Dispersant storage, maintenance, transport and testing

Dispersant storage, maintenance,transport and testingA technical support document to accompany the IPIECA-IOGP guidance on surface and subsurface dispersant

Oil spillpreparedness

THE GLOBAL OIL AND GASINDUSTRY ASSOCIATIONFOR ENVIRONMENTAL ANDSOCIAL ISSUES

www.ipieca.org

© IPIECA 2017 All rights reserved.

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bottom left: Gerard Koudenburg/Shutterstock.com; bottom right: OSRL.

This publication has been developed to support the implementation of IPIECA’s mission and vision.While every effort has been made to ensure the accuracy of the information, it is intended to providegeneral guidance only. It is not designed to provide legal or other advice, nor should it be relied uponas a substitute for appropriate technical expertise or professional advice. All attempts have been madeto ensure that the information is correct at of the date of publication. This publication does notconstitute a mandatory commitment which members of IPIECA are obliged to adopt. The views andconclusions expressed herein do not necessarily reflect the views of all IPIECA members or theindividuals, companies and institutions that contributed to this publication.

While reasonable precautions have been taken to ensure that the information contained in thispublication is accurate and timely, this publication is distributed without warranty of any kind, expressor implied. IPIECA neither endorses nor accepts responsibility for the content or availability of anywebsite referred to, or linked to, in this publication. The responsibility for the interpretation and use ofthis publication lies with the user and in no event will IPIECA or any of its members past, present orfuture regardless of their negligence, assume liability for any foreseeable or unforeseeable use madethereof, which liability is hereby excluded. Consequently, such use is at the recipient’s own risk on thebasis that any use by the recipient constitutes agreement to the terms of this disclaimer. Thisdisclaimer should be construed in accordance with English law.

A cautionary note regarding dispersants

This publication includes generic advice and guidance with respect to the storage, maintenance,transportation and testing of dispersant products. This does not replace applicable national regulations,manufacturers’ instructions or information contained within a product’s safety data sheet, whichshould be followed.

Acknowledgements

The text for this report was prepared by Peter Taylor (Petronia Consulting). Information and commentswere also gratefully received from various IPIECA member companies, as well as from other individualsand organizations including Alun Lewis (Oil Spill Consultant), the Australian Marine Oil Spill ServiceCentre (AMOSC), the Centre of Documentation, Research and Experimentation on Accidental WaterPollution (Cedre), Dasic International, the European Maritime Safety Agency (EMSA), the InternationalSpill Control Organization (ISCO), the UK Maritime and Coastguard Agency (MCA), Marine SpillResponse Corporation (MSRC), Maritime New Zealand, the Norwegian Clean Seas Association forOperating Companies (NOFO) and Oil Spill Response Limited (OSRL). Additional thanks are given toAMOSC and OSRL for sharing their internal dispersant storage and maintenance procedures with theauthor, to help inform the guidance in this report.

Dispersant storage, maintenance,transport and testingA technical support document to accompany the IPIECA-IOGP guidance on surface and subsurface dispersant

14th Floor, City Tower, 40 Basinghall Street, London EC2V 5DE, United Kingdom

Telephone: +44 (0)20 7633 2388 E-mail: [email protected] Website: www.ipieca.org

The global oil and gas industry association for environmental and social issues

2 — Dispersant storage, maintenance, transport and testing

Section 1: Introduction 3

Section 2: Key guidance and recommendations 4

Section 3: Composition of dispersants 5

Section 4: Hazard classification and labelling 7

Section 5: Shelf life 9

Section 6: Storage 10

Container types 10

Drums 10

Intermediate bulk containers (IBCs) 10

Bulk tanks 11

Construction materials 11

Storage facilities 13

Contingency for possible leakage 14

Stacking 14

Section 7: Maintenance 15

Visual checks 15

Stock control 16

Container replacement 17

Documentation 17

Section 8: Retesting 18

Physical properties 18

Efficacy 19

Periodic retesting 19

Test methodology 19

Section 9: Disposal 21

Annex 1: Visual inspection checklist 22

Annex 2: The Globally Harmonized System of 23Classification and Labelling of Chemicals (GHS)

