The Warehousing of Aerosols - SCRIP · 2019. 7. 4. · Warehousing Introduction Storage of filled...

Warehousing

The Warehousing of Aerosols

A BAMA Guide to Safe Storage

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Contents

Introduction

1. Scope

2. Terms and Definitions

3. General Requirements

4. Regulatory Framework for Storing Aerosols

5. General Safety

6. Control of Hazards in the Storage Area

7. Disposal of Aerosols

Bibliography

Annex A - Design Considerations for Aerosol Storage

Annex B – Framework Risk Assessment for the Warehousing of Aerosols

The information in this document is given in good faith, but does not imply acceptance of any liability or responsibility by the association for the consequences of its use or misuse in any particular circumstances. The illustrations given in this Guide are for illustrative purposes only and are not intended to be instructive.

Copyright BAMA 2008 All rights reserved

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Introduction

Storage of filled aerosols requires careful consideration because of the risks associated with flammable propellants and liquids. Several instances of very destructive warehouse fires have been reported, and as a result it is important to take safety very seriously. The storage of filled aerosols has been the subject of much study by BAMA and a detailed discussion of the design of aerosol warehouses is given in Annex A.

The purpose of this Guide is to help maximise safety levels in aerosol warehouses; it aims to cover the whole range of aerosol warehousing, both large and small operations, and all types of products. Therefore, some of the requirements may not be applicable to a particular warehousing operation. Separate but related advice on retail storage of aerosols is available, free of charge, from BAMA in the 'Guide to Retail Storage and Display of Aerosols'.

Organisations storing aerosols should establish access (either on site or immediately available off site) to a source of competent expert advice who can provide training on aerosol safety and advice in case of an incident. All relevant staff including temporary staff should have induction and follow-up training about the hazards of the products stored, correct handling techniques, good housekeeping, emergency procedures and procedures for dealing with damaged or leaking stock. Engineering staff should also be instructed in the correct maintenance procedures and written permit systems. Contractors should be informed of the person with accountability for their safety. BAMA also recommends that suppliers of aerosols ensure that their contractors store aerosols safely.

The philosophy encouraged by BAMA is one of examining an operation to identify any hazards, assessing the nature of the risk associated with that hazard and then using equipment, practices or procedures to minimise the risk. The intention when developing this Guide was to prescribe the level of safety not the means of ensuring that safety and so it is possible that the methods set out in the requirements are not appropriate for a particular operation.

It is important to be able to demonstrate that you have considered all of the hazards that could arise from your operations and that you have taken steps to ensure that the risk of those hazards occurring is reduced to an acceptable level. This Guide is taken from The BAMA Standard for Consumer Safety and Good Manufacturing Practice which includes a tool to help assess your operation not available in this Guide. The BAMA Standard is available from BAMA (www.bama.co.uk).

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Warehousing

1. Scope

This Guide presents requirements and guidance for the storage of aerosols. It includes storage of finished goods at the aerosol factory as well as in a warehouse for the purpose of distribution.

2. Terms and Definitions

Good Practice Practices in compliance with legal and regulatory requirements plus those that the industry believes ensure safety of the consumer and/or the workplace. A Good Practice requirement will be specified using the word 'shall'.

Best Practice Recommendations that provide enhancements over and above Good Practice. Best Practice will be specified using the word 'should'.

Guidance

Descriptive information giving background and/or advice on how to meet Good or Best Practice and on what to look for to assess compliance with the requirements.

Aerosol A non-reusable container made of metal, glass or plastic and containing a gas compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder, and fitted with a release device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, as foam, paste or powder or in a liquid state.

Burst In relation to an aerosol, burst means total failure of the aerosol.

Contract Warehousing When a supplier of aerosols contracts a third party to store finished aerosols on their behalf.

Fire Compartment An area which is separate from the rest of the building by construction of fire resisting (rated) walls, floors etc. A fire separation is positioned in wall openings or between racks to prevent fires from spreading.

Fire Separation A fire separation is positioned in the wall openings or between racks to prevent fire from spreading.

Flammable Gas Propelled Aerosol An aerosol propelled by a gas that is flammable in air at normal pressure.

MAPP A documented Major Accident Prevention Policy.

Normal Transport Provisions Aerosols can be transported as ‘dangerous goods in limited quantities’ if they have been tested to show they do not leak in the approved way and are in boxes or on stretch-wrapped trays marked ‘UN1950’ and secured on a pallet.

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Risk Assessment A careful examination of what could cause harm to people, to enable a decision to be made on whether sufficient precautions have been taken or whether more should be done to further reduce risk.

Supplier Filler or marketer of aerosols

Vent In relation to an aerosol, ‘vent’ means the aerosol container maintains its general integrity although the contents discharge uncontrollably, but usually directionally as a gas, liquid or as both gas and liquid phases.

Warehousing The keeping of aerosol stocks in premises for the purpose of distribution.

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3. General Requirements

Guidance to 3

This Section sets out general requirements for management of the storage of aerosols. The philosophy behind the requirements is to ensure implementation of policies for the safe storage of finished aerosols along the supply chain.

3.1 Supplier Warehousing

3.1.1 Suppliers of aerosols shall store aerosols in accordance with the requirements set out in Sections 4 to 7 of this Guide.

Guidance to 3.1.1

Suppliers of aerosols (i.e. fillers and marketers) who have their own finished products’ warehousing facilities are required to meet all of the relevant requirements if they wish to claim compliance with this Guide.

3.2 Contract Warehousing

3.2.1 Suppliers of aerosols who ‘contract-out’ storage of finished aerosols shall audit the warehousing operation.

Guidance to 3.2.1

Suppliers of aerosols who contract out storage of finished products prior to shipment to the wholesaler/retailer, should use this Guide to ensure that their contractor stores aerosols safely. This could be achieved by using the requirements of this Guide as a tool to aid in the auditing of suppliers.

Best Practice

3.2.2 Suppliers of aerosols who ‘contract-out’ storage of finished aerosols should require that contractors comply with the requirements set out in Sections 4 to 7 of this Guide.

3.3 Wholesaler/Retailer Warehousing

3.3.1 Suppliers of aerosols shall make available written advice to wholesalers and retailers that recommends storage in compliance with the requirements set out in Sections 4 to 7 of this Guide.

Guidance to 3.3.1

Suppliers cannot be expected to require wholesalers/retailers to comply with the requirements of Sections 4 to 7 of this Guide. However, they are required to demonstrate that they offered detailed advice on storage to wholesalers/retailers, even if it was not acted upon, if they wish to claim compliance with this Guide.

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4. The Regulatory Framework for Storing Aerosols

Guidance to 4

The regulations covering the manufacture and transport of aerosols require that after filling every aerosol is subjected to an integrity test such as the Hot Water Bath or has been made by a combination of Quality Assurance systems and micro-leak detections that ensures that leaking aerosols do not leave the filler. Product safety considerations also require the selection of containers and components that are compatible with the contents under the expected conditions of storage. These safeguards mean that undamaged aerosols are unlikely to leak if stored in accordance with the advice set out in this Guide.

However, pierced or damaged aerosols will release their contents and, if these are flammable, there will be a risk of ignition. For most aerosols the propellants used are extremely flammable liquefied petroleum gases that vaporise immediately upon release and which can generate an explosive atmosphere. Many aerosols also contain flammable solvents such as ethanol or paraffins. Therefore the majority of aerosols can be ignited by a fire and will contribute fuel and thus a fiercer fire may result. Aerosols will only start fires if the contents are released and, in fact, most fires involving aerosols are started in other materials within the warehouse.

