Safety at Work 6 E Part 16 ppsx

The Control of Substances Hazardous to Health Regulations 2002, The Stationery Office, London 2002 2.. Health and Safety Executive, Legal Series Booklet No.. Health and Safety Commission

Managing chemicals safely 875

operation together with electromechanical control systems Where thecontrol equipment incorporates computers additional studies areneeded

A HAZOP study requires a multi-disciplinary approach by a teammade up of technical specialists, i.e chemical engineer, chemist, produc-tion manager, instrumentation engineer, safety adviser etc It is co-ordinated by a leader who guides the systematic investigation into theeffect of various faults that could occur The success of this study reliesheavily on the quality of the leader and the positive and constructiveattitude of the team members It is essential that the team have all thebasic data plus line diagrams, flow charts etc., and understand how aHAZOP study works

The HAZOP study breaks the flow diagram down into a series ofdiscrete units Various failure and fault conditions are then consideredusing a series of ‘guide words’ to structure the investigation of thevarious circumstances that could give rise to those faults Each deviationfor each guide word is considered in detail and team members areencouraged to think laterally and to ask questions especially about the

potential for causing a fault condition Table 4.7.1 shows how each of the

guide words can be interpreted to highlight possible deviations from

normal operation and Figure 4.7.5 shows a HAZOP report form that could

be used to record the findings of the study

In the example in Table 4.7.1, under the first guide word, ‘None’, we

could ask:

 What could cause no flow?

 How could the situation arise?

 What are the consequences of the no-flow situation?

 Are the consequences identified hazardous or do they prevent efficientoperation?

 If so, can we prevent no-flow (or protect against the consequences) bychanging the design or method of operation

Table 4.7.1 Showing typical interpretations of HAZOP guide words

Guide word Deviations

None No forward flow, no flow, reverse flow

More of Higher flow than design, higher temperature, pressure or viscosity etc.Less of Lower flow than design, lower temperature, pressure or viscosity etc.Part of Change in composition, change in ratio of components, component

missing

More than More components present in the system, extra phase, impurities

present (air, water, solids, corrosion products)

Other than What else can happen that is not part of the normal reaction, start-up

or shutdown problems, maintenance concerns, catalyst change etc

876 Safety at Work

HAZARD AND OPERABILITY STUDY

Step

Number/

Guide Word

Figure 4.7.5 Report from a HAZOP Study

Managing chemicals safely 877

 If so, does the size of the hazard (i.e severity of the consequencesmultiplied by the probability of the occurrence) justify the extraexpense?

Similar questions are applied to each the other guide words, and so on.Each time a component is studied the drawing or diagram should bemarked Not until all components have been studied can the HAZOPstudy be considered complete Where errors occur on the drawing ormore informations needed the drawing should be marked (using adifferent colour) and the points noted in the report

To be effective the team needs to think laterally and there should be nocriticism of other team members’ questions A strange or oblique questionmay spark off a train of investigation which could lead to theidentification of potentially serious fault conditions

A well-conducted HAZOP study should eliminate 80–85% of the majorhazards, thereby reducing the level of risk in the plant In safety criticalplant another HAZOP study, carried out when the detailed design hasbeen finalised, could increase the probability of safe operations

When the HAZOP study has been completed the necessary remedialactions should be agreed for implementation by the project or processmanager Records of the changes in the design should be kept and checksmade to ensure that the modifications have been carried out during theconstruction of the plant

With plant that is controlled by computer, the HAZOP study needs toinclude consideration of the effects of aberrant computer behaviour andthe team carrying out the study may need to be reinforced by the softwaredesigner plus an independent software engineer able to question thephilosophy of the installed software program A technique known asCHAZOP has been developed for such plant which also highlights thesafety critical control items

4.7.9.3 Plant control systems

Many small, simple, and relatively low hazard plants are fully manuallyoperated However, with more complex plant automated controls usingelectronic control systems are employed This does not necessarily make itsafe since faults can, unknowingly, be built into the controlling software

To achieve optimum levels of safe operation, computer software for plantcontrol systems should be devised jointly by the software specialist andthe production staff All operational requirements must be covered toensure that the software designer does not make assumptions whichcould result in faulty or even dangerous operation of the plant Thesoftware must be designed to accommodate plant failures and any testing

or checking necessary during or following maintenance

Before installing it, the computer program must be challenged in allpossible situations to ensure that it matches operational requirements.Any review of software should include an independent software engineerwho can challenge the philosophy behind the software All software

Control panels should not be provided with too many instrumentssince this can confuse the operator and prove counterproductive.However, sufficient instrumentation is needed to enable the operators toknow what is going on inside closed vessels, pipes, pumps etc Criticalalarms should be set into separate parts of control panel to highlight theirimportance This will reduce the potential for their being confused withothers, and possibly overlooked The tone of audible critical alarmsshould be different from that of process alarm systems to preventconfusion.

Computer-controlled plant will frequently have three levels of tional and safety control:

opera-Level 1: Will mostly focus on process control of the plant and give

indicative warnings of possible safety concerns when, forexample, a rapid temperature rise may trigger a warning panelindicator

Level 2: Control occurs when computer software initiates changes to

control reaction kinetics If a reaction temperature continues torise, the software would initiate the application of cooling water

to the vessel to regain control and continue production

Level 3: Is entirely a safety system when the process is out of control It

will rely on hard-wired trips that shut the plant down safely andabandon production The hard-wired trips work independently

of the computer system

There is no universal formula for control systems and a control strategymust be developed for each plant based on the operating parameters Asmall batch plant consisting of two chemical reactors having a mixture of

manual and automatic controls is shown in Figure 4.7.6.

