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Kia ora koutou
Welcome to the fourth WorkSafe High Hazards newsletter where we’re covering:
- Lone Workers
- Emergency Response Planning
- Testing Scully High Level Probes
- Steel storage racking standard update
- Compliance Certifier Authorisations
- Incidents in the news
Please continue to share this newsletter with your colleagues, including your company’s Health and Safety Representatives. Only one key contact per site was signed up to the first edition’s mailing list.
If you have a question or any suggestions, please email HighHazardsNewsletter@worksafe.govt.nz
Ngā mihi nui,
Nick Dawtry, Liam Gannon and Geoff Taylor – Deputy Chief Inspectors
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Recently High Hazard inspectors conducted a series of unannounced visits to businesses that had the potential to be MHF sites. The businesses involved genuinely welcomed the opportunity to engage with WorkSafe and learn more about the management of hazardous substances and the MHF regulatory regime. The visits highlighted a knowledge gap about MHF specified substance quantity thresholds.
An interesting point identified by inspectors was that for some businesses, the quantities of certain hazardous substances that they were able to store as listed on their Location Compliance Certificate, put them into the MHF regime, most were storing well below the quantities stipulated on the certificate.
If your facilities are likely to exceed the MHF lower tier threshold then you are required to notify WorkSafe. More information on the notification process is available here Major Hazard Facilities: Notifications and Designation
My advice to industry is that if you have no intention to store or use specified substances over MHF threshold levels, you should speak to your compliance certifier and reduce the allowable levels specified on the Location Compliance Certificates, to below MHF thresholds.
Ngā mihi,
Dave Bellett
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Lone Working Devices
Genesis has rolled out intrinsically safe lone worker devices for filler / drivers delivering to remote areas and for bottle fillers where lone working is a regular occurrence. They use Guardian Angel - Blackline devices but there are other options available. Feedback from worker engagement sessions has been overwhelmingly positive. There are other operators who could benefit greatly from this, and recent inspections have shown there is a low level of awareness that these devices are available.
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Emergencies take place in real-world environments, often complicated by unanticipated events. To simulate this, WorkSafe has become aware of significant efforts by some operators to stress-test their emergency response plans by adding real-world considerations, for example:
- Hiring persons to pose as media personnel to simulate external influences, or to actively attempt to gain entry into an MHF to test security systems
- Adding props to emergency scenarios, such as fake medical injuries to increase worker engagement
- Escalating emergency scenarios to involve offshore partners to assess the adequacy of such support systems.
Going beyond average muster in the carpark at 9am emergency evacuations and instead finding creative ways to simulate emergencies (including escalation) can provide valuable insights regarding your organization’s emergency response readiness.
(See MHF regulations 31 - Duty to prepare emergency plan and regulation 32 Duty to test emergency plan).
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MHF Bulk Terminal Operators should consider asking for recorded evidence of any checks/adjustments made to the tanker Scully overfill probes. This could include asking for the standard (Petroleum Industry Transport Safety Forum) form “NZ Oil Industry – Overfill Probe Setting Form” to be completed each time tanker Scully switches are checked. This will help terminal operators assure themselves that tanker Scully switches are set correctly and that a suitable record is obtained and documented for future reference.
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Racking at major hazard facilities and petroleum/geothermal installations typically has different structural requirements than standard racking, since the racking is typically storing hazardous materials capable of causing hazardous conditions.
An important racking standard, AS 4084:2012, has been superseded by:
- AS 4084.1:2023 Steel Storage Racking Design and
- AS 4084.2:2023 Steel Storage Racking Operation and Maintenance
You should check that the competent person performing your formal inspections is also aware of the new standards and ask if any of the changes would affect your racking. They should now be carrying out their annual assessments against the new standard.
The 2023 standards do not require retrospective application, however they do form the basis of minimum controls for racking and are “what ought reasonably
to known”. Where any changes are easily incorporated they would be considered reasonably practicable.
Other relevant Standards and guides for racking are:
- AS/NZS 1170.0:2002 - Structural design actions - General
- NZS 1170.5:2004 Structural design actions – Earthquake actions – New Zealand
- The BRANZ Design Guide – Seismic Design of High Level Storage Racking Systems with Public Access.
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Does your Compliance Certifier’s authorisation allow them to certify your facility?
It’s an unusual question, isn’t it?
But did you know that not all compliance certifiers can undertake the types of compliance certification you may require for your location and stationary containers.
Compliance certifiers are limited in the types of certificates that they are authorised to issue and may have conditions applied to their authorisation.
The compliance certifiers database contains this information. It is updated every time a compliance certifier’s authorisation changes. It is important that you know what work a compliance certifier can undertake for you.
A change to an authorisation may affect the type of work that a compliance certifier may be able to do, even if they have certified your facility in the past.
So don’t risk your compliance. Check the database today and make sure you read all the terms and conditions regarding your compliance certifier’s authorisation.
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