Claude Thackwray of MHR ( Major Hazard Risk ) Consultants gave a presentation at the GCCA Africa Risk & Insurance seminar in Johannesburg earlier this year . The following article is derived from his presentation , edited by Eamonn Ryan .
ASSOCIATIONS
Major hazard risks in cold chain installations
Claude Thackwray of MHR ( Major Hazard Risk ) Consultants gave a presentation at the GCCA Africa Risk & Insurance seminar in Johannesburg earlier this year . The following article is derived from his presentation , edited by Eamonn Ryan .
Major hazard risk assessments play a crucial role in ensuring the safety and security of hazardous installations in the cold chain . While some clients may perceive these assessments as costly and unnecessary , it is essential to recognise the potential dangers associated with the storage and processing of hazardous substances , particularly ammonia in the case of refrigerants . This presentation aims to shed light on the importance of risk assessments in the cold chain and provide an overview of relevant legislation , regulations , and guidelines .
LEGISLATION AND INDUSTRY TYPES
Within hazardous industries , there are two primary types of installations : storage facilities and processing plants . Storage facilities involve contracts with suppliers who store and deliver substances like ammonia . These installations pose a significant risk of explosions and other catastrophic events . On the other hand , processing plants , with their complex operations , involvement of multiple individuals , and movement of equipment and materials , are more prone to incidents .
LEGISLATIVE FRAMEWORK
Definition : ‘ Acts ’ are pieces of statutory legislation that have been passed by Parliament which means that they are laws . An example is the Occupational Health & Safety Act 85 of 1993 ( OSH ).
To ensure the safety of workers and the public , legislative frameworks govern major hazard risk assessments . The OSH Act serves as the foundation for legal prosecution . Additionally , various departments issue regulations that provide detailed guidelines based on this Act . Major hazard regulations , promulgated by the Department of Employment and Labour
On 31 January 2023 , the Minister of Employment and Labour published new Major Hazard Installation Regulations under the Occupational Health and Safety Act 85 of 1993 ( OHSA ).
( DEL ), offer comprehensive instructions specific to hazardous installations . These regulations are further complemented by guidance notes , publications , and codes of practice , which provide industry best practices and guidelines for complying with the regulations .
Definition : Regulations are supplementary to acts . They link to existing acts , and they are designed to aid a person to apply the principles of the primary act . Essentially , they are formal guidelines . An example is the Major Hazard Installation Regulations .
The most recent code for Major Hazard Risk Assessments ( MHRA ) was issued in 2018 . It serves as the standard for preparing assessment reports , ensuring consistency and adherence to regulations . Departments also offer explanatory notes that assist in the interpretation of regulatory provisions . Compliance with these regulations is crucial , as non-compliance may lead to prosecution under legislation such as the OHS Act .
Regulations evolve over time to address emerging challenges and improve safety standards . Recently published MHRA regulations reflect ongoing efforts to refine the guidelines . However , implementing new regulations can be complex , and it may take several years for comprehensive explanatory notes to be issued . Despite these challenges , it is essential for industries to stay informed and adapt to the changing landscape of major hazard risk assessments .
RISK ASSESSMENT AND EMERGENCY PLANNING STANDARDS
Risk assessment and emergency planning go hand in hand when it comes to major hazard management . Standards defined by the OSH Act provide clarity on what constitutes a major incident . It involves the storage of a prescribed quantity of substances that have the potential to cause catastrophic consequences .
On 31 January 2023 , the Minister of Employment and Labour published new Major Hazard Installation Regulations under the Occupational Health and Safety Act 85 of 1993 ( OHSA ).
These latest MHRA regulations , introduced in January of this year , emphasise the contractual obligations of facilities to ensure adequate safety measures . The risk assessment requirements vary depending on the level of hazard , with higher risk installations necessitating more substantial investments . What is new ? Quantities of dangerous goods are now listed in three tiers :
• Low hazard : 15 tons
• Medium hazard : 50 tons
• High hazard : 200 tons
© All photos by Eamonn Ryam | Cold Link Africa
Some considerations are :
• Most accidents in the ammonia industry occur at refrigeration plants
• Most refrigeration plants fall below the low hazard quantity
• Most injuries and deaths happen at refrigeration plants that are below the low hazard quantity
• Of all types of installations , process plants have more accidents than storage plants because of the operational nature of processing
This raises the question of whether a risk assessment is necessary at a plant with less than five tons of hazardous material ? If an employee was seriously injured or killed as the result of a loss of containment of a dangerous substance on your site , it means that you had a quantity or handled it an a such a way that it caused a ‘ major incident ’.
Lizelle van der Berg , director , GCCA Africa .
DEFINING CATASTROPHIC PROPORTIONS
In 2001 , explanatory notes were introduced to guide risk assessors in determining catastrophic proportions . However , there are differences of opinion regarding the definition . While some may consider any potential loss of life or significant damage to a building as catastrophic , the DEL specifically highlights the involvement of a member of the public as a key criterion . This involvement can include scenarios where prompt actions , such as evacuating people , are necessary . Risk assessments play a vital role in determining when and how to carry out such measures , ensuring public safety .
The legislation surrounding major hazard risk assessments evolves to address emerging challenges . The fee structure introduced by the DEL in the
The crowd attending the GCCA Africa Risk & Insurance seminar in Johannesburg earlier this year .
6 www . coldlinkafrica . co . za COLD LINK AFRICA • November 2023