4.7.9.4 Assessment of risk in existing plants

A review of existing chemical facilities should be undertaken to identifypossible faults and so avoid acute and/or catastrophic loss Theassessment should focus on ‘instantaneous failure prevention’ of plantsuch as:

 bulk oil or chemical storage facilities

 multi-chemical 200 litre drum store (especially if large-scale dispensing

is carried out)

 chemical processes or mixing facilities

 solvent recovery plant

A number of techniques have been developed to identify the hazardsand to assess the risks from plant and equipment These techniques rangefrom the relatively simple to the highly complex A number are described

in a BS EN standard50 Whichever technique is used it should beappropriate to the complexity of the plant and the materials involved.4.7.9.4.1 Simpler techniques

The simpler techniques are aimed primarily at determining a rankingorder of the risks from the chemical processes carried out in the area.They should clarify which facilities create insignificant risks and require

no further action The position statement for these facilities should recordthe reasons for this decision The simpler techniques include:

1 The ‘What-if method’ is the simplest method to assess chemical processsafety risks and is based on questions such as ‘What if the mechanical

or electrical integrity of the process, the control systems and workprocedures all fail, what consequences could arise in the worstcase?’ While the potential consequences are largely determined by theinherent hazard of the material and the quantity involved, the reviewer

is focused on safety concerns, e.g those arising from fire, explosion,toxic gas release, and environmental protection

2 The ‘Checklist method’ is a structured approach whereby the reviewerresponds to a predetermined list of questions This method is lessflexible than the ‘What-if method’ and its effectiveness relies on thestrengths and weaknesses of a predetermined checklist Examples ofchecklists can be found in chemical process safety literature

3 The ‘Dow-Mond Index’ is a more structured approach than theprevious two techniques and takes into account quantities and hazards

to arrive at a basic risk classification This method provides a level ofquantification of risk and considers the ‘off-setting’ factors which exist

to control intrinsic hazards

4.7.9.4.2 More complex techniques

Where the ranking process, described above, identifies facilities thatwarrant an assessment in greater depth, one of the techniques describedbelow should be used:

1 HAZOP study (see section 4.7.9.2.1)

2 Failure modes and effects analysis (FMEA) FMEA is an inductivemethod for evaluating the frequency and consequence of failures It

Managing chemicals safely 881

involves examining every component and considering all types offailure for each It can indicate generic components that may have apropensity to fail

3 Fault tree analysis (FTA)51FTA is a deductive method which starts byconsidering a particular fault or ‘top event’ and works backwards toform a tree of all the events and circumstances that could lead to thehappening of that top event By assessing the probability of eachindividual event, an estimate of the probability of the top eventoccurring can be obtained If that probability is unacceptable the majorcomponents contributing to it can easily be identified and a cost-effective replacement of them implemented This method lends itself toassessing the impact of changes in the system and has been useful indetermining the causes of accidents

4.7.9.5 Functional safety life cycle management (FSLCM) 52

FSLCM is a new technique designed to enable plant safety systems to bemanaged in a structured way The technique has been designed toaccommodate computer-controlled plants from start-up to shutdown,including emergency shutdowns It aims to ensure that the safety relatedsystems which protect and control equipment and plant are specified,engineered and operated to standards appropriate to the risks involved.The key concepts of this technique are:

(a) The safety life cycle – begins with a clear definition of the equipment

and processes for which functional safety is sought and by a series ofphases provides a logical path through commissioning, operation tofinal decommissioning

(b) Safety management – sets a checklist for the things that need to be in place in order to prepare for and manage each phase of the safety life cycle These are incorporated into a formal safety plan.

(c) Design of safety related systems – puts the design of safety related

control and protective systems into the overall context of the safeoperation of equipment or facilities It requires that such systems aredesigned to meet specific risk criteria

(d) Competencies – provides guidance on the appropriate skills and

knowledge required by those people who will be involved in thetechnique

By following a structured life cycle approach the hazards inherent in theoperation of equipment or processes can be clearly identified Thestandards to which protection is provided can be demonstrated in anobjective and constructive way

4.7.10 Further safety studies

Having carried out a HAZOP study on the plant and incorporated itsfindings into the design, it is prudent to carry out a further review during

882 Safety at Work

the commissioning period to check that the design modifications haveproduced the desired results This is necessary since the final details ofthe physical installation are often left to the installing engineers to decideand these could produce unforeseen hazards Finally, once the plant iscommissioned and operational there should be routine safety checkscarried out on a regular basis

4.7.11 Plant modifications

Plant modifications, even apparently simple ones, can have majorconsequential effects15 It is crucial that the plant is not modified withoutproper authorisation and, for safety critical parts, the completion of aHAZOP study of the possible effects of the proposed changes A ‘processchange form’ should be used which should include the reasons for thechange Use of such a form also ensures a degree of control on themodifications made, especially if it has to be sanctioned by a seniortechnical specialist such as a process engineer, safety adviser, productionmanager and maintenance manager There needs to be clear guidance as

to when the process change form has to be used so that there can be nomisunderstanding After the plant has been modified it may be necessary

to retrain the operators in the changed operation techniques

4.7.12 Safe systems of work

Since human beings are necessary in the operation of chemical plantsthere is always the likelihood of errors being made that could result inhazards It is, therefore, important that operators are trained in the safeway to run the plant Such training, based on safe systems of work,should include the carrying out of risk assessments Errors in operationand misunderstandings can be reduced if the system of work is inwriting

4.7.12.1 Instruction documentation

There should be detailed written operating instructions for everychemical plant which can conveniently be considered in three parts:

1 Operator’s instructions that give specific instructions on how to operate

the plant and handle the materials safely The instructions shouldcontain information on the process, quantities and types of materialsused, and any special instructions for dealing with spillages, leaks,emergencies and first aid The instructions should also containinformation on the expected temperatures, pressures and conditions,and provide information on the actions to be taken if they are exceeded,the type of PPE to be worn, a copy of the safety data sheet for each ofthe materials involved, techniques for taking samples and cleaninginstructions

Managing chemicals safely 883

2 Manufacturing procedures aimed at the operators and the supervisor in

charge of the plant should explain the process and provide a synopsis

of the chemical process undertaken The procedure should refer tolikely problems such as exotherms and give details of actions to take.The sequence of operations, quantities of materials used, temperatureand pressure ranges, methods for dealing with spillages and leaks,disposal of waste, etc., should be included

3 A process dossier should be compiled containing detailed informationabout the process, the plant and equipment design specifications andthe basis of safety for the process This document should be a majorreference source for the process engineer and be consulted and updatedwhenever a change is made

4.7.12.2 Training

Both operators and supervision should be trained in the techniques foroperating the plant, the process, materials used, their hazards andprecautions to be taken, emergency procedures and first aid The trainingcan be based on the content of the Operator Instructions and theManufacturing Procedures and should include a study of the safety datasheets The importance of following the safe methods of work and thereporting of any deviations from the stated operating parameters should

be emphasised

Staff should be made aware of the potential hazards that could beencountered in the process if mistakes were made For example, whatcould happen if:

 Equipment was not bonded to earth and a fire started

 Another chemical was mistakenly added

 The agitator had been stopped and restarted when it should have been

on all the time

 The reaction was allowed to get too hot and an exothermal reactiontook place

 The reaction got out of control and pressure developed resulting in atwo-phase emission

It is important that the operating staff are regularly re-trained in theoperating instructions and that they are briefed on any changes made