Fires involving aerosol stocks can develop very rapidly. Safety of people is therefore of prime importance. The people to be considered will include not only employees, but also contractors, visitors and local residents. The protection of those fighting the fire and those off-site who may be downwind of the plume of smoke should not be overlooked. In general, the fire will spread very rapidly and involve other stored materials. It is the packaging and pallets that contribute most of the smoke to a fire. As a result, most of the damage to the buildings and infrastructure comes from the burning of materials other than aerosols.

As with any closed container, when an aerosol is involved in a fire, the pressure inside the container is greatly increased. One of the following may occur:

• The aerosol fails, usually at the base or the top, and depending upon the contents and size of the can, may be projected (rocket) a significant distance in any direction. At the same time, burning liquid may be thrown laterally or burning gas may rise vertically, thus spreading the fire.

• The aerosol fails by venting off a mixture of gas and liquid. The liquid may pool on the floor and if flammable and ignited spread the fire to the surrounding area depending upon the size of the pool.

• The aerosol fails but is a product such as shaving gel that contains only small quantities of flammable material and hardly contributes to the fire.

There are a number of secondary hazards that could also result in injury to persons or damage to buildings. Rocketing of burst aerosols may cause impact injuries as well as spreading fire. Reduced visibility and asphyxiation of personnel due to smoke resulting from burning packing material may hinder exit from the area. The additional hazards of some product types which may be corrosive, toxic, irritant or harmful should be considered on an individual basis but will obviously also make

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Guidance to 4 (continued)

any fire-fighting attempts more complicated. All sites having such products should endeavour to have all information available to the emergency services at all times. Although the freezing hazard of liquefied and compressed gases is well known, there are no known reports of freeze-burns as a result of contact with jetting liquefied or compressed gases in aerosol storage. The same is also the case for asphyxiation of operatives.

The bursting of aerosols involved in a fire is an intermittent occurrence. However, the burst cans may have razor sharp edges presenting a severe cut hazard, and all persons should be evacuated from any area of fire that involves aerosols because of the danger of flying container components. Flying parts of the aerosols are easily stopped by walls, substantial partitions and nearby stocks of goods or, if present, caging. In the event of a roof collapse, flying parts may be projected into the air and fall into the surrounding area. In this situation the emergency services will be able to evaluate the problem and take any necessary precautions.

The regulations covering the storage of flammable propellants are currently:

• Notification of Installations Handling Hazardous Substances (NIHHS) Regulations 1982

• Planning (Control of Major-Accident Hazards) Regulations 1999

• Dangerous Substances and Explosive Atmospheres (DSEAR) Regulations 2002

• Control of Major Accident Hazards (COMAH) Regulations 1999.

• Control of Major Accident Hazards (Amendment) Regulations 2005

4.1 All Warehouses 4.1.1 Keepers of packed aerosol stock containing more than 25 tonnes of LPG (liquefied petroleum gas) shall notify their Local Authority.

Guidance to 4.1.1

NIHHS requires businesses to notify their Local Authority if they handle or store hazardous substances over a threshold quantity. In the case of aerosol warehousing, the most appropriate threshold is 25 tonnes of LPG. Warehouse businesses will need to liaise with their suppliers for the information on the quantity of LPG in each type of aerosol stored so that they can aggregate the total to calculate an inventory figure. NIHHS requires only notification of premises; there is no permission requirement within this legislation

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4.1.2 Keepers of packed aerosol stock containing more than 25 tonnes of LPG (liquefied petroleum gas) shall obtain Planning Consent from their Local Authority.

Guidance to 4.1.2

The Planning (COMAH) Regulations 1999 came into force on 20 April 1999 as a consequence of the UK implementation of the Seveso Directive (96/82/EC). These regulations amended the Planning (Hazardous Substances) Regulations 1992 to remove the exemption for most aerosol warehouses from the requirement for Planning Consent. Therefore, from that date, businesses that store or handle aerosols have been required to obtain Planning Consent for operations involving quantities in excess of defined thresholds of hazardous substances. The Regulations require an application for Planning Consent to be made to the Local Authority before the threshold quantities are exceeded. The Planning (COMAH) Regulations were updated in 2005 to implement the amended Seveso Directive (2003/105/EC).

The relevant hazardous substances are named in Schedule 1 of the Planning (COMAH) Regulations, which amends Schedule 1 of the Planning (Hazardous Substances) Regulations. For aerosols the key substance is LPG, for which the controlled quantity is an aggregated total of 25 tonnes. However, it is important to note that the latest amendment aligns the regulations with COMAH (see 4.2) and other hazardous substances need to be taken into account when carrying out the aggregation calculation.

It was possible to obtain deemed consent for installations existing before 6 April 1999, but this possibility expired in October 1999.

4.1.3 All keepers of packed aerosol stock shall conduct a DSEAR risk assessment to identify the risk of fire or explosion.

Guidance to 4.1.3

DSEAR requires employers to identify any areas where flammable gases and liquids are present in the work place. If any are present, employers must conduct a risk assessment to identify the risk of fire or explosion. Employers must then provide ‘general safety measures’ to eliminate or control, as far as reasonable, the risks to workers from fire or explosion. Measures to prevent an explosive atmosphere forming could include equipment to control or disperse releases (e.g. ventilation), procedures to deal with accidents and emergencies, and information and training to employees. If, after implementing these measures, the risk assessment shows that the quantity or duration of the explosive atmosphere could cause harm to people then the area is a ‘hazardous place’ and further 'special precautions' are needed to control potential ignition sources in relation to construction, installation and use of equipment. The area must then be classified into zones in accordance with the expected frequency and duration of any explosive atmosphere. Zoned areas must be marked with specified 'EX' signs, workers will need to be provided with appropriate clothing that does not create an electrostatic discharge, and only equipment certified as suitable for use in the zone may be used.

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Guidance to 4.1.3 (continued)

Warehouses storing packaged finished aerosols can generally be considered as non-hazardous provided the operational safety and control measures described in Sections 5 and 6 of this Guide are implemented effectively. The small quantity and duration of explosive atmospheres generated by the accidental release of the contents of an aerosol would not normally present a risk to people. However, special consideration should be given to additional control measures where aerosols are stored in confined spaces, where escape would be difficult (e.g. man aloft fork lift trucks).

Annex B provides a framework for warehouse operators to use when carrying out their own risk assessment of the warehousing of filled aerosol products and suggests the types of measures they should take.

4.1.4 Aerosol warehouses shall have an emergency plan.

Guidance to 4.1.4

This requirement is formalised for COMAH sites as part of a MAPP (see 4.2.2), but a plan of action in the event of an emergency is good practice for any facility storing aerosols. Guidance on setting up and managing a Emergency Plan is given in the BAMA guide –Emergency Planning.

4.1.5 Systems and procedures for the management of risk associated with aerosol storage shall be subject to a regular programme of monitoring and review.

Guidance to 4.1.5

Minimum suggestions for regular inspections are:

• Daily inspection of fork lift trucks.

• Weekly inspection and test of fire sprinkler pumps and hydrants.

• Standards of housekeeping.

• Condition of pallets, pallet racking and shelving.

• Fire exits, signs and emergency lights

• Fire extinguishers

• Safety equipment (e.g. showers, eyewash bottles, spill control).

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4.2 COMAH (Control of Major Accident Hazards) Warehouses Guidance to 4.2

The COMAH regulations are the UK implementation of the Seveso Directives (96/94/EC and 2003/105/EC), they place duties on employers to prevent major accidents from happening, and to limit the consequences to human health and the environment for any that do occur. They are triggered by the presence of defined dangerous substances1 in excess of threshold quantities. COMAH is site specific and sets requirements at two levels - lower and upper tier - depending on the quantity of dangerous substances handled or stored on the site.

