ENVIRONMENTAL, HEALTH AND SAFETY GUIDELINES

Effective management of environmental, health, and safety (EHS) issues entails the inclusion of EHS considerations into corporation facility-level business processes in an organized, hierarchical approach that includes the following steps:

  • Identifying EHS project hazards and associated risks as early as possible in the facility development or project cycle.
  • Understanding the likelihood and magnitude of EHS risks, based on:
  • The nature of the project activities, such as whether the project will generate significant quantities of emissions or effluents, or involve hazardous materials or processes;
  • The potential consequences to workers, communities, or the environment if hazards are not adequately managed, which may depend on the proximity of project activities to people or to the environmental resources on which they depend.
  • Prioritizing risk management strategies with the objective of achieving an overall reduction of risk to human health and the environment, focusing on the prevention of irreversible and / or significant impacts.
  • When impact avoidance is not feasible, incorporating engineering and management controls to reduce or minimize the possibility and magnitude of undesired consequences, for example, with the application of pollution controls to reduce the levels of emitted contaminants to workers or environments
  • Preparing workers and nearby communities to respond to accidents, including providing technical and financial resources to effectively and safely control such events, and restoring workplace and community environments to a safe and healthy condition.
  • Improving EHS performance through a combination of on-going monitoring of facility performance and effective accountability.


Point Sources


Point sources are discrete, stationary, identifiable sources of emissions that release pollutants to the atmosphere. They are typically located in manufacturing or production plants. Within a given point source, there may be several individual ‘emission points’ that comprise the point source. Point sources are characterized by the release of air pollutants typically associated with the combustion of fossil fuels, such as nitrogen oxides (NOx), sulphur dioxide (SO2), carbon monoxide (CO), and particulate matter (PM), as well as other air pollutants including certain volatile organic compounds (VOCs) and metals that may also be associated with a wide range of industrial activities. Emissions from point sources should be avoided and controlled according to good international industry practice (GIIP) applicable to the relevant industry sector, depending on ambient conditions, through the combined application of process modifications and emissions controls.

Facilities or projects located within poor quality air sheds, and within or next to areas established as ecologically sensitive (e.g. national parks), should ensure that any increase in pollution levels is as small as feasible, and amounts to a fraction of the applicable short-term and annual average air quality guidelines or standards as established in the project-specific environmental assessment. Suitable mitigation measures may also include the relocation of significant sources of emissions outside the air shed in question, use of cleaner fuels or technologies, application of comprehensive pollution control measures, offset activities at installations controlled by the project sponsor or other facilities within the same air shed, and buy-down of emissions within the same air shed. Specific provisions for minimizing emissions and their impacts in poor air quality or ecologically sensitive air sheds should be established on a project-by-project or industry-specific basis. Offset provisions outside the immediate control of the project sponsor or buy-downs should be monitored and enforced by the local agency responsible for granting and monitoring emission permits. Such provisions should be in place prior to final commissioning of the facility / project.


Reaction, Fire, and Explosion Prevention


Reactive, flammable, and explosive materials should also be managed to avoid uncontrolled reactions or conditions resulting in fire or explosion. Recommended prevention practices include:

  • Storage of incompatible materials (acids, bases, flammables, oxidizers, reactive chemicals) in separate areas, and with containment facilities separating material storage areas
  • Provision of material-specific storage for extremely hazardous or reactive materials · Use of flame arresting devices on vents from flammable storage containers
  • Provision of grounding and lightning protection for tank farms, transfer stations, and other equipment that handles flammable materials
  • Selection of materials of construction compatible with products stored for all parts of storage and delivery systems, and avoiding reuse of tanks for different products without checking material compatibility
  • Storage of hazardous materials in an area of the facility separated from the main production works. Where proximity is unavoidable, physical separation should be provided using structures designed to prevent fire, explosion, spill, and other emergency situations from affecting facility operations Prohibition of all sources of ignition from areas near flammable storage tanks






Physical Hazards


Physical hazards represent potential for accident or injury or illness due to repetitive exposure to mechanical action or work activity. Single exposure to physical hazards may result in a wide range of injuries, from minor and medical aid only, to disabling, catastrophic, and/or fatal. Multiple exposures over prolonged periods can result in disabling injuries of comparable significance and consequence. Rotating and Moving Equipment Injury or death can occur from being trapped, entangled, or struck by machinery parts due to unexpected starting of equipment or unobvious movement during operations.

