Hazard identification for new engineering designs or modifications

A preliminary hazard review should be included as part of the reviews needed for a nuclear facility’s modification preliminary approval to proceed. This allows the modification approvers to consider the potential hazards to be incurred and the potential cost and difficulty of addressing them. It also serves to sensitize the design team and other project team members as to the OSH issues to be dealt with during the design process. Some considerations at this stage can include the following:

(a) Are any new OSH risks being introduced as part of the modification?

(b) What is the probability and severity of the risks being introduced during installation or operation? (Table 21 shows a potential ranking scheme based on one in use by a nuclear operating organization; higher risk modifications based on the scoping receive higher levels of scrutiny during design and during approvals.) (c) Will the design require a pre-start health and safety review (see Section 6.6.4)?

(d) Will the new process or facility impact on existing or require new OSH field equipment or emergency response arrangements (e.g. rescue equipment, emergency showers, fire extinguishers, fire planning and OSH training)?

11 Available at www.unece.org/trans/danger/publi/ghs/pictograms.html

FIG. 31. Examples of facility signage regarding lockout safety (courtesy of W.H. Brady Inc.), hard hat usage (courtesy of China National Nuclear Corporation) and fire prevention (courtesy of Nucleoeléctrica Argentina SA).

FIG. 32. United Nations GHS standard pictograms.

TABLE 20. STANDARD CONTENT OF SAFETY DATA SHEETS ACCORDING TO THE GHS

Safety data sheet section Comments

1. Identification Identification of the substance or mixture (GHS identifier and other unique identifiers)

Supplier’s details (name, full address and phone numbers) Recommended use of the chemical and restrictions on use Emergency phone number

2. Hazard(s) identification Classification of the substance or mixture GHS labels, including precautionary statements Other hazards which do not result in classification 3. Composition/information on ingredients Substances

— Chemical identity

— Common name, synonym of the substance

— CAS number and other unique identifiers

— Impurities and stabilizing additives Mixtures (for all hazardous ingredients)

— Chemical identity

— Identification number

— Concentration range

4. First aid measures Description

Most important symptoms/effects, acute and delayed

If needed, indication of immediate medical attention and special treatment

5. Firefighting measures Suitable extinguishing media

Specific hazards arising from the chemical

Special protective equipment and precautions for firefighters

6. Accidental release measures Personal precautions, protective equipment and emergency procedures Environmental precautions

Methods and materials for containment and cleaning up

7. Handling and storage Precautions for safe handling

Conditions for safe storage (including incompatibilities) 8. Exposure controls/personal protection Control parameters

Appropriate engineering controls

Individual protection measures, including PPE 9. Physical and chemical properties Appearance

Odour and odour threshold

TABLE 20. STANDARD CONTENT OF SAFETY DATA SHEETS ACCORDING TO THE GHS (cont.)

Safety data sheet section Comments

10. Stability and reactivity Reactivity

Chemical stability

Possibility of hazardous reactions Conditions to avoid

Incompatible materials Hazard decomposition products

11. Toxicological information Provide data for all the health hazards covered by the GHS — if data for any of those hazards are not available, they should be listed on the safety data sheets with a statement that data are not available

Information on the likely routes of exposure

Symptoms related to the physical, chemical and toxicological characteristics

Delayed and immediate effects and chronic effects from short or long term exposure

Numerical measures of toxicity (i.e. acute toxicity estimate) Interactive effects

Where specific chemical data are not available Mixtures

13. Disposal considerations Disposal methods

14. Transport information UN Number

UN Proper Shipping Name Transport hazard class Packing group, if applicable Environmental hazards Special precautions for user

Transport in bulk according to Annex II of the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78) and the IBC Code [150]

15. Regulatory information Regulatory information not provided elsewhere in the safety data sheets Safety, health and environmental regulations specific for the chemical in question

16. Other information Date of preparation of the latest version of the safety data sheets Clear indication of the changes made to the previous revision

Key/legend to abbreviations and acronyms used in the safety data sheets Key literature references and sources for data used to compile the safety data sheets

Note: CAS — Chemical Abstracts Service; GHS — Globally Harmonized System of Classification and Labelling of Chemicals;

PPE — personal protective equipment.

Risks identified during this scoping phase should be documented and addressed by the project team as part of the modification design. A design process to help do this, known as a COMS review, is discussed in the next section.

6.3.3.2. Constructability, operability, maintainability and safety reviews

Industrial safety reviews are often performed during the scoping or detailed design phases of a project to help address safety issues prior to them impacting on facility workers. Such reviews can be standalone reviews or be part of modification constructability or the COMS process. The concept is often referred to as ‘safety by design’, and encourages designers to ‘design out’ health and safety risks during early stages of design development. In EU Member States, construction designers are legally bound to design out risks during design development to reduce hazards in the construction and end use phases via the Mobile Worksite Directive [151] (also known as construction, design and management regulations [152] in the United Kingdom).

Design tools such as building information management systems can allow visualizations of key construction activities, and make planning for hazardous activities easier. They can also facilitate the early incorporation of safety elements, such as provisions for fall protection, lift/crane access, temporary access, confined space access and temporary structure planning into initial designs [5].

The CII defines constructability as “the optimum use of construction knowledge and experience in planning, design, procurement, and field operations to achieve overall project objectives” [153]. It involves obtaining current construction expertise at early project stages and incorporating such expertise into the project planning and design stages. A constructability planning workshop is part of the process and attempts to fully exploit construction experience in a timely and structured fashion. Such a workshop covers the use of special construction methods, site logistics, equipment access, site security planning, industrial safety and other aspects.

A COMS workshop takes a similar approach and is used by numerous nuclear operating organizations to confirm that a modification is fit for its purpose. In such a workshop, construction, operations and maintenance expertise is sought for a particular project, which is incorporated into project planning and detailed designs. The project or modification manager typically leads the meeting. A follow-up meeting is typically held to confirm that the issues identified have been satisfactorily addressed. Technical specialists with knowledge of ergonomics, industrial hygiene, human factors, fire protection, chemistry, procurement, training or other areas might also attend the meetings. Of particular interest is to ensure that safety considerations are not compromised during the modification’s construction, operation or maintenance. Such workshops typically follow a structured checklist, identify potential COMS issues and dispositions them as either fully addressed in the design, not relevant to the design, presenting negligible risk as assessed, can be addressed via administrative controls or soft solutions, or cannot be addressed in modification design and contingencies need to be in place. Appendix IV contains a list of sample industrial safety related questions that can be considered for a COMS meeting.

TABLE 21. SAMPLE OCCUPATIONAL SAFETY AND HEALTH SCOPING ASSESSMENT TABLE FOR MODIFICATIONS

Probability

Severity

High

Worker exposed to multiple hazards over a wide variety of non-routine tasks

Medium Worker exposed to a single hazard over a wide variety of non-routine tasks or to multiple hazards for routine tasks

Low

Worker exposed to a single hazard for routine tasks

Source: Canadian Centre for Occupational Health and Safety, www.ccohs.ca/oshanswers/hsprograms/hazard_control.html