Commonwealth of Australia 2010
Current Environmental Risk Management
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- 71.1General environmental controls and monitoring
- 71.2Major hazard facilities (MHF)
- 71.3Dangerous goods management
- 71.3.1Storage and handling of dangerous goods
- 73.Australian Standard applying to storage and handling
- 73.1.1Transportation of dangerous goods
- 74.Land transportation of dangerous goods
- Further comments on road transport in WA
- 75.Air transportation of dangerous goods
- 76.Sea transportation of dangerous goods
- 76.1.1Packaging specifications for dangerous goods
- 76.1.2Complementary state/territory legislation
- 76.1.3Procurement of sodium cyanide
71.Current Environmental Risk ManagementThis chapter discusses measures that have been implemented or are being implemented to reduce the likelihood of adverse environmental effects from exposure to sodium cyanide and its products. The inherent hazards of cyanide are generally well known and there is a range of established government and industry environmental controls covering the lifecycle of sodium cyanide from manufacturing, storage, handling, transportation and uses through to waste management (including waste emplacement facilities). In addition to measures applying in Australia, international and overseas legislation are also discussed, where appropriate. The following topics are discussed in this chapter:
References in the report that have not been sighted are marked with an asterisk(*). 71.1General environmental controls and monitoringIn Australia, the activities involving manufacturing, procurement, industrial use, storage, handling, transportation and discharge of sodium cyanide to the environment are controlled by state and territory regulations. These regulations pertain to major hazard facilities, dangerous goods, safety and emergency procedures, emissions, waste management and protection of the environment, and are enforced by means of a system of conditional permits, licenses and warrants. In addition, the major industry groups, such as chemical manufacturers and mining and metal extraction industries, have established self-regulating programs for occupational safety and environmental protection. These include environmental management systems (EMS) (e.g. Ticor, 1996) under ISO 14000 or equivalent, quality assurance/control (QA/QC) systems, safety and environmental management (SEM) systems, Standards and Codes of Practice. Within the industry, and there is a general philosophy of continuous improvement through the Responsible Care® program and other industry initiatives. 71.2Major hazard facilities (MHF)Major Hazard Facilities (MHF) are one of seven priority hazard issues identified by the Commonwealth Government for which the Safe Work Australia (formerly the Office of the Australian Safety and Compensation Council (OASCC) or the National Occupational Health and Safety Commission (NOHSC)) maintains a national standard and a national code of practice. These are the National standard for the control of major hazard facilities [NOHSC:1014(2002)] and the National code of practice for the control of major hazard facilities [NOHSC:2016(1996)], both initially declared in 1996 (NOHSC, 2002a). A MHF is an area where an activity takes place involving specified materials nominated in Schedule 1 of the National Standard by NOHSC (1996a). Facilities that manufacture, store, handle or use >20 tonne per annum of NaCN (solid or liquid form) or HCN are classified as MHFs. This means that the MHF legislation includes not just the two Australian sodium cyanide manufacturing facilities, but also extends to storage facilities, and most ore processing sites using NaCN. There has been existing legislation to protect employees, the community and the environment from the hazards associated with normal industrial operations, but the operation of a MHF can create hazards of a scale and type which was not necessarily covered by existing legislation. Hence there was a need for controls designed to eliminate the underlying and immediate causes of major accidents and to limit their consequences (NOHSC, 2005ab). In 2001, Workplace Relations Ministers Council (WRMC) endorsed five strategies (and three related actions) to achieve national consistency in MHF regulation and assigned responsibility for progressing achievement to OASCC. The strategies are:
The related actions include consistency in who regulates MHFs, monitoring implementation in each jurisdiction, and risk based cases for exemption. To address the WRMC strategies, a Major Hazards Facilities Implementation Reference Group (MHFIRG) was formed consisting of representatives of the state, territory and Commonwealth jurisdictions and employer and employee representatives. To provide guidance, a review of key differences between states, territories and the Commonwealth at the time was undertaken (NOHSC, 2002b). Implementation of legislation/regulations giving effect to the National Standard for the Control of Major Hazard Facilities is complete or well advanced in all states and in the Northern Territory. Priority is being given to other regulations under the Dangerous Substances Act 2004 in the ACT, where there are currently no facilities which would be classified as MHFs.
