SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 Safe Working Guidelines (SWG) Hazardous Substances Introduction These guidelines provide advice on the dangers associated with hazardous substances and the precautions that should be taken. The guidelines are based on the main requirements of the Control of Substances Hazardous to Health Regulations and its associated Approved Codes of Practice. Finding Out if a Substance is Hazardous Hazardous substances are defined in the regulations as: (a) Substances classified in the Globally Harmonised System (GHS) GHS Elements Compared to the current EU system the most noticeable change are the pictograms (formerly: hazard symbols). While the most of the GHS pictograms have an equivalent in the old system, the pictograms GHS 04, GHS 07 and GHS 08 are completely new. The GHS System is built on 16 physical, 10 health and 3 environmental hazard classes and comprises the following communication elements: 9 Pictograms Description Pictogram Hazard class and hazard category: Exploding Bomb Unstable explosives Explosives of Divisions 1.1, 1.2, 1.3, 1.4 Self reactive substances and mixtures, Types A,B Organic peroxides, Types A,B Flame Flammable gases, category 1 Flammable aerosols, categories 1,2 Flammable liquids, categories 1,2,3 Flammable solids, categories 1,2 Self-reactive substances and mixtures, Types B,C,D,E,F Pyrophoric liquids, category 1 Pyrophoric solids, category 1 Self-heating substances and mixtures, categories 1,2 Substances and mixtures, which in contact with water, emit flammable gases, categories 1,2,3 Organic peroxides, Types B,C,D,E,F 1 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 Flame Over Circle Oxidizing gases, category 1 Oxidizing liquids, categories 1,2,3 Gas Cylinder Gases under pressure: - Compressed gases - Liquefied gases - Refrigerated liquefied gases - Dissolved gases Corrosion Corrosive to metals, category 1 Skin corrosion, categories 1A,1B,1C Serious eye damage, category 1 Skull and Crossbones Acute toxicity (oral, dermal, inhalation), categories 1,2,3 Exclamation Mark Acute toxicity (oral, dermal, inhalation), category 4 Skin irritation, category 2 Eye irritation, category 2 Skin sensitisation, category 1 Specific Target Organ Toxicity – Single exposure, category 3 Health Hazard Respiratory sensitization, category 1 Germ cell mutagenicity, categories 1A,1B,2 Carcinogenicity, categories 1A,1B,2 Reproductive toxicity, categories 1A,1B,2 Specific Target Organ Toxicity – Single exposure, categories 1,2 Specific Target Organ Toxicity – Repeated exposure, categories 1,2 Aspiration Hazard, category 1 Environment Hazardous to the aquatic environment - Acute hazard, category1 - Chronic hazard, categories 1,2 2 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 (b) Substances for which a Workplace Exposure Limit has been ascribed by the Health and Safety Executive. These are listed in Table 1 of Workplace Exposure Limits’ (EH40) (c) Biological agents (d) Any dust at a concentration in air equal to or greater than: 10 mgm-3 total inhalable dust, 8 hour Time weighted Average (TWA), or 4 mgm-3 respirable dust, 8 hour TWA (e) Any substance not in (a) to (d) above but which creates a health hazard comparable to any of them. Sources of information Information about the hazardous properties of substances can be obtained from: information on labels and safety data sheets provided by suppliers. Regulations require suppliers to provide information - see (a) above) guidance material (including EH40 – see (b) above) published by the Health and Safety Executive or other authoritative bodies experience gained as a result of previous use of the substance or similar substances textbooks, scientific and technical papers, trade journals etc professional institutions, trade associations, trade unions Risk Assessment Employers must not carry on any work which is liable to expose any employee to any hazardous substance unless a suitable and sufficient assessment has been made of the: (a) risks to the health of those employees created by that work, and (b) steps that need to be taken to meet the requirements of the regulations. Suitable and sufficient A suitable and sufficient assessment should include: an assessment of the risks to health consideration of the practicability of preventing exposure the steps needed for adequate control of exposure where prevention is not reasonably practicable 3 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 identification of other actions required by the regulations (as outlined in these guidelines). The assessment should consider: the hazardous properties of the substances (including biological agents) to which employees might be exposed, taking account of the consequences of the possible failure of a control measure, the form in which the substances are likely to be present, the possible effects on the body and the ways in which and the extent to which employees could be exposed and the possible routes of entry into the body (i.e. inhalation, skin absorption or ingestion); information on health effects provided by the supplier; the level, type and duration of exposure; the circumstances of the work, including the amount of the substance involved; activities, such as maintenance, where there is the potential for a high level of exposure; any relevant workplace exposure limit or similar occupational exposure limit; the effect of preventive and control measures which have been or will be taken; the results of relevant health surveillance; the