One common deficiency we encounter in our chlorine (Cl2) work is the management of these emergency response kits (e.g. A, B, and C Kits). We find three common failures regardless of the type of Kit:
- Kit(s) is not inspected “routinely”
- Kit contents are not managed per their specific requirements (i.e.. hood gaskets)
- Personnel lack training on applying the Kit(s)
Let’s discuss each opportunity and how putting our kits into our Centralized Maintenance Management System (CMMS).
Kit(s) is not inspected “routinely” and Kit contents are not managed per their specific requirements (i.e.. hood gaskets)
I say this often; we MUST DEFINE and QUANTIFY our safety process to achieve greatness in safety. How we define and quantify “inspections of safety-critical equipment” is actually relatively easy.
The Cl2 Institute states the following regarding their B-Kit: (emphasis added by me)
|
7.3 It is recommended that Kit “B” be inspected ANNUALLY, at minimum. Increased inspection frequency may be necessary if the kit is located in a geographical area that may experience extreme weather conditions (e.g., high heat, extreme cold, excessive rain/humidity, flooding, hurricanes, etc.). The purpose of this routine inspection is to ensure Moveable parts should be lubricated with a lubricant that is non-reactive to chlorine (see Cl Pamphlet 164) (9.1). It is recommended that an inspection checklist be used and kept on record at least until the next inspection. A sample inspection checklist can be found in Appendix D. 7.3.1 7.3.1 Gasket Inspection Gaskets are critical to the effectiveness of the kit mitigating a chlorine leak. Ensure all gaskets are still in their original packaging and have never been used. Replace the gaskets if they are not in their original packaging. … All Viton® gaskets are stamped with the date of manufacture. It is strongly recommended that the Viton® gasket be removed from emergency use after NO MORE THAN A FOUR-YEAR (4-YEAR) SHELF-LIFE. For further guidelines concerning the Viton® gaskets , consult the kit manufacturer or The Chlorine Institute. Gaskets that have been replaced may be used for training purposes. If used for training, the gasket should be very obviously marked, accordingly, to ensure it is not accidentally used in an emergency. |
For me, we included a spot check MONTHLY of our Kit(s). As long as the “car seal” was still in place on the box, we did not open the box monthly – simply verifying the car seal was still in tack. We did break the seal and OPEN the box and inspect the contents of the box QUARTERLY. Both the MONTHLY and the Quarterly were in our Work Order System. The quarterly inspection W.O. included the checklist for the contents of the Kit(s). Each type of Kit (A, B, and/or C) had its own W.O. as their contents checklist is different.
We also would establish another W.O. for our gaskets. The frequency of these W.O.s was every 3.5 years, to ensure that we could order the replacement gaskets and have them installed in the kit BEFORE the originals expired.
Personnel lack training on applying the Kit(s)
We always conducted the application of these kits in a FORMAL training course on an annual basis. But we also would have speed contests or their quiz contests quarterly on our ER equipment, so one quarter would also be a contest of which 2- person team could apply the Kit “Error-Free” the fastest
The kits are intuitively designed, but a lack of hands-on training at least annually on such High-Risk tasks can lead to some harmful consequences. For me, the kit(s) application training was separate from our traditional 8-Hour refresher courses, even though some years our 8-Hour refresher course hands-on drill involved a Cl2 cylinder and applying the Kit correctly.
I need to say this; this was actual HANDS-ON training. Yes, I used the Cl2 Institute Training Videos for the Kit(s). Still, each person had to team up with a partner and demonstrate their ability to use all the tools within the kit(s). When you have 85 people on an ERT, these evolutions take time. NEVER get comfortable with your own abilities and the intuitive design of the kits and just assume any responder can manage the correct application of these kits!