Raw materials control / sampling
This Technical Measures Document refers to the 'cradle to grave' approach to prevent an unwanted chemical being used in a plant resulting in a major accident or hazard. A chemical can be a contaminant, raw material, reactant, intermediate, by-product or product.
See also Technical Measures Documents on:
The relevant Level 2 Criterion is 5.2.1.9(50).
General principles
The following aspects should be considered with respect to Raw Materials Control/Sampling:
- Human factors;
- Poorly skilled work force;
- Unconscious and conscious incompetence;
- What would happen if the wrong material was used in the wrong place; and
- What would happen if contaminated or out of specification material was used.
The following issues may contribute towards a major accident or hazard.
- Human error during acceptance of delivery and sampling;
- Incompetent quality control staff;
- Contaminant entering the plant for example, flammables in non-flameproof areas, oxidisers mixing with flammable solvents;
- Failure to understand the properties of substances handled;
- Failure of quality assurance procedures; and
- Failure to identify all credible contaminants and resultant reaction pathways that could disrupt the integrity of the plant involved.
Contributory factors for an assessor to consider concerning raw material delivery, test and storage
The Safety Report should address the following points:
- Whether there is are sufficient management systems in place to control the handling and use of all raw materials on site (Quality Safety Management, Quality Control/Assurance Procedures);
- Whether staff is sufficiently informed, instructed, trained and supervised to minimise a potential human failing during raw material delivery, test and storage;
- Whether there a sufficient chemical inventory of all chemicals used on site (COSHH assessments);
- The procedures in place to vet the suppliers of raw materials (Audits, supplier history, reputation);
- The amount of information with each raw material delivery (Trem Cards, Certificate of Analysis, Safety Data Sheets, representative samples);
- The suitability of quality assurance procedures in place to test all incoming raw materials on site if deemed necessary (Quarantine procedures, quality control procedures, representative sampling procedures);
- The suitability of validated quality control test methods and equipment in place to identify any potentially hazardous contaminants present within a raw material delivery; and
- The effectiveness of the systems of work in place to prevent contamination of raw materials once placed in storage, after QC approval (Storage procedures, QC tests to approve stored chemicals before use).
Contributory factors for an assessor to consider during plant production
The Safety Report should address the following points:
- The possibility of a major accident as a result of a change in the process reaction kinetics due to contaminants in the raw materials (R&D data, safety reliability data, engineering constraints);
- Whether all raw materials, reactants, intermediates, products and by-products known and can be retained safely without a deterioration in plant integrity (R&D data, analytical data, safety reliability data, engineering constraints); and
- Identification of required emergency procedures, systems and provisions in place to deal with events resulting from raw materials control failure.
Major hazards
The Safety Report should address the following points:
- Static discharge during sampling of flammable substances;
- Exposure to head-space gases during profile sampling of raw material tanker;
- Overfilling of storage vessels;
- Non-compliance of quality and safety procedures resulting in a 'Domino effect';
- Failure of safety systems manual or automatic.
Codes of Practice relating to raw materials control / sampling
The following publications can be used as guidance material relating to safety issues surrounding the testing and sampling of raw materials:
- LPGA COP 1 Bulk LPG storage at fixed installations. Part 1 : Design,
installation and operation of vessels located above ground, LP Gas
Association, 1998.
Supersedes HS(G)34 Storage of LPG at fixed installations, HSE, 1987.
Part 1, section 7.3.3 requires that the receiving vessel should be checked to ensure that the grade of LPG being transferred in is compatible with its content. - HS(G)64 Assessment of fire hazards from
solid materials and the precautions required for their safe storage and
use, HSE, 1991.
Paragraph 78 refers to the types of tests available to assess the flammability of a substance.
Paragraph 83 refers to the HSE test for assessing the fire hazard of a flammable solid material.
Paragraphs 90 –95 refer to the information obtained from the HSE test such as the hazard arising from the temperature of an ignited flammable solid and how specific flammable materials can be risk rated in terms of maximum rate of rise of temperature. - HS(G)131 Energetic and spontaneously
combustible substances : identification and safe handling, HSE,
1995.
Paragraph 31 refers to exothermic decomposition of raw materials, finished products, intermediates and products during reaction and storage. It stresses the importance of all stages of a production process be assessed and understood. - CS21 Storage and handling of organic
peroxides, HSE, 1991.
Paragraph 28 refers to the need for compatible containers for storing Organic Peroxides such as glass lined or stainless steel vessels.
Further reading material
The following British Standards are useful references for quality assurance issues surrounding the testing and sampling of raw materials:
- BS EN 1826 : 1997 Biotechnology. Large Scale Process & Production. Control Procedures for Raw Materials, ISBN 0 580 26890 X, British Standards Institution.
- Quality Management and Quality Assurance Standards Part 2: Generic Guidelines for application of ISO 9001, 9002, 9003, ISBN 0580280810.