4.2.1 All keepers of packed aerosol stock shall quantify the likely aggregate mass of hazardous materials present.

Guidance to 4.2.1

The warehouse operator must identify the maximum quantity of each dangerous substance that will be on the site at any one time either as a substance, in mixtures or in preparations. Schedule 1 of COMAH sets specific thresholds for over 50 named dangerous substances and general thresholds for the two tiers for 10 categories of dangerous substance as classified under the CHIP regulations.

If no dangerous substance is present in a quantity equal to or above one of the relevant thresholds, then the operator must use the prescribed formula to sum together all of the quantities of the various dangerous substances present. The calculation should be done for all substances (including the named ones) in three hazard groups:

• Toxic, very toxic or CMR category 1 or 2.

• Oxidising, explosive, flammable, highly flammable, extremely flammable.

• Dangerous for the environment.

For aerosols the principle hazard is the presence of flammable solvents and propellants, however other hazards need to be considered both on an individual basis and because their presence may make fire-fighting more complicated.

From the result of the sum it is possible to determine whether the warehouse will be an upper tier site, a lower tier site or an exempted (sub-COMAH) site. COMAH 2005 amends Schedule 1 by extending the list of named dangerous substances, revising some of the thresholds and clarifying the prescribed calculation. Aerosol propellants such as DME, propane and butane are classed as ‘liquefied extremely flammable gases’ and are a named substance in Part 2 of Schedule 1 of COMAH. Therefore if the propellants are the only source of flammable substances, then the thresholds of 50 tonnes (lower tier) and 200 tonnes (upper tier) apply to the warehouse. An important point to remember when determining whether an aerosol warehouse is subject to the COMAH regulations is that often aerosols are not the only goods containing dangerous substances stored in the warehouse.

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If the amount of propellant is below the COMAH threshold, hazards from other chemicals used in the product formulation will also need to be considered and the prescribed calculation performed. For example ethanol, a solvent used in many aerosols, is flammable but has thresholds of 5,000 tonnes (lower tier) and 50,000 tonnes (upper tier). Information from suppliers (e.g. product safety data sheets) should be used in order to identify the amount of hazardous materials present in each aerosol. The warehouse operator can then use this information to calculate the total quantity of hazardous materials likely to be present on the site at any one time.

The liquefied extremely flammable gas content of aerosols varies from less than 5% to over 95% and the liquid contents of an aerosol can be up to 750 ml. It is therefore difficult to give precise guidance on how many pallet loads of aerosols are needed for a warehouse to become a COMAH site. However, as a rough guide, for an aerosol with contents >50% of liquefied extremely flammable gas, a warehouse storing 200 pallets of aerosols might be a lower tier COMAH site and 800 pallets might be a top tier COMAH site. It is therefore essential to obtain reliable information from suppliers (e.g. product safety data sheets) in order to quantify the dangerous substances present in each aerosol type stored. It should also be noted that planning consent might be needed for storing about 100 pallets of aerosols.

4.2.2 Keepers of aerosols shall document, in a MAPP, the policies implemented to comply with their obligations under COMAH.

Guidance to 4.2.2

For a lower tier COMAH site, the operator is required to:

• Notify the competent authorities that dangerous substances are handled or stored.

• Prepare, document and implement a major accident prevention policy (MAPP).

• Demonstrate to the Competent Authorities that all measures have been implemented.

• Provide Competent Authorities with specified information upon request.

In addition top tier COMAH site operators are required to:

• Prepare, test and review on- and off-site emergency plans.

• Submit, and keep up to date, a safety report covering the major hazards on the site, the implementation of the MAPP and the emergency plans.

• Send specified information about the operation and safety measures to people in the local area and also make it available to the general public.

4.2.3 In the case of retail warehouses the supplier shall be responsible for providing information to enable the warehouse operator to comply with the provisions of requirements 4.2.1 and 4.2.2.

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5. General Safety

Guidance to 5

The regulations covering the manufacture and transport of aerosols require that every aerosol is subjected to an integrity test. This can be the Hot Water Bath test after filling or, a combination of Quality Assurance systems and micro-leak detections that ensures that leaking aerosols do not leave the filler. Product safety considerations also require the selection of containers and components that are compatible with the contents under the expected conditions of storage. These safeguards mean that undamaged aerosols are unlikely to leak and cause a fire if stored in accordance with the requirements set out in this Guide. However, because of their contents, if pierced or damaged, aerosols will release their contents and, if these are flammable, there will be a risk of ignition. Because aerosols containing flammable material may produce a fierce fire, care is needed in the design of warehouses to install measures to prevent and control fire. A detailed discussion of the design of aerosol warehouses is presented in Annex A of this Guide.

Regulations, such as Management of Health and Safety at Work (MHSW), Control of Substances Hazardous to Health (COSHH), Control of Major Accident Hazards (COMAH) and the Dangerous Substances and Explosive Atmospheres (DSEAR), mean that it is important to be able to demonstrate that all of the hazards that could arise from a warehousing operation have been considered and that all steps have been taken to ensure that the risk of those hazards occurring is reduced to an acceptable level. This Guide provides information about the specific hazards of storing aerosols to be considered when carrying out the risk assessment of the operation as required by DSEAR and suggests suitable controls that could be used.

The central activity for achieving this is the Risk Assessment. Whilst risk assessments are required for all work activities, the storage of aerosols introduces special hazards that require specific actions. A good risk assessment will enable the warehouse to be designed effectively and for controls to address any risks of storing aerosols to be defined, documented, resourced and communicated to staff. The documentation of the risk assessment should identify the individual roles, responsibilities and authorities needed for the implementation of the health and safety management system.

The risk assessment should be reviewed periodically to ensure that it remains valid and the appropriate risk controls are identified. Systems and procedures for the management of risk associated with aerosol storage should be subject to a regular programme of monitoring and review. Relevant additional risk management advice may be obtained from fire insurers, fire safety professionals, health & safety practitioners, HSE, trade associations and aerosol suppliers. A list of such publications is included in the Bibliography.

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5.1 Security 5.1.1 The warehouse shall have security (e.g. fencing) that is adequate to guard against intruders on to the site to prevent the threat of malicious fire raising (i.e. arson).

Guidance to 5.1.1

Fencing should be sufficiently high as to guard against missiles being thrown onto the site. Access to the site should be via a security checkpoint or some other form of access control. Ideally the site should have routine security patrols or closed circuit television surveillance operating outside of operating hours.

5.2 No Smoking Policy

Guidance to 5.2

Smoking in warehouses gives rise to major fire hazards.

5.2.1 Smoking shall be strictly prohibited at all times with enforcement notices displayed to remind staff and visitors.

Best Practice

5.2.2 Receptacles should be placed at all entrances to the warehouse for the disposal or storage of smoking materials.

5.2.3 An external smoking area should be designated where staff and visitors may smoke without creating a fire hazard.

5.3 Fire detection

5.3.1 Measures shall be provided for detecting a fire.

5.3.2 Measures shall be provided for raising an alarm in the event that fire is detected.

Guidance to 5.3.2

The alarm should alert all persons, including disabled or sensory impaired persons, to the danger.

