Tannery effluent pit gas release

Tick each point that your answer made clearly and only once. Points here are this site's own. A real examiner may accept other valid points.

• A risk assessment identifies the hazards, who may be harmed and what precautions are needed, so that decisions on control can be made.
• The assessments at Noorani are six years old, are one page for each department and do not mention the effluent pit or the mixing of chemicals, so they are out of date and do not cover the most serious hazards.
• The assessment should identify hazards such as the release of hydrogen sulphide when acid meets sulphide, skin and lung harm from chemicals, chromium exposure, the pit as a confined space and falls into the open pit.
• It should identify who is at risk, including the workers in the drum area, the contract workers who clear the pit, the storekeeper, the maintenance fitters and anyone who has to rescue another.
• It should assess the likelihood and severity of harm, taking into account the controls that exist, such as the cover on the pit and the labels, which were not working.
• The complaints of headache and dizziness in month 1 and the burn in month 2 were warnings that the risk was real and known.
• Safety data sheets should be used to find the hazards of each chemical and the incompatibilities between them.
• It should consider the hierarchy of control, such as eliminating the need to enter the pit, substituting less harmful chemicals and keeping incompatible substances apart.
• The assessment should be done by a competent person who talks to the workers, because they know how the chemicals are really used.
• Significant findings should be recorded and an action plan with owners and dates should be made.
• The assessment should be reviewed after changes to the process, after incidents and near misses, and at planned intervals.
• The results should be explained to workers, including contract workers, in a language that they understand, and the controls should be checked.

Practice points counted: 0 of 12

Tick each point that your answer made clearly and only once. Points here are this site's own. A real examiner may accept other valid points.

• Eliminate or substitute where possible, for example by using a less hazardous chemical for dehairing or a process that gives off less gas.
• Store the chemicals in a purpose built store with a floor that holds spills, and keep acids away from sulphides and other incompatible substances, on separate shelves or in separate rooms.
• Label every container with the name and the hazard in a language that the workers read, and never refill unlabelled containers.
• Keep safety data sheets in a place where workers can reach them, in a language that they understand, and train workers to use them.
• Provide good ventilation in the store and in the process areas, with local exhaust ventilation where fumes are given off.
• Use closed systems and enclosed pipes for the transfer of chemicals, so that workers do not pour them by hand.
• Give suitable protective equipment, such as chemical resistant gloves, goggles, aprons, boots and respirators that fit, free of charge, with training in how to use and maintain it.
• Provide emergency eyewash and showers close to the places where chemicals are handled.
• Never pour acids into drains that carry sulphide liquor, and set up a written procedure for the disposal of waste chemicals and spills.
• Put in place a procedure for spills, with absorbent material, trained people and the correct way to dispose of the waste.
• Monitor the exposure of workers with air tests and arrange health surveillance, such as checks of skin and lungs.
• Keep records of the chemicals, the quantities, the incidents and the health checks, and review them regularly.

Practice points counted: 0 of 12

Tick each point that your answer made clearly and only once. Points here are this site's own. A real examiner may accept other valid points.

• The pit is a confined space, because it is enclosed and can contain gas and a lack of oxygen, with a risk of serious harm or death.
• There was no written procedure for entry, so workers relied on custom and were told that the pit was safe.
• There was no permit to work, no gas test and no check that the acid and sulphide would not be mixed during the work.
• There was no gas detector, no harness and lifeline, no breathing apparatus, and no one outside to watch.
• There was no rescue plan, so two workers entered to help without equipment and were also overcome.
• The first step is to avoid entry, for example by using a vacuum tanker, a pump or a design that allows the sludge to be removed from the outside.
• Where entry cannot be avoided, the work should be planned, assessed and done under a permit that states the task, the hazards, the precautions and the time limit.
• The permit should require the isolation of the drains and pipes that lead to the pit, so that no liquid or acid can enter while people are inside.
• The atmosphere should be tested before entry and monitored during the work for hydrogen sulphide, oxygen and other gases, using a calibrated instrument.
• Assess and provide suitable ventilation and atmospheric monitoring for any unavoidable authorised entry, with defined evacuation criteria. Ventilation or an acceptable gas reading does not address inflow, access, machinery or rescue hazards by itself.
• A trained attendant should stay outside, in contact with the person inside, with the authority to raise the alarm, and who must never enter to rescue.
• Select any harness, retrieval and respiratory equipment through competent task-specific entry and rescue planning, considering the actual access and hazards. A tripod/winch or breathing apparatus is not automatic permission to enter or a guarantee of safe recovery.
• Only trained and authorised workers should enter, and contract workers should be included in the training.
• The cover should be fixed and locked when the pit is not in use, with signs that warn of the danger, and the system should be audited.

Practice points counted: 0 of 14

Tick each point that your answer made clearly and only once. Points here are this site's own. A real examiner may accept other valid points.

• The bonus for exports and the pressure to ship the order show that production is put before safety.
• There are no figures for accidents or near misses, and the accident book was not used for the burn in month 2, so reporting is poor.
• Warnings, such as the headaches in month 1 and the open pit cover in month 3, were ignored or dealt with only by a verbal warning.
• The safety policy names no one, and the safety officer's duties were given to the EM, who has a conflict of roles.
• Contract workers fear that they will lose their work if they report a problem, and have to pay for gloves, so they do not feel valued or safe.
• Senior managers should set out and sign a policy that gives safety a high priority and names the people who are responsible for each task.
• They should change the targets and the bonus so that safety measures are included and output is not the only reward.
• They should appoint a competent safety adviser with the authority to stop unsafe work.
• They should be visible on the site, take part in safety talks, and act on the reports that they receive.
• They should consult workers and contract workers, and set up a way of reporting hazards and near misses without penalty.

