Performance Assessment

Table 1: Criteria for Judging Success – AN Strategic Topics
Performance Assessment
Each risk control topic should be assessed against the following performance descriptor criteria, a score of 20 or less must satisfy all specified criteria.
Topic
60
50
40
30
20
10
Unacceptable
Very Poor
Poor
Broadly
Compliant
Fully Compliant
Exemplary
Management
● Significant
● Inadequate segregation
● Schemes or written
● Schemes in place
Relevant Legislation
of non
quantities e.g. 2-50
from sound products e.g.
procedure for dealing with
supported by written
COMAH sites – COMAH Reg 4, HSWA S2(1), 3(1)
conforming
tes (interpretative
in next bay or adjacent to
non conforming material
procedures for the
material
quantity) of non
AN
are inadequate/not being
handling and treatment of
* non
conforming materials
● Larger quantities of non
used
non-conforming materials
conforming
are kept untreated
conforming AN (e.g. > 10
● Records maintained of
● Records of non
material
includes fines,
caked material,
materials which
have
deteriorated in
DRT failed material,
caked material,
contaminated
material
● Large quantities of
non conforming AN
tes) kept untreated with no
supporting risk
assessment
● No risk assessment prior
to mixing different non
conforming materials
non conforming materials
are inadequate
● Small quantities e.g. < 2
2-50 tes (interpretative
tes (interpretative quantity)
quantity) of non
conforming materials are
(e.g. 50+ tes)
● Schemes or written
kept untreated
sweepings.
(interpretative
The most
procedure for dealing with
Off-spec products e.g. pH,
quantity) kept
hazardous
non conforming material
minor contamination e.g.
untreated
not in place (absent)
sweepings
which is likely
to fail a DRT.
● No segregation
from sound products
maybe incomplete
● Significant quantities e.g.
storage
material is that
conforming materials
● No records maintained
● Inadequate risk
of non conforming
assessment prior to mixing
of non conforming
materials are kept
untreated
Sub-COMAH sites – MHSWR Reg 3, HSWA S2(1),
3(1)
● Detailed schemes in
place supported by
written procedures which
recognises the different
types of non-conforming
materials (off-spec,
● Schemes in place supported by written
reject, returns) and which
procedures for the handling and treatment of
details appropriate
non-conforming materials [EFMA guidance, Ref
methods for dealing with
5 2.1.III & Ref 6, 2.1.ii]
them
● Proper records kept of non-conforming
● Records maintained of
materials; types, sources, quantities and
all non-conforming
utilisation [EFMA guidance, Ref 5 2.1.IV]
materials; as to their
● Quantity of non-conforming materials
types, sources, quantities
minimised and dealt with in a timely manner
and utilisation
[EFMA guidance, Ref 5 2.1.V & Ref 6 2.1.iii]
● No untreated non-
(Note This can be assessed based on operating
conforming material on
procedures and amount of non-conforming
site
material present; expectation that the quantity of
● Non-conforming
● Small quantities
materials
(e.g. <1 te) of non
different non conforming
untreated non-conforming material kept to less
materials are kept in a
materials
than 1 te )
different building
conforming AN mixed
● Non conforming materials are kept separated
with urea
from sound products [EFMA guidance, Ref 5
● Non conforming
2.1.VII & Ref 6 2.1.v] (Note The expectation here
materials mixed with
would be that it is kept in a clearly marked area
urea
or bay segregated from normal products.)
● Different non-conforming
materials not mixed
● Different non-conforming materials are not
mixed without prior risk assessment [EFMA
guidance, Ref 5 2.1.VII & Ref 6 2.1.v]
Incompatible
● Large quantities of
● Significant quantities of
● Vehicles left overnight in
● Risk assessment carried
Relevant Legislation
Storage
combustible or
combustible or
a segregated area, but not
out to ensure no materials
COMAH sites – COMAH Reg 4, HSWA S2(1), 3(1)
incompatible
incompatible materials
effective and where fire
which are incompatible
materials co-stored
present in the building and
would impact on the AN
with AN are stored in the
and not effectively
not effectively segregated
● Some small quantities of
building but not supported
segregated e.g.
