The Risk Management Tool Box Blog

UK Pressure Safety Regulations, 2000

Graham Marshall - Sunday, March 31, 2013

In the United Kingdom, the Pressure Systems Safety Regulations (2000) deal with the safe operation of a pressure system and the Pressure Equipment Regulations 1999 deal with the design, manufacture and supply of pressure systems.

The laws for pressure systems are comprehensive because many types of pressure equipment can be hazardous.

Pressurized equipment include steam boilers and associated pipework, pressurized hot-water boilers, air compressors, air receivers and associated pipework, autoclaves, gas (eg LPG) storage tanks and chemical reaction vessels.

If not properly controlled, pressurized equipment which fails can explode and cause serious injuries and lead to fatalities.

But putting proper controls in place will minimize the chances of any unwanted pressure releases occurring.

As with all safety management, the key to good control of pressurized equipment is to assess the risk associated with the specific equipment in the workplace and to use the hierarchy of control to develop the appropriate safeguards.

The risk associated with a the failure in pressurized  equipment depends on a number of factors including:

+  The operating pressure in the system;
+  The type of liquid or gas under pressure and its properties;

+  The suitability of the equipment and pipework that contains the pressure;

+  The age and condition of the equipment;

+  The complexity and control of its operation;

+  The other applicable conditions (e.g., operating temperature of equipment); and

+  The expertise of the people who maintain, test and operate the pressurized equipment.

To reduce the risk associated with pressurized systems, Managers need to know (and act on) some basic precautions:

+  Ensure the system can be operated safely;

+  Be careful when repairing or modifying a pressure system;

+  Following any major repair or modification, have the whole system re-examined before start-up;

+  Ensure there is a set of operating procedures for all of the equipment in the system, including in emergencies;

+  Ensure that there is a maintenance program for the system;

+  The maintenance program should account for the age, use and the environment in which the system is used.

In addition to those controls, a written scheme of examination is required for most pressure systems:

+  This should be certified as suitable by a competent person;

+  It should address all protective devices, every pressure vessel and those parts of pipelines that could be dangerous;
+  The written scheme must specify the nature and frequency of examinations, and include any special measures that may be needed to prepare a system for a safe examination.

Remember, a statutory examination carried out in line with a written scheme is designed to ensure your pressure system is suitable for your intended use. It is not a substitute for regular and routine maintenance.

And finally...

+  Ensure that pressure equipment complies with the relevant regulations;

+  Before using pressure equipment, ensure that you have a written scheme of examination if one is required.

+  Make sure that inspections have been completed by a competent person, and that the results have been recorded;.

+  Always operate the equipment within the safe operating limits;

+  Provide instruction and relevant training for the workers who are going to operate the pressure equipment;

+  Ensure to have an effective maintenance plan in place, which is carried out by appropriately trained people; and

+  Make sure that any modifications are planned, recorded and do not lead to danger.

UK Courts highlight the need for conveyor guarding

Graham Marshall - Sunday, January 20, 2013

The importance of appropriate guarding of moving and rotating parts on equipment has again been highlighted by the UK courts following a successful prosecution of a Deeside company.

Mainetti (UK) Ltd has been fined £60,000 and ordered to pay costs of £21,668 after a worker had her hair ripped out by a poorly guarded conveyor belt.

Kelly Nield, 25, was working on a conveyor when her scarf and hair became caught in the chain and sprocket drive of the belt as she bent over to remove accumulated clothes hangers.

She sustained serious throat injuries, lost a substantial part of her hair and fractured a finger in the incident on 11 April 2009 at Mainetti (UK) Ltd in Deeside Industrial Park.

Miss Nield needed a number of operations and was in hospital for three months.

The incident was investigated by the UK HSE which prosecuted the company for serious safety failings at Mold Crown Court.

Mainetti (UK) Ltd pleaded guilty to breaching three regulations under the Provision and Use of Work Equipment Regulations (1998) and one breach under Regulation 3 of the Management of Health at Safety at Work Regulations (1999).

