Updated: Dec 2, 2020
As dangerous goods consultants we see a lot of common mistakes across many industries. This series looks at some of the most common and easily rectifiable mistakes. In this article we look at 4 common mistakes made by sites storing dangerous goods in cabinets.
This article is general information only. Want expert advice, specific to your needs: get in touch.
1. INCOMPATIBLE PRODUCTS
"That's the DG cabinet, just chuck all the DG in there."
Some dangerous goods can have dangerous reactions if combined. By keeping these products in the same cabinet, you increase the chances of this occurring in the event of a small leak from either package. Some of these reactions could result in:
contamination - making the product unusable
damage to the packaging or the cabinet
release of flammable and/or toxic gas
production of large quantities of heat
You also have a legal requirement to prevent this from happening under the WA Dangerous Goods Safety (Storage and Handling of Non-Explosives) Regulations 2007. Regulation 52 requires:
"An operator of a dangerous goods site must take all reasonably practicable measures to ensure that the dangerous goods are isolated so that they cannot — (a) interact with goods that are not compatible; or (b) contaminate any other goods."
This means there are some products you just can't keep in the same cabinet.
To fix this, you need to ensure you have good segregation between your dangerous goods. Segregation means having sufficient measures in place to keep two products separate. The amount of separation required depends on:
the products' physical properties (are they liquids? solids?)
how dangerous the potential reaction could be
other factors such as your store conditions
The best way to the compatibility of two products is to check their Safety Data Sheets. In the storage section there will always be guidance as to the compatibility of the product. The relevant standard or code of practice will provide further guidance as to how to best segregate the products.
As a rule of thumb, the following separation table could be applied based on the class of the dangerous good:
Segregation charts like this make it much easier to ensure you're segregating your products correctly. Our dangerous goods consultants can put together a personalised segregation chart for your facility. If that sounds useful, please get in touch!
2. INCORRECT PLACARDING
Operational needs change, different products get used, the placard on the cabinet becomes a faded memory…
Failure to correctly label a dangerous goods cabinet can have an impact on housekeeping (see Segregation above) as site personnel put the wrong products in the cabinet. It can also have more severe consequences for emergency responders as they may take the wrong firefighting measures for the products you have.
Stores above a certain quantity also have an obligation under the WA DGS Regs to make sure the correct placards are in place. Regulation 70 is applicable to the storage of packaged dangerous goods.
It is also important to note that in accordance with regulation 71, even if you have the correct placard:
“…a sign is not properly displayed unless it is — (a) clean, in good order and unobstructed; and (b) clearly legible to persons approaching it; and (c) separate from any other sign or writing that contradicts, qualifies or distracts attention from it.”
To ensure that your cabinet is correctly labelled:
1. Check the relevant legislation, Australian Standard or code of practice for the correct placard and labelling required.
2. Obtain the required labels ensuring that all are the appropriate size and colour. For example the WA DGS Regs Schedule 4 requires class diamonds to have a side length of at least 100mm.
3. Install the label in a location clearly visible on approach and clear of any markings which contradict or distract from the label.
4. Implement a housekeeping procedure which includes checking that the labels are still legible and match the contents.
If dangerous goods are no longer stored in the cabinet, any placarding should be removed or obscured.
Not sure what your placarding requirements are? Get in touch with an expert and find out.
3. IGNITION SOURCES
Your new cabinet arrives, you put it in the corner, fill it with dangerous goods and then you leave, not noticing the small power outlet waiting to cause all sorts of drama…
Some dangerous goods can produce flammable vapours. If the vapours are released from the container and resulting cloud encounters an ignition source, an explosion can occur. The area where these flammable vapours can potentially exist is referred to by dangerous goods engineers as a Hazardous Area. These areas have a rating (zone) and dimensions (extents). This depends on the source of the release and the ventilation in the area.
Hazardous Areas are also a legal risk as they are covered under the WA DGS Regs. Regulation 56 requires:
“An operator of a dangerous goods site must ensure that any ignition source in a hazardous area within the site is eliminated or, if this is not reasonably practicable, the risk arising from the ignition source is controlled.”
