6. Signage, labelling, hazardous chemical agents (HCA) register and disposal

Signage

At each entrance a full-sized primary hazard warning diamond as detailed in SANS 10232-1 must be displayed.  The class of hazard presented by the stored goods must be indicated.  Where more than one type of SANS 10228 class of goods is stored in the area a full size “multifold” warning diamond must be displayed.  

Symbolic safety signs must be displayed as necessary to comply with SANS 1186.  These shall include “no smoking”, “no naked flames”, “no fires”, positions and types of fire related equipment and protective clothing requirements. 

All openable panels in building walls shall be appropriately identified as well as first aid stations, other apparatus, and emergency exit routes.  

Warehouses must be marked to indicate which classes of goods are permitted to be stored in each area, and the floor area must be marked showing designated storage areas and traffic/escape/rescue routes.

          Labelling of hazardous containers

          Introduction

          It is vital that a label is fixed to a hazardous agent’s container.

                    Label requirements

                    The amount of information on a label will depend on the size of the container.  However, where the container is so small that the label cannot be placed on the actual container, the label can be attached by other means, for example, by a string round the neck of a test tube.   

                    Labels should be fixed to the container in colours that provide sufficient contrast to the background.  Lettering should be of a size and style that is clearly legible and in the English language.  

                    If an SDS has been amended by the manufacturer, the label should be changed to ensure that it contains the same information as the amended SDS.

                              Decanted hazardous agents

                              When a substance is decanted at work, the requirement for labelling will depend on whether the substance is used immediately or over a longer period of time.  

                              Where a hazardous agent is decanted to be used straight away, the container into which the hazardous agent has been decanted does not require labelling only if the container has been cleaned of any residue.  

                              The labels on the decanting containers should be used to provide information for the safe disposal of both the remaining hazardous agent and the container.  

                              If the container into which the hazardous agent is decanted is small, it may not provide sufficient room for label information.  In this case, attach the label to a supporting device or container.  

                              For example, in the case of a test tube, the label may be attached to the test tube rack.  Alternatively, a tag with the required label information may also be used.  

                              If a container label is damaged or defaced, obtain a replacement copy from the supplier.  If the label cannot be obtained, the information on the SDS should be used to produce a label for the container.

                                        Unlabelled containers / unknown agents

                                        If the container is not labelled and the contents of the container not known, the container should be marked as follows:

                                                  “CAUTION DO NOT USE: UNKNOWN AGENT”

                                                  A container of an unknown agent should be stored away from other agents where it cannot be used until its contents can be identified and the container appropriately labelled.  If the contents cannot be identified, they should be disposed of following consultation with the relevant Local Authority.

                                                            Hazardous agents in enclosed systems

                                                            Mark enclosed systems such as piping, conduits and ducts by signs designed in accordance with appropriate standards and other requirements.  

                                                            Colours, letters, and symbols on the sign should enable everyone (not only workers, but visitors such as emergency services personnel) to identify the contents easily.

                                                                      Working in a confined space

                                                                      Confined spaces potentially contain many hazards.  These hazards can include:  

                                                                      • Oxygen deficient atmospheres.  
                                                                      • Toxic atmospheres.  
                                                                      • Flammable or explosive atmospheres; and 
                                                                      • Engulfment

                                                                                Hazardous materials register

                                                                                Introduction

                                                                                Maintain a register of all hazardous materials.  Review the register at least annually.

                                                                                          Content of the register

                                                                                          The register should contain the following:  

                                                                                          • Material name.  
                                                                                          • HAZCHEM code. 
                                                                                          • SDS
                                                                                          • Summary of maximum inventory.
                                                                                          • Location.  
                                                                                          • Where they are used. 
                                                                                          • Approved method of disposal. 
                                                                                          • Storage requirements and precautions, and 
                                                                                          • Physical properties of materials where they are used.

                                                                                          The SHERQ Department should make the register available to the local emergency services.

                                                                                                    Disposal of HCA

                                                                                                    Introduction

                                                                                                    The disposal of hazardous agents is the responsibility of Local Authorities.