4.7.12.3 Permits-to-work

Permits-to-work are required where the work to be carried out issufficiently hazardous to demand strict control over both access and thework itself This can occur when maintenance and non-routine work isbeing carried out in a chemical plant or for any normal operation wherethe risks faced make clear and unequivocal instructions necessary for thesafety of the operators

884 Safety at Work

The essential elements of a permit to work are:

(a) The work to be carried out is described in detail and understood byboth the operators of the plant and those carrying out the work.(b) A full explanation is given to those carrying out the work of thehazards involved and the precautions to be taken

(c) The area in which the work is to be carried out is clearly identified,made as safe as possible and any residual hazards highlighted.(d) A competent, responsible and authorised person should specify thesafety measures, such as electrical isolation, pipes blanked off etc to

be taken on the plant, check that they have been implemented andsign a document confirming this and that it is safe for workmen toenter the area

(e) The individual workmen or supervisor in charge must sign the permit

to say they fully understand the work to be done, restrictions onaccess, the hazards involved and the precautions to be taken.(f) The permit must specify any monitoring to be carried out before,during and after the work and require the recording of the results.(g) When the work is complete, the workmen or supervisor must sign thepermit to confirm that the work is complete and it is safe to return theplant to operations

(h) A competent, responsible and authorised person must sign thepermit, cancelling it and releasing the plant back to operations.The format of a permit to work will be determined by the type of work

involved but a typical permit is shown in Figure 4.7.7.

Typical work requiring a permit to work includes hot work, entry intoconfined spaces, excavations, high voltage electrical work, work involv-ing toxic and hazardous chemicals etc For a permit to work to beeffective it is essential that all those involved understand the system, theprocedure and the importance of following the laid down procedure.Before the work starts all those concerned should be trained in the systemand their individual responsibilities emphasised

4.7.13 Laboratories

The use of chemicals in laboratories poses totally different problems fromthose met in a production facility The scale is much smaller, theequipment generally more fragile and, while the standard of containmentfor bench work is often less, the skill and knowledge of those performingthe reactions are very high

Work in quality control laboratories is normally repetitive using closelydefined analytical methods Research laboratories are far wider in thescope of the reactions they investigate, sometimes dealing with unknownhazards, and in the equipment they use The principal hazards met inlaboratories are fire, explosion, corrosion, and toxic attacks A limitshould be specified for the total amount of flammables allowed in alaboratory at any one time, which should be enough for the day’s workbut not exceed 50 litres

Managing chemicals safely 885

person requesting work

PART 2 SAFETY MEASURES

I hereby declare that the following steps have been taken to render the above

equipment/plant safe to work on:

Further, I recommend that as the work is carried out the following precautions are taken:

Note: After signing it, this Permit-to-Work must be retained by the person in charge of the work until the work is either completed or suspended and the Clearance section (Part 4) signed.

PART 4 CLEARANCE

I hereby declare that the work for which this Permit was issued is now completed/suspended* and that all those under my charge have been withdrawn and warned that it is no longer safe

to work on the equipment/plant and that all tools, gear, earthing connections are clear.

* delete word not applicable

PART 5 CANCELLATION

This Permit-to-Work is hereby cancelled

being a person authorized to cancel a Permit-to Work

886 Safety at Work

Hazardous and potentially hazardous reactions should be carried out

in a fume cupboard The effectiveness of the fume cupboard’s extractionshould be checked regularly in line with COSHH requirements The fumecupboard should not be used for extra storage space since this can reducethe efficiency of the extraction system A well-ordered and tidy fume

cupboard is shown in Figure 4.7.8.

Further measures that can improve laboratory safety include:

(a) Instituting a ‘peer review’ assessment by asking a competentcolleague to review the proposed reaction before allowing experi-ments to be carried out

(b) Regular checks of laboratory storage areas to ensure old stocks andout-of-date reactive chemicals (e.g chemicals which can degrade toform peroxides) are removed for disposal Only minimum inventories

of chemicals should be held

Figure 4.7.8 Well ordered fume cupboard (Courtesy British Sugar plc)

Managing chemicals safely 887

(c) Producing a laboratory safety manual and regularly training staff inits contents

(d) Providing spillage cleaning equipment and adequate training in itsuse

(e) Establishing safe waste disposal procedures

(f) Maintaining a high standard of housekeeping

(g) Not storing liquids at high level over the workbench

Laboratory safety is a very wide subject and there are a number ofpublications giving sound guidance53–55 Many of the larger chemicalmanufacuring companies produce their own practical guidance and arepleased to supply copies

4.7.14 Emergency procedures

The Management of Health and Safety at Work Regulations 1999(MHSWR)62 imposes on employers an explicit duty to have in placeeffective procedures to be followed in the event of serious or imminentdanger to people at work The COMAH Regulations also require affectedmanufacturers to prepare on-site emergency plans In addition, COMAHrequires employers to co-operate with the local authority in developingoff-site emergency plans (See the publication ‘Emergency Planning forMajor Accidents’61.) Irrespective of these statutory requirements it isprudent for every user and storer of hazardous substances to prepare anemergency plan to cover all reasonably foreseeable events such as fire,major spillage or toxic release The plans can be at two levels, one for theimmediate production or storage area and the second for the site as awhole taking account of the likely effects on the local community

It is very important that employees and the local emergency servicesknow exactly and unambiguously what to do should an incident occur.The Dangerous Substances (Notification and Marking of Sites) Regula-tions 199063require that the entrances to sites are labelled such that theemergency services have pre-warning that there are hazardous chemicals

on site Additionally, the Planning (Hazardous Substances) Regulations

199264 require notification to the local authority of the amounts ofhazardous substances held on site A clear drawing or sketch showing thelayout of the site should be available for the emergency services It shouldalso contain details of the buildings and highlight fire extinguishers,emergency exits, spillage control equipment, etc All employees should beproperly instructed, fully trained and rehearsed in those emergencyplans The local emergency services should be encouraged to familiarisethemselves with the site

Where there is a potential for a major emergency, which would involvethe local emergency services and local authority, there must be an agreedplan of action to co-ordinate all the services including managers andemployees on the site with their specialised knowledge of the site and itsprocesses The emergency plans should include a list of emergencycontacts including such bodies as the Fire Authority, Local Authority

