MODERN DAY HAZARDOUS SUBSTANCE CONSENTS AT TRINITY STREET
Regulating Hazardous Substances
In order to regulate and upgrade the use of dangerous substances in industry, the UK Government enacted the Control of Major Accident Hazards Regulations 1999 and the Amendment Regulations 2005, commonly referred to as COMAH. These regulations amended the Planning (Hazardous Substances) Regulations 1992.
COMAH regulations and related guidance supposedly aims to prevent major accidents involving dangerous substances and to limit the consequences to people and the environment of any that do occur. This includes:
- Identifying installations that store or use a threshold amount of hazardous substances (Lower tier and Top tier)
- Providing guidelines on the prevention of accidents through the control of substances (Major Accident Prevention Plans, Safety reports)
- Providing guidance on mitigating the effects of hazards, including the effect on the environment and neighbouring sites, through the development of emergency plans.
In the European Union Material Safety data sheets have been made an integral part of the system of Regulation (EC) No 1907/2006 (REACH).
The SDS follows a 16 section format which is internationally agreed and for substances especially, the SDS should be followed with an Annex which contains the exposure scenarios of this particular substance.The SDS must be supplied in an official language of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide(s) otherwise (Article 31(5) of REACH).
These are :
- Identification of the substance/mixture and of the company/undertaking
- Hazards identification
- Composition/information on ingredients
- First aid measures
- Firefighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/personal protection
- Physical and chemical properties
- Stability and Reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport Information
- Regulatory information
- Other information
Risk and safety statements, also known as R/S statements, R/S numbers, R/S phrases, and R/S sentences, is a system of hazard codes and phrases for labeling dangerous chemicals and compounds. The R/S statement of a compound consists of a risk part (R) and a safety part (S), each followed by a combination of numbers. Each number corresponds to a phrase. The phrase corresponding to the letter/number combination has the same meaning in different languages. An explanation of these Risk and safety phrases can be found HERE.
Much information can be gleaned from these sources of information concerning hazardous substances used at establishments such as that at Trinity Street. Unfortunately this information was not available to local residents over many decades of hazardous chemicals being released into the environment from this site.
Though the hazardous substances at the plant and the effluents produced have not changed that greatly, the new legislation meant that Albright and Wilson and latterly Rhodia have had to declare and apply for consents to store certain “hazardous substances” at the site. The legislation assured an exclusion zone or CONSULTATION ZONE of 2km around the works had to be introduced within which there were restrictions on schools, hotels and businesses.
Some applications previously came under the influence of The Black Country Development Corporation, given that Trinity Street lay within its area, but are now decided by the local authority, Sandwell Council. Though the Health and Safety Executive (HSE, Environment Agency (E.A) and West Midlands Fire Service are consulted on such matters, these organisations appear to have offered little in the way of considered responses, judging by the associated replies available on Sandwell Council’s Public Access website. Additional quantities of hazardous substances applied for appear only to question the basis of whether the increase would substantially increase the risk to off site receptors. It should perhaps be noted that ANY existence let alone increase of such dangerous chemicals are already putting people at risk.
Though the applications themselves have to be “publicly advertised”, there is nothing in the way of detailed description, and Rhodia appear to do little more than the minimum to satisfy this criteria. An example of a hazardous substance consent HS/034 buried in the Express and Star classifieds can be found HERE. Note that members of the public are invited to contact the the HSE manager at Rhodia directly, rather than making any informed investigations to the planning authority for the application. Is it really in the interests of the business applicant to tell people living locally that these are “very dangerous chemicals”?
A Summary of hazardous substance consents and amended consents stored and used at the Trinity Street Plant in chronological order is explained on these pages. These are important to understanding the products made at the site, and the subsequent waste generated from these activities. We hope that residents living locally to the Trinity Street site can get a bettter flavour of what lies on their own doorstep, and also appreciate that much of this cocktail ended up being mixed and blended in the effluent treatment plant with the next stop being Rattlechain lagoon.
Next time you look up to read the time at the main entrance, perhaps save some time to consider what lies on the doorstep of Langley, and ponder just who allowed it to be there.
As they say in these parts, “It ay saif ah kid.”
TIME AND CHEMICALS WAIT FOR NO MAN