Test certification

1. Test certification What’s it all about?

2. HSNO Act Hazardous Substances (Classes 1-5 Controls) regulations Hazardous Substances (Classes 6-9 Controls) regulations Specify requirements for: Hazardous Substance Locations Approved Handlers

3. Hazardous Substance Locations • Commonly referred to as ‘DG stores’ • Required to establish HSL when threshold quantities set in legislation exceeded for Classes: 1, 2, 3, 4 and 5 • Thresholds vary by HSNO Class and Category • HSLs need to be issued ‘Location Test Certificate’ by Test Certifier • HSLs are NOT Exempt Laboratories • HSL not currently required for Classes 6, 8 and 9

4. Location Test Certification • Carried out annually by ‘Test Certifier’ • Design/Structural issues; • Fire rating of walls, ceilings, doors • Bunding (secondary containment) • Ventilation • Electrical systems/Hazardous atmosphere zoning • Security • Signage • Operational aspects: • Housekeeping (esp. Build up combustible materials) • Segregation of incompatible substances • Decanting practices • Labelling • Emergency management

6. Common non-compliance issues in HSLs • Storage of incompatible substances. • Class 3 and 5 must be segregated. • organic acids (acetic, propanoic, formic) are flammable. • oxidizing/mineral acids – Nitric, Perchloric, Sulfuric – must not be stored with flammable solvents and acids. • Flammable solids must be segregated from flammable liquids. • Build up of combustible material in stores – polystyrene, cardboard. • Deteriorating containers. • Emergency preparedness – spill kits and procedures, earthquake restraints, fire extinguishers, eye wash facilities. • Decanting procedures.

7. Decanting of solvents • Decanting operations will release flammable vapours. • Unlikely to generate hazardous atmosphere in store as a whole BUT • Potential for flash-fire. • Control of static discharges important. • Recently emptied containers may be full of saturated air/vapour mix. • Some solvent vapours are toxic (including chronic toxicity). • Some solvents irritating or even corrosive to eyes. • Consider emergency management.

8. Approved Handlers • Required when threshold quantities set in legislation exceeded for Classes 1, 2, 3, 4, 5, 6.1, 6.7, 8.2 and 9.1-9.4. • Where class/quantity thresholds exceeded – work must be carried out by or under supervision of approved Handler • Approved Handler certificate issued by Test Certifier • must meet he Skill and Knowledge requirements specified in Hazardous Substance (Personnel qualifications) regulations, 2001. • Not required in Exempt Laboratories • But is usually required for; • HSLs (not exempt labs) • May also be required for; • Transporting substances in vehicles

9. Supervision – what the law says: “Regulation 56 (2) Class 2, 3, and 4 substances required to be under the personal control of an approved handler may however be handled by a person who is not an approved handler if— (a) (b) the approved handler has provided guidance to the person in respect of the handling; and (c) the approved handler is available to provide assistance, if necessary, to the person at all times while the substance is being handled by the person.” My interpretation would be that the AH should be within earshot, or at least present in an immediately adjoining area (no phone contact in DG store). My advice would be to train all store users as Approved Handlers.

10. Approved Handler – Knowledge and skill requirements • ‘Theoretical’ – knowledge of: • Legislative background • Relevant codes of practice, group standards etc • Hazard classifications and adverse effects • Controls e.g. Segregation requirements • Emergency procedures • ‘Practical’ - ability to demonstrate: • working knowledge of any equipment used to handle the substances handled, e.g. PPE, earthing-cables, pumps).

11. Approved Handler Certificates – What are the responsibilities of the Test Certifier? Before issuing an AH certificate, Test certifier must be satisfied that handler meets the required knowledge and skill requirements. • Can do this by; • Assessing the knowledge and skill of the person themselves • Obtaining a written record from a work supervisor or course provider that states; • That the handler meets the required knowledge and skill requirements. • How this was assessed.

12. Our current service provider (Envirocom Ltd); • Takes responsibility for assessing the ‘theoretical’ knowledge requirements. • BUT • Requires a signed ‘Record of Competence’ from employer/manager/supervisor covering the ‘practical aspects’. • Use of PPE (gloves, eye protection, respirators etc) • Use of Equipment (earthing cables, pumps etc)

13. ‘Record of competence’ “This is to confirm that:____________________ has been additionally assessed as demonstrating knowledge of, and competence to operate the equipment and ppe associated with the substances handled in accordance with HSNO and the Health and Safety in Employment legislation through practical on-site demonstration to the employer, course provider or work supervisor, of safe work practices” Signed:___________________ Print Name:_________________ (Designation: Employer, Manager, Supervisor, Trainer – circle one) Signed:___________________ Print Name:__________________ (Employee) Company:___________________ __/__/20__

15. Common questions about Approved Handler Certification: I don’t have Class 5.1 listed on my certificate – does that mean I am not allowed to work with oxidizers? An AH certificate is not required if use is in an Exempt Lab or if under quantity limits specified in legislation. My certificate is about to/has expired – what do I do? Envirocom have on-line renewal system – contact me for advice on this. New in-house system to be developed (Wayne Temple has now been issued with Test Certifier status for the University)

16. Summary • Test certified HSLs established when class/quantity thresholds exceeded • Subject to annual certification • Not exempt labs • AH trigger thresholds will also usually be triggered in these areas, therefore should have Approved Handlers for store areas.. • AH can supervisor non-AH in store areas – but should be present or close-by (must be available to provide assistance at all times). • New in-house AH training system to be developed