5.3.3 Fire detection and alarm systems shall be subject to a specified regular test and maintenance programme.

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5.4 Means of Escape

5.4.1 Measures shall be provided for the safe evacuation of all buildings in the event of fire.

5.4.2 Emergency and fire exit routes shall be clearly signed.

5.4.3 Clear access to, from and along emergency and fire exit routes shall be maintained at all times.

5.4.4 No emergency door shall be locked in a way which prevents immediate exit from the hazardous side.

5.4.5 Pedestrian evacuation routes shall be given priority over vehicle routes and storage of materials and finished goods.

5.5 Fire Fighting Guidance to 5.5

In-house fire fighting teams should not be encouraged to fight aerosol fires. Instead attention should be given to protecting exit routes for personnel and providing facilities for the fire brigade to use in the event of an aerosol fire. However, in order to reduce losses in the event of a fire many insurers require that equipment and measures be provided for fighting fires in warehouses.

5.5.1 Priority routes shall be maintained through the site for access by the emergency services.

5.5.2 Measures shall be provided for fighting fires.

Guidance to 5.5.2

It is important to install the appropriate type of fire fighting equipment (e.g. sprinklers, extinguishers, etc.) for the products stored (for more information on fire fighting equipment see Annex A.2).

5.5.3 All fire fighting equipment (including sprinklers, extinguishers, etc.) shall be tested and maintained according to a specified regular test programme.

Best Practice

5.5.4 A sprinkler system should be installed in the storage area.

5.5.5 Any sprinkler system should be designed in accordance with locally recognised codes of practice and in conjunction with the local fire prevention officer and building insurers.

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Best Practice

5.5.6 Two independent water sources should be provided which are capable of delivering the maximum fire water demand for a minimum of about 2 hours.

Guidance to 5.5.6

The water sources should be independent at time of need, therefore a suitably sized storage tank filled from the mains and the mains supply would be acceptable as long as the storage tank is kept full. An alternative is to have permission to use an adjacent canal or river as a back-up in case the mains supply fails.

5.5.7 Water used in the event of a fire shall be retained so that it does not constitute a threat to the environment.

Guidance to 5.5.7

Care should be taken when designing the warehouse to ensure that water used to control a fire emergency does not turn into an environmental disaster (see also Annex A.4). This requirement is particularly important for upper tier COMAH sites (see 4.2) where the regulations specifically require containment systems to be employed.

5.5.8 Where a trained fire fighting team exists, they shall have equipment, protective clothing and training to keep themselves safe whilst engaged in an emergency response.

Guidance to 5.5.8

The primary function of a fire fighting team should always be the preservation of life – especially their own. There should be a procedure in place to ensure that either the fire fighting team is fully manned at all times or are trained for operating with depleted numbers. In the event of a fire involving aerosols, in-house fire fighting teams should not fight the fire; instead they should focus on protecting exit routes for personnel and providing facilities for the fire brigade to use.

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5.6 Contact with the Fire Services

Guidance to 5.6

Emergency plans should be drawn up in consultation with the local community, local authority and local fire service. For some warehouses this is a legal requirement under COMAH (see Section 4.2). The plan should also cover press management, contacts with next of kin and business recovery.

The information provided should include:

• Layout of premises e.g. a site map or building plan

• Type, quantity and hazards of material stored

• Location and type of fire fighting equipment

• Whom to contact in an emergency.

This plan needs to be readily accessible at all times and the fire service should be informed of any significant changes to the building, its contents or its use. This is particularly important if the warehouse has a fire certificate.

BAMA recommends emergency planning for all warehouses storing aerosols. Further details on developing an emergency plan for a site handling aerosols see the BAMA guide – Emergency Planning..

5.6.1 In the event of fire, procedures for contacting the local fire service shall be implemented immediately.

5.6.2 All the information necessary to react to an emergency situation shall be provided to the fire service.

5.6.3 The fire service shall be notified of any significant change to the building, its contents or its use.

Guidance to 5.6.3

This is particularly important if the warehouse is covered by the Planning Consent Regulations (see 4.1.2).

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6. Control of Hazards in the Storage Area

Guidance to 6

As described previously (Guidance to 5), controls in the manufacturing process reduce the risk of aerosols spontaneously bursting in storage. However, since the majority of aerosols contain extremely flammable gas propellants and flammable liquids (some of which may not be miscible with water). DSEAR requires that a risk assessment is carried out to identify measures that must be implemented to minimise the risk of fire or explosion.

The primary basis of safety in the warehouse should be prevention to avoid the development of a flammable atmosphere. Precautions should be taken by screening pallets on entry into the warehouse to ensure that aerosols are not leaking. This could be achieved using portable gas detectors whilst the pallets are confined in a transit vehicle en-route to the warehouse.

The secondary basis for safety is ensuring the storage area is sufficiently well-ventilated to prevent a flammable atmosphere developing if there is seepage over time. This is relatively easy to achieve in large well-ventilated warehouses but not in small confined areas where forced ventilation will be required to reduce the potential for the build-up of vapours.

General good ventilation can deal with seepage, but not incidents such as burst aerosols. In such cases the tertiary basis for safety is the elimination of ignition sources. Sensible precautions should therefore be taken for situations where a risk assessment identifies that such incidents could occur.

6.1 Design of Storage Area

Guidance to 6.1

Consideration should be given to whether it is necessary to separate flammable products from other hazardous products such as oxidising agents. A detailed discussion of the design of aerosol warehouses is given in Annex A.

6.1.1 Aerosols shall be stored in dry, well-ventilated warehouses and not in basements.

6.1.2 Localised heating of aerosols shall be avoided.

Guidance to 6.1.2

Aerosols should not be stored in direct sunlight or in localised hot spots, (as in a window, for example), near heaters, hot air vents or hot pipes.

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6.1.3 Racking shall be safe, stable, secure and designed to avoid accidental actuation of aerosols.

Guidance to 6.1.3

Consideration should be given to the racking including support bars to prevent pallets from 'spilling'. Accidental actuation can occur if aerosols are stacked so that pressure is applied to the top of aerosol resulting in activation of the valve.

Best Practice

6.1.4 If the warehouse is a large open plan building, the aerosol storage area should have wire mesh caging as a means to control rocketing aerosols from spreading the fire to stock in other parts of the warehouse.

Guidance to 6.1.4

Manual fire fighting for loss prevention purposes is made almost impossible if caging is not fitted, as the physical threat to fire fighters can be an unacceptable risk. Design advice for caging is given in Annex A.1.3.

6.1.5 Connecting doors in fire compartment walls shall be of a self-closing type held open with a fusible link or other ‘fail safe’ device which can operate in the absence of external power supplies and have a minimum fire resistance of 2 hours.

6.2 Ventilation Guidance to 6.2

As described in the Guidance to 5 controls in the manufacturing process will eliminate the risk of aerosols that are leaking or likely to spontaneously burst whilst in storage. However there is the possibility of slow seepage over time, and to prevent an explosive atmosphere developing, it is important to ensure that the storage area is sufficiently well-ventilated.

6.2.1 The ventilation in the warehouse shall be sufficient to prevent any build up of flammable gas due to slow seepage from stored aerosols.

Guidance to 6.2.1

This is relatively easy to achieve in large open warehouses with normal stock movements, however, in small confined areas, forced ventilation may be required to reduce the potential for the build-up of vapours.

Best Practice

6.2.2 If mechanical ventilation is used, e.g. long-term storage in enclosed premises, then devices warning of fan failure should be installed.

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6.3 Sources of Ignition Guidance to 6.