results of monitoring of exposure; in circumstances where the work will involve exposure to more than one substance hazardous to health, the risk presented by exposure to such substances in combination; the approved classification of any biological agent; and such additional information needed in order to complete the risk assessment. In the simplest cases, it is only necessary to read supplier’s information sheets to conclude that existing control is adequate. In other cases, it may be necessary to read HSE guidance notes and other reference sources (see ‘sources of information’ above) before deciding what control measures should be applied. It may also be necessary to determine exposure by means of atmospheric sampling, particularly where EH40 sets a workplace exposure limit for the substances involved. If the assessment indicates that control of the hazard is inadequate, or is likely to become inadequate, then appropriate remedial actions should be identified and implemented. 4 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 Review of Assessment The assessment should be reviewed at appropriate intervals, and: (a) whenever there is evidence that it is no longer valid because of, for example: the results of tests and thorough examinations of engineering controls the results of exposure monitoring at the workplace the results of health surveillance or ill-health records new information about health risks. (b) where there has been a significant change in the work to which the assessment relates, for example: in the nature or quantity of substances used plant modifications (including engineering controls) in the process or work-methods in the volume of production. The regulations do not specify a frequency for review, but the assessor should specify this when carrying out the initial assessment. An annual review is often appropriate. Prevention or Control of Exposure to Hazardous Substances Employers must ensure that the exposure of employees to hazardous substances is either prevented or, where this is not reasonably practicable, adequately controlled. Control by means of personal protective equipment should only be considered after all other control measures have been taken, so far as is reasonably practicable. Priority for prevention First priority must be given to prevention, by: changing the method of work so that the operation giving rise to exposure is no longer necessary; modifying the process to eliminate a hazardous by-product; or substituting the hazardous substance with one that presents less risk. Control measures (for non-carcinogens) Where prevention is not reasonably practicable, adequate control of exposure must be achieved, so far as is reasonably practicable, this must be done by means other than use of personal protective equipment. Protection measures must be applied, in the following priority order, which are appropriate to the activity and consistent with the risk assessment: (a) the design and use of appropriate work processes, systems and engineering controls and the provision and use of suitable work equipment and materials; 5 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 (b) the control of exposure at source, including adequate ventilation systems and appropriate organisational measures; and (c) where adequate control of exposure cannot be achieved by other means, the provision of suitable personal protective equipment in addition to the above measures. The measures in (a) – (c) shall include: (a) arrangements for the safe handling, storage and transportation of substances hazardous to health, and of waste containing such substances, at the workplace; (b) the adoption of suitable maintenance procedures; (c) reducing, to the minimum required for the work concerned: the number of employees subject to exposure, the level and duration of exposure, and the quantity of substances hazardous to health present at the workplace; (d) the control of the working environment, including appropriate general ventilation; and (e) appropriate hygiene measures including adequate washing facilities. The Approved Code of Practice identifies that control measures could typically be a combination of: (a) total enclosure of the process and handling system; (b) plant or process changes which: minimise the generation of hazardous dust, fume, biological agent etc contain hazardous substances within the plant reduce or eliminate the need for maintenance staff to go into hazardous areas, and limit the area contaminated if spills and leaks occur; (c) ventilation: partial enclosure, with local exhaust ventilation, local exhaust ventilation, and/or sufficient general ventilation; (d) reducing to the minimum required for the work: the number of employees exposed and excluding non-essential employees by use of restricted access and refuges the level and duration of exposure, and the quantities of hazardous substances used or produced; 6 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 (e) regular cleaning/disinfection of walls, surfaces etc; (f) provision of means for safe handling, storage, transport and disposal of hazardous substances; (g) hygiene measures: prohibition of eating, drinking, smoking in contaminated areas, provision of adequate facilities for washing, changing and storage of clothing and PPE, laundry arrangements for contaminated clothing and separate accommodation for clothing worn at work which may become contaminated, provision of suitable personal protective equipment that will adequately control