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Health and SafetyExecutive
Andrew Hall HID CI 1G HM Specialist Inspector (Mechanical)
Case 1: North West Aerosols
Gas house 1 had been isolated from the LPGsupply to use compressed air for filling aerosols
The LPG manifold connections used to supplyLPG to the filling lines were only isolated by apneumatically operated control valve
The only other valve on the line was a manuallyoperated ball valve that had been left open
The LPG supply manifold pipe work had not beenblanked off as per BAMA recommendations (selfseal, quick release couplings) representing goodpractice
MAH’s are prevented by layers of protection -Some were in place but others were not:
Gas detection was thought to be non-functional
Control valves were defeated - (HS(G) 253recommends that control valves are not generallysuitable for isolations)
No end caps on manifold
Manually operated valve left open
Line change-over procedures were not followed
No specific isolation procedure
North West Aerosols ceased trading
Criminal Prosecution returned ‘Guilty Verdict’
Crown Court made financial checks andimposed a nominal penalty
Judge indicated a £250,000 fine for thecompany had it still been trading
Loss of Reputation
Civil Litigation
The Health and Safety at Work etc Act 1974 Section 2 (1) says: "It shall be the duty of every employer to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees.“
Section (2) (a) says: "The provision and maintenance of plant and systems of work that are, so far as is reasonably practicable, safe without risks to health"
Loss of Containment of 20 to 35 te ofMethanol when filling tank - ship to shore
This incident had the potential to be aCOMAH major accident
½” drain valve had been left open andunplugged after maintenance work to fit aROSOV and new valve on a thermal reliefline
½” drain valve
Human error, inadequate management systems andinadequate safe system of work
Work authorisation was poorly completed, with no detailsof valves to be replaced, tank isolations, reference todrawings P&ID’s
Method statement for work raised without training - It did not identify the isolation of valves or checks to return thesystem to a safe condition
The completed permit was not signed off as beingcompleted. Despite the permit remaining open for work tobe carried out on the tank, the site permitted the filling ofthe tank from the ship
Chlorine gas was introduced into a plant during a routineshort duration plant shutdown
The chlorine entered ducting and entered the workshop viaa fan housing
This resulted in a chlorine release into the workshop
The chlorine gas also reacted with hydrocarboncontamination within the ducting that resulted in a local fire
The level of gas present adjacent to the housing wasthought to be substantial enough to cause fatal injury to any unprotected individual.
Chlorine gas supply was not isolated effectively
The power operated shutoff valve used to isolate thechlorine gas was passing and the manually operatedisolation valve was left open
Chlorine gas entered the towers main extraction system,built up and migrated to the adjoining extraction system ofthe steel dissolver vessel because the tower extractsystem wasn’t running
The Chlorine gas (heavier than air) flowed down thedissolver extract duct (only intended for hydrogen and air)and collected at the fan housing at ground level
The gas vented into the plant from the fanhousing
The gas exothermically reacted withhydrocarbon deposits in the ducting causing asmall fire
Estimated LoC was 50kg/hr Chlorine Gas overa 21 minute period