Our expectations for managing the damage to cylinders, transportable containers, and stationary container systems in areas affected by Cyclone Gabrielle.
Our overarching expectation is that PCBUs take steps to establish whether any cylinders, transportable containers, stationary container systems (i.e., above ground tanks, below ground tanks, process containers) or secondary containment systems have been damaged because of Cyclone Gabrielle. If a PCBU is competent and it’s safe to do so, we expect PCBUs to eliminate or minimise any risks to workers or other people that may have arisen due to damage, so far as is reasonably practicable.
Where PCBUs are unable to eliminate or minimise one or more risks, they should take appropriate precautions, seek professional advice, and contact Fire and Emergency Services New Zealand if necessary.
Situations will vary
The damage and issues Cyclone Gabrielle has caused will be specific to your situation and depend on many variables. Our greatest concern is where hazardous substances are leaking, or there’s a high likelihood that containers may fail and no longer contain the substance.
We encourage you to think carefully about how Cyclone Gabrielle may have affected your plant and what the flow-on effects could be. For example, consider:
- Was your plant submerged in floodwater, or is it currently?
- Is it covered by silt, or has it been struck by debris?
- Could there be debris, silt or floodwater inside the plant or pipework?
- Could it be corroding?
We also encourage you to consider the different aspects of your plant that could have been damaged. For example:
- The structural integrity of containers.
- The continued suitability of land underneath installations e.g., no longer bearing seismic load of the tank, or land erosion.
- The integrity and maintenance of secondary containment.
Only access plant if safe to do so
Before attempting to access plant, consider whether you can do so safely. Things to think about include:
- Whether the plant or pipework is damaged and/or leaking.
- Whether the fill level on containers have changed since the cyclone.
- Your existing processes and procedures for safely managing hazardous substances, including your emergency response plan where applicable.
- The safety measures you should put in place, including using personal protective equipment (see also, Using personal protective equipment (PPE) to clean up after Cyclone Gabrielle)
- What skills, knowledge and competence you and your workers have, and who is most appropriate to access and assess the plant. - Whether floodwater, debris or silt is present, and what it could be contaminated with (note, you should always assume flood water and silt are contaminated).
- How you will evacuate the workplace if necessary.
If, with all considerations in mind, you can’t access the plant safely, restrict access where necessary and seek professional advice.
If you can safely access plant, undertake a risk assessment if possible
If you can access the plant safely and are competent and capable to do so, you should undertake a risk assessment. Ensure you take appropriate precautions (as above) if you do so.
If you aren’t competent to conduct a risk assessment, engage a third party. For example, the continued suitability of land underneath installations, such as bearing the seismic load of the tank, should always be checked by a qualified professional.
We expect clear, accurate and comprehensive documentation of any risk assessment/s to be started, maintained and made available for inspection by anyone who needs to see them, including compliance certifiers and WorkSafe inspectors. We recommend you develop a checklist to help you document your review.
Taking action following a risk assessment
A risk assessment may identify damage or other hazards to be addressed. Your actions will vary depending on what you’ve identified, but could include relocating or removing hazardous substances, carrying out repairs, engaging a third party or contacting Fire and Emergency New Zealand.
Carrying out repairs and maintenance
There may be parts of your site that you can and should repair or undertake maintenance.
For example, where secondary containment is intact and full of silt or floodwater, you should empty it to ensure it has sufficient capacity to retain pooling substances in the event of spills and/or equipment failure.
Alternatively, if your risk assessment identified that secondary containment is damaged, you’ll need to ensure that appropriate steps are taken so that workers and others are not exposed to hazardous substances. Substances should be safely contained in the event of spills and/or equipment failure.
You should be aware that repairs and alterations to your stationary container systems may affect your certification. You should remain in touch with your compliance certifier so that you can renew your certification as soon as possible, where this is the case.
Engaging a third party
Your risk assessment may have identified circumstances that require you to engage a third party, for assistance with repairs or for further advice.
Third parties you could consider engaging include:
- Your gas supplier
- A compliance certifier
- A structural engineer
- Fire and Emergency New Zealand
- Cylinder Testing Laboratory Association New Zealand. You can also use the HASANZ register(external link) to find health and safety professionals to advise you.
Contacting Fire and Emergency New Zealand
If you identify a hazardous substances emergency such as substances leaking from their containers, follow your emergency response plan (if you have one) and/or contact Fire and Emergency New Zealand.