SHIPPING OF PROCESS EQUIPMENT FROM HAZARDOUS SERVICE (SAF-SPI-24)

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Rosaline Flowers
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1 1. PURPOSE 1.1 To ensure that all shipments of used equipment that contain or are soiled with hazardous materials are cleaned and tagged; and 1.2 To ensure legislative requirements (OH&SA, WHMIS Regulation) are met. Individuals working on or handling used equipment, containing or soiled with hazardous contaminants, have the right to know what they are working with. 2. SCOPE 2.1 All plants/mines in the Sudbury Operations Vale Limited are required to ship equipment from hazardous service according to this procedure. Site procedures specifying additional measures are to conform to the intent of this SPI. Each site is to do a risk assessment of the equipment to be sent off property to see if it falls under the intent of this SPI. 2.2 Applies to equipment that is being sent to a warehouse for storage. 2.3 All shipments [internal (between plants) and external] of used equipment that may contain or be soiled by potentially hazardous materials must be cleaned and tagged. 2.4 Any equipment shipped internal or external must have a current hard copy of the MSDS / SDS of the product or material that the equipment was exposed to while in service. 2.5 If equipment is being removed from hazardous service containing potential sewage, Appendix I must be included in detailed planning package or work order sent with the equipment (as there is no MSDS / SDS for sewage). 3. REFERENCES Plog et al Fundamentals of Industrial Hygiene, 5 th Edition. National Safety Council, Itasca, Illinois 4. DEFINITIONS Hazardous Material: Any substance or compound that has the capability of producing adverse effects on the health and safety of humans (From: Plog et al Fundamentals of Industrial Hygiene, 5 th Edition. National Safety Council, Itasca, Illinois) Examples: designated substances, corrosives, sewage, solvents, process materials, explosives. Clean: Preparation to minimize potential contact with a hazardous material. Material Safety Data Sheet / Safety Data Sheet: A Material Safety Data Sheet (MSDS) / Safety Data Sheet (SDS) is a technical document or bulletin that summarizes the health and safety information available for a hazardous product. It supplements the warning information on the label. (To ensure latest version, refer to Safety tab under Sudbury s Safety, Health & Environment Intranet Homepage) Page 1 of 8

2 5. SPECIFICATIONS 5.1 Roles and Responsibilities The Facility Managers and Superintendents are accountable for: Implementing the procedure at their respective plants; Communicating the expectations of following the requirements outlined in the procedure; Ensure that incidents, near misses and unsafe conditions related to the procedure are reported and investigated and that corrective actions are taken; and Ensure inspections are conducted and corrective actions are taken when necessary Line supervisors are responsible for: Knowing and understanding the requirements outlined in the procedure as they apply to their area of accountability; Ensuring employees are aware of the requirements outlined in the procedure and that where applicable (as per section 6.1) they review the procedure at specified frequency ; and Conducting incident, near miss and unsafe condition investigations/inspections related to the procedure Employees are responsible for: Knowing, understanding and following the requirements outlined in the procedure as they apply to their work; Reporting hazards, incidents, near misses and unsafe conditions relating to the procedure to their supervisor; Assisting in incident, near miss and unsafe condition investigations/inspections related to the procedure; and Participating in periodic reviews of the procedure as applicable in section 6.1; The Joint Health and Safety Committee is responsible for: Conducting inspections of the application of the procedure in applicable workplace The Originating Site shall perform the following: A detailed planning package or a detailed work order shall be generated identifying the equipment being removed or repaired, as being in Hazardous service; If equipment has been identified as being in Hazardous service then a Hazardous service tag must be securely attached to the equipment with the proper sections of the tag completed; (To ensure latest version, refer to Safety tab under Sudbury s Safety, Health & Environment Intranet Homepage) Page 2 of 8

3 Equipment must be flushed, drained, and washed; Hazard information, such as a hard copy of the current MSDS / SDS must be sent with the equipment; and When equipment has been in Nickel Carbonyl service the Shipping of Equipment in Carbonyl Service Assessment Form must be completed and sent with the equipment (form attached in Appendix III (a)). If applicable based on the completion of the above noted form, Divisional Shops Carbonyl Support Guideline must be followed (Appendix III (b)) The External Cleaning Facility: Shall be provided with a hard copy of the current MSDS / SDS of the product or material that the equipment was exposed to while in service. The external cleaning facility must: Be trained on this procedure; Read the tag; Be trained to recognize the hazard(s) (e.g. must be current on WHMIS training (Norcat)); Be trained to take appropriate precautions; Complete the appropriate section of the tag if applicable; and Ensure tag remains or is replaced after cleaning The Transporter must: Read the tag; Be trained to recognize the hazard(s) (e.g. must be current on WHMIS training (Norcat or Vale s WHMIS annual review)); Be trained to take appropriate precautions; and Ensure the tag remains intact throughout the delivery The Receiver (non-warehouse receiver) must: Ensure that there is a detailed planning package or work order for the equipment prior to disassemble and that the hazardous service tag is still attached to the equipment; Ensure that there is a hard copy of the MSDS / SDS with the equipment prior to disassembling; Review the MSDS / SDS prior to working on the equipment; Read the tag; Be trained to recognize the hazard(s) (e.g. must be current on WHMIS training (Norcat or Vale s WHMIS annual review)); Be trained to take appropriate precautions; (To ensure latest version, refer to Safety tab under Sudbury s Safety, Health & Environment Intranet Homepage) Page 3 of 8