Practice points counted: 0 of 10

Tick each point that your answer made clearly and only once. Points here are this site's own. A real examiner may accept other valid points.

• Employers must give workers the information, instruction and training needed to work safely, and it should be matched to the risk and to the worker.
• Induction should be given before work starts and should cover the hazards of the chemicals, the layout, the rules, the alarm and the emergency procedure.
• The induction should be in the languages that the workers speak, with pictures, signs and demonstrations as well as talks.
• Workers who handle chemicals should be trained in the hazards, the labels, the safety data sheets, the correct way to mix and pour, and the use of protective equipment.
• They should be told never to mix acids with sulphides and why, and should know the signs of gas exposure such as smell, headache and dizziness.
• Workers who may enter the pit should be trained in confined space entry, the permit system, gas tests and rescue.
• Supervisors need training in their role, in the control of the chemicals and in how to respond to reports, and they should not be allowed to order an unsafe task.
• Contract workers should receive the same training as employees, and Noorani should agree in writing with the labour provider who is responsible for what.
• Refresher training should be given at intervals, and after changes and incidents.
• Training should be recorded, and its effectiveness should be checked by observation and by questions.
• Communication can be improved with notice boards in simple language and with pictures, regular safety talks, and a system for reporting hazards.
• Safety data sheets and emergency numbers should be displayed where workers can see them, in the right languages.

Practice points counted: 0 of 12

Tick each point that your answer made clearly and only once. Points here are this site's own. A real examiner may accept other valid points.

• An emergency plan should be based on the risk assessment and cover events such as a gas release, a chemical spill, a fire and a person trapped in the pit.
• The plan should name people with roles, such as the incident controller, the rescue team, the first aiders and the person who calls the emergency services.
• The alarm at Noorani was a hand bell that workers could not find, so it should be replaced by an electric alarm that is heard throughout the plant and tested.
• Gas detectors with alarms should be fitted in the areas where gas could collect, such as near the pit and in the drum area.
• Rescue arrangements should be ready before any entry, with trained rescuers, breathing apparatus, a tripod and winch, and the aim of rescue without entering.
• Workers should be told not to enter to rescue another without the equipment, since many of the dead in such events are rescuers.
• Emergency numbers should be correct, in the right languages and displayed where they can be seen, and all supervisors should know them.
• An evacuation route and a muster point upwind of the gas should be marked and known to everyone, with a roll call.
• Drills should be held at intervals and used to improve the plan, and there had been none since the plant opened.
• First aid should match the risk, with trained first aiders on every shift and equipment for chemical burns and for gas exposure, such as oxygen and eyewash.
• A first aid room should be provided, and a plan for transport to the hospital that is 30 minutes away.
• The emergency services should be told about the chemicals and the site, and should be invited to take part in exercises.
• After an emergency the site should be made safe, evidence should be preserved and workers should be counted and given care.
• The plan should be reviewed after every event and drill, and workers should be offered support after a traumatic incident.

Practice points counted: 0 of 14

Tick each point that your answer made clearly and only once. Points here are this site's own. A real examiner may accept other valid points.

• The aim of an investigation is to find the causes so that a repeat can be prevented, not to find a person to blame.
• The first step is to give care to the injured, make the scene safe and call the emergency services, and then to preserve the evidence.
• Information should be collected from the scene, photographs, the log of complaints, the training records, the safety data sheets and witness statements.
• The team should include a manager, a supervisor and a worker representative, with the right competence, and outside experts may be needed.
• Witnesses should be interviewed soon, separately and with care, since they are in shock, and in a language they understand.
• The team should build a timeline and look for immediate, underlying and root causes.
• Immediate cause: acid was poured into a drain that carried sulphide liquor, which released hydrogen sulphide into the pit.
• Immediate cause: a worker was in the pit without a gas test, a lifeline, breathing apparatus or an attendant, and was overcome.
• Immediate cause: the rescuers entered without protection and were overcome, because there was no rescue plan or equipment.
• Underlying cause: there was no safe system of work or permit for the pit, and the storage and disposal of the chemicals were not controlled.
• Underlying cause: the workers had not been trained about the chemicals, the labels were missing and the safety data sheets were not available.
• Underlying cause: the warnings in earlier months were not acted on, and the supervisors ordered the work under pressure to ship the order.
• Root causes include a poor safety culture, no competent safety adviser and unclear responsibilities.
• The team should make recommendations with an action plan with owners and dates, and the findings should be shared with all workers and reported to the authority as the law requires.

Practice points counted: 0 of 14

Tick each point that your answer made clearly and only once. Points here are this site's own. A real examiner may accept other valid points.

• Moral: a worker died and others were hurt at work, and nobody should lose their life or health because of their job.
• Moral: the family of the dead worker has lost its income and a loved one, and colleagues may be affected by the distress for a long time.
• Moral: Noorani has a duty of care to contract workers as well as employees, and they are often the most vulnerable.
• Legal: employers have a duty to provide safe plant, safe systems of work, safe storage and use of chemicals, information, instruction, training and supervision.
• Legal: the failures at Noorani are likely to breach these duties, and the authority may issue a notice or prosecute.
• Legal: managers and directors may be personally liable.
• Legal: the injured workers or the family may bring a civil claim for compensation.
• Financial: the direct costs include the closure of the pit and the plant, damage, the clean up and the cost of the investigation.
• Financial: the delay of the export order may lead to lost income, penalties from the buyer and loss of future orders.
• Financial: fines, compensation and higher insurance can be large, and some costs, such as loss of trust, cannot be recovered.
• Financial: good health and safety management reduces losses and improves productivity and the retention of workers.
• Reputation: buyers who import leather often check labour and safety standards, and a fatal accident may damage the name of Noorani.

Practice points counted: 0 of 12