4.7.15 Conclusions

This chapter has summarised some of the health, safety and tal problems posed by the use of chemicals A systematic review has beenapplied in an attempt to clarify the issues and facilitate an understanding

environmen-of legislative requirements and good practices Those with ties for handling and using chemicals should study the relevant laws andguidance to ensure that their areas of responsibility meet the higheststandards Management commitment, leadership and setting a goodexample play important roles in achieving high standards in health,safety and the environment which, in turn, lead to a successful enterprise

responsibili-To quote the HSC’s slogan ‘Good health is good business’

References

1 The Control of Substances Hazardous to Health Regulations 2002, The Stationery Office,

London (2002)

2 Health and Safety Executive, Legal Series Booklet No L5, General COSHH ACOP and

Carcinogens ACOP and Biological Agents ACOP, HSE Books, Sudbury (2002)

3 The Chemicals (Hazard Information & Packaging for Supply) Regulations 2002, The

Stationery Office, London (2002)

4 Health and Safety Commission, Legal Series Booklet No L124, Approved Supply List.

Information approved for the classification & labelling of substances and preparations dangerous for supply (7th edn), HSE Books, Sudbury (2002)

5 Health & Safety Executive, Legal Series Booklet No L130, Approved Code of Practice:

Safety data sheets for substances and preparations dangerous for supply 3rd edn HSE Books,

Sudbury (2002)

6 The Merck Index, 10th edn, Merck & Co Inc (1983)

7 Sax, N.I., Dangerous Properties of Industrial Materials (7th edn), Van Nostrand Reinhold

(1989)

8 Bretherick, L., Handbook of Reactive Chemical Hazards, Butterworth, Oxford (1979)

9 Health & Safety Executive, Guidance Series Booklet No HSG 117, Making Sense of

NONS A Guide to the Notification of New Substances Regulations 1993, HSE Books,

Sudbury (1994)

10 The Chemical Weapons Act 1996, The Stationery Office, London (1996)

11 European Union, European Inventory of Existing Commercial Substances, EU,

Luxembourg

12 European Union, European List of Notified Chemical Substances, EU, Luxembourg

13 Edwards v National Coal Board (1949) IKB 704; (1949) 1 All ER 743

14 Health and Safety Executive, Environmental Hygiene Series Guidance Note No EH 40,

Occupational Exposure Limits, HSE Books, Sudbury, updated annually

15 Health & Safety Executive, Investigation Report: Flixborough Disaster, HSE Books,

Sudbury (1975)

16 The Control of Major Accident Hazard Regulations 1999 (COMAH), The Stationery Office,

Managing chemicals safely 889

London (1999) also The Health and Safety Executive, booklet no: L 111, A Guide to the

Control of Major Accident Hazards Regulations, HSE Books, Sudbury (1999)

17 The Notification of Installations Handling Hazardous Substances Regulations 1982, The

Stationery Office, London (1982), also The Health and Safety Executive, booklet no: HSR

16, Guide to the Notifications of Installations Handling Hazardous Substances Regulations

1982, HSE Books, Sudbury (1982)

18 European Union, Directive No 82/501/EEC, Council Directive on Major Accident Hazards

of Certain Industrial Activities, EU, Luxembourg (1982)

19 Health & Safety Executive, Health and Safety Regulation Booklet No HSR 21, Guide to the

Control of Industrial Major Accident Hazards Regulations 1984, HSE Books, Sudbury (1984)

20 Health & Safety Executive, Health and Safety Guidance Booklet No HSG 25, Control of

Industrial Major Accident Hazards Regulations 1984: Further guidance on emergency plans,

HSE Books, Sudbury (1985)

21 Health and Safety Commission, Legal Series Booklet No L90, Approved Carriage List,

Information approved for the carriage of dangerous goods by road and rail other than explosives and radioactive material, HSE Books, Sudbury (1999)

22 Health & Safety Executive, Legal Series Booklet No L100, Approved Guide to the

Classification & Labelling of Substances and Preparations Dangerous for Supply, HSE Books,

Sudbury (1999)

23 Health & Safety Executive, Health and Safety Guidance Series Booklet No HSG 97, A

step by step guide to COSHH assessment, HSE Books, Sudbury (1992)

24 Health and Safety Executive, Legal Series Booklet No L5, General COSHH ACOP and

Carcinogens ACOP and Biological Agents ACOP (2002), HSE Books, Sudbury (2002)

25 Health & Safety Executive, Legal Series Booklet No L86, Control of Substances Hazardous

to Health in Fumigation Operations: Approved Code of Practice: COSHH ’94, HSE Books,

Sudbury (1996)

26 Health and Safety Executive, booklet no: HSG 143, Designing and Operating Safe Chemical

Reaction Processes, HSE Books, Sudbury (2000)

27 The Control of Lead at Work Regulations 2002, the Stationery Office, London (2002)

28 The Ionising Radiations Regulations 1999, The Stationery Office, London (1999)

29 Health & Safety Executive, Health and Safety Series Guidance Booklet No HSG 40,

Chlorine from drums and cylinders, HSE Books, Sudbury (1999)

30 Health & Safety Executive, Chemical Series Guidance Note No CS4, Keeping of LPG in

cylinders and similar containers, HSE Books, Sudbury (1986)

31 Health & Safety Executive, Health & Safety Guidance Series Booklets Nos HSG 50, The

Storage of Flammable Liquids in Fixed Tanks (up to 10,000 m 3 total capacity) (1990); HSG 51, The Storage of Flammable Liquids in Containers (1990); HSG 52, The Storage of Flammable Liquids in Fixed Tanks (exceeding 10,000 m 3 total capacity) (1991); HSE Books, Sudbury

32 British Distributors’ & Traders’ Association, Warehousing of Chemicals Guide, British

Distributors’ & Traders’ Association, London (1988)

33 Health & Safety Executive, Health and Safety Guidance Series Booklet No HSG 71,

Chemical warehousing Storage of Packaged Dangerous Substances, HSE Books, Sudbury

(1998)

34 Health and Safety Commission, Consultative Document No CD120, Proposals for new

petrol legislation, HSE Books, Sudbury

35 Health & Safety Executive, Investigation Report (not numbered), Fire and explosions at B &

R Hauliers, Salford, 25 September 1982, HSE Books, Sudbury (1983) (ISBN 0 11 883702 8)

36 Health & Safety Executive, Investigation Report (not numbered), Fire and explosions at

Cory’s Warehouse, Toller Road, Ipswich, 14 October 1982, HSE Books, Sudbury (1984) (ISBN

0 11 883785 0)

37 British Oxygen Company Ltd, Safe Under Pressure, Guidelines for all who use BOC Gases in

Cylinders, British Oxygen Company, Guildford, Surrey (1993)

38 Health & Safety Executive, Legal Series Booklets Nos L89, Approved Vehicle Requirements (1999); L91, Suitability of vehicles and containers and limits on quantities for the carriage of

explosives: Carriage of Explosives by Road Regulations 1996–Approve Code of Practice (1996);

L92, Approved requirements for the construction of vehicles for the carriage of explosives by road (1999); L93, Approved Tank Requirements: the provisions for bottom loading and vapour

recovery systems of mobile containers carrying petrol (1996); HSE Books, Sudbury.