72.National Standard applying to storage and handlingThe National standard for the storage and handling of dangerous goods [NOHSC: 195(2001)] sets out requirements to ensure the effective control of the storage and handling of dangerous goods, including NaCN, so as to protect the safety and health of workers and the public as well as the protection of property and the environment. This standard was also produced by the OASCC/NOHSC. As with other national standards and codes of practice produced by the OASCC, these are guidance and advisory documents only, and may be adopted by governments in the state and territory regulations to make up part of their Occupational Health and Safety (OHS) framework (http://www.ascc.gov.au/ascc/AboutUs/LegalFramework/ accessed May 2007). The introduction to the documentation for this Standard (NOHSC, 2001a) explains the nature of the Standard as follows: In terms of managing the storage and handling of dangerous goods, the national standard marks a significant change in approach. The national standard replaces current prescriptive requirements with a performance-based approach incorporating the principles of hazard identification, risk assessment and risk control. This approach includes a storage and handling system which covers the risks associated with the premises where any dangerous goods are stored and handled, as well as the risks associated with the use of any container, tank, vehicle or freight container, spill containment system, plant and fire fighting and fire protection systems used on premises, in connection with the storage and handling of dangerous goods. The national standard provides a framework within which individual Commonwealth, state and territory regulatory authorities can develop workplace regulations so that a nationally consistent regulatory regime can be achieved. To that end OASCC established two administrative mechanisms to facilitate the development of a nationally consistent regime:
Traditionally, dangerous goods legislation has extended beyond the workplace to address public safety and the environment. OASCC recognises that for non-workplaces the performance and duty-based approach applied to various hazards in the workplace may not be appropriate. Therefore, in declaring this national standard, OASCC states that it intends that for non-workplaces, the performance-based approach will be only the framework within which regulation of non-workplaces will operate. It is envisaged that individual jurisdictions may need to supplement the requirements of the national standard with more prescriptive requirements to ensure public safety where dangerous goods are stored and handled in non-workplaces. The National standard for the storage and handling of dangerous goods is accompanied by the National code of practice for the storage and handling of workplace dangerous goods [NOHSC: 2017 (2001)] (NOHSC, 2001b), which provides practical advice on compliance for those who have duties under the national standard. The National code of practice for the storage and handling of dangerous goods also provides the information and guidance for the storage and handling of dangerous goods as minor quantities, and as consumer packages supplied by retailers. Each Australian state and territory provides statutory controls on storage, handling and transport of dangerous goods. Table 11. provides a list of primary state and territory legislation and guidance.
This Standard is referred to by various regulations, codes of practice and other guidance pertaining to the storage and handling of NaCN. For example, the Standard is referred to as one of various secondary codes of practice incorporated as part of the draft WA Storage and handling of Dangerous Goods Code of Practice (WA DCEP, 2006), and in regard to bunding and spill management, the NSW DECC (NSW EPA, 2005) indicates that ‘where applicable, the construction of bunds must comply with the requirements of AS/NZS 4452:1997: The storage and handling of toxic substances’. This Standard does not apply to the transport on land of toxic substances, which is covered by the ADG Code, or storage in port areas. Storage of dangerous goods in port areas is covered by Australian Standard AS 3846-2005 The handling and transport of dangerous cargoes in port areas. Each state and territory provides legislative controls in accordance with AS 3846-2005.