Although the manufacturing process will eliminate the risk of aerosols bursting in storage, it cannot prevent incidents occurring during handling that damage the aerosols causing them to leak. In such cases, the basis for safety is the elimination of ignition sources. Sensible precautions should therefore be taken for situations where a risk assessment identifies that such incidents could occur. In a warehouse, the main causes of such aerosol failures are:

• Puncture by truck forks or sharp objects.

• Being run over when loose on the floor.

• Falling from a height, e.g. high racking.

• Bursting as a result of heating.

The risk of aerosols being punctured and releasing flammable gases and/or vapours is greatest when manipulating packs outside their transport unit, i.e. a fully wrapped pallet. DSEAR (see 4.1.3) requires that if accidental release of significant quantities of a flammable gas/vapour is likely, procedures should be implemented or equipment installed that will eliminate the risk of ignition.

6.3.1 All potential sources of ignition shall be eliminated or strictly controlled.

Guidance to 6.3.1

Sources of ignition include, but are not restricted to:

• Hot surfaces or radiant heat.

• Smoking materials (e.g. cigarettes, matches, lighters, etc.).

• Sources of static electricity (e.g. flooring, clothes, mobile phones, etc.)

• Faulty electrical installations.

• Hot works, e.g. open flame cutting or welding.

• Faulty mechanical handling equipment.

• Friction caused by careless handling

Engineering work should be assessed for ignition risk, appropriate controls include written permits to work, limiting the extent of authorised work in scope, time and location, and specifying precautions to be observed by engineers and contractors and communicated to warehouse staff. Aerosols should be temporarily relocated or covered with fire-resistant material. Work on fire protection systems such as fire alarms and sprinklers, etc. should be notified to the insurers prior to commencement.

6.3.2 Electrical socket outlets and switches should be installed above 1m from the floor.

Guidance to 6.3.2

This is to prevent accidental damage by mechanical handling devices (e.g. fork lift trucks).

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6.4 Aerosol Storage Protocol

6.4.1 Aerosols shall be stacked in racks or block stacked.

Guidance to 6.4.1

Pallets and packs of aerosols should not be stored in aisles even on a temporary basis.

6.4.2 Pallets of stacked aerosols shall not be interleaved.

Guidance to 6.4.2

Interleaving of pallets in warehouses can result in collapse of the stack if a pallet is inadvertently moved from the storage in the wrong order. However it should be noted that interleaving collations on a pallet is recommended for maximum stability of the pallet.

6.4.3 The maximum height of block stacks of aerosols shall be 3 m.

Guidance to 6.4.3

Exceeding the maximum safe top-loading value for the bottom pallet in a stack may lead to collapse, distortion and/or accidental actuation of aerosols and a release of large quantities of flammable material.

The maximum stack height for storage purposes should always be calculated for each and every product and product variable. Parameters to take into account include cap strength and the type of packaging material used. For contract warehouse operations the supplier should provide advice on the maximum stack height for each product type.

The overall stacking height should also take account of the height, positioning and operation of the sprinkler system.

6.4.4 Block stacks of aerosols should not exceed 3 m in width and 10 m in length.

6.4.5 There shall be a minimum separation distance of 2 m between areas of block stacked aerosols.

Guidance to 6.4.5

This distance is the recommended minimum and insurance companies may require greater distances.

6.4.6 Empty pallets and other combustible materials shall be stored in an area separate from aerosols or other flammable products, preferably in another building.

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6.5 Goods In

Guidance to 6.5

It is recommended that where the warehouse operator receives deliveries or collections from foreign drivers, signs and notices that depict hazardous operations or control of risks should be multi-lingual and meet the current Health and Safety (Safety Signs and Signals) Regulations and the EC Directive on Safety Signs (92/58/EEC). To prevent breakdown in communications, key staff, including security, should hold certain documents that are written in the languages of the nationals employed. Examples include: No Smoking, No Naked Lights, Switch off Engine, Reversing not allowed, Emergency Procedures, etc.

6.5.1 Aerosols shall be examined for damage upon receipt.

Guidance to 6.5.1

Since the majority of aerosols contain extremely flammable gas propellants and flammable liquids (some of which may not be miscible with water), pallet loads should be visually inspected on entry into the warehouse to ensure that aerosols are not damaged. Signs to look for include cloudy wrapping, wet packs or strong smells of perfume.

Best Practice

6.5.2 Portable gas detectors should be used to inspect the aerosols on arrival at the warehouse whilst the pallets are confined in the transport vehicle.

6.5.3 Leaking or suspected leaking aerosols shall be dealt with according to the requirements of the Section 7.

Best Practice

6.5.4 Records of unsatisfactory deliveries should be made and the matter reported to the supplier for investigation.

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6.6 Internal Transport

6.6.1 Aerosols shall be stretch-wrapped securely onto pallets to minimise handling and to avoid falls of loose containers.

Guidance to 6.6.1

If stretch-wrapping is being undertaken within the aerosol warehouse, the machines should be firmly secured and maintained. Particular attention should be taken to ensure that all static electricity is eliminated and that control integrity is maintained and regularly checked.

6.6.2 The supplier shall be consulted about appropriate methods for distribution and suitable packaging for onward delivery into the supply chain.

Guidance to 6.6.2

Where pallets of aerosols are broken down at the warehouse into packages for onward delivery into the supply chain, the supplier should be consulted about the gauge of shrink-wrap and quality of trays used, and the protection of spray through caps from accidental actuation. Where pallet loads of aerosols are fully encapsulated in plastic stretch-wrap, it is possible that any propellant released if aerosols are damaged or accidentally actuated during transport could be trapped within the pallet load.

6.6.3 Before any pallet is broken down it shall be inspected for signs of damaged aerosols as described in 6.5.

6.6.4 The appropriate forklift and powered pallet trucks for use in the storage area shall be determined by the DSEAR risk assessment (4.1.3).

Guidance to 6.6.4

Fork tips should be rounded rather than sharp to minimise piercing of aerosols and clad in stainless steel to reduce the risk of sparks caused by friction between rust on the forks and aluminium can (thermite reaction).

6.6.5 Fork lift and pallet truck drivers shall be licensed to operate their trucks.

6.6.6 Staff using mechanical handling devices shall be trained to avoid damaging aerosols.

Guidance to 6.6.6

In particular, care should be exercised when locating forks in pallets. It is advisable that trucks should only carry one pallet at a time.

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6.6.7 Pallet conveyors (roller beds) used to transport pallets of aerosols shall have devices to prevent misaligned pallets falling off the rollers.

Guidance to 6.6.7

These may be in the form of raised flanges at the edges of rollers, or detection devices such as trip wires or beams to photoelectric cells (magic eyes). All automatic pallet handling machines should be risk assessed for possible causes of pack/aerosol damage.

6.6.8 Battery chargers used for forklift and pallet trucks shall be located and used in an area ruled safe by the DEASR risk assessment (4.1.3).

Guidance to 6.6.8

Battery-operated truck charging can give rise to incendiary sparks and hydrogen. Therefore truck charging points should be in an area remote from the aerosol storage area and assessed as safe.

Best Practice

6.6.9 Battery charging should occur in a separate building or in compartmentalised areas that are contained by 2-hour fire rated walls and doors activated by smoke detectors.

6.7 Housekeeping

6.7.1 Good standards of housekeeping shall be maintained at all times.

Guidance to 6.7.1

Minimum suggestions for regular inspections are:

• Daily inspection of fork lift trucks.

• Weekly inspection and test of fire sprinkler pumps and hydrants.

• Standards of housekeeping.

• Condition of pallets, pallet racking and shelving.

• Fire exits, signs and emergency lights.

• Fire extinguishers.

• Safety equipment (e.g. showers, eyewash bottles, spill control).