Although Mainetti had fitted a guard to the conveyor, it did not fully enclose the dangerous moving parts.

And there was no emergency stop button on the conveyor.

The company's risk assessment also failed to identify the dangers of entanglement in conveyors, and the need to keep hair and loose clothing secure when near the machinery was poorly enforced.

HSE Inspector David Wynne, speaking after the hearing, said: "These horrific, life-changing injuries sustained by Ms Nield could easily have been avoided if the right safeguarding measures had been taken by Mainetti (UK) Ltd.  There are well-known risks associated with working with conveyor belts. It is vital, therefore, that the risks are fully assessed and guarding provided to prevent access to moving parts. Where appropriate, emergency stop controls should be installed in readily accessible places.  Employers must also ensure that workers are properly monitored, supervised and trained when working with this sort of equipment."


Tips for Working on Hot Days

Graham Marshall - Friday, June 01, 2012

With the onset of summer across the northern hemisphere, today is a timely date to remind all workers about the dangers associated with working in the heat.

Below is an image showing the heat index which highlights how the air temperature can feel when consideration is also given to the ambient humidity.

As the index shows, the working temperature can feel a lot hotter than the thermometre may be showing if you're working on a humid day.

In response to high temperatures, always always use the hierarchy of control to select the best possible control mechanisms when working outdoors on hot days.  These controls include:

+  Eliminate the hazard by canceling the work or re-scheduling to a cooler time of day (or cooler season);

+  Substitute the work by doing something else indoors in a cooler environment;

+  Engineer the environment to provide shade, air-moving fans or cooler units;

+  Administrate to ensure that plenty of water is drunk and regular rest breaks are taken in a cool spot;

+  Protect yourself with PPE using wide brimmed hats, long sleaved shirt and long pants, and sub block cream.







Risk Associated with 240 Volt Hand Tools

Graham Marshall - Thursday, April 19, 2012

In the past three years from April 2009 to April 2012, NOPSEMA has received 39 notifications of electric shock

Fortunately, there have been no deaths associated with these electric shock incidents, but they are, nonetheless, high-potential incidents.

We all need to ensure we take advantage of the “lessons learnt” from these incidents because more personnel are being exposed to the potential for serious injury or death due to electric shock.

According to NOPSEMA, Of the 39 notifications:

+   Nineteen involved the use of Hand Tools, Temporary Lighting, Extension Cables etc;

+   Thirteen involved fixed equipment (Lighting, Switches, General Power Outlets); and

+   Seven were related to welding activities (5 of which involved Earth Clamps condition / application).

Schedule 3 of the Offshore Petroleum and Greenhouse Gas Storage Act 2006 places duties on the operator
of a facility to take all reasonably practicable steps to ensure that:

A.  The facility is safe and without risk to the health of any person at or near the facility; and

B.  All work and other activities carried out on the facility are carried out in a manner that is safe and
without risk to the health of any person at or near the facility.

Good practice demands that the layers of control are being used to reduce risk to ALARP, taking account of:

+   Elimination of the hazard;

+   Substitution (for a less hazardous alternative);

+   Engineering – redesign or use isolation and LOTO;

+   Administrative controls are in place including PTW, Procedures, JSA, tool box talks and such like; and

+   PPE is being used.

To take advantage of our JSA covering the safe use of powered hand-held tools, which highlights the hierarchy of controls to be used, simply click here.

Define Housekeeping

Graham Marshall - Monday, April 09, 2012

Here's a funny thing; I've been working up a Housekeeping Procedure for one of my clients, and I thought it would be a good idea to start with a definition of housekeeping.

I thought this would be straightforward enough since everyone knows what housekeeping is.  Right? 


Housekeeping is not just keeping a work place tidy. It's not just about hygiene and cleanliness either.

As I thought about it a little more, it occurred to me that "housekeeping" is much more than these things. 

So here is the definition I came up with.  What do you think?