Contents


Dispersant use can mitigate the overall impact of an oilspill by removing oil from the sea’s surface (or avoiding oilsurfacing in the case of subsea use), thereby protectingmarine mammals, birds, coastal habitats and shorelines.Dispersant can also improve responder health and safetyby reducing the concentrations of volatile organiccompounds in the vicinity of a release, particularly insubsea scenarios. Their use can, however, result in ashort-term increase in hydrocarbon exposure for aquaticorganisms residing in the water column proximal to thedispersant application. Dispersants enhance the naturalbiodegradation processes that break down oil.1

Dispersant use identified as a response option in an oilspill contingency plan will be most effective in the earlystages of an incident or for treating ongoing releases.This is when spilled oil is fresher and slicks may be indeeper, offshore waters that are best suited to dispersantapplication. Furthermore, the use of dispersant can beone of the most rapid response options, and can achievethe highest oil encounter rates through application byspraying from vessels and aircraft, or by subsea injection.

To facilitate rapid and effective dispersant use, thoroughplanning should be undertaken. This includes ensuring thatauthorization procedures for dispersant product approvaland use are in place, application equipment andspraying/injection platforms are available, personnel aretrained and suitable stockpiles of dispersant are established.

The oil and shipping industries and their regulators placea high priority on the prevention of oil spills. This hasresulted in a welcome downward trend in the frequencyof major spills. In turn, this has led to an increasedlikelihood that dispersant stockpiles may remain unusedand stored for long periods, potentially many years. It isimperative that dispersant held within stockpiles remainseffective and fit for purpose. This report examines theconsiderations for storage, maintenance, transportationand retesting of dispersant stocks.

PURPOSE OF THIS REPORT

This report provides guidance and recommendationsonly, and is aimed at personnel who may be responsiblefor the procurement or custodianship of dispersantstocks.

It is recognized that there may be variations in thecircumstances and the ambient conditions of dispersantstorage that require flexibility in the application of thisguidance. Manufacturers’ or suppliers’ recommendationsshould be followed, which may be included in safety datasheets (SDS) or other technical documentation. There arealso national regulations in some countries that mandatecertain dispersant maintenance protocols, for examplethe periodicity of product retesting for effectiveness.

The guidance in this document applies to dispersantsthat are generally available on the international market,typically having passed product approval protocols inseveral jurisdictions.

Section 1

Introduction

1 IPIECA-IOGP (2015). Dispersants: surface application (IOGP Report 532) and Dispersants: subsea application (IOGP Report 533). IPIECA-IOGP GoodPractice Guide Series, Oil Spill Response Joint Industry Project (OSR-JIP). http://oilspillresponseproject.org


l Hazard warnings apply to leaks or mishandling of theproduct.

l Clear and relevant labelling is integral to properstorage.

l Dispersants are not classified as dangerous goodsunder international transportation agreements.

l Dispersants are chemically stable and may have long,potentially unlimited, shelf lives if stored properly.

l Intermediate bulk containers (IBCs) are the mostcommon type of storage container for dispersants.

l High-density polyethylene (HDPE) is the mostcommon storage container construction material.

l Using ethylene vinyl alcohol (EVOH)-HDPE laminatetechnology for IBC construction greatly reducespermeation and improves the potential to achieveextended shelf lives.

l Nitrogen blanketing can be coupled with EVOH-HDPEconstruction to prevent distortion of IBC containersover time.

l Storage in ventilated and cool warehousing ispreferred.

l Regular visual checks can identify storage units thatmay need replacement, or product that may requireretesting.

l Thorough inspection and retesting records should bemaintained.

l Retesting of the density and viscosity of a product maybe used to screen or identify product in containers/batches that should then be retested for efficacy.

l Retesting after an initial 10 years and then every 5years is recommended for dispersant stored in IBCs orequivalent containers.

l The results from different test methodologies are notdirectly comparable and should not be extrapolated todescribe potential effectiveness during real-worlddispersant use.

Section 2

Key guidance and recommendations


Understanding the composition of dispersants providesinsight into their physical properties, low hazard andpotential for extended shelf life. The precise formulationsof most dispersants are proprietary information, althoughthey may be supplied in confidence to national regulatoryauthorities. Dispersants typically consist of a blend of twoor three non-ionic surfactants, and sometimes include ananionic surfactant, mixed with a low-toxicity substancethat dissolves them to create a liquid mixture. Somedispersants contain other additives, e.g. anti-corrosives.Most modern surfactants used in dispersants are alsoused in many household products including skin cream,baby bath soaps, shampoo and mouthwash, and asemulsifiers in food.