exposure (where the above measures do not provide adequate control). Control measures (for carcinogens and mutagens) Where it is not reasonably practicable to prevent exposure to carcinogens or mutagens, then the following controls must be introduced in addition to the general controls listed above: (a) total enclosure of the process and handling system, where reasonably practicable; (b) prohibition of eating, drinking and smoking in contaminated areas; (c) cleaning floors, walls and other surfaces at regular intervals and whenever necessary; (d) designating those areas and installations which may be contaminated and using suitable and sufficient warning signs; and (e) storing, handling and disposing of substances safely, including using closed and clearly labelled containers. Control measures (for biological agents) Where it is not reasonably practicable to prevent exposure to biological agents, then the following controls must be introduced in addition to the general controls listed above: (a) displaying suitable and sufficient warning signs, including the biohazard sign; (b) specifying appropriate decontamination and disinfection procedures; (c) instituting means for the safe collection, storage and disposal of contaminated waste, including the use of secure and identifiable containers, after suitable treatment where appropriate; (d) testing, where it is necessary and technically possible, for the presence, outside the primary physical confinement, of biological agents used at work; 7 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 (e) specifying procedures for working with, and transporting at the workplace, a biological agent or material that may contain such an agent; (f) where appropriate, making available effective vaccines for those employees who are not already immune to the biological agent to which they are exposed or are liable to be exposed; and (g) instituting hygiene measures compatible with the aim of preventing or reducing the accidental transfer or release of a biological agent from the workplace, including: the provision of appropriate and adequate washing and toilet facilities; and where appropriate, the prohibition of eating, drinking, smoking and the application of cosmetics in working areas where there is a risk of contamination; and where there are human patients or animals which are, or are suspected of being, infected with a Group 3 or 4 biological agent, the most suitable control and containment measures shall be selected with a view to adequately controlling the risk of infection. Workplace Exposure Limits Inhaled Substances assigned a workplace exposure limit (WEL) Table 1 of EH40 lists a number of substances, which have been assigned workplace exposure limits (WELs). These were introduced in April 2005 due to concerns expressed by the Advisory Committee on Toxic Substances (ACTS) about how well employers and other stakeholders understood the previous system. WELs are occupational exposure limits set out under COSHH, in order to help protect the health of workers. WELs are concentrations of hazardous substances in the air, averaged over a specified period of time referred to as a time-weighted average (TWA). Two time periods are used: long term (8 hours) and short term (15 minutes). Short-term exposure limits (STELs) are set to help prevent effects, such as eye irritation, which may occur following exposure for a few minutes. Where there is exposure to a substance for which a maximum exposure limit has been assigned, the control of exposure by inhalation is only adequate if it is reduced to the lowest level that is reasonably practicable and is below the maximum exposure limit. Under COSHH, where prevention of exposure to a substance is not possible, then control of that exposure will only be adequate if: (a) the principles of good practice listed below are applied: processes and activities are designed and operated to minimise emissions, release and spread of substances hazardous to health consideration is given to all relevant routes of exposure - inhalation, skin absorption and ingestion - when developing control measures 8 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 exposure to hazardous substances is controlled by measures that are proportionate to the health risk the most effective and reliable control options are chosen to minimise the escape and spread of substances hazardous to health suitable personal protective equipment is provided where adequate control of exposure cannot be achieved by other means, in combination with other control measures all elements of control measures are checked and regularly reviewed for their continuing effectiveness all employees are informed and trained on the hazards and risks from the substances with which they work and the use of control measures developed to minimise the risks the introduction of control measures does not increase the overall risk to health and safety; (b) any workplace exposure limit approved for that substance is not exceeded (c) exposure is reduced to as low a level as is reasonably practicable for a substance which is classified in the GHS as: Health Hazard Inhaled Substances not assigned a workplace exposure limit (WEL) Not all-hazardous substances are listed in EH40 and the absence of a WEL does not mean that it is not hazardous. Exposure should be controlled to a level to which nearly all the working population could be exposed day after day without adverse health effects. Employers should determine their own safe