The first step is to perform a hazardous area classification to determine the zone rating and extents of the hazardous area associated with your cabinet. Such an assessment needs to be performed by a suitably qualified person in accordance with the relevant part of AS/NZS 60079.10. Depending on the products you are storing you may be able to get advice from the cabinet supplier or from examples in an Australian Standard or code of practice.
For example AS/NZS 60079.10.1 subclause ZA 5.2.3(c) provides the following classification for a flammable liquids cabinet complying with AS 1940.
Zone 1 – Interior of cabinet
Zone 2 – Exterior of cabinet together with any vent provided on the cabinet from ground level to 1m above and 3m laterally
Once the hazardous areas have been determined you need to remove all the ignition sources. These could include:
Mechanical equipment - such as fans which can cause sparking
Open flames - such as pilot lights and smoking
Electrical equipment - such as lighting and power points
Hot surfaces - such as boilers, heated pipes, cooking implements
Where you can’t remove an ignition source the risk must be reduced in an alternative manner such as using electrical equipment which is rated for that Zone.
Need help with hazardous areas? Get in touch! Cadre has the experience and qualifications to let you know your exact requirements and help keep your site safe.
4. POOR HOUSEKEEPING
Things get busy, a new delivery arrives, there’s too many products and not enough space.
A lot of dangerous goods cabinets become a dumping ground – packages are placed inside randomly and are forgotten about. This can become a problem over time as products and packaging start to degrade, extraneous items start to build up and the risk increases. Some key issues Cadre sees regularly includes:
Packages stored upside down or on their side
Lids not properly closed
Packages falling out when the door is opened
Old stock is left at the back to degrade
Spills which haven’t been cleaned
Damage to the interior of the cabinet
Buildup of combustible material such as cardboard.
Some of these issues are covered under the WA DGS Regs. For example spills under regulation 51:
“If dangerous goods, except Class 2 dangerous goods, spill or leak from an area of the site where the goods are stored or handled, the operator of the site must ensure the goods are cleaned up as soon as practicable after the spill or leak.”
And the buildup of combustible material under regulation 67:
“An operator of a dangerous goods site must ensure that the area within 3 m of a storage or handling system is kept clear of combustible material that presents a fire hazard to any dangerous goods contained in the system.”
Managing the risks of poor housekeeping is an ongoing process which requires buy in from the entire team. To solve poor housekeeping issues, follow these steps:
1. Develop a list of the key tasks which need to be performed to ensure good housekeeping. Seek guidance from the product Safety Data Sheet, relevant Australian Standards and Codes of Practice. Tasks could include:
Clean out the old products which are no longer in use
Relabel any containers where the label is fading
Remove any combustible material such as cardboard
Dispose of any damaged or leaking containers
All packages are stored upright in a stable position
Clean up any spills
Close any open containers
2. Write a housekeeping procedure which includes a checklist of the key tasks identified above. Remember to consider the safety of the personnel performing these housekeeping tasks when developing the procedure.
3. Train all staff who have access to the cabinet in good housekeeping procedures. Training should include how to safely perform housekeeping tasks and explain the importance of good housekeeping.
4. Implement a regular inspection of the cabinet which checks that the housekeeping procedure is being followed and identifies any flaws in the housekeeping procedure. The inspection frequency should depend on the frequency of use of the cabinet and what can be consistently maintained by the team.
Do you need some housekeeping procedures for your dangerous goods storage? Cadre’s dangerous goods consultants have a lot of experience in writing procedures and working with you keep things safe and compliance. Get in touch!
Did you have any of these issues on your site? Hopefully this article helped you fix the 4 common mistakes we see with dangerous goods cabinets. Stay tuned for future articles where we look at more common mistakes made with other dangerous goods storage types.
Although these are some common mistakes, remember there are a whole heap of other compliance and safety issues associated with dangerous goods storage cabinets. Make sure you check your risk assessment and get in touch if you have any questions!
This article was prepared as general guidance only and based on information current at time of publication. The use of this information is at the reader's own risk, Cadre Engineering accepts no liability for any outcomes of following this guidance. For expert advice, specific to your needs, please get in touch.