e.g. 100 pallets, several
combustible or
by written procedure
several hundred
pallets of bags or shrink
incompatible materials in
pallets, tens of pallets
wrap materials
the building e.g. a few
of bags or shrink
(interpretative quantity)
pallets, a few bags of
wrap, bays of grain or
Note. Depends on nature
combustible or
barley (interpretative
of combustible material –
incompatible materials
quantity)
e.g. readily combustible
(interpretative quantity)
● Loose urea and AN
materials such as sawdust
Note. For
mixed
more hazardous. HSE
blending/bagging
● Significant
guidance allows some
operations no more than ½
quantities of highly
concession regarding the
day (interpretative
flammable materials
co-storage of pallets but it
quantity) packaging
Sub-COMAH sites – MHSWR Reg 3, HSWA S2(1),
3(1)
● Fully dedicated
warehouse for AN – no
other materials stored
● No combustible or
incompatible materials in
the building
● Ammonium nitrate is not stored in the same
building with materials such as flammable
liquids, powdered metals, acids, chlorates,
nitrates, zinc, copper and its salts, oils, grease,
gas cylinders and chemicals of incompatible or
unknown properties [HSE guidance, Ref 1]
● Where it is necessary to keep pallets in the
store, they are separated from the AN by a
suitable fire break or partition [HSE guidance,
Ref 1] (Note The expectation here being that
AN would not be affected by a fire involving the
● No vehicles left
unattended or parked
overnight in the building
co-stored e.g. >10
would be difficult to accept
materials should be
stored combustible material – as per industry
tonnes (interpretative
the necessity of co-storing
present
guidance.)
quantity)
hundreds of pallets – even
● No written procedure or
● Fertilisers are not stored where they may be
● Vehicles left
if it was considered
risk assessment in place to
affected by any source of heat or stored
overnight in the store
absolutely necessary, the
ensure that no materials
combustible materials [EFMA guidance, Ref 2,
in an un segregated
expectation remains that
which are incompatible
10.4.2.ii]
area
the AN would not be
with AN are stored in the
affected by a fire involving
● Fertilisers not stored where they can become
building
contaminated with incompatible or combustible
● Bay of loose urea
adjacent to a bay of
the pallets co-stored]
materials, such as hay, straw, grease, farm
loose AN with walls
●Vehicles left overnight in
chemicals etc. [EFMA guidance, Ref 2, 10.4.2.iii]
less than 1m beyond
a segregated area, but not
● The building should not be used at any time
the limit of storage of
effective and where fire
for the storage of any non-fertiliser material,
each material –
would impact on the AN.
including packaging materials and pallets
visible mixing
Note. Depends on fire
unless these are separated from the fertiliser by
● Stack(s) of bagged
break/barrier
a suitable firebreak. A fire in these packaging
urea co-stored with
stack(s) of bagged
AN with no
segregation
● Vehicles left
running in the
building unattended
● A few bags of urea costored with stack(s) of
materials should not be able to affect the
fertiliser. [EFMA guidance, Ref 2, 11.8.2.iv]
bagged AN with no or
● Where absolutely necessary to store urea and
minimal segregation e.g.
AN products in the same building, they are kept
1m air gap
in such a manner that they cannot mix with each
● Bay of loose urea
adjacent to a bay of loose
other in any likely accident [HSE guidance, Ref
1]
AN with walls less than 1m
● For loose bulk in heaps: Where unavoidable
beyond the limit of storage
that urea and AN-based fertilisers are stored in
of each material – no
the same building, conditions are such that
visible mixing
neither fertiliser can affect each other in any
circumstances, in particular in the case of a fire
[EFMA guidance, Ref 2, 10.8.2.xii]
● Storage with other products: Where urea is
stored in the same building as AN-based
fertilisers, arrange the storage so that they
cannot contaminate or affect each other even in
the event of fire [EFMA guidance, Ref 2, 11.5.5]
● Vehicles are not left running unattended [HSE
guidance, Ref 1]
● Vehicles are parked overnight in the building
in a segregated area with a suitable firebreak
[HSE guidance, Ref 1] (Note The expectation
here being that AN would not be affected by a
fire involving the vehicle(s))
● When not in use for loading or unloading, forklift trucks should preferably be parked outside
the store building which is segregated from the
fertiliser by a fire barrier. Mechanical shovels
used for bulk products should be dedicated to
single stores and not removed other than for
major repairs. When parked they should be
segregated as above. [EFMA guidance, Ref 2,
