o)Risk Management o.1Assessment of current control measures

o)Risk Management

o.1Assessment of current control measures

o.1.1Elimination and substitution

As indicated in Section 7.2.1, there is a declining market for LRP sales and hence AVSR additives due to attrition from the Australian motor fleet of vehicles designed to run on leaded petrol.

By 2004, bulk sales of LRP are expected to decline to less than 5 % of total petrol sales (Australian Petroleum Gazette, 1999). The general provision and sale of bulk LRP by the oil refineries and terminals will become uneconomical at some point. This will eliminate the requirement for refinery or terminal addition of MMT as an AVSR to fuel.

When bulk LRP is phased out, aftermarket addition of AVSR fuel additives rather than bulk treatment by the oil refineries and terminals will become the only option for motorists with vehicles designed to run on leaded petrol. Given the likelihood of a base population of vehicles for which mechanical alteration of engine components to run on unleaded petrol may be prohibitive e.g. vintage vehicles, the total elimination of AVSRs from the Australian fuel market is unlikely and the use of MMT as an aftermarket additive may continue indefinitely.

Several AVSR additives that are potential substitutes for MMT are available on the Australian market (Section 1.1). However, users need to consider the efficacy, cost, health, safety and environmental effects of each in considering these as alternatives for MMT.

o.1.2Isolation and engineering controls

At refineries, MMT is isolated by containment of the MMT isotainer in a special bunded enclosure distant from worker control areas. Engineering controls consist of automatic metering of MMT from the isotainer through enclosed transfer lines to the enclosed blending manifold and finished product tank and similar automatic, enclosed transfer from the LRP finished product tank to terminals or to road tankers. The connection to the dip leg of the isotainer to which transfer lines are fastened is located at the top of the isotainer above fluid level, preventing inadvertent gravity flow and spillage of MMT concentrate during manipulation.

The main isolation and engineering control measure in laboratory areas where quality analyses are conducted is confinement of handling procedures to a ventilated fume cupboard.

Third party formulators

At third party formulators, isolation of MMT occurs by the opening of import drums or cylinders in bunded enclosures. Engineering controls for MMT during formulation consist of pumping via enclosed transfer lines to a closed mixing or storage vessel and subsequent enclosed feeding to automated filling/packing plant. Access bungs are located at the top of the drums or cylinders above fluid level, preventing inadvertent spillage through gravity flow of MMT concentrate during emptying.

In a similar fashion to refineries, the main isolation and engineering control measure in laboratory areas where quality analyses are conducted is confinement of handling procedures to a ventilated fume cupboard.

Petrol stations

At petrol stations, isolation and engineering controls of exposure for MMT are achieved through enclosed transfer hoses for transferring LRP containing MMT from road tankers and storage in underground tanks.

With regards to USTs, there are currently no existing leak prevention or detection requirements for operators of underground fuel storage tanks in all states to detect and control leakages from UST facilities. UST leak detection systems are implemented on a voluntary basis by industry, particularly by major petroleum suppliers.

Aftermarket product use

Engineering controls of exposure for the public and occupational users of aftermarket products containing MMT consist presently of containers with childproof screw caps and long spouts. These long spouts enable sufficient insertion into the fuel filler of the vehicle to minimise backflow and spillage during addition to unleaded fuel.

o.1.3Safe work practices

Refineries operate under a permit-to-work system, which requires job safety audits before work can commence. Professional occupational health and safety personnel available on site typically oversee these. A HiTEC 3062 Product Handling Manual supplied by Ethyl Corporation is used at refineries to provide guidance on storage requirements, blending procedures, handling precautions, maintenance procedures and decontamination and disposal procedures.

The blending and packaging of aftermarket additives are conducted at formulator sites in accordance with internal written standard operating procedures. These procedures incorporate safety and quality control instructions, PPE requirements and first aid directions.

o.1.4Personal protective equipment

The Ethyl Corporation HiTEC 3062 Product Handling Manual used by refineries recommends personal protective equipment for use when handling bulk MMT solution. For normal operations with good ventilation, PPE recommendations include safety glasses or chemical goggles, face shield (when making or breaking connections), light coloured overalls and neoprene, PVC or butyl rubber gloves and boots. In poorly ventilated environments, an organic vapour cartridge respirator is recommended also. In practice at the refinery, rubber gloves, nomex clothing, safety shoes goggles and respirator with an organic vapour cartridge are used during connection and disconnection of transfer lines with imported isotainers.

PPE consisting of protective clothing, gloves and goggles are used during blending and packaging of aftermarket additives.

At petrol stations during unloading of road tankers and the dipping of underground tanks, workers typically wear PPE consisting of protective clothing, footwear and gloves. Auto mechanics with potential exposure to MMT in fuel also use PPE consisting of protective clothing and footwear but gloves or protective eyewear are not typically worn.