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.