Management of Hazardous Substances

Management of Hazardous Substances

1 INTRODUCTION
Singapore is an island of about 620 square kilometres in area. The average population density in Singapore is about 4,000 people per square kilometre. Such high population densities make it imperative for hazardous substances to be controlled so that public exposure to accidental release is, if not avoided, minimised.
In addition, large parts of Singapore are used as water catchment areas. It is necessary to ensure that chemical storage facilities and transport avoid such areas as far as possible. This is to prevent pollution and to protect drinking water sources against contamination.
The awareness of the hazards or risks posed to both human health and the environment from the manufacturing, storage, transport, and use of hazardous chemicals has come about in recent years as a result of a number of reported major industrial accidents in both developed and the developing countries. Two well known catastrophic incidents occurred in the mid 1980s in the less developed countries. These were the release of toxic methyl isocyanate from a pesticide factory in Bhopal, India and the explosions and fires at an LPG installation in Mexico. Both incidents caused great losses of lives.
In Singapore, the Government has implemented measures to control and minimise the risks from industrial developments handling large quantities of hazardous substances not only to protect workers within the hazardous plants but also the general public and the environment.
Pollution Control Department (PCD) of the National Environment Agency controls toxic and environmentally hazardous chemicals under The Environmental Protection and Management Act (EPMA) and The Environmental Protection and Management (Hazardous Substances) Regulations.
Flammable petroleum products in Singapore are controlled under the Fire Safety Act by the Fire Safety & Shelter Department (FSSD) of the Singapore Civil Defence Force (SCDF).
Radioactive substances are controlled by the Centre for Radiation Protection and Nuclear Science (CRPNS).
2 POLLUTION CONTROL DEPARTMENT
CONTROL STRATEGIES
The hazardous chemicals controlled by PCD (see Table 1) are those that:

• Pose a mass-disaster potential
• Are highly toxic and polluting
• Generate wastes which cannot be safely and adequately disposed of

In Singapore, the control of hazardous chemicals are implemented mainly through the following measures:

• Planning control
• Licensing control
• Enforcement

PLANNING CONTROL
On new developments, PCD checks and ensures that new residential and industrial developments are properly sited and are compatible with surrounding land use. PCD also imposes environmental pollution control requirements to be incorporated into designs of developments to minimise pollution and to mitigate pollution impact on surrounding developments.
The Jurong Town Corporation (JTC) and Housing Development Board (HDB) are developing agencies for industrial land and premises and they consult PCD on the allocation of industrial premises. PCD assesses and evaluates the environmental impact of the proposed industries to ensure that they do not pose unmanageable health and safety hazards and pollution problems. A proposed industry will be allowed only if emissions of pollutants can comply with standards, wastes can be safely managed and properly disposed of, and the factory can be sited in a suitable industrial estate.
For major developments, PCD requires developers to carry out pollution control assessment for their proposals. Examples of major developments include industries involving the use or storage of hazardous chemicals in bulk quantities, port development, landfill site, etc. The study includes an assessment of all pollution impact on the environment and recommendation of measures to mitigate such impact. PCD will issue clearance to the proposed development only if its evaluation of the study reports confirms that pollution impact could be mitigated to acceptable levels.
In addition, PCD encourages industries to reuse, recycle and recover their by-products to minimise waste generation. Disposal of wastes by landfill is only used as a last resort. For proposed industrial developments, PCD also checks and ensures that clean technology is adopted in industrial processes to conserve resources, and minimise pollution.
After a proposed development has been granted planning approval, a developer can proceed to submit building plans to the Building Control Division (BCD) of the Public Works Department for approval. Under the current procedure on building plan approval, the developer is also required to submit building plans to technical departments including PCD for clearance on technical requirements. PCD checks the building plans of the development for compliance with technical requirements on environmental health, drainage, sewerage and pollution control. In addition, PCD also checks and ensures that pollution control measures are incorporated into the design of buildings.
After the completion of a development, PCD inspects it to ensure compliance with technical requirements before granting clearance to BCA for the issue of Temporary Occupation Permit (TOP)/Certificate of Statutory Completion (CSC) to the completed development.
Industries are required to apply for written permission, licence and permits from PCD before they can start operation.
LICENSING CONTROLS
Licensing controls are implemented under the Environmental Protection and Management Act (EPMA) and the Fire Safety Act. The licensing controls prevent unauthorised persons from handling such substances and ensure proper safeguards are taken at all times in the handling of the substances to prevent accidental releases and mitigate the adverse effects if they occur.
The following Licensing Controls over the import, transport, storage and use of hazardous substances are implemented under The Environmental Protection and Management Act (EPMA) and its Regulations:
Hazardous Substances Licence Control
Any person who wishes to import, sell or export any hazardous substance controlled under the Environmental Protection and Management Act (EPMA) must obtain a Licence.
A licence will be issued to a person if:

• he could show proof that the Hazardous Substances will be stored safely in an approved location and in compliance with the storage requirements;
• the use of the Hazardous Substances at his factory has been approved;
• he has sat and passed the Management of Hazardous Substances Course conducted by Singapore Environment Institute (SEI); and
• his academic qualification must be at least a technical diploma.