The NTC is responsible for maintaining regulations on the transport of dangerous goods by land within Australia. In developing policy and legislation relating to the transport of dangerous goods by road and rail, the NTC has been advised by a representative group of industry sectors and appropriate government regulatory authorities. The NTC produces model legislation which is then copied or referenced by jurisdictions to produce operational law in their respective States and Territories. The NTC also has responsibility for the production of the Australian Dangerous Goods Code. This Code is a reference document setting out detailed technical and procedural requirements for a range of activities performed in the day-to-day preparation for and transportation of dangerous goods by either road or rail. The 6th Edition of the Australian Dangerous Code (ADG 6) has been reviewed and the technical requirements in the latest version (ADG 7) brought up to date with the 15th edition of the United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations (NTC, 2007). ADG 7 is supported by a revised legislative framework consisting of a Model Act, and a model set of regulations (or Model Subordinate Law). The Model Act on the Transport of Dangerous Goods by Road or Rail replaces the Road Transport Reform (Dangerous Goods) Act 1995 (Commonwealth). The Model Subordinate Law on the Transport of Dangerous Goods by Road or Rail replaces the existing Road Transport Reform (Dangerous Goods) Regulations 1997 and the Rail (Dangerous Goods) Rules and underpins the Code. ADG 7 has been implemented in most jurisdictions this year (as of August 2009), with a transitional period of up to 12 months, and is expected to be implemented by the remaining jurisdictions by the end of 2009 (Department of Infrastructure, Transport, Regional Development & Local Government, pers. comm., 2009). Technical advice on the application of the ADG Code is obtained through the ‘Competent Authority’ appointed in each state or territory for road and rail, air, or sea transport (NTC, 2008b). If a matter covers more than one state or is for an extended period, it will normally be referred to the Competent Authorities Panel (CAP).
Australian Standard AS 1678.6.0.002-1998 (Standards Australia, 1998) provides emergency procedures for the management of incidents that may occur during domestic land transportation of sodium cyanide. The Standard describes the chemicals hazards, protective clothing, emergency procedures, and first aid in the event of a transportation accident involving sodium cyanide. Due to the potential human and environmental health risks during transportation, major transportation issues are incorporated within state and territory environmental impact assessment legislation, such as the Transportation Route Study Review by the Western Australian Environment Protection Authority (EPA WA, 1987). The National Road Transport Commission (NRTC, 2003) has prepared guidance for the preparation of transport emergency response plans to identify the necessary resources, personnel and logistics which allow for a prompt, coordinated, and rational approach to a transport incident. In addition to such a plan, it is stressed that continual appraisal using table-top and simulation exercises, regular updating of equipment, contact lists, and training of personnel are needed to improve the capability to successfully respond to transport emergency situations, and that liaison and communication with emergency and security services along the transport route is a critical element in the development of the plan. Northern Territory WorkSafe have indicated that the principal transporters of sodium cyanide in Australia no longer use triple road-trains for the transport of solid sodium cyanide in containers. The mode of road transport used currently is either double road-trains with end-loading containers or road-trains with tank containers on drop decks. Tank containers are transported as triples. They note that both of these configurations would be considered lower risk
Under EPA requirements in WA, wherever possible transport of liquid NaCN from the Kwinana factory is required to be by rail, except where goldmines cannot be serviced practicably and/or efficiently by rail from Kwinana, or rail services are temporarily unavailable (EPA WA, 2004). Thus for the Eastern Goldfields, sodium cyanide is transported from the factory to Kalgoorlie by rail and then distributed by road, but transport may occur directly by truck to northern areas. Various requirements have been in place as part of the conditions for the transport of sodium cyanide from the Kwinana manufacturing site (EPA WA, 2004). These have included liaison with Local Government Authorities, relevant government departments, state emergency authorities and local emergency management advisory committees, including setting up emergency plans and training programs, consistent with the recommendations of NRTC (2003) discussed above. Vehicles are equipped with means of 2-way communication, equipment and materials in accordance with an approved emergency response plan, and provision and maintenance of stocks of neutralising agent at the manufacturing plant and along the main transport routes at agreed locations for use in emergencies. Ferrous sulphate is recommended as the preferred neutralising agent for offsite incidents and hydrogen peroxide for use within the plant, but information in EPA WA (2004) indicates that sodium hypochlorite may be used under strict direction from the manufacturer. The legislation under which these provisions have applied in WA has changed with the introduction of national ADG legislation (EPA WA, 2004). Similar measures apply to varying degrees in other states and territories through their respective legislation complementing the ADG legislation. However, the WA requirements appear more comprehensive and detailed. 75.Air transportation of dangerous goodsThe transportation of dangerous goods by air is administered by the Civil Aviation Safety Authority (CASA). Sodium cyanide is generally not transported by air in Australia; however, small quantities are imported by airfreight as a minor component of electroplating solution. 76.Sea transportation of dangerous goodsA large component of sodium cyanide manufactured domestically (~40%-60%) is exported by ship to many countries, and a much smaller quantity is imported by ship into Australia for domestic uses. The Australian Maritime Safety Authority (AMSA) is responsible for the management of the transportation of dangerous goods by ship. Shipping safety and pollution from ships is managed at a National level by AMSA. Australia is a member of the International Maritime Organisation (IMO), and a signatory to the International Convention for the Prevention of Pollution from Ships 1973, as modified by the Protocol of 1978 (MARPOL 73/78; Department of Foreign Affairs and Trade, 1988a) that controls operational pollution and introduces measures to mitigate the effects of marine pollution. MARPOL 73/78 covers pollution by chemicals. The International Maritime Dangerous Goods (IMDG) Code, published by the International Maritime Organisation (IMO, 2000), provides guidance and standards for transport of dangerous goods by sea. IMO's Intervention Convention affirms the right of a coastal state to take measures on the high seas to prevent, mitigate or eliminate danger to its coastline from a maritime casualty. The 1990 International Convention on Oil Pollution Preparedness, Response and Co-operation (Department of Foreign Affairs and Trade, 1995) provides a global framework for international co-operation in combating major incidents or threats of marine pollution. Sodium cyanide has an IMO classification of 6.1.