The ingredients contained within several commonlystockpiled dispersants have been published, and acombined list of these ingredients is shown in Table 1.

Some of the most widely used non-ionic surfactants havea water-loving ‘hydrophilic’ part based on sorbitan(derived from sorbitol, a sugar) and an oil-loving‘oleophilic’ part based on a fatty acid (a vegetable oil).These non-ionic surfactants are sorbitan esters and havethe generic trade name of ‘Spans’. Other non-ionicsurfactants used are ethoxylated sorbitan esters whichare generically known as ‘Tweens’. Spans and Tweenshave widespread applications in the pharmaceutical,cosmetic, food and agrochemical industries. The anionicsurfactant used in many modern dispersants is DOSS (seeTable 1). This surfactant is used in many householdproducts, such as various types of cleaners, and is alsoused to treat or prevent constipation.

Composition of dispersants

Section 3

Table 1 Combined list of ingredients in several commonly stockpiled dispersants

NAMECHEMICAL ABSTRACTSSERVICE NUMBER

Sorbitan, mono-(9Z)-9-octadecenoate

Sorbitan, mono-(9Z)-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivatives

Sorbitan, tri-(9Z)-9-octadecenoate, poly(oxy-1,2-ethanediyl) derivatives

Butanedioic acid, 2-sulfo-, 1,4-bis(2-ethylhexyl)ester, sodium salt (1:1) [contains 2-Propanediol]

Ethoxylated fish oil

Tall oil

Propanol, 1-(2-butoxy-1-methylethoxy)

Distillates (petroleum), hydrotreated light

Propylene glycol

Ethanol, 2-butoxy

GENERIC NAME

Surfactant (Span)

Surfactant (Tween)

Surfactant (Tween)

Surfactant (DOSS)

Surfactant

Surfactant

Glycol ether solvent

Hydrocarbon solvent

Solvent

Glycol ether solvent

1338-43-8

9005-65-6

9005-70-3

577-11-7

103991-30-6

8002-26-4

29911-28-2

64742-47-8

57-55-6

111-76-2


Many surfactants are high-viscosity liquids and/or solids.They need to be blended into a low-toxicity substance (asolvent) to produce a dispersant of relatively low viscositythat can be easily sprayed. The solvent also helps thesurfactant to penetrate the spilled oil. Some key physicalproperties are indicated in Table 2.

Some jurisdictions stipulate a maximum or minimumvalue for some dispersant properties. For example, 60°C isa minimum flashpoint for transportation and insurancepurposes.

Section 3Composition of dispersants

Table 2 Key physical properties of dispersants

TYPICAL RANGEPROPERTY

Orange/brown/amber clear liquid

60 to 250 mPas

65 to 95°C

-10 to -40°C

0.85 to 1.035

COMMENT

Visual assessment

Measure of the internal resistance to flow

Temperature at which vapours will ignite

Temperature below which the liquid does not flow

Density relative to pure fresh water

Appearance

Dynamic viscosity at 0°C

Flashpoint

Pour point

Specific gravity at 20°C


The United Nations’ Globally Harmonized System ofClassification and Labelling of Chemicals (GHS) providesan international system and criteria for:

l classification of substances and mixtures according totheir physical, environmental and health hazards; and

l hazard communication elements, includingrequirements for labelling and SDS.

The GHS becomes legally binding through a suitablenational or regional legal mechanism. For example,European Regulation (EC) No 1272/2008 onclassification, labelling and packaging of substances andmixtures applies in all European Union Member States.The US Occupational Safety and Health Administration(OSHA) has developed a Hazard CommunicationStandard (HCS) that includes hazard classification,labelling and SDS requirements in compliance with theprovisions of the GHS. Various national administrationsaround the world are following suit with legislation

aligned to the GHS. Further information on the GHS canbe found in Annex 2 on page 23 of this guidance.

In their correctly stored form, i.e. safely contained,dispersants pose no risk to human health and theenvironment. The risk of exposure to dispersant onlyoccurs in cases of leaks or incorrect storage, handlingand use of the product. The most common hazardclasses for dispersants are skin corrosion/irritation, andserious eye damage/irritation. Under the GHS, the SDSshould identify relevant classes, with associated hazardsand precautionary statements. These statements,together with relevant hazard pictograms, should bereproduced on the product’s label. For further details, seeAnnex 2 on page 23 of this guidance.