Hazardous Substances Permit Control
Any person who wishes to purchase, store and/or use any hazardous substance controlled under the Environmental Protection and Management (Hazardous Substances) Regulations must obtain a Permit.
A Permit will be issued to a person if:

• he could show proof that the Hazardous Substances will be stored safely in an approved location and in compliance with the storage requirements;
• the use of the Hazardous Substancesat his factory has been approved; and
• he has declared that he has read and understood the Environmental Protection and Management Act (EPMA) and its Regulations.

The Licence/Permit application form is in Annex 9. In addition, the public can submit an electronic application for a Hazardous Substances Licence/Permit via the Internet. The Internet address is: http://app1.env.gov.sg/pcls/index.jsp
Transport Approval Control
Any person who wishes to transport any hazardous substance in quantities exceeding those specified in the Environmental Protection and Management (Hazardous Substances) Regulations (see Table 2) must obtain a Transport Approval. The limits varies from 0 kg for highly toxic chemicals such as organochlorines pesticides to 1000 kg for corrosives such as sulphuric acid.
A Transport Approval will be issued to a person if:

• he holds a Licence to handle hazardous substances,
  he could show proof that the Hazardous Substances will be transported safely in compliance with the transportation requirements.

The licence holder can also submit an application for a Hazardous Substances Transport Approval via the internet.
Import Control
The most effective stage of control to ensure that all chemicals that enter Singapore can be and will be safely managed and handled at all times by approved competent licence holders is at the import stage.
Under the Environmental Protection and Management Act (EPMA), all import of Hazardous Substances listed under Second SchedueI of the Act must be approved by PCD. PCD will approve the import only if:

• the Hazardous Substances are stated in the importer's licence,
• there is a valid transport approval for the Hazardous Substances if the Hazardous Substances are to be transported out of the port.

TECHNICAL REQUIREMENTS UNDER LICENSING CONTROLS
The Environmental Protection and Management Act (EPMA) and its Regulations provide provisions for technical requirements to be imposed and complied with to ensure the safe management and handling of hazardous substances and to prevent an accident from occuring. These technical requirements are briefly described below.
Storage Requirements
The storage area should be sheltered; fenced-up; under lock and key; provided with kerb/hump all round the storage area; provided with fire protection and safety facilities; equipped with leak detection and warning devices and emergency scrubbing systems for storage of toxic gases.
The containers and storage tanks for the chemicals must be designed, manufactured and tested in accordance to an internationally-acceptable standards.
Hazardous Substances Licence and Permit holders must keep records of stock movements of the hazardous substances in accordance to the formats specified by PCD.
Adequate emergency action plan (see Annex 1) for dealing with any accidental release of chemicals must be drawn; with adequate stock of emergency equipment such as neutralising agent, adsorbents, oversized drums, protective gears, etc on kept on standby.
The implementation of a safety audit procedure is strongly encouraged to systematically identify and rectify weaknesses in the management system and practices of handling hazardous chemicals on a regular basis. Attached are the elements that should be audited and a list of consultants that are able to conduct such audits. (see Annex 2 & 3)
Transport Requirements
The containers and tankers used for bulk chemical transportation must be designed, manufactured and tested in accordance to an internationally-acceptable standards. The tankers must be certified by an approved third party inspection body to have met the stipulated standards (see Annex 4) before it can be used for transportation on Singapore roads.
The containers, tankers and vehicles must be properly labelled and carry appropiate hazard warning panels.
All transportation of controlled Hazardous Substances must strictly adhere to NEA's approved routes and must be between 9.00 am and 5.00 pm (Monday to Saturday excluding Sundays and Public Holidays).
All drivers must be trained in the handling of accidental spills and have attended the HazMat Driver Course conducted by SCDF's Civil Defence Academy or Singapore Port Institute (PSA Institute). Drivers renewing their Hazardous Material Transport Driver Permit (HTDP) are required to attend  the HazMat Driver's Course once every 2 years.
An adequate transportation emergency response plan (TERP) (see Annex 5) must also be put up to deal with any accidental release of the hazardous substances; with adequate stock of emergency equipment carried on the vehicles; such as chemical fire extinguisher, neutralising agent, adsorbents, oversized drums, protective gears, etc.
The consignor has to prepare a set of instructions for the carrier or transport company containing the following :-

