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C3 completes another full site DSEAR Assessment

C3 Technical are pleased to announce the completion of another full site DSEAR Assessment, looking at the requirements of Regulations 5 through 11 for one of our clients, including the generation of a Hazardous Area Classification based on 300+ discrete release points and addressing the site’s historical over reliance on ‘Blanket Zones’, an approach the UK regulator no longer considers as Recognised Good Practice.


Consultant fined for providing incompetent health and safety advice

A self-employed consultant was fined for breach of legislation for providing health and safety advice on technical and complex matters while not being qualified to advise his clients.

Luton Crown Court heard how a self-employed health and safety consultant provided inadequate and flawed advice to small and medium sized enterprises on the management and control of risk in relation to hand arm vibration, work place noise and the control of substances hazardous to health.

A HSE investigation found that Clive Weal incorrectly identified risk from exposure to hand arm vibration as ‘low’ and advised to use ‘anti vibration gloves’ as an appropriate control measure. He also failed to identify that paints containing isocyanates can cause asthma. The poor and incompetent advice resulted in a lack of remedial action being implemented to prevent employees being exposed to levels of noise, hand arm vibration and chemical substances that may have a damaging impact on their health.

Clive Weal of Torksey, Lincolnshire, was found to be incompetent at advising his clients in the assessment and control of risks from workplace noise, hand arm vibration and substances hazardous to health. He pleaded guilty to breaching Section 3(2) of Health and Safety at Work Act 1974 and was fined £1,400.

After the hearing, HSE specialist inspector, Parmjit Gahir said: “Employers are more likely to use external consultants to provide assistance in complex situations where a higher level of competence is required.

“How consultants achieve competence is up to them, however they will have to be able to satisfy employers that they have a sufficient level of competence for the job in hand.

“Being a member of a relevant professional body, which sets competence standards for its members and operates continuing professional development schemes is one way of helping; as is presenting evidence of relevant experience such as references from previous clients; or obtaining qualifications.”

Where health and safety consultants are found to be in breach of legislation, HSE will hold persons to account for their failings.


CSB Video of Fertiliser Explosion in West, Texas

U.S. Chemical Safety Board Releases New Safety Video, "Dangerously Close: Explosion in West, Texas,” Detailing Report Findings and Recommendations on 2013 Fatal West Fertilizer Company Explosion and Fire.

January 29, 2016, Washington, DC – Today the U.S. Chemical Safety Board (CSB) released a safety video into the fatal April 17, 2013, fire and explosion at the West Fertilizer Company in West, Texas, which resulted in 15 fatalities, more than 260 injuries, and widespread community damage. The deadly fire and explosion occurred when about thirty tons of fertilizer grade ammonium nitrate (FGAN) exploded after being heated by a fire at the storage and distribution facility.

The CSB’s newly released 12-minute safety video entitled, “Dangerously Close: Explosion in West, Texas,” includes a 3D animation of the fire and explosion as well as interviews with CSB investigators and Chairperson Vanessa Allen Sutherland. The video can be viewed on the CSB’s website and YouTube.


Buncefield - 10 Years On

In the early hours of Sunday 11th December 2005, a number of explosions occurred at Buncefield Oil Storage Depot, Hemel Hempstead, Hertfordshire. At least one of the initial explosions was of massive proportions and there was a large fire, which engulfed a high proportion of the site. Over 40 people were injured; fortunately there were no fatalities.

Ten years on from the Buncefield major incident, the COMAH Strategic Forum has produced a short report summarising the improvements which have been made and the work which is ongoing in large bulk petroleum storage sector and other major hazard industries to help ensure that an accident on the scale of the Buncefield explosion should not happen again.

The report can be found on the HSE's website:


HSG 176 - Second Edition, 2015 out now!

The HSE has recently issued a revised version of HSG 176 'The storage of flammable liquids in tanks' (Second edition, 2015)

This guidance applies to above and below ground fixed bulk storage tanks. It applies to premises where flammable liquids are stored in individual tanks or groups of tanks. It may also be applied to portable or skid-mounted vessels with capacities in excess of 1000 litres.

It also gives guidance on the design, construction, operation and maintenance of installation used for the storage of flammable liquids in fixed and transportable tanks operating at or near atmospheric pressure.

It will help you assess the risks arising from the use of flammable liquids and decide how to control those risks.

The guidance has been updated to align with the recommendations of the Buncefield report.


HSG 176 is available to download, free of charge from the HSE's website.


