards proactively, using the same methods already used for other topics, you can reduce the impact on your business. Start by undertaking a risk assessment.
You need to ensure that senior management is committed to tackling the issues. Collating evidence of the problem and level of risk by using data such as absence reports, complaints, staff survey and quantifying this in financial terms is helpful in gaining senior management support.
Tip. Engaging with workers at all levels will make them feel more valued. Setting up working groups or steering groups with a representative from various departments will help to gather information as well as update workers.
The Australian government has published practical guidance on effective measures to identify and manage the risks. It provides detailed information including how to identify psychosocial hazards, assess and control the risks and conduct appropriate investigations (see The next step).
The next step
For the full guidance, visit https://www.tips-andadvice.co.uk, code TAHS22DA03.
› Psychosocial hazards include job insecurity, poor work-life balance, etc. They can cause disruption to your business in terms of increased absenteeism and potential claims. Approach them by assessing the risks and putting controls in place, such as visible management commitment and a good consultation process.
TIPS & ADVICE Health, Safety & Environment 5 16 October 2023 MENTAL HEALTH
Morrisons fined £3.5m after death of employee
Supermarket chain, Morrisons, has been found guilty of four health and safety failings following the death of one of its workers in 2014. What did it fail to do and what should be put in place to avoid a similar prosecution?
Chain of events
Matthew Gunn (G), 27, had worked for Morrisons (M) in its Tewkesbury store for ten years and had suffered from epilepsy since the age of four. He had been moved to the grocery department from the canteen following an epileptic seizure and adjustments had been made by M to ensure he had a safe working environment.
However, a week before his fatal fall, G had suffered an epileptic seizure in the warehouse and went home. He subsequently suffered what was described as an “absence” while retrieving some of his belongings.
The incident
In September 2014, G was discovered unconscious at the foot of the staff stairs and was subsequently taken by air ambulance to hospital. He was found to have a number of injuries including fractures and neurological damage. Following surgery, no neurological improvement was detected and he died twelve days later of a traumatic head injury. The inquest heard that a seizure may have caused the fall, although it was not possible to determine that with any certainty. An accidental death and narrative conclusion was returned by the jury.
In response
M said that it had measures in place to record any epileptic episodes in store, either in the employee’s personnel file if the episode required first aid treatment, or in the company’s accident book and/or reported to the local authority or HSE if the epileptic event caused an accident or was RIDDOR reportable.
However, M failed to put in place a number of
simple measures which could have kept G safe at work. Furthermore, M failed to co-operate with elements of the investigation.
Sentencing
Following a three-week trial the jury found M guilty on four charges, which were failure to:
• ensure the health and safety of an employee who had epilepsy
• carry out a suitable and sufficient assessment of the risks to the employee who had epilepsy
• review risks to which an employee with epilepsy might be exposed
• supply the council with requested information relating to the death of the employee.
The judge placed the offences in the highest category of culpability and harm, and the company was fined £3.5 million. In conclusion the judge stated that he hoped the outcome will send a message to all employers on the importance of complying with basic health and safety duties, and properly assessing risks, especially when it comes to vulnerable employees.
Vulnerable employees
When an employee has a chronic health condition or a disability you must ensure that your risk assessments take their needs into account.
Tip. A good way to double check that you’ve done all that’s required is to carry out a specific personal risk assessment focused on the individual’s circumstances (see The next step).
The next step
For our personal risk assessment, visit https://www. tips-and-advice.co.uk, code TAHS22DA03.
› Morrisons failed to suitably assess the safety of the workplace which compromised the employee’s needs, contributing to a fatality. Undertake a personal risk assessment for any vulnerable employees and make reasonable adjustments in liaison with them.
TIPS & ADVICE Health, Safety & Environment 6 16 October 2023 RISK ASSESSMENT
Time to go public with your plastic footprint?
More businesses are being urged to voluntarily disclose details of the plastic they use. What’s the story and what are the pros and cons associated with making such information publicly available?
Footprints
In recent years some of the world’s largest businesses have disclosed the tonnages of plastics they use. This is done voluntarily, e.g. through the Ellen MacArthur Foundation (EMF) global commitment on plastics. They also show how much of their packaging is recyclable, compostable or reusable and how much recycled content they are using in their packaging. The EMF admitted recently that most of the targets for 2025 won’t be met though.
CDP’s plastic move
The Carbon Disclosure Project (CDP) is best known for its platform through which businesses disclose their greenhouse gas emissions and water use data. But this year it has expanded its platform to cover plastics too. The CDP’s plastics module, which is incorporated into the water security questionnaire, covers plastics mapping, potential impacts to the environment, business risks and targets (see The next step). The CDP also urged governments to expand their mandatory environmental reporting to plastics too. There have been noises in the UK around this but don’t expect anything soonpackaging policies are moving incredibly slowly.
Keeping track
Understanding how much energy you use or even how much waste you create is fairly straightforward. But detailing the amount of plastic you use is much trickier, especially for small companies. There is also an argument that doesn’t give the full picture, either, and disclosures should cover all types of packaging. Focus on easier wins such as:
• ensuring any packaging you use is easily recyclable, and if it’s not you should be clear
and honest to customers about it (see The next step)
• reduce the amount of single-use packaging you use, i.e. not just plastic but paper, aluminium, glass, etc. too. This will save you money.
What about plastic free?
This idea really caught on a couple of years ago and some are still making such claims. It might sound great to your customers but you need to be very careful. For example, consider what has happened to Iceland, the frozen food retailer, which claimed it would be “plastic free” in its own ranges by 2023. Twelve months ago it admitted that it was now “impossible”, pointing to the pandemic and a lack of available alternatives. Rather than being applauded for its honesty, critics suggested the target was ill-thought through and nothing more than a PR stunt at a time when such claims were hot stuff. Iceland has been left redfaced and has (understandably) gone quiet on making green claims of late. Tip. If you’re going to set a target then think carefully about the pros and cons of making it public. A target relating to your packaging doesn’t have to be external.
A final point on plastic
Measuring your plastic footprint is hard (and not for most SMEs) but so too is unpicking what packaging choices to make. Tip. Be wary of suppliers making claims that turn out to be greenwash. For example, “paper-based” packaging can contain plastic, which can make it harder to recycle. It also wouldn’t be classed as plastic free.
The next step
For the CDP module and information on packaging, visit https://www.tips-and-advice.co.uk, code TAHS22DA03.
› Disclosing your plastic footprint is tough for a small business. Stick to simple approaches like reducing single-use packaging (of all types). Steer clear of making bold claims like “plastic free” as you could face criticism for greenwashing.
TIPS & ADVICE Health, Safety & Environment 7 16 October 2023 ENVIRONMENT