• information on the hazards of hazardous substance and safety precautions for its safe handling,
• restrictions on the mode of transport and any necessary routing instructions,
• special operational requirements for loading, unloading and transport or a statement that none is needed,
• emergency response plan for transportation of the hazardous substances.

The carrier is required to obtain a set of the above instructions from the consignor and be conversant with the information it contained before proceeding to transport the consignment of the hazardous substance. The carrier must instruct and train his driver to ensure he understood the instructions given and is capable of carrying them out effectively. All documents pertaining to the chemicals transported (i.e. MSDS, transport approval and all emergency response, spill control and first aid equipment) should be kept within ready reach in event of emergency.
The consignor has to ensure that the instructions given to the carrier are accurate and sufficient to enable the carrier to carry out the transportation safely. The consignor is also required to be present on-site to personally deal with any chemical release during transportation.
Tanks of road tankers and tank containers used for transporting hazardous substances must meet approved standards of design, construction and testing. The design of the tanks must be reviewed and its construction surveyed by an approved third party inspection body. Once the third party inspection body is satisfied that the tank or tank container meets the approved standards, it will issue an initial inspection certificate. Under the approved standards, the tank and tank container must undergo periodic inspections.
The following standards are acceptable:

• European Agreement of Road Transport of Dangerous Goods (ADR Standards)
• United Nations Recommendations on the Transport of Dangerous Goods (UN Standard)
• International Maritime Dangerous Goods Code (IMDG Code)
• United States Code of Federal Regulations (US-DOT Standards)

The carrier needs to ensure that the vehicle and its tanks or containers are properly labelled in accordance to the Singapore Standards 286, 'Cautionary Labelling for Hazardous Substances'.
Labels are given for each class of hazardous substances and should be affixed on packagings and the vehicle. Road tankers and vehicles carrying hazardous substances in tank containers should have Emergency Information Panels. These are hazard warning panels containing the following emergency information :-

• the appropriate class label and subsidiary risk label, if any
• the correct technical name of the substance
• the UN number of the substance
• the Hazchem code number
• contact numbers and names of company and emergency response authority

EMERGENCY RESPONSE PLAN
Notwithstanding the controls and precautions taken, one cannot rule out the possibility of spillages and accidental releases of hazardous substances during transportation. With well drawn up emergency plans and proper training, such releases can be effectively contained and the damage to the environment and dangers to the health and safety of public minimised.
As a condition for granting licences and transport approvals, companies are required to put up emergency response plans.
The plan must be comprehensive and should contain the following key elements :-

• notification procedures; (persons and authorities to contact and how to contact)
• emergency procedures to contain and decontaminate spills; (immediate actions to be taken by driver/ground staff and actions to be taken by the company upon being informed)
• emergency equipment to be carried on the vehicle and at base such as personal protection equipment, absorbents, neutralising solutions and salvage drums;
• Material Safety Data Sheets of the hazardous substances transported.

The emergency response plan (ERP) shall be vetted and approved by SCDF before a Transport Approval may be issued.
Under the provisions of The Environmental Protection and Management (Hazardous Substances) Regulations, in the event of a chemical fire / release, the licence holders\transport approval holders are required to:

• block off the area contaminated by the hazardous substance;
• notify SCDF and the PCD;
• take immediate action to have the area decontaminated and return the situation to normal.

ENFORCEMENT
Under the Act and its Rules, PCD officers are empowered to carry out regular inspection to check into the following aspects of controls:

• Import, purchase and sale of Hazardous Substances
• Storage
• Transportation
• Labelling
• Maintaining and updating of records and sales documents
• Ensure that all hazardous substances are safely disposed of

PCD officers are authorised to:

• check and search premises;
• extracts records and documents for investigations; and
• conduct surprise checks on road tankers used for transportation on the road.

CONCLUSION
Hazardous chemicals have the potential to seriously endanger life and pollute the environment. Such chemicals have to be carefully managed at all time to prevent any accidental release. The successful implementation of a chemical safety programme requires co-operation from the industries to manage their hazardous chemicals properly and the support of the general public.