39 Health & Safety Executive, Health and Safety Regulations Booklet No HSR 13, Guide to

the Dangerous Substances (Conveyance by Road in Road Tankers and Tank Containers) Regulations 1981, HSE Books, Sudbury (1981)

46 The Packaging, Labelling and Carriage of Radioactive Material by Rail Regulations 1996, The

Stationery Office, London (1996)

47 The Transport of Dangerous Goods (Safety Adviser) Regulations 1999, The Stationery Office,

London (1999)

48 Kletz, T., HAZOP & HAZAN – Identifying and Assessing Process Industry Hazards, The

Institution of Chemical Engineers, Rugby (ISBN 0 85 295285 6)

49 Chemical Industries Association, A Guide to Hazard and Operability Studies, Chemical

Industries Association, London (1992)

50 British Standards Institution, BS EN 1050, Safety of Machinery – Principle for Risk

Assessment, BSI, London (1997)

51 British Standards Institution, BS IEC 61025, Fault Tree Analysis, BSI, London

52 British Standards Institution, BS IEC 61508, Safety of machinery – Functional safety of

electrical, electronic and programmable electronic safety related systems, BSI, London

53 Bretherick, L., Hazards in the Chemical Laboratory, 4th edn, The Royal Society of

Chemistry, London (1986)

54 Weston, R., Laboratory Safety Audits & Inspections, Institute of Science & Technology,

London (1982)

55 The Royal Society of Chemistry, Safe Practices in Chemical Laboratories, The Royal Society

of Chemistry, London (1989) (ISBN 0 851 86309 4)

56 The Society of Industrial Emergency Services Officers, Guide to Emergency Planning,

Paramount Publishing Ltd., Boreham Wood (1986)

57 Chemical Industries Association, Be prepared for an emergency – Training & Exercises,

Chemical Industries Association, London (1992) (ISBN 0 900623 73 X)

58 The Control of Asbestos at Work Regulations 2002, The Stationery Office, London (2002)

59 The Noise at Work Regulations 1989, The Stationery Office, London (1989)

60 The Construction (Head Protection) Regulations 1989, The Stationery Office, London

(1989)

61 Health and Safety Executive, booklet no: HSG 191, Emergency Planning for Major

Accidents, HSE Books, Sudbury (1999)

62 The Management of Health and Safety at Work Regulations 1999, The Stationery Office,

London (1999)

63 The Dangerous Substances (Notification and Marking of Sites) Regulations 1990, The

Stationery Office, London (1990)

64 The Planning (Hazardous Substances) Regulations 1992, The Stationery Office, London

(1992)

Chapter 5.3 Waste management (Samantha Moss) 921

Chapter 5.4 Chemicals and the environment (J L Adamson) 956Chapter 5.5 The environment at large (G N Batts) 986

Health and safety have for long been recognised as important aspects ofworking life and there is a long record of legislation and of the partplayed by caring employers In the past two decades concern about theenvironment has become a major issue as scientists have developed ways

to measure the damage done to the ecology and the quality of life and toidentify the cause of it Natural disasters have, over the eons, had theiradverse effects on the environment but, in the main, nature has been able

to accommodate them What nature cannot accommodate is the grossmisuse of the environment by man This point is being increasinglyrecognised, both nationally and globally, and there are growing bodies oflegislation and standards aimed at checking those abuses

Within the workplace, responsibility for ensuring compliance withenvironmental standards and legislation is often delegated to the safetyadviser Suddenly the health and safety professional is to be found in anew front line without training or experience This part of the book setsout to outline the standards and legislation concerning the environmentand to explain how, with goodwill and the right approach at the rightlevel, high environmental standards can, like safety, materially contribute

to the well-being and profitability of the enterprise

Chapter 5.1

The environment: issues,

concepts and strategies

J E Channing

5.1.1 Introduction

The word ‘environment’ generates many different responses To some it

is a question of survival of the world as an inhabitable planet To others

it is an over-hyped scare founded on myth rather than fact The

‘environment’ does evoke considerable emotion and trying to establish alogical rational position in the midst of scientific uncertainty and stronglyheld feelings is a significant challenge Some facts are not in dispute Thehuge growth in the human population is the major driver of today’senvironmental concerns The number of human beings inhabiting theplanet has mushroomed over the last one hundred years The demandsthey make on the resources of the planet have grown exponentially.United Nations population data1is shown in Table 5.1.1 demonstrating

the actual and predicted growth of the human population

To the increased birthrate, caused by advances in nutrition and areduced child death rate, must be added the longevity of the averagehuman being Both result from the success of the species in developingtechnologies, medical and social, which have increased life expectancy.More people have added to the strain on resources The growth in the

Table 5.1.1 Population growth

2050 (middle estimate) 8.9 billion

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human population has not been matched by a growth in the availableland The inhabitable land mass is unchanged and technologies are notyet available to allow large populations to comfortably inhabit theinhospitable deserts of the Sahara or the icy tundra of Canada or Siberia.The consequences are predictable – less space and more competition foravailable resources leading to local tensions in crowded parts of theworld with geo-political tensions and conflicts between nation states Inparticular tensions arise between wealthy nations, which consume moreresources per capita and want to continue to do so, and less developednations which seek a fair share The response from political leaders is tofind ways to accommodate the imbalances, so far as their electorates willallow, by introducing regulations to change the behaviour of societies,businesses, and individuals The basis of the decisions and the directionstaken is the known facts of the issue Herein lies a major problem Thefacts of environmental life are constantly changing The scientificcommunity struggles to make sense of emerging and often conflictingdata Political leaders base their policy decisions on their prognostica-tions The potential consequence of a wrong decision, given theworldwide scale of the environmental issue, is either to permit anenvironmental catastrophe or to waste money (another resource) on ahuge scale The challenge of correct decision-making is daunting.Nevertheless it is clearly sensible to take steps to conserve resources.Governments around the world have, to differing degrees, risen to thischallenge