"Housekeeping is a systematic process for reducing the risk off accidents.  It achieves this objective by ensuring that:

+  Areas of work are laid out to a specific plan, taking account of necessary EHS considerations;

+  Due consideration is given to the "hierarchy of control" when designing a given work space;

+  Equipment, tools and other items are placed, used and/or stored appropriately;

+  Chemicals are stored, used and disposed of correctly;

+  Safety signage, barriers and barricade areas  are installed and used appropriately; and

+  The location is continuously monitored and kept in a fit and tidy state."

Decommissioning Underground Storage Tanks

Graham Marshall - Sunday, December 18, 2011

Unfortunately, there is a high risk of pollution during the decommissioning and removal of underground storage tank (UST) systems which previously contained petrol, diesel, fuel oil, aviation fuel, waste oil, domestic heating oil and other potentially polluting materials such as organic solvents.

A UST system is any tank, associated underground pipework, and ancillary equipment that is completely or partially below ground level.

That definition includes any tank that is partially above ground but covered with earth, and any tank in a vault or basement where its base and sides cannot be inspected.

If it is possible to inspect all the base and walls of the tank, it is considered to be an above ground storage tank.

As per our standard hierarchy of hazard control, elimination of the hazard is always the most favoured option.  For that reason, and for the purposes of pollution prevention, it is best to store potentially polluting substances in above ground accessible tanks.

But since this "elimination" option is not always available, the UK Environment Agency has prepared this useful Pollution Prevention Guide (PPG-27) which address many of the safety issues in decommission and removing USTs.

To access the pollution prevention guide on underground storage tanks, simply click here.

Control the risk when re-fuelling portable petrol generators

Graham Marshall - Sunday, November 13, 2011

Filling portable generators with petrol creates flammable  vapors that can be easily ignited by static electricity or other ignition sources.

Two recent accident  examples illustrate how workers can be killed or seriously injured if petrol ignites.

The first incident occurred when workers who were lining a dam with high density polyurethane suffered burns when the portable generator they were refueling ignited.  The movement of the workers walking across the plastic liner resulted in the generation of static electricity which probably  discharged and ignited the petrol vapors released during the fueling process.

The second incident occurred at a construction site where a worker sustained serious burns when the portable generator he was refueling on the back of his vehicle caught fire.  Petrol vapors may have been ignited by static electricity or the hot components of the generator.

Control Measures
Before using a portable petrol-powered generator, consider the hierarchy of control to highlight the  following safety measures:

1.  Eliminate the hazard - is a petrol generator really necessary?

2.  Substitute - is there a source of mains power available or is a diesel generator available?

3.  Engineering controls - always used appropriate fuel containers and funnels to reduce the risk of generating static electricity while decanting petrol.

4.  Administrative controls - as with most jobs, there are a whole bunch of administrative controls you should have in place.  These controls include:

+  Write up a JSA for the job;

+  Ensure workers understand the hazards and controls by doing a pre-job tool-box talk;

+  Ensure suitable fire extinguishers are available in close proximity to the re-fueling activity;

+  Ensure generators are placed on firm ground, in well-ventilated areas, away from heat and ignition sources.

+  Do not fill generators in low lying areas where vapors could accumulate and increase the risk of ignition.

+  Do not fill generators inside a vehicle or other 'confined' space.

+  Before filling the generator, check that the person filling touches the generator and fuel filling container to ensure any build up of static electricity can be dissipated before starting the filling operation.

+  Ensure the container cap is replaced tightly on the filled generator before moving the generator.

+  Allow the generator to cool and is in an upright position in a well-ventilated space before transporting.

+  Consider PPE requirements - gloves, eye protection and possible FR clothing for refueling jobs.

Further Information
AS/NZS 2906 – Fuel containers – Portable Plastics and Metal.
AS/NZS 1940 – Storage and handling of flammable and combustible liquids Service stations.

An don't forget, always refer to the operators manual for guidance.