Hazard classification and labelling

Section 4

Key pointHazard warnings apply to leaks or to

mishandling of the product.

PRODUCT NAME

Oil Spill Dispersant

Not classified ashazardous for transport

Always consult product Safety Data Sheet and technicaldata sheets prior to use

Manufacturer’s NameAddress

Telephone number / Email / Website

Batch number: xx-xxx-xxDate of manufacture: xx-xx-20xx

Volume: 1,000 litresNet weight: 1,004 kg

Gross weight: 1,068 kg

Danger:Causes skin iriritation.Causes serious eye damage.IF IN EYES: Rinse cautiously with water forseveral minutes. Remove contact lenses, ifpresent and easy to do. Continue rinsing.If eye irritation persists: Get medicaladvice /attention.IF ON SKIN: Wash with plenty of water/soap.If skin irritation occurs: Get medicaladvice /attention.Wear protective gloves /protective clothing/eye protection /face protection.

Ingredients:30% non-ionic surfactants20% anionic surfactantHydrocarbon and Propylene Glycol solvents

Storage instructions:Keep only in original container. Keep cool.Store in a well-ventilated place.

IBC unit number: xxxx-xxxx

A typical example of ageneric hazardwarning label. Labels should beweatherproof andcapable of remaininglegible throughoutlong periods ofstorage.


A manufacturer should be aware of the relevantregulations and should supply dispersant that is labelledaccordingly. If not covered by the applicable regulations,all products and containers should be clearly labelled withthe following information:l product name;

l name, address and contact number of manufactureror importer;

l unique reference code for the production batch anddate;

l appropriate GHS hazard warning pictogram(s), signalword, hazard statement(s) and precautionarystatement(s), or equivalent national requirements;

l date of container’s manufacture and unique referencecode (these may be branded onto the container);

l volume/weight of unit; and

l recommended storage instructions.

An example generic label is provided on page 7. The labelshould be weatherproof and capable of remaining legiblethroughout long periods of storage. Fixing the label to thecontainer in two places (e.g. on the metal plates of anIBC) will help to ensure that a label is visible whencontainers are stacked. It is prudent to either haveduplicate labels in stock or to have an arrangement withthe supplier for obtaining replacements.

The hazards associated with accidental exposure todispersant are identified and classified under the GHS aspreviously described. However, dispersants are notclassified as dangerous goods under the followinginternational agreements for transportation, and aretherefore not regulated:

l ADR (European Agreement on International Carriageof Dangerous Goods by Road)

l IATA (International Air Transport Association)

l IMDG (International Maritime Dangerous Goods Code).

Under the UN classification for transportation, dispersantsare categorized as ‘Packing Group III: Substancespresenting low danger’.

Section 4Hazard classification and labelling

Key pointClear and relevant labelling is

integral to proper storage.

Key pointDispersants are not classified as dangerous goods under

international transportation agreements.


The surfactants and solvents in dispersants arechemically stable. The dispersant components do notundergo chemical reaction with each other or with the oilonto which they are applied. When stored in suitablefacilities, they do not decompose or otherwise change,provided they are kept in suitable sealed containers thatremain intact.

Consequently, most dispersant manufacturers orsuppliers indicate that their products have long shelf lives.For example, 12 of the 18 dispersants listed on the USNational Contingency Plan Product Schedule2 (as ofSeptember 2017) have shelf lives stated as ‘unlimited’,‘indefinite’ or ‘potentially unlimited’. The remaining sixproducts have stated shelf lives ranging from ‘≥ 2 years’to ‘15 years or more’. The suppliers typically placeemphasis on the need for storage containers to remainsealed/unopened for these shelf lives to be achieved.

In the 1980s and 1990s, a series of controlled studieswere undertaken in the UK by Warren Spring Laboratory3

for the Institute of Petroleum and others, concerning thepotential deterioration of dispersants products. Thisincluded testing a variety of products over severalmonths, including at higher temperatures (up to 50°C),examining their possible loss of efficacy (i.e. effectiveness)and potential to corrode containers. The overallconclusions of this work included the following:

l If products are stored according to manufacturers’instructions, the loss of efficacy should be minimal.

l Limited corrosion of mild uncoated steel containersoccurred with some products; there was no evidencethat this led to reduced product efficacy.

l A recommendation was made that bulk storage ofdispersants in mild steel containers should be avoided.

l At low temperatures, some cloudiness of products wasobserved. On return to ambient temperatures, theproducts returned to normal appearance when mixed,with no loss of efficacy.

