HSC 3-12 (13-14) [Health and Safety Committee, 15 July 2014] Item 9 Flammable Gases Audit Summary: recommendations and a proposed UCL Standard Action proposed to the Committee: approve the proposals in this document Author/Proponent: Steve Tidmarsh Background: Flammable Gases Audit Executive Summary An audit of how UCL departments manage their use of flammable gases was conducted using a number of departments selected as the result of earlier management systems reviews. Failure to manage flammable gases could result in formation and detonation of an explosive atmosphere with the potential for loss of life, destruction of property and reputational damage that could be associated. There is also the risk that an enforcing agency could use failure to comply with the DSEAR regulations as evidence that UCL and its departments are in breach of Section 2.2 of the Health and Safety at Work Act (1974) which would result in enforcement action. It was found that of the departments inspected only one was managing its use of flammable gases in a way that was not in breach of regulations, a second department had the physical equipment and infrastructure, but had not trained or instructed their staff in the necessary procedures so they were working in breach of regulations. Recommendations have been made to the departments involved. Proposals: Flammable Gases Strategic Action Plan As a result of analysing the recommendations to departments, a number of key improvements to the management of work with flammable gases at UCL are required to bring UCL departments to legal compliance. These have been formulated into a strategic action plan. The proposed changes are designed to improve UCL compliance with regulatory requirements but also to provide better overarching management control of the procedures and systems required for safe working with flammable gases at UCL. A number of requirements are proposed in Annex 1. The proposals and improvements will put UCL in a much stronger position with respect both to legislative requirements and overall management control. Safety Services will monitor the implementation of the action plan and report back to the Health and Safety Committee. Steve Tidmarsh, Safety Adviser 4 July 2014 ANNEX 1 Strategic Action Plan – Flammable Gases 1 2 3 4 5 6 7 8 9 10 Recommendation Each department using flammable gases must appoint a person to be responsible for the management of flammable gases. This person must ensure that the use of flammable gases is covered by risk assessment, that the people carrying out the work are competent (as below) and that the area the gas is to be used in is suitable. Procurement Services, with the advice of Safety Services should review the UCL BOC contract to make it explicit what services are agreed and how UCL departments can access the services UCL to adopt a standard ‘safe to connect form’ that departments must complete, stating that risk assessment has been completed and signed by an authoriser where cylinders are to be connected. BOC to only deliver or connect cylinders of flammable gases where a ‘safe to connect form’ has been completed. A risk assessment for the use of the flammable gas must be in place before any the purchase of any flammable gas ordered. This must take into account the area and other substances / sources of ignition in the area. The responsible person must maintain an inventory of the flammable gases held and their location. Persons using flammable gases must be competent to do so and have received training and instruction. This must be recorded, even if the training is given at the bench. The cylinders must be stored in an area which has good ventilation, away from any sources of ignition and have appropriate signage. If it is not possible to store cylinders away from sources of ignition appropriate enclosures must be used. Responsibility UCL Heads of Department Date Sept 14 Procurement Services Sept 14 UCL Departments Sept 14 BOC Sept 14 UCL Departments Sept 14 UCL Departments – Appointed person UCL Departments Sept 14 UCL Departments Where explosive atmospheres might occur, sensors and alarms must be fitted and appropriate signs and instructions posted. Where it is foreseeable that an explosive atmosphere could occur, the area must be appropriately zoned (in accordance to DSEAR) and only equipment rated for the specific zone may be used in that area. UCL Departments Immediate for all new installations, within 12 months for existing installations where enclosures are required unless exceptional circumstances Dec 14 UCL Departments Sept 14 Immediate for all new installations, within 12 months for existing installations 11 12 13 14 Recommendations for BOC and UCL cooperation. Reports of annual regulator inspections by BOC to be provided to the department concerned and to the UCL contract manager. Training in the safe use of gases (including flammable gases) should be requested by departments from BOC where a need has been identified. BOC should provide safety data sheets to departments. Departments should display Safety data sheets at point of use or storage.