What does "reasonably practical" mean?

Graham Marshall - Saturday, October 08, 2011
The legal definition of the term "Reasonably Practicable" was established in English courts by Lord Justice Asquith in the case brought by Edwards against the National Coal Board in 1949.
Lord Justice Asquith said:

"To imply that a computation must be made by the owner, in which the quantum of risk is placed on one scale and the sacrifice involved in the measures necessary for averting the risk (whether in money, time or trouble) is placed in the other; and that if it be shown that there is a gross disproportion between them the risk being insignificant in relation
to the sacrifice the defendants discharge the onus on them.  Moreover, this computation falls to be made by the owner at a point of time anterior to the accident".

This decision of the English courts has since been confirmed by the Australian High Court (in 2001) in the case Slivak v Lurgi (Australia) Pty Ltd.

If Lord Justice Asquith's judgment leaves you none the wiser, in simple terms demonstrating that risk is reduced to a level that is reasonably practicable means that the duty-owner (e.g., an owner or operator) has to show, through reasoned and supported arguments, that there are no other practical measures that could reasonably be taken to reduce risks further.

Hope that's clear enough but if not, feel free to get in touch with your questions.

What is the best way to reduce risk?

Graham Marshall - Saturday, September 03, 2011
In many cases, the best way to reduce risk is through inherently safer design at the front end of project development and prior to construction and operation.

The principles of inherently safer design typically involve an attempt to eliminate risk by removing sources of hazard potential.

Within the "hierarchy" of risk control, elimination of hazards is always the most favoured approach to risk reduction.

Inherently safer design also involves attempts by designers to substitute the potentially more dangerous hazards with less hazardous ones.

Inherently safer design also seeks out ways to separate people from hazards and from the potential consequences of foreseeable future (unwanted) events.  An example of separation can be found where offshore (marine) well-head platforms are designed to be "unmanned" and controlled from a shore-based central control room (CCR).

Other aspects of inherently safer design include the following:

  • Attempts to control of the magnitude and frequency of potential accidents;


  • Attempts to mitigate the impact of foreseeable incidents on people; and


  • Appropriate consideration of emergency response planning.


Respiratory Protection

Graham Marshall - Tuesday, August 09, 2011

According to the National Institute of Occupational Safety and Health (NIOSH), more than 28,000 workers died as a result of pneumoconiosis between 1999 and 2004.

So, how do you know if a respiratory safety program is required at your workplace?

The first step in determining the required respiratory protection measures in any work place is to perform a hazard identification assessment.

What type of hazardous substance may be present and in what form?

Is the potential hazard a vapour, smoke, mist, spray droplet, dust, metallic fume, or gas?

The general identification of the hazardous substances present in the workplace and their forms may not be too difficult.

Determining the toxicity and measuring employee exposure to the hazards may, however, require specialist expertise and equipment.

In the US, OSHAs Respiratory Protection Standard (29 CFR 1910.134) provides mandated requirements for respiratory protection programs and the Air Contaminants Standard (CFR 1910.1000) lists legally binding exposure limits for toxic chemicals.

In general terms, once a hazardous substance is identified with the potential to cause respiratory problems, the hierarchy of safety controls provides the best guide to a preferred course of action.

The starting point should always be via attempts to eliminate the potential for atmospheric contamination.  This may involve the elimination of the hazard source or by eliminating the activity which results in air pollution.

The next most preferential method of control is via substitution controls. 

This could include substitution of one hazardous substance for something inherently less toxic or through substitution of a work process that causes air quality problems.

Engineering controls to prevent air contamination may include such controls as the introduction of natural or forced ventilation, air filtration or air extraction methods and air oxidation using catalytic converters.

Administrative controls may include personnel monitoring, frequent health checks and such like.

Assuming that all alternative methods of controls have been considered, implemented or ruled-out as impracticable, then personal protective equipment may be considered.

Further information on NIOSHs respiratory selection guidance is available by clicking here.

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