have tanker connection points within the bund where possible – if not possible you must provide adequate containment for spillages or leakage You must inspect storage areas, containers and infrastructure daily. You must deal with any issues immediately. You must keep written records of the inspections. You must rectify and log any spillages of waste.

Wherever practicable you should store all other wastes under cover. Covered areas must have good ventilation. This applies to any such container: You must provide bunds for all tanks containing liquids (whether waste or otherwise) which could be harmful to the environment if spilled. Bunds must meet the CIRIA C535 or C736 standard and: Ensure that all workers who operate moving vehicles are properly trained, maintain appropriate speed limits, and follow best practices when it comes to vehicle safety. It is also vital to service and maintain vehicles correctly, and maximise visibility for drivers with the correct mirror set up, especially when manoeuvring and reversing. 2. Slips, trips and falls You must provide suitable containment measures (for example drip trays) for aerosol canisters held in containers which cannot collect and hold free liquids released from the canisters. Or you should transfer them to secure containers that are able to hold free liquid. HSG251: Fumigation: Health and safety guidance for employers and technicians carrying out fumigation operationsYou must have systems in place to make sure that loading, unloading and storage are safe, considering any associated risks. This can include: HSG166: Formula for health and safety: Guidance for small and medium-sized firms in the chemical industry HSE guidelines come in the form of HSE guidance documents. These are best practice documents which offer pragmatic — rather than legal — advice on matters of occupational safety. A common misconception is that HSE guidelines and HSE guidance documents are the law. However, they are not, and this short paragraph at the start of every HSE guidance document makes this clear:

You must follow safe operating procedures designed to reduce the risk of explosion and fugitive emissions when you transfer waste from powder tankers into silos. You must use trained and competent personnel.You must make sure that transfers into and from tankers only take place after you have completed any relevant verification and compatibility testing, and then only with the approval of an appropriate chemist or manager. The approver must specify: You must provide adequate bunding of all storage areas, and containment and treatment of any water run-off. The regulations as they are haven’t changed since HSE published its HSG76 guidance document in 2007. A lot of that HSE guidance document is based on EU Directive EN 15635, including the part about an expert inspection at least once every 12 months. All pipes, hoses, connections, couplings and transfer lines must be fit for purpose and resistant to the wastes being stored. You must use a suitable pipework coding system (for example, RAL European standard colour coding). You must not overfill containers used to store canisters. Overfilling can result in canisters being actuated and discharging their contents, either:

maintain a sound coupling at each end of the transfer hose, even when a gravity feed system is in place, and protect the transfer hose In 2009/10 the storage, warehousing and road haulage industries reported over 8500 work related accidents to the Health and Safety Executive (HSE) and Local Authorities. Almost 1600 of these accidents were classified as major injuries such as fractures and amputations. Resources If a waste is mixed with other similar wastes, where the resulting mixture does not have significantly different characteristics from the mixed wastes (for example blending compatible combustible or flammable wastes as a fuel), this activity is mixing or blending (coded D13 or R12). Any other mixing that changes a waste is treatment. You must store all waste containers in a way that allows easy inspection. You must maintain safe access, with a gap of at least 0.7m between rows of bulk containers or palletised wastes. You should pay particular attention to avoid the build-up of static electricity when you are storing or handling flammable wastes and materials. You should use leak detection systems and alarms (for example VOC alarms) and automatic fire suppression equipment based on a recorded risk assessment.

Warehouse hazards to consider

You must store containerised wastes that are sensitive to air, light, heat, moisture or extreme ambient temperatures under cover protected from such ambient conditions. Covered areas must have good ventilation. This applies to any such container: HSG254: Developing process safety indicators: A step-by-step guide for chemical and major hazard industries Not following HSE guidelines is legal. However, following the guidelines is normally “enough to comply with the law”. What’s more, because the advice is from the British government, it’s advice which is as objective and trustworthy as you can get in occupational safety. Why Aren’t HSE Guidelines Legally Binding? The HSE and The Storage Equipment Manufacturers’ Association (SEMA) advise looking at the following areas to uncover potential problems.

HSG210: Asbestos essentials: A task manual for building, maintenance and allied trades on non-licensed asbestos work HSG158: Flame arresters: Preventing the spread of fires and explosions in equipment that contains flammable gases and vapours HSG90: The law on VDUs: An easy guide: Making sure your office complies with the Health and Safety (Display Screen Equipment) Regulations 1992 (as amended in 2002) You must manage waste in a way that prevents pests or vermin. You must have specific measures and procedures in place to deal with wastes that are identified as causing pests or vermin.

As such, post-Brexit, HSE could completely overhaul HSG76. Yet, this isn’t likely to happen, as there are no calls for HSE to do so. Instead, what is likely to happen is that all existing HSE legislation will remain the same.