working practices and control standards. This can be done by reference to information provided by manufacturers and suppliers and other reference sources (see ‘Sources of Information’ above). Monitoring strategies Compliance with exposure limits may be demonstrated by measuring and recording the exposure of employees in accordance with the principles set out in the HSE document Monitoring Strategies for Toxic Substances HSG 173 and COSHH Essentials. Exposure by Routes other than Inhalation Substances may (depending on their form and characteristics) present a hazard through ingestion or absorption through the skin or mucous membranes. Such exposure must be controlled to a standard so that nearly all of the population 9 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 could be repeatedly exposed repeatedly without harmful effects on health. Typical control measures include suitable design and construction and layout of plant, personal hygiene and use of personal protective equipment. Personal Protective Equipment Situations where personal protective equipment may be necessary: Use of personal protective equipment (PPE), as a control measure should be considered as a last resort, but may be necessary in some cases, for example: where it is not technically practicable to achieve adequate control of exposure solely by engineering measures such as process control as a temporary means to achieve control where a new or revised assessment indicates that PPE is necessary in order to safeguard health where urgent action is required, for example, due to plant failure and PPE is the only practicable means of control during routine maintenance operations where the infrequency of the work, and the small number of people involved make engineering/process controls impracticable. The assessment of risk should take account of the practical limitations of the use of PPE such as the difficulty of ensuring that it is used continuously and effectively. Selection of personal protective equipment (Refer also to Safe Working Guidelines – ‘Personal Protective Equipment’). Personal protective equipment should adequately control exposure to the hazards to which the wearer is liable to be exposed. When selecting PPE, consideration should be given to: (a) the ability of the material to resist penetration by the substance; (b) adequacy of design of clothing and suitability for the intended use; (c) the environment in which it will be worn; and (d) in the case of dust, the release characteristics of the material. Manufacturers of PPE must ensure that their products comply with the Personal Protective Equipment Regulations and with relevant EN standards. This is demonstrated by the affixing of the CE mark. Facilities for Washing, Eating, Drinking and Clothing, Accommodation Adequate, conveniently accessible washing facilities must be provided to enable exposed persons to meet adequate standards of personal hygiene in relation to the adequate control of exposure and the need to avoid spreading hazardous substances. 10 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 Accommodation should be provided for personal protective clothing and for outdoor clothing where there is a risk of contamination by hazardous substances. Changing facilities should be designed and located so as to prevent contamination to personal clothing and from one facility to another. So as to prevent ingestion of hazardous substances, eating, drinking, smoking etc should not be permitted in areas contaminated with hazardous substances. In such cases, employers have a duty to provide suitable eating and drinking facilities in an uncontaminated area. Use of Control Measures Employers should establish procedures to ensure that control measures (including PPE where appropriate) are being properly used. The procedures should include visual checks at appropriate intervals and prompt remedial action where necessary. Employees have a statutory duty to take all reasonable steps to make full and proper use of control measures, to ensure that it is properly stored after use and to report defects and should: use the control measures provided for materials, plant and processes wear the PPE provided in a proper manner store PPE in accommodation provided when not in use remove PPE that could cause contamination before eating, drinking or smoking practice a high standard of personal hygiene make proper use of washing, showering facilities etc report promptly to management and defects found in any control measures, devices, facilities or items of PPE. Maintenance, Examination and Test of Control Measures Operating procedures relating to exposure control should be reviewed periodically. Engineering controls Where possible (without putting maintenance personnel at undue risk) all engineering control measures in use should be visually checked at least once every week to ensure that they are maintained in an efficient state, in efficient working order, and in good repair. Planned, preventive maintenance/inspection procedures should specify the control measures to be serviced, the frequency and responsibility for doing so and method of rectifying defects. Engineering controls must be thoroughly examined and tested by competent persons at suitable or specified intervals to ensure that they continue to perform 11 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 as originally intended. Defects disclosed, as a result of the examination or test should be rectified as soon as possible. Local exhaust ventilation