5.1.2 Environmental predictions

The Inter-governmental Panel on Climate Change (IPCC)2is a body set

up to study the environment which produces data to assist internationalpolicy development on global warming The data are collected from suchorganisations as the World Meteorological Organisation3which has airpollution stations in such remote places as Cape Grim, Tasmania,Australia, Barrow in Alaska, and Ushuaia near Cape Hope, to name but

a few These stations measure temperature, airflow, and the composition

of greenhouse gases such as carbon dioxide, methane and nitrous oxide.Their data, from the purest sea air in these remote locations, shows thatcarbon dioxide levels have risen 10% over the last 20 years The IPPC hasalso provided data from air bubbles trapped in samples brought up fromundersea bore holes in the Antarctic and Greenland It shows the amount

of carbon dioxide now in the air is the highest it has been for the past

400 000 years The effect of the increasing carbon dioxide levels is to raisethe temperature of the earth From the end of the last Ice Age, around

14 000 years ago, to the beginning of the Industrial Age, around 1800 AD,the carbon dioxide level remained constant at around 280 parts permillion It now stands at 370 parts per million and is rising The increase

is due to human beings burning fossil fuels and removing forests (Forestsact as ‘sinks’ which absorb carbon dioxide through photosynthesis.) Thepossible consequences of unrestrained global warming were outlined in a

review in The Times4that is summarised in Table 5.1.2.

The environment: issues, concepts and strategies 895

But predictions are just that – predictions There are alternative viewswhich challenge these predictions Some scientists believe the currentwarming is merely the ongoing cyclical change in the Earth’s atmosphere.Others believe the model that produced the predictions is flawed Forexample, it doesn’t take into account cloud formation When the Earth’ssurface heats up cloud cover changes in such a way that more energy isreleased into space

but the concept of the Waste Management Hierarchy in Figure 5.1.1 is a

way of achieving this

The concept is to encourage those activities which ascend theHierarchy The top of the Hierarchy is ‘Reduce’ This is the only optionwhich does not use up initial resources such as raw materials and energyfrom fossil fuels to make the product or supply the service in the firstplace In sophisticated applications the Waste Management Hierarchy is

applied to all stages of a product cycle as illustrated in Figure 5.1.2.

Table 5.1.2 Observations and predictions arising from global warming

Year Observation or prediction

900 to 1250 AD Medieval warm period Vineyards in Britain

1550 to 1750 AD ‘Little Ice Age’ The River Thames in England regularly freezes

with ice so thick that fires could be lit on it to roast animals

at fairs

1800 to 1900 AD Volcanic activity cooled the earth by throwing into the

atmosphere sulphur dioxide that absorbed heat

1900 to 2000 AD Increasing use of coal and oil for power generation raises

carbon dioxide levels

By 2050 AD A 1°C rise in global temperature increases ocean

temperatures affecting fish breeding grounds; glaciers shrinkand ice caps melt; low lying areas flooded

By 2100 AD Increased sea levels (up to 88 cm in worst case scenario)

overwhelms many islands in Indonesia and coastal cities such

as New York, London and Sydney Birds who thrive ontundra become extinct; tropical disease and agricultural pestsmigrate north

By 3000 AD Sea levels rise up to 7 metres

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The product designers are most influential in reducing the rawmaterials used in the product For example, the quantity of metal used incar chassis and panel manufacture has declined as sophisticatedengineering has shaped metal parts to provide strength that was onceonly achieved by using thicker slabs of metal Production managers canadopt lean manufacturing techniques to cut waste in operations Wastegenerated in transportation and distribution (the use of fuel, wear andtear on roads and tyres etc.) can be reduced if less distances weretravelled between producer and consumer This at once raises theeconomic and political aspects of environmental issues Relocating afactory to another part of the same country, or even to another country orcontinent altogether, means for the original location a loss of jobs, less taxrevenue and can also mean more costly goods for the consumer if thebenefits of large-scale production are lost

Sachs et al.5 argue that many of today’s norms can be successfullyaltered if there is the social and political will for change Ideas include:

 focus on total door-to-door time from producer to consumer and notjust speed of product distribution from warehouse to supermarket.Limit vehicle speed, acceleration and fuel consumption, and introducegraduated distance charges for vehicles These factors will promoteregional sourcing of products;

 encourage the greater use of rail transportation bearing in mind that amajority of people live within a few miles of a station;

 reconstruct the tax regime so that profits rise as energy consumptiondeclines;

Figure 5.1.1 The Waste Management Hierarchy

The environment: issues, concepts and strategies 897

 encourage new building on existing or previously used sites ratherthan ‘greenfield’ sites;

 promote healthy eating – more fruit and vegetables – which can beproduced locally;

 adjusting international trade and loan criteria from satisfying primarilynorthern (wealthy) countries to satisfying southern (less wealthy)countries;

 shifting towards fairer trade practices with an emphasis on ability rather than just structural development

sustain-These ideas are finding support The Climate Change Levy6in the UKtaxes high and inefficient energy users The Contaminated LandRegulations7 seek to identify areas of contaminated land so that thosewho cause it can be made to pay for its subsequent clean up.Contaminated Land is defined as ‘ land which appears to the localauthority to be in such a condition, by reason of substances in, on orunder the land, that significant harm is being caused or that pollution

of controlled waters is, or is likely to be, caused’ Clearly there is aconsiderable scope for interpretation with the major difficulty ofproving a ‘negative’, i.e at what concentration some trace metal or non-biodegradable chlorinated solvent, for example, will not cause harm Agood review of this topic is available from Butterworth8 The intention

is however clear – to make so-called ‘brownfield’ sites available forfurther use and lessen the need to use up virgin ‘greenfield’ sites

Figure 5.1.2 The product life cycle and sustainable development

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5.1.4 Environmental hazards

The focus of concern is the elimination, or, at least, the control thenreduction of substances or agents that harm the environment Morenarrowly the emphasis tends to be upon harm to the human being Harm

to other fauna and flora are relevant to most people only insofar as itaffects, or may affect, human beings now or in the future Thus thesimplest organisms of life are a concern because they are among the firstlinks in the food chain that eventually supplies homo sapiens Concernover the environment is essentially homo sapiens centred

5.1.4.1 The appliance of science

The starting point for the identification of environmental hazards is theimpact on mankind In nearly every instance an impact has beenobserved only where it occurs at much higher doses than normally exist

in the environment at large Scientific evaluation of the dose–responserelationship at higher levels is usually extrapolated linearly to zero Theresult is to suggest that any dose above zero will cause harm and present

a risk The issue has been considered in the context of radiation by theUnited Nations Scientific Committee on the Effects of Atomic Radiation(UNSCEAR)10 It took epidemiological data on survivors from theHiroshima and Nagasaki atomic bombs They were irradiated with highdoses and at high dose rates – equivalent to annual doses in the region of

500 to 5000 milli-sieverts (mSv) From this data UNSCEAR tried to judgethe impact of nuclear weapons tests generating what are considered ‘safe’doses of 0.01 mSv per year Assuming a linearity of effect from theHiroshima and Nagasaki data, and no threshold before any effect isincurred, they estimated a risk factor for leukemia of 0.52% per 1000 mSv.This translates into 60 000 leukemia cases worldwide However, if there is

a threshold level of 4000 mSv before leukemia is triggered, then zero caseswould arise In its conclusions UNSCEAR stated:

(1) ‘Linearity has been assumed primarily for purposes of simplicity’ and(2) ‘There may or may not be a threshold dose Two possibilities ofthreshold and no-threshold have been retained because of the verygreat differences they gender.’