11.6.4]
● Do not park vehicles in any storage
building/area other that for the purpose of
loading or unloading and do not leave their
engines running. [EFMA guidance, Ref 2, 11.6.5]
● Vehicles, fork-lift trucks and mechanical
shovels should only be parked in designated
safe areas and kept in a clean condition and free
from oil leaks. [EFMA guidance, Ref 2, 10.6.10]
● For loose bulk in heaps: Store mechanical
shovels or other mobile handling equipment
outside the storage building or in such a
position that fertiliser in the heaps or spilled on
the floor cannot be affected by a fire involving
the vehicle. [EFMA guidance, Ref 2, 10.8.2.ix]
● Extreme care should be taken with the storage
of non-fertiliser products, in particular
combustible and reactive chemicals, in the same
storage area as classified ammonium nitrate
based fertilisers. Non-fertiliser products should
be separated by means of a fire-fighting barrier,
the resistance of which has been assessed
according to the expected amounts and nature
of the other products to be stored. [EFMA
guidance, Ref 2, 11.5.1]
● Scheme in place supported by written
procedure and risk assessments to ensure that
no materials which are incompatible with AN are
stored in the building
Relevant Legislation
● DRT’s readily available
● Contingency plan for
COMAH sites – COMAH Reg 4, HSWA S2(1), 3(1)
● Procedure detailing
DRT failure but with some
Sub-COMAH sites – HSWA S2(1), 3(1)
Detonation
● No contingency plan for
● Several DRT’s missing
Resistance
DRT failure
Testing (DRT)
● One DRT not available
when a DRT re-test is
appropriate
key elements missing
● All DRT’s available
● A manufacturer, or importer, must also have a
contingency plan in place should any AN
materials they are dealing with fail the DRT. It is
essential, especially for importers, that they
identify stores/blenders that will receive
materials that has failed a test and that those
sites have taken the required action as outlined
at paragraph 2 above. [AIC/defra/HSE Guidance
Note, Ref 3, 3.]
[Note - Paragraph 2: Refers to application of
COMAH – see Guidance Note.]
Building
● Wooden building
● Tarmac or asphalt
● Tarmac or asphalt
● Tarmac or asphalt
Relevant Legislation
Construction
● Significant quantity
flooring, AIC member and
flooring, non-AIC member
flooring with documentary
COMAH sites – COMAH Reg 4, HSWA S2(1), 3(1)
of wood or other
no documented evidence
and no documented
evidence that bitumen
combustible material
of bitumen content
evidence of bitumen
level is > 9% and a
used in the
● Some wood or other
content
remedial action plan is in
construction of the
combustible material used
● Small amount of fire
place
building
in the construction of the
resistant wood used in the
building
construction e.g. beams,
Sub-COMAH sites – HSWA S2(1), 3(1)
● Tarmac or asphalt flooring with documentary
evidence that bitumen level is less than 9% [HSE
agreement with AIC, May 2010, Ref 7]
not in contact with the AN
● Building constructed from materials that will
but not supported by a fire
not burn such as concrete bricks or steel [HSE
risk assessment
guidance, Ref 1]
● Construct the buildings from not-readily
combustible materials such as brick, concrete
or steel, suitably protected where necessary
against corrosion. Plain/common wood or other
combustible materials should not be used.
Laminated or similar fire resistant wood, may be
used in the construction of beams provided they
● No combustible
materials used in the
construction of the
building including floor
do not come into direct contact with the product
and a fire assessment confirms their safe use.
[EFMA guidance, Ref 2, 11.3.1]
● Floors should be of non-readily combustible
material such as (a) concrete, preferably without
bitumen joints or surface coating or (b) highly
filled asphalt (typical grade 6-12% bitumen).
[EFMA guidance, Ref 2, 11.3.1] Note. In the UK
we have agreed with AIC that the bitumen
content should be 6-9% hence the remedial
action plan for >9%.
Risk gap:
EXTREME
Risk gap:
SUBSTANTIAL
 Initial enforcement
 Initial enforcement
expectation*:
expectation*: Formal
Formal enforcement
enforcement
Notice and/or
Notice/Letter.
Risk gap: MODERATE
 Initial enforcement
expectation*: Letter/IN.
Risk gap: NOMINAL
 Initial enforcement
expectation*: Verbal
instruction/letter.
Risk Gap: Not applicable
 No formal action necessary. Verbal advice may
be appropriate.
Risk Gap: Not
applicable
 No formal action
necessary
Prosecution.
*Initial Enforcement Expectation dependent upon the authority of the relevant standards applicable to the areas of non-compliance; Actual enforcement conclusion is dependent upon Duty holder and
Strategic factors as per HSE’s Enforcement Management Model.