                                                                                                    For this reason, the majority of SDS’s do not give adequate instructions on disposal and generally state “disposal in accordance with local authority regulations” (or similar).

                                                                                                              Disposal procedure

                                                                                                              Disposal of hazardous agents is an issue closely monitored by Environmental Departments who have an overall responsibility for protection of the environment.  

                                                                                                              Because of the very strict environmental regulations in force and the urgent need to protect the environment, every hazardous agent, empty containers, and contaminated waste should be disposed of strictly in accordance with regulations.  

                                                                                                              As a minimum you may expect control to be accomplished by the collection of waste and removal from site by a licensed waste contractor.

                                                                                                                        Select at least 5 hazardous chemical agents used at your workplace and list current practice for disposal, including container and contaminated rags, etc.

                                                                                                                        Transportation of hazardous chemical agents

                                                                                                                        Introduction

                                                                                                                        In this part we are going to discuss at how hazardous chemicals can be safely transported.  

                                                                                                                        It is particularly important that hazardous agents are transported safely because such transport often takes place on public roads. 

                                                                                                                        This means that if there is an accident, members of the public are likely to be involved.

                                                                                                                                  Transport laws, systems, and codes

                                                                                                                                  The following transport laws, systems and codes pertain to HCA: 

                                                                                                                                  • National Road Traffic Act, Act 93 of 1996.  
                                                                                                                                  • Road Tanker Regulations.  
                                                                                                                                  • SANS Codes
                                                                                                                                      • SANS 10228: The identification and classification of dangerous agents and goods.
                                                                                                                                      • SANS 10229: Packaging of dangerous goods for road and rail transportation in South Africa.
                                                                                                                                      • SANS 10230 – 10232: Transportation of dangerous goods.

                                                                                                                                  The transportation of hazardous agents was previously governed by the Hazardous Substances Act, Act 15 of 1973, but was only applicable to substances in tankers holding 500 litres or more.  

                                                                                                                                  Chapter VIII of the National Road Traffic Act, Act 93 of 1996 was amended and as from August 2001 it became compulsory to comply with this Act.  Regulation 280 of the Act requires drivers transporting dangerous goods in bulk or packaged form in excess of the vehicles should be competent in terms of the Occupational Health and Safety Act, Act 85 of 1993.  

                                                                                                                                  The new legislation governs the transportation of dangerous goods and regulates packaged dangerous goods. 

                                                                                                                                   

                                                                                                                                            SANS codes

                                                                                                                                            Extensive provisions are further contained in the nine SANS specifications or codes of practice.  These codes are regulatory in terms of section 76 of the Act.  

                                                                                                                                            The nine SANS codes contain fine detail and cover the following subjects:  

                                                                                                                                            • Identification and classification of dangerous goods.  
                                                                                                                                            • Packaging of dangerous goods for road and rail transportation in SA.  
                                                                                                                                            • Intermediate bulk containers for dangerous agents.  
                                                                                                                                            • Road tank vehicles for petroleum-based flammable liquids.  
                                                                                                                                            • Transportation of dangerous goods.  

                                                                                                                                            The Regulations require the driver of dangerous goods to carry a Tremcard (Transport Emergency Card).

                                                                                                                                             

                                                                                                                                                      example of a Tremcard

                                                                                                                                                      Checklist for safe transport

                                                                                                                                                      • Is the substance packaged correctly?  
                                                                                                                                                      • Are substances compatible?  
                                                                                                                                                      • Are packages securely attached to the vehicle?  
                                                                                                                                                      • Are vehicles correctly labelled?  
                                                                                                                                                      • Is the vehicle roadworthy and maintained?  
                                                                                                                                                      • Have Tremcards been obtained?  
                                                                                                                                                      • Is the driver licensed, fit, and trained?  
                                                                                                                                                      • Has the route been pre-planned?  
                                                                                                                                                      • Have you informed local authorities en route?  
                                                                                                                                                      • Have arrangements been made for off-loading on arrival?  
                                                                                                                                                      • Are emergency plans and equipment in place?