The quest for better scientific data may be a long way off The difficulties ofimproving our knowledge is demonstrated by Wienberg’s10example Hestated that to determine experimentally at a 95% confidence level that a1.5 mSv dose will increase the mutation rate by 0.5%, as predicted by thelinearity assumption, will require tests on 8000 million mice! At this pointthe predicted effects clearly transcend science Amidst all this uncertainty,difficult decisions must still be made Following the Chernobyl incidentsome 400 000 people were forcibly re-settled elsewhere in Belarus, Ukraineand Russia They had exceeded an evacuation intervention level set by theInternational Commission on Radiological Protection (ICRP)11 of aradiation dose of 70 mSv over a 70 year lifetime However, a subsequentstudy by Sohrabi12estimated that the Chernobyl fallout in Central Europe

in the first year generated an additional dose of 0.3 mSv/year compared

The environment: issues, concepts and strategies 899

with the average national dose estimated at 2.4 mSv per year This datashould also been seen in the context that the average lifetime dose inNorway is 365 mSv (Herrikson and Saxebol)13, and 2000 mSv in regions ofIndia (Sunta)14, and the inhabitants of these regions are not relocated Thedecision to relocate the Chernobyl victims may now seem to be irrationalbut it does demonstrate the considerable difficulties which arise whenscientific knowledge reaches a frontier and situations arise when social andpolitical decisions must be made The example of radiation has been dealtwith at length because it can be replicated to many other substances oragents which are subjected to environmental control but about whichmuch less detailed data are available

The health effects of lead at high levels are well known and includeanaemia and alimentary symptoms There is uncertainty about the effects

at blood concentrations in the range 35 to 80 g/dl as stated in theLawther15report to the Royal Commission on Environmental Pollution16.Nevertheless the UK Health Department recommended that blood leadlevels should not exceed 25 g/dl especially in children17

These examples demonstrate the problems faced by regulators Thescientific basis of many decisions is uncertain The impact of lowconcentrations or doses over extended periods of time on people, floraand fauna are difficult to establish In such circumstances decisions areoften made under pressure from the public or pressure groups, to adopt

a precautionary principle.

To most practitioners who work in the day to day issues ofenvironmental control these uncertainties are irrelevant The decision onwhat constitutes an acceptable level of control for a particular substance

or agent has already been made by national or international bodies Thedaily task in practice is to manage the consequences However, for someareas of activity the fact of data uncertainty is of very real concern In thechemical business, for example, researchers develop new chemicalswhich have to be tested to demonstrate the point at which toxic effectsoccur (most chemicals are toxic at some dose rate) Once a toxic effect isobserved the precautionary principle can be applied so that environmen-tal concentrations are 10 times to 100 times below the known effect level

This becomes the predicted no-effect concentration (PNEC) The more toxic

a chemical appears, the more sensitive the species upon which the testsare performed before the precautionary principle is applied TheNotification of New Substances Regulations18, dealt with in anotherchapter, enshrines this process in law

Existing chemicals and processes face similar problems For example,cadmium is toxic and has been severely controlled Silver, which is in thesame family of elements, is guilty by association even though only ionicsilver – which does not occur in nature (silver ions rapidly combine inwater to form non-toxic chloride, oxide or sulphate salts) – is toxic

5.1.4.2 Hazard identification in practice

For most day-to-day practical purposes governments and their agencieshave listed the environmental materials and substances which requirecontrol They fall into four broad categories:

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(1) Direct effects on people in the community whose health and/or safety

can be affected following the release of hazardous substances as aresult of a significant loss of containment This may occur throughspillage, fire, explosion or a toxic gas cloud release There is a fullinteraction with health and safety issues, procedures and practices inthese circumstances

(2) Indirect effects on people in the community whose health and safety

can be impaired by a persistent low level loss of containment such asmay occur if the contents of an underground storage tank leaks into

an aquifer from which drinking water is abstracted Food safety can

be compromised if poor production control permits contaminants toarise One example was the contamination of Perrier Water by traces

of benzene Indirect effects arise from pesticides used in the foodchain In today’s international commercial markets produce arrives

on supermarket shelves from around the world The impact ofpesticides used on fruit or vegetables in one part of the world mayaffect the inhabitants of another continent

(3) Quality of life, which may not affect health and safety also constitutes

an environmental hazard These include the use of land, perhapsturning a green and pleasant valley alongside a motorway into acommercial business park with a loss of amenity value to localresidents Odours from factories, noise from late night bars or discos,late night or early morning landings and take-offs at airports all fallwithin this category Some will argue that these activities do have adirect impact on health by raising stress levels Perhaps more complex

is the location of waste collection stations, landfill sites andincinerators Whilst necessary, many people object to such facilitiesbeing sited next to their homes because of the increase in the size andnumber of vehicles they bring to the area with the consequent odoursand litter Such is the outcry on developments that the ‘NIMBY’syndrome has become well known – Not In My Back Yard!

(4) The eco-system concerning local flora and fauna Into this category

comes the acid rain issue which arises when sulphur dioxideemissions from power stations fall as precipitates to acidify lakescausing fish deaths and affecting afforestation

5.1.5 Evaluating environmental risks

It must be remembered that hazard and risk are not the same.