New CSB Video - Gasoline Tank Overfill

CSB Safety Video on the 2009 massive explosion at the Caribbean Petroleum, or CAPECO, terminal facility near San Juan, Puerto Rico. The incident occurred when gasoline overflowed and sprayed out from a large aboveground storage tank, forming a 107-acre vapour cloud that ignited. While there were no fatalities, the explosion damaged approximately 300 nearby homes and businesses and petroleum leaked into the surrounding soil, waterways and wetlands. Flames from the explosion could be seen from as far as eight miles away.


HSG 51 - Third Edition, 2015 out now!

The HSE has recently issued a revised version of HSG 51 'The storage of flammable liquids in containers' (Third edition, 2015)

This guidance is for those responsible for the safe storage of flammable liquids in containers at the workplace. It applies to storage of flammable liquids in containers up to 1000 litres capacity.

It explains the fire and explosion hazards associated with flammable liquids and will help you determine how to control the risks in your workplace.

In recognition of the diversity of premises in which flammable liquids are stored and/or used, the guidance now contains discrete topic areas which outline the potential risks and recommended control measures for a number of different types of business.

HSG 51 is available to download, free of charge from the HSE's website.


HSG 140 - Second Edition, 2015 out now!

The HSE has recently issued a revised version of HSG 140 'Safe use and handling of flammable liquids' (Second edition, 2015)

This guidance is for those responsible for the safe use and handling of flammable liquids in all general work activities, small-scale chemical processing and spraying processes.

It explains the fire and explosion hazards associated with flammable liquids and will help you determine how to control the risks in your workplace.

The revised document incorporates information and cites relevant standards in relation to the following publications which have been withdrawn:

  • HSG113 - Lift trucks in potentially flammable atmospheres;
  • HSG158 - Flame arresters: Preventing the spread of fires and explosions in equipment that contains flammable gases and vapours;
  • HSG178 - The spraying of flammable liquids.

HSG 140 is available to download, free of charge from the HSE's website.

1 October 2015

COMAH 2015 Compliance

All Upper Tier sites need to demonstrate compliance with COMAH 2015 by 31 May 2016, which means that the majority of sites have to submit an addendum to their COMAH Safety Report or even completely revise it.

The deadline may seem a long way off for a change that can be seen as minor, but an early start is always beneficial as a COMAH review inevitably grows beyond its original scope.  The required changes under COMAH 2015 are subtle but may initiate other changes – e.g. can you explicitly demonstrate that you have considered lessons learned from accidents with similar substances and/or similar plant?

Here at C3 we are already working with our clients to determine the extent of the changes that apply to them.  Like many other people we thought that the alignment with CLP would result in only administrative changes to Safety Reports, but we have seen a surprising number of reclassifications that have resulted in new major accident hazards.

There are also changes that could affect the contents of your MAPP and associated section of your COMAH Safety Report, on subjects such as continuous improvement, subcontractors, ageing plant and audit and review.

You may also take the opportunity to carry out an interim review of your Safety Report in order to reduce the workload at the next 5-year Review stage, or just review your risk assessment to take credit for recent risk reduction initiatives.

Clear, Concise Compliance:  Whatever your scope, C3 personnel have been helping sites with COMAH compliance for 15 years offering advice that is proportionate to your hazards, size and budget.  Call us now for a no-obligation visit to discuss your situation and how we can help.

Many COMAH sites also have an action on their Intervention Plans that refers to the CDOIF (Chemical and Downstream Oil Industries Forum) guidance ‘Environmental Risk Tolerability for COMAH Establishments’.  The COMAH Competent Authority now considers this to be a benchmark standard and expects that COMAH sites consider the CDOIF guidance when carrying out or reviewing their environmental risk assessments.  This could be neatly tied into your COMAH 2015 review, especially if you exceed the Upper Tier thresholds for environmental hazards.

Although the CDOIF guidance may seem lengthy and onerous, it can be distilled into a series of tables and could provide financial benefits to many sites due to the more realistic tolerability boundaries that reflect a lower environmental risk.   A more accurate and proportionate environmental risk assessment will result in better informed ALARP decisions; targeting financial resources more effectively and avoiding unnecessary spend.

We have already completed many CDOIF assessments that have been well received by the EA / SEPA.


New CSB Video - DuPont La Porte Chemical Release

CSB animation of the accident at DuPont’s La Porte facility, located east of Houston, which killed four workers and injured a fifth when methyl mercaptan, a toxic chemical used in the company’s insecticide and fungicide manufacturing process, was released.