Catherine Murphy (Kildare North, Social Democrats)

QUESTION NO: 108

To ask the Taoiseach and Minister for Defence if a report on the use of Trikelone N in the Air Corps workshop compiled in 2014 by the formation safety office of the Air Corps was made available to the independent person (details supplied) appointed to investigate health and safety matters in the Air Corps; if not, the reason it was not available to them; and if he will make a statement on the matter. [50343/18]

Paul Kehoe (Wexford, Fine Gael)

The report of the independent person appointed to investigate health and safety matters in the Air Corps is published and available on my Department’s website. Appendix C of that report lists documents and materials consulted and reviewed by him.

The document, to which the Deputy refers, is the subject of legal advice and in light of ongoing litigation, I am not in a position to comment further.

*****

Introduction

Trikelone N is a vapor de-greaser which was used as a cleaning agent in the process of cleaning engine parts due to be overhauled. Its use was  discontinued in the Air corps just prior to September 2007.

Work practices

One (1) pair of gloves was available to be used between all personnel who could be required to carryout the process. No personnel P.P.E. issue was made to individuals. MSDS sheets were available but no records of training on the dangers of using Trikelone N or the process or how to properly carryout the process exists. Two large extractor fans were placed on the wall behind where the process took place, but there is no record of the capacity of the fans, their specification or if they were adequate. There was no organised segregation of work areas. The double doors that separated the area where the Degreasing process took place from the adjoining area here normally left open. The personnel’s tea making and meeting room was in an annex off this adjoining Engine assembly area. The workshop heating system was also located in the adjoining Engine assembly area. Originally peoples personnel lockers were located in the immediate area where the Degreasing process took place, but the lockers where relocated into the adjacent Engine assembly area at a later date.

Possible Trikelone N exposure sources

Current Trikelone N MSDS states that exposure through, skin, hair, eyes and inhalation should be avoided and that contaminated clothes should be removed.

• Trikelone N exposure through inhalation, skin, hair and eyes could have resulted as individuals were not issued P.P.E. to protect against the substance. Due to the lack of records it can not be assumed that the two fans located on the wall behind where the process took place offered adequate ventilation.
• The lack of organised segregation of work areas where doors between areas were left open meant that vapours could travel from one area to another. No seals or segregation areas existed.
• Vapours could have travelled to the personnel’s tea making and meeting room which was located in an annex off the adjoining Engine assembly area and could have resulted in ingestion of the chemical by way of food contamination.
• The location of people’s personnel lockers which were located in the immediate area where the Degreasing process took place, and then relocated into the adjacent Engine assembly area at a later date. Would give a reasonable assertion that the contamination of persons clothes contained in their lockers would have taken place.
•  The heater located in the Engine assembly area took air in just above floor level and pushed out hot air above head height circulating the air around the Engine assembly area. When the doors between the Engine assembly area and the area in which the De-greasing took place were left open, the air would be circulated between both areas. Due to the Trikelone N being heavier than air a high concentration of Trikelone N would have been located near the heaters inlet vents.
•  The heater was adapted by Cpl. XXXXX so that the air being heated would be circulated into various other areas in the building including the Machine Workshop, NTD bay and Workshop offices by way of ventilation duct which could have exposed a risk of contamination of the air in those locations that might not have occurred previously. There is no record available if this work was approved, who authorised it, or was the design appropriate.
• Due to the fact that Trikelone N expands when heated, the risk of explosion
  increased when the Trikelone N contaminated air passed through the  heater.
• Poor hygiene controls before food consumption and going to the toilet would also be a cause of exposure.

Controls

The following controls are currently recommended when using Trikelone N.

• Isolating controls should be put in place to limit exposure.
• Adequate ventilation and extraction should be in place.
• Do not use in a confined space as vapour is heavier than air.
• Appropriate P.P.E to be provided including overalls, boots, chemical eye protection, impervious gloves and organic vapour respirator.
• Wash hands before smoking, eating, drinking or using the toilet.
• Contaminated clothes to be washed.

The Defence Forces Safety Standards 1991 which were a precursor to the Defence Forces Safety Statement is the closest thing I could find regarding some form of documented control standard in the Defence Forces. The Safety, Health and Welfare at Work Act 1989 would have been in affect, but the Safety, Health and Welfare at Work (Chemical Agent) Regulations 2001 would have only been in affect for a short period of the exposure. The Defence Forces Safety Standards 1, Control of Substances Hazardous to Health (COSHH) covers…

Section 1 Information Sources

• MSDS sheets should be given by suppliers of Chemicals to the Defence
  Forces.

Section 3 Principles of Assessment

• Obtaining and Passing on knowledge about a Chemical
• Assessment of Hazards posed by its use, byproducts, storage and disposal.
• Control of the Chemical using Engineering techniques, safe operating procedures and Personal Protective Equipment (PPE)
• Monitoring the Effectiveness of the Control strategy.

Section 4 Control

Documents how controls are to be put in place using a hierarchy of Controls
not unlike what is currently used.

• Elimination
•  Substitution
• Enclosure
• Isolation
• Local exhaust ventilation and reduced time exposure
• Dilution ventilation
• Use of PPE
• Personnel hygiene and washing facilities
• Training

Summary

As time, processes and technology has changed It is clear that the appropriate controls that would be the standard today were not in place at the time of the process taking place and that potential exposure risks were prevalent. The question posed should be was everything reasonably practicable done to ensure personals safety and health at the time.

On that note did the controls deemed reasonable at the time mirror those deemed reasonable in the present. Can the Defence Forces be found not to have done everything reasonably practicable?

DELAY – DENY – DIE