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6.7.2 All staff involved in the movement and storage of aerosols shall be trained about aerosol hazards.

Guidance to 6.7.2

All relevant staff including temporary staff should be trained in the correct handling techniques, emergency procedures and procedures for dealing with damaged or leaking stock. Engineering staff should also be instructed in the correct maintenance procedures and written permit systems. Contractors should be informed of the person with accountability for their safety.

6.7.3 Any aerosols loose on the floor shall be picked up immediately.

Guidance to 6.7.3

Any aerosols loose on the floor should be collected, inspected and if not damaged re-secured in storage. Damaged or leaking aerosols should be removed immediately to a safe, secure, well-ventilated place (preferably outdoors) for disposal as described in Section 7.

6.7.4 Empty pallets shall be stored in an area separate from the aerosols.

6.7.5 Combustible waste shall be removed without undue delay.

Best Practice

6.7.6 If long-term storage is necessary, especially for slow moving lines, stock should be inspected regularly for deterioration or leakage.

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7. Disposal of Aerosols

Guidance to 7

This Section provides some Requirements for the disposal of aerosols from warehouses; The BAMA Guide to the Disposal of Full and Part Full Aerosols should be consulted for more details on the disposal methods. BAMA recommends that suppliers provide a written procedure for the safe handling and disposal of aerosols from warehouse.

Damaged or leaking aerosols should be removed immediately to a safe secure well-ventilated place (in the open air preferably). In all cases, it will be necessary for a risk assessment of the nature of the hazard (i.e. flammable, toxic, harmful, corrosive, Dangerous to the Environment, etc.) and the quantity of aerosols involved to be performed by a competent person.

It is important to remember that under the ‘duty of care’ imposed by the waste regulations, the company producing the waste has the responsibility to check that any company or haulage contractor used to dispose of the waste has the appropriate waste handling licences. It is recommended that aerosol suppliers provide warehouse operators with a list of waste management companies that will dispose of full or part-full aerosols.

7.1 Leaking Aerosols 7.1.1 All leaking aerosols shall be placed in a well-ventilated area until all leakage has ceased and then disposed of appropriately.

Guidance to 7.1.1

For single leaking aerosols, one way of ascertaining that leakage has ceased is to measure the weight of the aerosol; if there is no change after 24 hours, then it is safe to assume that the aerosol has stopped leaking. Another possible method (depending upon the contents of the aerosol) is to immerse

the aerosol in cold water and look for bubbles (wear rubber gloves).

If the aerosol still contains product after leakage has ceased it should be disposed of through a licensed waste management company.

If the aerosol is completely empty then the container should be sent for recycling. If the manufacturer/marketer wants to retrieve the empty aerosol for further investigation, then a suitable company representative who can carry out a risk assessment to establish the best means of carrying the aerosol will collect it.

If it is not possible to deal with the leaking aerosol on site, then measures need to be taken to ensure that any risk associated with transporting leaking aerosols is controlled prior to carriage

continues…

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If aerosols within a pallet are found to be leaking then the following guidance should be followed:

• If the aerosols were damaged by a fork lift truck, the truck could be a source of ignition. The driver should immediately leave the truck for a safe place, assess the situation and act accordingly, if necessary activating an alarm.

• If it is safe to leave the pallet where it is, suspend normal working for a distance at floor level of 5 metres either side of the pallet. Using a portable gas detector frequently check the atmosphere around the pallet until the atmosphere is safe (i.e. the propellant gas concentration is less than 5% of the lower explosive limit). Move the pallet to a well-ventilated area for further inspection and appropriate disposal in appropriately.

• If it is not safe to leave the pallet where it is, then it must be moved to a well-ventilated area. It is important to move the pallet using a mechanical handling device that is not a potential source of ignition, for example, a non-powered hand pallet truck or hazard certified forklift truck. The route taken to remove the pallet must be checked to ensure that the leaking pallet will not pass any potential sources of ignition.

• If it is not possible to deal with the leaking aerosols on site, then they should be disposed of via a Waste Management Company licensed to accept Hazardous Waste.

7.2 Damaged – Not Leaking 7.2.1 Aerosols that are damaged but are not leaking shall be assessed for appropriate disposal.

Guidance to 7.2.1

Aerosols that have suffered minor damage and are not leaking could be repacked and sent back to the aerosol filler as ‘stock returned for examination’ under the normal transport provisions. Alternatively, they could be disposed of as hazardous waste. Waste aerosols should only be returned to suppliers who hold an appropriate waste handling licence.

7.3 Product Recall 7.3.1 Procedures shall be in place to deal with aerosols subjected to a product recall, product withdrawal or returned as out of date stock from the retailer.

Guidance to 7.3.1

If aerosols are subjected to a product recall, product withdrawal or returned as out of date stock from the retailer, the warehouse is likely to be involved in some way. BAMA recommends that, as part of the business contract between the companies, suppliers of aerosols agree written procedures with the warehouse for the packaging and return of aerosols for ‘examination’ or for disposal as waste aerosols . Further advice is given in the BAMA Guide –Product Recalls and Consumer returns.

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Bibliography

Chemical Agents Directive - CAD (98/24/EC)

Explosive Atmospheres Directive - ATEX 95 (94/9/EC)

Explosive Atmospheres Directive - ATEX 137 (99/92/EC)

Control of Major-accident Hazards Directive -Seveso II (96/82/EC)

Control of Major-accident Hazards Directive -Seveso III (2003/105/EC

Safety Signs Directive (92/58/EEC)

Environmental Protection Act 1990

Environment Act 1995

Fire Precautions Act 1971

Health and Safety at Work (HSWA) Act 1974

Town and Country Planning Act 1990

Carriage of Dangerous Goods and Use of Transportable Pressure Receptacles Regulations 2007 (SI 2007 No 1573)

Control of Major Accident Hazards Regulations 1999 (SI 1999 No 743)

Control of Major Accident Hazards (Amendment) Regulations 2005 (SI 2005 No 1088)

Control of Substances Hazardous to Health (COSHH) Regulations 2002 (SI 2002 No 2677)

Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR) (SI 2002 No. 2776)

Hazardous Waste (England) Regulations 2005 (SI 2005 No.814)

Management of Health & Safety at Work Regulations 1999 (SI 1999 No 3242)

Notification of Installations Handling Hazardous Substances Regulations 1982 (SI 1982 No. 1357)

Planning (Control of Major-Accident Hazards) Regulations 1999 (SI 1999 No981)

Planning (Hazardous Substances) Regulation 1992 (SI 1992 No 656)

Regulatory Reform (Fire Safety) Order 2005 (SI 2005 No 1541)

The Health and Safety (Safety Signs and Signals) Regulations 1996 (SI 1996 No. 341)

National Fire Protection Association Code (NFPA) 30B

Factory Mutual Global Operating Standards 7-31: Storage of Aerosols

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The following are available from The Fire Protection Association, London Road, Morton in Marsh, Glos., GL56 0RH – www.thefpa.co.uk

Recommendations for Fire Safety in Warehouses. RC18 LPC 1999

Recommendations for the Storage of Aerosol Products. RC19: FPA 2004

LPC Rules for Automatic Sprinkler Installations: Technical Bulletin 216:2003: Sprinkler Protection of Aerosols

The following relevant publications are available from BAMA:

BAMA Guide: The Disposal of Full or Part Full Aerosols

BAMA Guide to Retail Storage and Display of Aerosols

BAMA Product Recall Guide

The BAMA Standard for Consumer Safety and Good Manufacturing Practice

The following publications are available from HSE Books, PO Box 1999, Sudbury, Suffolk, CO10 2WA, tel: 01787 881165 or from www.hsebooks.com/Books :

HS(G) 65 Successful Health and Safety Management (Revised 1997)

HS(G) 71 Chemical Warehousing – The Storage of Packaged Dangerous Goods (Revised 2008)

L134 Design of plant, equipment and workplaces ISBN 0 7176 2199 5

L135 Storage of Dangerous Substances ISBN 0 7176 2200 2

L136 Control and mitigation measures ISBN 0 7176 2201 0

L137 Safe maintenance, repair and cleaning procedures ISBN 0 7176 2202 9

L138 Dangerous Substance and Explosive Atmospheres Approved Code of Practice and Guidance ISBN 7 7176 2203 7

Fire and Explosion – how safe is your workplace? INDG 370. Single copies are free.