‘Hazard’ is the intrinsic property of the material to cause harm ordamage

‘Risk’ is the probability of the hazard actually causing the harm ordamage and the severity or consequence of it Some definitions add a timecomponent The Second Report of the Advisory Committee on MajorHazards19defines risk as ‘the probability that a hazard may be realised atany specified level in a given span of time’ The time component adds adimension to an assessment of an environmental risk compared to anassessment of a safety risk For example a chemical or combustion processmay have a designed life span of 30 to 40 years before being dismantled

The environment: issues, concepts and strategies 901

The risk assessment of the design may identify immediate hazards butshould be extended to consider the effects of emissions, fuel leakages, etc.,over the time span of the plant An environmental risk from, for example, aleachate escaping from a toxic landfill site is likely to have an impact overmany more years These complex issues of environment risk estimation aregenerally considered by regulatory bodies when control limits andstrategies are set by them However, as there are often several controloptions available, suitable techniques must be employed to assist thedecision makers in arriving at the most environmentally friendly answer

5.1.5.1 Cost benefit analysis

The problem of dealing with environmental risks is often approached byidentifying the most suitable strategy that controls the risk at least cost

Cost benefit analysis can be applied to this task In fact cost benefit analysis

is advocated in UK legislation20in the form of control systems which are

the best available techniques not entailing excessive cost (BATNEEC).

Guidance on cost benefit analysis has been produced by a UKGovernment/Industry Working Group21 The ‘costs’ are those incurred

by industry, government and society whereas the ‘benefits’ are defined asreductions in risks to health and the environment arising from regulation.The process consists of:

 identifying the dose–response data or other information that quantifiesthe environmental impact

 estimating the current or baseline exposure level

 calculating the harm or damage caused by the current exposureimpact

 estimating the exposure following the application of the proposedregulatory controls

 calculating the remaining or residual harm or damage

 translating the harm or damage prevented into cash terms

The process is applied to new regulations under consideration and can beapplied to the choice of abatement technologies to reduce emissions Inthe latter case the benefits are probably easier to identify, mainly tocontrol emissions to below a regulated level However, judgment andflexibility is still needed to determine the regulatory level For example,

an environmental impact is frequently caused by a total burden ofmaterial emitted from a process over a period of time Regulatorycontrols, however, tend to be absolute limits which should not beexceeded even momentarily Consequently reduced emissions arisingfrom less production during weekends or holidays cannot be offset byabove-the-limit emissions at other times even if the time weightedaverage remains below the control limit

Costs are easy to quantify or are they? Costs of abatementtechnologies are not capital costs alone Maintenance and servicing costsmust be taken into account Over a span of time they can outweigh theinitial capital costs Furthermore cash spent buying abatement technologyamounts to cash that cannot be invested These costs (opportunity costs)may be calculated and discounted cash flow techniques used to arrive at

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a present day cost estimate22 Cost benefit analysis is a beguiling idea and

is a useful tool for gaining insights into the variability of costs withbenefits so that as sound a decision as possible, covering economic,practical and political issues can be reached by the regulators

Figure 5.1.3 illustrates the basic concept of cost benefit analysis The

objective is to identify the optimum solution to an environmental risk thatbalances the gain (or risk reduction) against the cost

5.1.5.2 Environmental risk perception

In all areas of risk assessment the confounding factor is perception.

However rigorously a cost benefit analysis is undertaken to reduce thebandwidth of uncertainty, the decision to proceed in a chosen directionmay be made or will certainly be influenced by how the risk is perceived

An oft-quoted study by Slovic et al.23asked four groups of people to rank

in order of perceived risk 30 activities and technologies The results from

six of the elements of the study are listed in Table 5.1.3

A review of this partial list demonstrates the wide range of riskperceptions between groups of people Most striking are the differences

of view that exist between experts and other groups Experts rate

‘surgery’ and ‘x-rays’ as more threatening risks than the other groups.Risks from pesticides generate widely divergent points of view Mostfascinating is the data on power generation Experts rate nuclear power

as significantly less risky than all other groups Nuclear power is one ofthe most highly regulated activities on the planet yet there is greatresistance to the construction of new nuclear power stations even thoughmany do not emit into the environment harmful gases which contribute

to global warming Paradoxically, experts rate non-nuclear electric powergeneration as more risky – once again differing from all other groups.Slovic identifies the reason for this difference in further work

Figure 5.1.3 The cost benefit analysis model

The environment: issues, concepts and strategies 903

Figure 5.1.4 places the hazards and technologies in a two-by-two

matrix The vertical axis looks at the extent to which the hazard ortechnology is ‘familiar’ or ‘known’ The horizontal axis considers theextent to which they are seen as local and controllable risks withacceptable consequences or, at the other end of the scale, risks with highpotential consequences where there is seen to be a lack of control.The conclusion is that the newer the risk and the less known about it,the greater is the concern This becomes greater when the activity isperceived as having high consequences if control of it is lost andcatastrophic results ensue

Perception is shaped by the media Sandman24 has studied andpublished this aspect extensively and his conclusions include:

 The amount of coverage accorded to an environmental risk topic is notrelated to the seriousness of the risk in health terms Instead, it relies ontraditional journalistic criteria like timelines and human interest

 Within individual risk stories, most of the coverage is not about therisk It is about blame, fear, anger, and other non-technical issues such

as ‘outrage’ rather than ‘hazard’

Table 5.1.3 Risk ranking of hazards and technologies by four groups (Slovic)

Activity or technology Group 1* Group 2* Group 3* Group 4*

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 When technical information about risk is published in news stories ithas little if any impact on the audiences

 Alarming content about risk is more common than reassuring content

or intermediate content except, perhaps, in crisis situations, where animpulse to prevent panic seems to moderate the coverage

 Exactly what information is alarming or reassuring is very much amatter of opinion The media audience tends to be alarmed even byinformation the expert world considers reassuring

Examples of the above occur weekly if not daily in the media.Occasionally, a more reasoned media view appears An article in theLondon Times on the scare that reusable trial contact lenses (aftersterilisation) can lead to the spread of Creutzfeldt-Jakob Disease wasentitled ‘Panic is now the plague’25 It sought to provide a greater degree

of rationality and science in reporting Such articles are rare

While the above looks at perception on a nation-wide level, each local

or business decision also has an element of perception There is a need tomake rational, professional environmental judgements and follow upwith suitable care being given to the presentation of the findings takinginto account the likely viewpoint of the receptor – whether they be localcompany management, a local regulator, or a community group

5.1.6 Environmental control strategies

Control strategies apply on global, regional, national and local levels At

a global level, international conferences such as the Kyoto and Rioconferences were convened to address the issue of global warming At aregional level the European Union has produced directives with whichmember states must comply covering areas such as:

 Transfrontier shipments of waste

 Packaging regulations

 Regulations which encourage re-use and re-cycling by compellingbusinesses to take back old equipment and strip down components forre-use