Local exhaust ventilation provided as a control measure should be thoroughly examined and tested at least once in every 14 months (or at the frequency specified in Schedule 4 of the COSHH regulations for specified processes). Employers must keep a suitable record of the examinations and tests and of any subsequent repairs for at least five years. The report must also make reference to information about the LEV plant showing its intended operating performance for controlling the hazardous substance. Examples of the details, which should be available, are: Enclosures/hoods - Maximum number to be in use at one time; location or position; static pressure behind each hood or extractor point; face velocity. Ducting - Dimensions; transport velocity, volume flow. Respiratory Protective equipment (RPE) Thorough examination and test of RPE (other than disposable respirators) must be carried out at least once every month and more frequently if conditions are severe. The required frequency should be assessed. Once every three months may be adequate for half-mask respirators used for short periods against low toxicity fumes or dust. The examinations/tests should include: visual examination of all parts of breathing apparatus (integrity of facepieces, straps, filters and valves) tests of any gas cylinders or electric motors in the case of airline-fed RPE, the volume and quality of the supplied air. Records of the examination/test must be kept and any defects must be remedied before use. The record should include: name and address of the employer responsible; particulars of the equipment (make, model, serial number etc); date of examination and name and signature of the person who carried out the test; condition of the equipment (including filters or canisters) and particulars of any defects found; pressure of oxygen or air in cylinders; and 12 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 volume flow and quality of supplied air (airline-fed apparatus). Monitoring of Exposure at the Workplace Employers must ensure that suitable monitoring is carried out where required for maintaining adequate control of exposure or for protecting employees’ health. The requirement for and required frequency of monitoring should be identified during risk assessment. Monitoring is required (except where it is immediately obvious whether control is adequate) if any of the following circumstances apply: failure or deterioration of the control measures could result in a serious health effect, either because of the toxicity of the substance or the potential extent of exposure, or both; measurement is necessary so as to be sure that a workplace exposure limit (WEL) or self imposed exposure standard is not being exceeded; or as an additional check on the effectiveness of any control measure and always for certain specified substances/processes (vinyl chloride monomer and spray from electrolytic chromium processes). Procedures for monitoring Monitoring means the use of valid and suitable occupational hygiene techniques to derive a quantitative estimate of the exposure of employees to hazardous substances. Monitoring must be done by competent persons and will normally involve the collection of a sample (using personal sampling equipment) from the employee’s breathing zone. Sampling may be carried out on a group basis where groups of employees are carrying out similar tasks and exposed to similar risks. Where appropriate, periodic or continuous ‘static’ sampling of the atmosphere in the workplace may be used. Generally, monitoring should be carried out at intervals of 12 months. Occupational health/hygiene textbooks and HSE guidance documents in the MDHS series - ‘Methods for Determination of Hazardous Substances’ provide advice on suitable sampling and analysis techniques. Record of monitoring Employers must keep a suitable record of monitoring: where the record relates to or represents the personal exposure of identifiable employees, for at least 40 years; and in other cases (e.g. static samples) for at least 5 years. The record must provide sufficient information about: when the monitoring was done and the results 13 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 the monitoring procedures used (including duration) the locations where samples were taken, the operations in progress at the time and, in the case of personal samples, the names of individuals concerned. Records must be available to employees or their representatives. Health Surveillance Purpose of health surveillance and situations where it should be provided Health surveillance may involve a range of techniques including suitable medical surveillance by a medical adviser and biological monitoring or biological effects monitoring and is used: so that adverse health effects can be detected in their early stages to assist in the evaluation of the measures taken to control exposure to detect and evaluate health hazards in relation to specific work activities involving biological agents, to assess the immunity of employees. Employees should be under suitable health surveillance where: the exposure is such that an identifiable disease or adverse health effect may be related to the exposure; and there is a reasonable likelihood that the disease or effect may occur under the particular conditions of his work; and there are valid techniques for detecting the disease or health effect. Health surveillance must also be carried out where the employee is exposed to one of the substances specified in Schedule 