HAZCHEM Codes: a little bit of history with thanks to Peter Cope Senior Scientific
Adviser to the London Fire Brigade and Bureau Veritas
Still referred to as HAZCHEM Codes in New Zealand they have for many years been
called Emergency Action Codes in their country of origin - the UK.
Originally developed by three members of the London Fire Brigade and championed
by their Divisional Officer in the early 70's. D.O. Clisby pushed the Home Office to
adopt the system as a nationwide means of marking bulk loads of hazardous
chemicals for transportation in 1975.
The system faced competition from the European ADR Kemmler code, based system
and requirements to include ever more detailed information - UN Numbers, Hazard
Class, Tremcard number and proper shipping names. Most of these are very familiar
in this country now as well.
HAZCHEM Codes themselves largely stand apart from the legally required signage
under our Health and Safety at Work (Hazardous Substances) Regulations 2017 and
Land Transport legislation, though the word HAZCHEM (but not the Code) is now
required by Regulation 2.6 as a general duty signage requirement.
The original concept is and remains remarkably simple and effective providing an
immediate emergency response statement to enable the risk from the hazardous
substance to be managed at least in the first instance.
And some personal thoughts from my experience:
I would add here that while matrices exist to Code for multiple hazards, the system is
most effective when there is a unique Code per substance. That may, and in my
opinion should result in multiple Codes for multiple facilities even on the same
premises.
Usage in New Zealand has essentially remained true to this original "rather neat risk
assessment" and its intended use even while the UK and others, especially the
European Union have moved on, that is, I believe to the detriment of that simplicity.
Can they be improved? It really is rather difficult to see how they could be in concept
at least. There are a few anomalies that probably should be addressed; to explain
using some examples:
1
The Code for petrol is 3YE. As you will see from the example, the fire would be
fought with foam indicated by the 3, the 'Y' is accompanied by a 'Z' meaning the
reaction could be violent, the FENZ crew protection is normal firefighting kit, there is
a requirement to contain any fuel spillage / fire water / foam, and there is a need to
consider evacuation denoted by the 'E'. Nothing much wrong with that.
But, do we really want to fight such a fire or is the environment better served by
allowing the fire to burn efficiently?
Take a dangerous goods store with multiple flammable hazardous substances, again
all 3YE, none of the solvents or fuels incompatible but in combination if solubilised
by foam, the volume increased by the water used, and the combustion reduced in
efficiency to the point of evolving significant quantities of toxic high particulate
smoke, an argument could be made to let it burn. And it should be encouraged to burn
as hot as possible to take the combustion products back as close as possible to
elemental chemistry while protecting the exposures (other buildings or property) with
water spray.
So maybe:
The 'E' could be redesignated to 'Consider the Environment.' Like the EPA
requirement this would be the environment in its widest sense - people, the natural
environment, and the built environment. It would still mean evacuation of people if
that was called for, but the consideration would also involve a decision on potential
environmental effects and maybe a decision not to fight the fire as a result.
Another and perhaps more pertinent example:
The HAZCHEM Code for concentrated sulphuric acid is 2P - fine water spray, violent
reaction, full protective suits and dilute - really? All Code letters P to T involve the
emergency action to dilute. In today's environment you would not even apply that
action to milk. There are very few miscible liquid hazardous substances that you
would want to discharge to the environment with dilution as the only action. The EPA
Hazardous Substances Disposal Notice 2017 does not recognise dilution as a suitable
disposal method. Why should emergency action be any different?
So maybe:
Containment is the control method for Code letters W to Z, so that control should
really apply to all action codes from P to Z.
Why you might ask does the Code start at P (with the exception of E) - that again
originated in London where the Fire Districts radio call signs of that city ran from A
to L and there was a desire to avoid confusion.
2
HAZCHEM Codes in New Zealand are backed up by the Health and Safety at Work
(Hazardous Substances) Regulations 2017: Part 2 – Signage: Regulations 2.5 – 2.10.
This includes but is not limited to the word HAZCHEM for classes 2,3,4,5,6 or 8
substances, a hazard pictogram (Diamond); or a hazard statement, and the precautions
to be taken and describing the immediate actions in the event of emergency.
The latter commonly requires 111 - Fire, Ambulance, Police, a 24 hour company
contact number which may be a security company, an information number for the
substance; 0800POISONS, 0800CHEMCALL typically, or a NZ Chemical Supplier
plus often the appropriate Regional Council Pollution Control Hotline for EPA
compliance.
All good stuff, but for a first arriving fire officer faced with a HAZCHEM Code of
3Z, the immediate response is very clear, and speed is what saves your company
premises, limits your insurance claim, protects the wider environment and that
includes jobs. 3Z by the way covers Diesel.