Recommended protective measures include:

  • Designing machines to eliminate trap hazards and ensuring that extremities are kept out of harm’s way under normal operating conditions. Examples of proper design considerations include two-hand operated machines to prevent amputations or the availability of emergency stops dedicated to the machine and placed in strategic locations. Where a machine or equipment has an exposed moving part or exposed pinch point that may endanger the safety of any worker, the machine or equipment should be equipped with, and protected by, a guard or other device that prevents access to the moving part or pinch point. Guards should be designed and installed in conformance with appropriate machine safety standards.
  • Turning off, disconnecting, isolating, and de-energizing (Locked Out and Tagged Out) machinery with exposed or guarded moving parts, or in which energy can be stored (e.g. compressed air, electrical components) during servicing or maintenance.
  • Designing and installing equipment, where feasible, to enable routine service, such as lubrication, without removal of the guarding devices or mechanisms.


Noise


  • No employee should be exposed to a noise level greater than 85 dB(A) for a duration of more than 8 hours per day without hearing protection. In addition, no unprotected ear should be exposed to a peak sound pressure level (instantaneous) of more than 140 dB(C).
  • The use of hearing protection should be enforced actively when the equivalent sound level over 8 hours reaches 85 dB(A), the peak sound levels reach 140 dB(C), or the average maximum sound level reaches 110dB(A). Hearing protective devices provided should be capable of reducing sound levels at the ear to at least 85 dB(A).
  • Although hearing protection is preferred for any period of noise exposure in excess of 85 dB(A), an equivalent level of protection can be obtained, but less easily managed, by limiting the duration of noise exposure. For every 3 dB(A) increase in sound levels, the ‘allowed’ exposure period or duration should be reduced by 50 percent.65
  • Prior to the issuance of hearing protective devices as the final control mechanism, use of acoustic insulating materials, isolation of the noise source, and other engineering controls should be investigated and implemented, where feasible · Periodic medical hearing checks should be performed on workers exposed to high noise levels.


Eye Hazards


Solid particles from a wide variety of industrial operations, and / or a liquid chemical spray may strike a worker in the eye causing an eye injury or permanent blindness. Recommended measures include:

  • Use of machine guards or splash shields and/or face and eye protection devices, such as safety glasses with side shields, goggles, and/or a full face shield. Specific safe operating procedures may be required for use of sanding and grinding tools and/or when working around liquid chemicals.
  • Moving areas where the discharge of solid fragments, liquid, or gaseous emissions can reasonably be predicted (e.g. discharge of sparks from a metal cutting station, pressure relief valve discharge) away from places expected to be occupied or transited by workers or visitors. Where machine or work fragments could present a hazard to transient workers or passers-by, extra area guarding or proximity restricting systems should be implemented, or PPE required for transients and visitors.
  • Provisions should be made for persons who have to wear prescription glasses either through the use over glasses or prescription hardened glasses.


Working at Heights


Fall prevention and protection measures should be implemented whenever a worker is exposed to the hazard of falling more than two meters; into operating machinery; into water or other liquid; into hazardous substances; or through an opening in a work surface. Fall prevention / protection measures may also be warranted on a case-specific basis when there are risks of falling from lesser heights. Fall prevention may include:

  • Installation of guardrails with mid-rails and toe boards at the edge of any fall hazard area
  • Proper use of ladders and scaffolds by trained employees
  • Use of fall prevention devices, including safety belt and lanyard travel limiting devices to prevent access to fall hazard area, or fall protection devices such as full body harnesses used in conjunction with shock absorbing lanyards or self-retracting inertial fall arrest devices attached to fixed anchor point or horizontal life-lines
  • Appropriate training in use, serviceability, and integrity of the necessary PPE · Inclusion of rescue and/or recovery plans, and equipment to respond to workers after an arrested fall.