6 of the regulations. Types of health surveillance Health surveillance may involve: biological monitoring - the assessment of workplace agents in tissues, secreta, excreta, expired air etc biological effects monitoring - the measurement and assessment of early biological effects in exposed workers medical surveillance - clinical examinations and measurements of physiological and psychological effects by or under the supervision of medical adviser or registered medical practitioner inspection, examination or enquiries by a suitably qualified person (e.g. an occupational health nurse) inspection by a responsible person (e.g. chrome ulceration by a supervisor, manager etc) 14 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 review of health records and occupational history during and after exposure - this review should be used to check the correctness of risk assessment findings e.g. in respect of employees exposed to known or suspected carcinogens. Records Where employees are subject to health surveillance, a health record must be kept and maintained for at least 40 years from the date of the last entry made in it. The record must include the following particulars listed in the Approved Code of Practice: Personal details: Surname Forenames Gender Date of birth Permanent address and post code National Insurance number Date when present employment started A historical record of jobs in this employment involving exposure to identified substances requiring health surveillance; Results of all health surveillance procedures, and the date on which and by whom they were carried out - the conclusions should relate only to the employee’s fitness for work and should include, where appropriate: a record of the decisions of the medical inspector or appointed doctor; or conclusions of the medical practitioner, occupational health nurse or other suitably qualified or responsible person. Employees for which health surveillance is required must (in working time and at cost of the employer) present themselves for health surveillance and must furnish the appointed medical adviser with such health information as the medical adviser may reasonably require. Employees must be allowed (at reasonable notice) access to health records that relate to them. Employees may apply to HSE for a review in situations where a medical adviser has recorded a decision to suspend the employee from work, which exposes the employee to hazardous substances. Information and Instruction and Training Employers must provide employees who may be exposed to hazardous substances with sufficient information, instruction and training regarding the: 15 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 nature and degree of risks to health or safety caused by exposure; control measures and other precautions which should be taken and how to use them properly (including the reasons for using any personal protective equipment and the jobs where it is necessary; results of any workplace exposure monitoring (especially if a WEL has been exceeded); and reasons for health surveillance, their duty to attend for health surveillance and information on the collective results (to be provided in a form that does not breach individual medical confidentiality). This information should also be made available to representatives in accordance with the Safety Representatives and Safety Committees Regulations and the Health and Safety (Consultation with Employees) Regulations. Persons (whether individuals or a body corporate) who have duties under the regulations must also have the necessary information, instruction and training to perform their duties effectively. This may require engaging persons from outside the undertaking. In this case the employer will need to ensure that the people engaged receive sufficient information about the circumstances of the work. Fumigations The regulations place restrictions and duties on employers where fumigations are to be carried out. Schedule 8 of the regulations lists the fumigations that are exempt. Schedule 9 identifies the arrangements for notification of fumigations. Prohibited Substances Schedule 2 of the regulations lists substances that are prohibited for certain purposes. Biological Agents Schedule 3 of the regulations deals with special provisions relating to biological agents. Records Records should be kept of the following: risk assessments undertaken thorough examination and tests of engineering control measures maintenance and inspection of engineering control measures maintenance, examination and test of local exhaust ventilation maintenance, examination and test of Respiratory Protective Equipment (RPE) monitoring of exposure at the workplace health records (where health surveillance is required). 16 SWANSEA UNIVERSITY – Document Ref: SWG/001 Issue 002 Further Information Control of Substances Hazardous to Health Regulations COSHH ACOP - (Approved Code of Practice relating to the Control of Substances Hazardous to Health Regulations) Monitoring strategies for Toxic Substances COSHH Essentials EH40 - Workplace Exposure Limits The above guidelines provide advice on the danger associated with hazardous substances and the precautions that should be taken and are intended to be of assistance when undertaking risk assessments and in developing Safe Working Procedures. However, they should not be construed as an exact interpretation of legislative requirements. For additional information, please contact Safety, Health & Environmental Services. 17