If the role of security is to protect the assets and functions of the organisation, hazardous items on site are not only of safety and regulatory concern, but also a security issue because:
- they can be attractive and therefore subject to theft, and
- they can lead a small event, like a fire or explosion, to become a catastrophic event putting life and the business at risk.
This article addresses the overlaps between safety, compliance and security, and then provides additional considerations for managing hazardous items and processes.
Common use materials, such as cleaning products, are attractive items because they are accessible. Staff may see it as acceptable to take such items, particularly as the company buys them in bulk at a price well below those available to the individual. Staff and contractors may even see it as a ‘perk of the job’ to take materials home, in the same way office workers may be inclined to take stationary items home for personal use. Other items that are attractive and therefore exposed to theft include fuel, gardening supplies and pool chemicals.
Other hazardous material may be expensive or difficult to obtain, therefore making it attractive for personal use or on-selling. Chemicals, including cleaning agents, can be used as the basis for powerful explosives and for developing poisonous gases. Similar concerns exist for materials that can be diverted to support illegal drug manufacturing. Some of these are governed by regulations on controlled substances; the monitoring of which has led to the arrest and conviction of drug manufacturers and bomb makers. As regulatory controls become tighter, the attractiveness of these materials increases. Therefore, businesses need to be able to demonstrate to the Executive, investigative agencies and possibly the Courts, their awareness of the risks and responsibilities as well as application of adequate and appropriate controls.
Hazardous items should be secured from unauthorised access to prevent theft. Ideally they should only be released in quantities that can be controlled and monitored as determined by the operating environment of the site. If materials must be issued in large quantities, other control measures can be implemented, for example: comparing shifts or work teams to detect unusual consumption or patterns. Access controls should be applied to all attractive hazardous stores, not just those specified by regulation.
Another option is to accept the concept of “employees’ rights in property”. If adopting this system, it is important to:
- define the boundaries, for example: how much of a 20 litre drum is considered ‘remainders’?
- ensure the policy is clear, well distributed and understood, and
- make clear any penalties for those found abusing the privilege.
Different standards and policies may be required for in-house staff and contracted staff.
Facility and Security Managers are aware of the need to safely and legally store materials which are deemed ‘hazardous’. Many dangerous goods are identified under the HAZMAT regulations which specify the correct storage and use. From a security and emergency management point of view, HAZMAT addresses only part of the problem.
There are many materials and processes that while normally safe, become dangerous when acted upon by hazards such as fire or an explosion. These items can be considered ‘Secondary Hazards’.
Examples of Secondary Hazards include:
- HAZMAT items
- High pressure steam lines
- Gas lines
- High voltage lines and sub-stations
- Pressure vessels and their control systems
- Molten metals, plastics and similar materials
- Others specific to each site.
In some industries, such as in the petro-chemical refineries, Secondary Hazards are well known and recorded. On other sites, Secondary Hazards may not be as obvious as they are seen as part of the normal operating environment and may be unnoticed until a review is undertaken. Some items, while in their normal quantities are considered safe, when concentrated can become hazardous. For example: party poppers, pressure cans, gardening and pool chemicals. Again such considerations are often addressed under HAZMAT regulations but managers need to be aware of when, and how, such concentrations can occur on their sites, even temporarily. Some hazards are mobile, such as refuel trailers and welding cylinders; there is a need to know the location of these hazards.
Special events can change the hazard status of a site. Therefore, secondary, as well as primary hazards, such as pyrotechnics, should be reassessed. Examples include an increase in the number of:
- cooking oils and gas cylinders used by food vendors
- vehicles with fuel tanks and oils
- power supplies
- storage of additional chemicals
- flammable display materials.
If there is an incident, the responding emergency services need to know what and where the Secondary Hazards are. This is of particular interest to fire services and bomb squads. The Security/Facility Manager should be able to answer, among other questions, “what is on the other side of that wall and what will happen if the fire/explosion gets to it?”
Examples of Secondary Hazards:
- During a bomb disposal exercise, a small 0.5kg (training) device was placed on the controls for a large industrial boiler. Access to the device was difficult, and tested the bomb technicians’ flexibility in both body and thought. However, the primary intent of the exercise was for the technician to determine what would occur should control over the boiler be lost. The engineers advised that the resultant explosion would be catastrophic, affecting major transport corridors and suburbs. It took some hours to safely close down the boiler and days to flash it up again. This meant that the company would have been out of business for about a week. It should also be noted that the controls for the boiler were not to be left unattended; therefore, the decision to evacuate the site was not a simple one.
- One bomb disposal task involved a reasonably small bomb in a laboratory; possibly placed by a disgruntled employee. The problems in this situation were not only the known hazardous material stored in the lab, but also the gas lines and high-voltage lines on the other side of the wall from the bomb.
- A site with a large water feature stored a tonne of chlorine to save delivery costs. The material was safely stored near the filtering and pump rooms. The consequences, should a fire have occurred, were considerable. Advice was provided that the resultant toxic gasses would have generated a significant down-wind hazard to the CBD and surrounding areas. In addition, that quantity of chlorine would have changed the nature of the fire. The solution was to store on-site, only enough chlorine required for one day, and the changes to the delivery costs were minimal.
Consideration of Secondary Hazards may also alter emergency management planning. The Emergency Control Organisation needs to understand the hazards created by leaving production processes unattended and the time taken to close them down in a safe manner. Some industries construct on-site bunkers or off-site control rooms to enable critical processes to be monitored and managed during an emergency.
Most industries that move molten metals, plastics and similar material have considered, from a business continuity perspective, the implications of an emergency shut down and evacuation. Consideration is not always given on how an unexpected release of molten material from an explosion can change the nature of the incident immediately.
To manage hazardous materials and Secondary Hazards, Security Managers may consider the following:
- Conducting a security assessment of hazardous materials to identify those that might be subject to theft, by whom and why.
- As part of the security assessment, review access and procedural/accounting controls over attractive hazardous materials to reduce shrinkage and also to be able to demonstrate ‘due care’.
- Identify those items and processes on-site which are potential Secondary Hazards and ask “what if this was ruptured, damaged or stopped?”
- Document what Secondary Hazards are, where and why they are of potential concern.
- Consider if the items and processes are needed and if so, is the amount held really appropriate?
- Share the information and seek the opinion of managers responsible for: safety, security, emergency management, compliance, HR and production.
- Have the documents showing the location and nature of the Secondary Hazards available where they can be provided to the responding emergency services, including after hours.
- Monitor the Secondary Hazards as the type and location will change in response to operational needs, variations in production techniques and changes in the materials themselves.
HAZMAT and Secondary Hazards exist. Organisations need these materials and processes to carry out their functions and usually they are perfectly safe – until something goes wrong. Knowing what they are and where they are will reduce losses, save lives, protect the business and prevent the statement “well I wasn’t expecting that to happen”.
This article was originally published in facility perspectives Aug 10 Vol4 No2