ADG 7 provides specifications for intermediate bulk containers (IBCs) for the transport of dangerous goods. IBCs for containing and transporting dangerous goods must comply with these specifications and other legislative requirements. Composite IBCs as used for NaCN are packed in freight containers, providing several layers of protection for the contents. For example, CIBCs used by CSBP’s Kwinana plant contain NaCN briquettes in a polythene bag which is contained in a hermetically sealed plastic liner in a plywood outer box, and the CIBC has to meet specifications such as a drop test (Fozdar pers. Comm. 2005; Peirce, pers. comm. 2006). Under EPA requirements in WA, isotainers used by CSBP to transport liquid NaCN are manufactured to meet Australian and international codes and are comprised of a tank mounted in a steel frame. These are fitted to flat-top rail wagons (2 per wagon on standard gauge rail) or road trailers (a single isotainer per trailer) by twistlocks designed to ensure that in the event of a derailment the container will remain secured to the wagon. They are provided with safety features including the use of top loading and discharge, a pressure relief device, an integral ruggedised steel frame enclosure and additional strengthening around the loading/discharge point to provide roll-over protection (EPA WA, 2004). The StoL containers developed by Orica for transport of solid NaCN for sparging at the point of delivery (Section 4.2.2) have also been designed to Australian and International standards and the ADG and IDMG Codes (http://www.orica-miningchemicals.com accessed May 2007). Other Australian Standards also relate to containers used for the transport of dangerous goods and may therefore apply to sodium cyanide, including AS 2809.1-2008 (Road tank vehicles for dangerous goods - General requirements for all road tank vehicles) and AS 2809.4-2001 (Road tank vehicles for dangerous goods - Tankers for toxic and corrosive cargoes), and AS ISO 16106-2007 (Transport packages for dangerous goods - Dangerous goods packagings, intermediate bulk containers (IBCs) and large packagings - Guidelines for the application of ISO 9001).
Table 11.. Primary dangerous goods legislation and guidance
76.1.3Procurement of sodium cyanideThroughout Australia, procurement (purchase) of sodium cyanide is illegal without a license issued by state and territory Health Departments under various regulations pertaining to poisons including:
Control of procurement provides a means for minimising the risk of sodium cyanide being obtained and used inappropriately. No incidents of inappropriate acquisition in Australia were identified during this assessment. Directory: data -> assets -> word doc -> 0017 0017 -> National Industrial Chemicals Notification and Assessment Scheme word doc -> Priority Existing Chemical word doc -> Rail safety news issue 6 – October 2011 word doc -> Review of Multiple Chemical Sensitivity: Identifying 0017 -> Rail Safety News Edition 8, December 2012 0017 -> Real-Time License Plate Localisation on fpga 0017 -> Careers network bulletin issue 6 July 16 2012 0017 -> Wiser science: Finding References inspec for Physics and Engineering 0017 -> Part A: Depth Study: The globalising world Popular culture and public policy Download 2.29 Mb. Share with your friends:
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