The European Commission has a guidance document for implementing ATEX 137. The reference number is COM (2003) 515 final. It can be obtained from the Europa web site at: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2003:0515:FIN:EN:PDF.

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http://www.thefpa.co.uk/

http://www.hsebooks.com/Books%20%20:

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2003:0515:FIN:EN:PDF

Warehousing

Annex A

Design Considerations for Aerosol Storage

This Annex aims to give the principles on which warehouses containing aerosols should be designed. It does not aim to be prescriptive but to give general points to consider.

A.1 Protection of Stock In practice, the protection of stock in a warehouse will involve a combination of the methods described. The protection measures should take account of all the hazards, not just those relating to aerosols which are present on the site.

A.1.1 Segregation This is where a clear space in all directions segregates aerosols from other products and packaging, empty pallets, etc. by a clear space in all directions. The distance from the other products will depend on the nature of those products. For example, the storage of flammable aerosols near oxidising substances is particularly hazardous and adequate separation needs to be provided. The factors that need to be considered are:

• Radiant heating - Burning empty pallets will produce intense heat, which will cause exposed aerosols to burst.

• Flammable liquids - will flow taking the fire with them. The segregation distance will depend on the number and quantity of flammable liquids stored.

• Fragile products - Those products that could be damaged by rocketing or bursting aerosols should be relocated so that they are not in the direct line of sight of stored aerosols.

A.1.2 Fire Separation and Compartmentation Fire walls and separations have a specific fire rating, e.g. 2 or 4 hours. The rating used will depend on how easy and how quick it would be to extinguish a fire. It is important to ensure that fire doors and shutters used are the same rating as the rest of the wall because the structure will fail at its weakest point. Prolonged exposure to rocketing aerosols may cause fire shutters to become distorted and damaged leading to early failure. The size of any compartment will depend on the value of the compartment's contents and its rebuild cost. Most insurance companies have a limit on this combined value.

A.1.3 Wire Mesh (Caging) Where aerosols cannot be segregated from other stock, wire mesh caging is recommended around aerosol storage, so far as is practical, to limit rocketing aerosols in a fire. Open mesh caging should be used, as it will allow water to be directed through the mesh at the fire. Manual fire fighting for loss prevention purposes is made almost impossible if caging is not fitted, as the physical threat to fire fighters can be an unacceptable risk. The wire used should be at least 2 mm thick and the mesh size should not exceed 25 mm by 25 mm. Small numbers of aerosols could be stored in meshed bins of similar construction. When designing mesh cages all sides should be covered, so far as is practical with doors that are kept shut when the storage area is not being accessed. Consideration should also be given to installing devices to shut the cage doors automatically in case of a fire anywhere in the warehouse. Fire barriers within racks will also help to prevent rocketing aerosols.

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A.2 Methods for Controlling Fire

A2.1 Hose Pipes Provision should be made to provide adequate fire water for the local fire brigade or in-house fire fighting team (if one exists). Water for fire fighting should be supplied by two independent water sources and should be capable of delivering the maximum water needed to fight the ‘worse-case’ fire determined by a risk assessment for a minimum of about 2 hours. It is recommended that water is supplied by either a hydrant, ideally forming part of a ring main system, or by a static or natural water supply capable of delivering as a minimum 67,500 litres. Hydrant outlets should be situated no more than 70 m and no less than 6 m from the site of the risk; they should be outside the warehousing and adjacent to roadways or hard standing for fire appliances.

The water sources should be independent at time of need, therefore a suitably sized storage tank filled from the mains and the mains supply would be acceptable as long as the storage tank is kept full. An alternative is to have permission to use an adjacent canal or river as a back-up in case the mains supply fails.

Installed hose reels are not recommended because of difficulties with ensuring the correct water pressure and potential health problems; cases have also been reported of the Legionella bacteria being found in the water in the hose.

A.2.2 Sprinklers Sprinklers are best suited for fire suppression rather than fire fighting. If sprinklers are to be used, their design will depend on the following questions:

• Does the aerosol tend to burst or vent in a fire situation?

• Is the product miscible with water?

• How is the aerosol packaged - cartons or shrink-wrap?

• What types of pallets are used - wooden or plastic?

• Rack or palletised (block stack) storage?

• What are the structures inside the racks - are there solid shelves or fire barriers?

Sprinklers fall into two broad categories; ceiling sprinklers and in-rack sprinklers. Each of these can be subdivided into different types, in brief:

• Ceiling Sprinklers fall into many categories; different orifice of sprinkler head, early suppression fast response (ESFR); large drop sprinklers and fast response. All of these types give different water spray patterns and coverage areas (per sprinkler head).

• In-Rack Sprinklers have various arrangements of the sprinkler heads; in the flue space, on the face of the pallets, distance between heads and whether sprinklers will be positioned on every tier or not.

All sprinklers can be fitted with heads that operate at different temperatures, e.g. 65°C and 140°C or above. Specialist advice can be obtained from the Association of British Insurers, the Fire Protection Association, NFPA 30B or insurance companies.

Water supplies are critical to sprinklers working and need to be separate to water supplied for fire fighting. The water demand for different sprinklers varies widely, as does the pressure required at the sprinkler head. Another determining factor will be the design area and number of sprinklers assumed to be involved in the fire. In most cases, town mains water will not have enough pressure to supply sprinklers which means that fire pumps and other water sources will be required and consideration needs to be given to how the supply will be ensured for the duration of an incident.

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A.3 Smoke Vents Smoke venting systems help prevent smoke build up and can be installed in warehouses for both life and property protection purposes. The local fire brigade sometimes requires them. However, for sprinkler protected warehouses, smoke vents can interfere with the operation of the sprinklers and so it is important to get expert advice if both systems are present.

A.4 Environmental Issues Water used to fight or suppress a fire should be retained so that it does not constitute a threat to the environment. Care should be taken when designing the warehouse to consider the use of bunds and interceptor drains to ensure that water used to control a fire emergency does not in turn create an environmental problem. This is particularly important for upper tier COMAH sites where the regulations specifically require containment systems to be employed.

Sites storing aerosols containing ingredients which could significantly damage the environment should consider total firewater retention. For example substances which are labelled: R50 - ‘Very toxic to aquatic organisms’; R51 - ‘Toxic to aquatic organisms’; R53 - ‘May cause long term adverse effects in the aquatic environment; R58 - ‘May cause long term adverse effects in the environment’. Warehouse operators should note it is not only substances in their pure form which will give concern but also the products which are formed when the pure substance is subjected to fire.

Warehousing

Annex B

Framework Risk Assessment for the Warehousing of Aerosols

RISK ASSESSMENT CONTROL MEASURES

Step Hazard or Problem Cause of Hazard Consequences of No Action General Safety Measures Additional Notes

RECEIPT OF DELIVERY

1 Unloading product from delivery vehicle.

Leaking aerosols in the truck.