4 Isolate equipment if not adequately prepared and/or accompanied by the above noted documentation and contact the originator ; and Remove tag upon completion of repair The Warehouse must: ` 5.2 Procedures: Preparation: The plant or mine shall ensure that all equipment is drained of hazardous materials and cleaned prior to leaving the boundaries of the plant or mine. If necessary the originating plant or mine will disassemble the equipment as far as needed to ensure hazardous material is not trapped in the equipment cavities. If the equipment is to be cleaned by others it must be properly prepared prior to shipping i.e. tagged and contained (e.g. bagged, catch basin, spill tray). NOTE: If the equipment has been in Carbonyl service, it must be decontaminated prior to shipping according to the Shipping of Equipment in Carbonyl Service Assessment Form (Appendix III (a)). The form must accompany the item being shipped. If it cannot be fully decontaminated, the Divisional Shops Carbonyl Support Guideline must be followed (Appendix III (b)) Identification: The originator at the plant or mine will ensure that the equipment is properly tagged with a yellow tag [(Stock Code ) (Note: Orange tag to be used if equipment has come in contact with Carbonyl from the Copper Cliff Nickel Refinery)] indicating that the equipment has been prepared and tagged before transfer (Sample tag included in Appendix II) Filling in the Tag: The tag must be filled in legibly and printed in ink; and All sections of the tag must be completed. a) Equipment type must be clearly identified in the equipment description section; b) Work order must be identified; c) Based on the process, hazard materials must be identified and included in the hazard description section. This information may be gathered from sources, such as MSDS / SDSs, site experts, etc; (To ensure latest version, refer to Safety tab under Sudbury s Safety, Health & Environment Intranet Homepage) Page 4 of 8

5 5.2.4 Tag Placement: d) The Vale MSDS / SDS reference number is to be provided; e) The plant or mine contact, location, and phone number must be provided; f) The tag must be securely attached to the equipment prior to shipping; and g) The tag must be protected so it will not deteriorate and that all written information remains legible. The tag must remain intact during transportation and after cleaning. The repair facility will remove the tag from equipment only when the repairs have progressed to a stage where any possible, hidden contamination (dismantlement may be required) has clearly been eliminated. 6. PERIODIC REVIEW 6.1 All occupations involved in the shipment, transport, receipt and storage as per the roles and responsibilities outlined in Section 5.1 must review this procedure on an annual basis. The following VES identifier has been created and is to be assigned to these applicable employees: Shipping of Process Equipment from Hazardous Service 7. AUDITING 7.1 The requirements outlined in this procedure should be periodically audited to verify conformance. 8. REVISIONS This SPI should be reviewed as required when the referenced standards, new standards arise, or regulatory requirements change; a formal review shall be required within three years of the revision date. REVISION TRACKING Appendix I: Information on the Health Hazards of Sewage To accompany all equipment removed from hazardous service where equipment may have come in contact with sewage (as there is no MSDS / SDS for sewage in the Vale hazardous materials database. Information on the Health Hazards of Sew (To ensure latest version, refer to Safety tab under Sudbury s Safety, Health & Environment Intranet Homepage) Page 5 of 8

Appendix II: The service tag (front of tag) Describe the hazards based on the area of the process where the equipment is in service. Reference MSDS/SDS Vale Reference No.

6 Appendix II: The service tag (front of tag) Describe the hazards based on the area of the process where the equipment is in service. Reference MSDS/SDS Vale Reference No. Hard copy of MSDS/SDS must be sent with equipment. Reference equipment type and any other relevant information. Reference work order number. Identify originating Plant, Mine, Area Identify Originator contact information (To ensure latest version, refer to Safety tab under Sudbury s Safety, Health & Environment Intranet Homepage) Page 6 of 8

7 Appendix II: The service tag (back of tag) (To ensure latest version, refer to Safety tab under Sudbury s Safety, Health & Environment Intranet Homepage) Page 7 of 8

8 Appendix III: Reference Guidelines from the Copper Cliff Nickel Refinery regarding Carbonyl Equipment (a) Shipping Carbonyl Service Equipment Assessment Form Shipping Carbonyl Service Equipment Ass (b) Divisional Shops Carbonyl Support Guideline Divisional Shops Carbonyl Support Guid (To ensure latest version, refer to Safety tab under Sudbury s Safety, Health & Environment Intranet Homepage) Page 8 of 8

Chemical Hygiene Plan

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