Aerosols damaged in transit.

Accumulation of flammable gases/vapours in truck.

Staff training. Check the load, do not offload if any damage or product leakage evident. Procedures to dispose of damaged or leaking aerosols.

Quality controls at dispatch and in manufacturing will prevent leaking aerosols being loaded into the truck by the consignor.


Aerosols punctured by Fork Lift Truck (FLT) forks.

Poor driving of FLT or difficult operating conditions, e.g. sloping dock levellers, badly stacked pallets, or movement during transport.

Temporary cloud of flammable gas/vapour around damaged aerosols.

Driver trained to recognise hazard and drive carefully. Ensure suitable material for forks if aluminium aerosols transported, to prevent thermite reaction.

Friction between aluminium and other metals may generate localised high temperatures sufficient to ignite aerosol contents.


Crushing of loose aerosols on floor of truck.

Damage to pallets during transit.

Aerosols run over and crushed by FLT resulting the release of flammable gas/vapour.

Driver trained to recognise hazard and to pick up any loose aerosols.

Consignors must ensure that the product transport packs are robust.

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Aerosols fall off the pallet whilst it is being moved.

Movement of insufficiently secured load.

Aerosols fall to the floor and are damaged either by impact with floor or by pallet disintegrating and loose aerosols being run over by vehicles. Both cases resulting in the release of flammable gas/vapour.

Driver trained to recognise hazard. Check pallet, pick up loose aerosol and, if necessary, re-secure aerosols on the pallet before moving it.

5 Check for damaged stock.

Leaking aerosols. Faulty stock delivered. Accumulation of flammable gas/vapour.

Staff training. Check the stock for evidence of any damage or product leakage evident. Procedures to dispose of damaged or leaking aerosols.

Quality controls at dispatch and in manufacturing will prevent leaking aerosols being sent by the consignor.

STORAGE

6 Putting pallet away in block stack.

Aerosols fall off pallet whilst it is being moved.

Jerky movement of insufficiently secured load.

Aerosols on the floor being run over and crushed by vehicles resulting in the release of flammable gas/vapour.

Driver trained to recognise hazard. Check pallet, pick up loose aerosol and if necessary re-secure aerosols on the pallet before moving it.

7 Putting pallet away in block stack.

Collapse of stack. Stacking too high. Unstable stacking.

Aerosols fall to the floor and are damaged either by impact with the floor or by pallet disintegrating and loose aerosols being run over by vehicles. Both cases resulting in the release of flammable gas/vapour.

Limit to single stacking unless specified by supplier.

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8 Putting pallet away in racking.

Collapse of rack beam. Racking insecure. Aerosols fall to the floor and are damaged either by impact with the floor or by pallet disintegrating and loose aerosols being run over by vehicles. Both cases resulting in the release of flammable gas/vapour.

Maintenance of safe racking.

9 Putting pallet away in racking.

Collapse of pallet. Pallet not placed securely in racking.


Safe system of racking. FLT driver training and licensing and eyesight checks for drivers.

10 Storage in block stack.

Collapse of stack. Stacking too high. Collapse of aerosol package.



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11 Storage. Leaking Aerosols. Faulty stock delivered. Accumulation of flammable gas/vapour.

Good natural ventilation, no basements. Mechanical ventilation if required.

Manufacturers test all aerosols for leakage before dispatch. Air changes provided for operator comfort will be adequate to dissipate gas from slowly leaking aerosols.

12 Storage. Leaking Aerosols. Internal corrosion. Accumulation of flammable gas/vapour.

Staff trained to recognise signs of can corrosion hazard. Housekeeping checks. Regular checks and disposal of products at or beyond shelf life.

Manufacturers design and manufacture products to a specified shelf life.

13 Storage. Leaking Aerosols. Accidental actuation due to weight of pallets above.

Accumulation of flammable gas/vapour.


Design and manufacturing quality controls ensure that aerosols are safely stacked.

14 Storage. Leaking Aerosols. Aerosols damaged by handling equipment.


Safe system of handling. FLT driver training and eyesight checks for drivers.

15 Storage. Leaking Aerosols. Aerosols bursting due to exposure to temperatures >55°C.


Store aerosols away from heaters and direct sunlight.

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RETRIEVAL

16 Removal from storage location.

Aerosols punctured by Fork Lift Truck forks.

Inaccurate placing of forks stabbing aerosols.

Temporary cloud of flammable gas/vapour around damaged aerosols.

Driver trained to recognise hazard. Ensure suitable material for forks if aluminium cans transported, to prevent thermite reaction.

Friction between aluminium and other metals may generate localised high temperatures sufficient to ignite aerosol contents.

17 Removal from racking.

Pallet dropped. Pallet not picked up properly.

Pallet disintegrates and loose aerosols are run over by vehicles or aerosols are damaged by impact with floor, etc. Both cases resulting in the release of flammable gas/vapour.

Safe system of racking. FLT driver training and eyesight checks for drivers.

18 Order Picking. Loose aerosols on floor. Pack dropped. Aerosols on the floor being run over and crushed by vehicles resulting in the release of flammable gas/vapour.

Picker trained to recognise hazard. Pick up loose aerosols immediately. Behaviour reinforced by housekeeping checks.

Aerosols in closed transit packs should not easily escape and roll across the floor.

19 Palletisation of picked loads.

Leaking Aerosols. Aerosols damaged by faulty handling equipment.


Maintenance of equipment. Training of operators.

20 Palletisation of picked loads.

Loose aerosols on floor. Packs damaged by faulty handling equipment and aerosols fall to the floor.


Picker trained to recognise hazard. Pick up loose aerosols immediately. Behaviour reinforced by housekeeping checks.

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21 Loading of transport vehicle.

Aerosols fall off pallet whilst it is being moved.

Jerky movement of insufficiently secured load.


Driver trained to recognise hazard and pick up loose cans. Load securely palletised.

22 Returned or faulty stock.

Leaking Aerosols. Faulty aerosols in returned stock.


Staff training. Check the load, not off-load if any damage or product leakage evident. Procedures to dispose of damaged or leaking aerosols.

Inform customers they must not return leaking aerosols.

DESIGN AND MANAGEMENT OF WAREHOUSE

23 Storage. Deliberate fire. Arson. Personal Injury or Property Damage.

Security of the site. Alarm system linked to emergency services.

24 Storage. Fuel available to fire. Storage of empty pallets and packaging.

Spread of fire to aerosols. Store empty pallets and packaging away from other goods.

25 Battery charging.

Generation of Hydrogen and Oxygen.

Battery charging. Source of Ignition. Battery charging to be kept away from storage or done in a well ventilated area.

26 Storage. Movement of fire between building compartments.

Openings in building. Spread of fire. Openings fitted with self closing fire doors.

27 Storage. Uncontrolled spread. Fire. Loss of complete facility and stock. Alarm system linked to emergency services. Tested regularly.

37 Issue 3

38 Issue 3

Warehousing



28 Storage. People in the vicinity of fire.

Fire. Injury of people. Identified Fire Exits, Evacuation Plan, Practise Evacuations.

29 Storage. Uncontrolled growth of incident and subsequent impact on business, people and neighbours.

Management, people and local services unprepared for incident.

Major disaster. Have an agreed Emergency Plan and ensure management, staff and local services understand their part. Carry out fire risk assessment.

The Warehousing of Aerosols - SCRIP · 2019. 7. 4. · Warehousing Introduction Storage of filled...

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