Practical evidence of long shelf life is available. A USstudy4 reported in 2008 that dispersant samples fromstockpiles ranging from 10 to >30 years old retainedacceptable effectiveness in laboratory tests. This studycovered nine locations in the USA stretching from the Gulfof Mexico to Alaska. Storage containers consisted of a mixof drums, ‘totes’ (i.e. IBCs), bulk tanks and tank trailers.

If dispersants are exposed to the air, evaporation ofsolvent may occur. Loss of solvent may also occurthrough the walls of a container, depending on theconstruction material, or through cap vents if a containerhas them. Reduced solvent levels can lead to an increasein the product’s viscosity, potentially rendering it difficultto spray and altering the formation under which it islicensed. Loss of solvent may also lead to reducedeffectiveness, this being due to the diminished ability ofthe product to penetrate oil, i.e. the surfactant is less ableto reach the oil/water interface. Ingress of oxygenthrough breather tubes or through the walls of acontainer may lead to oxidation of the surfactants,resulting in the formation of residues or gums. Theseresidues may block spray nozzles, hindering orpreventing the dispersant application.

Section 5

Shelf life

2 See https://www.epa.gov/emergency-response/national-contingency-plan-subpart-j#schedule3 Including The storage stability of oil dispersants, report no. LR 670, 1989; and Storage stability of dispersants (6 years ambient storage),

report no. LR 1012, 1994. Reports available from http://discovery.nationalarchives.gov.uk4 See http://ioscproceedings.org/doi/pdf/10.7901/2169-3358-2008-1-695

Key pointDispersants are chemically stable and may have long, potentially unlimited,

shelf lives if stored properly.


The size of the stockpile and the possible need foronward transportation by road, sea or air will determinethe types of containers that may be used for storage.Stockpile volumes can vary from a few cubic metres tomany times this amount. For example, the internationaloil industry, through Oil Spill Response Limited, hasestablished the ‘Global Dispersant Stockpile’, consisting ofaround 5,000 m3 of dispersant stored at a network ofworldwide locations. National government stockpiles canalso be substantial. For example, the two largest nationalgovernment-owned stockpiles in Europe are in Franceand the UK, each holding around 1,200 m3 of dispersant.The European Maritime Safety Agency (EMSA) maintainsaround 800 m3 of dispersant, equally distributed acrossfour stockpiles in Europe.

The use of suitable containers kept in appropriatecondition is fundamental to dispersant stockpilesachieving their potentially unlimited shelf lives.

While all dispersants are formulated for the same purposeand contain a mix of similar surfactants and solvent(s),their specific components and blends vary. For thisreason, different products should not be mixed in thesame container, either when in storage or in use. Suchmixing could result in reduced effectiveness, causeoperational issues with spraying gear and maycontravene product approval protocols.

CONTAINER TYPES

Drums

Historically, dispersants were primarily supplied in steeldrums with a nominal volume of 208 litres (55 US gallons/46 imperial gallons). While these can be palletized, theydo not allow for the most efficient use of space. Drumscan also be supplied in plastic materials in a wide range ofsizes; this reduces the corrosion risk but does notovercome the space utilization issue. Drums also raisepotential handling challenges when loading or unloadingduring land or sea transportation, slowing down responsetimes. It is unlikely that significant quantities of newdispersant would be supplied in drums.

Intermediate bulk containers (IBCs)

IBCs are stackable containers or ‘totes’, mounted on apallet to facilitate movement using a forklift or pallettruck. Composite IBCs commonly take the form of awhite/translucent high-density polyethylene (HDPE)cube, sitting within a tubular galvanized steel cage. Thepallet may be steel, plastic or wood. Alternatively, rigidheavy-duty HDPE IBCs are available with no steel cageand the option of an integral moulded pallet.

Typical IBC volumes are either 1,060 litres (280 US gallons/233 imperial gallons) brim-full, often described as having1,000 litres capacity, or 1,250 litres (330 US gallons/275 imperial gallons). The gross weight when filled islikely to be in the range of 1,050 to 1,150 kg. (2,315 to2,535 pounds). The fittings can also be stipulated by theclient or supplier. IBCs have a filling cap at the top, andusually have a built-in discharge valve (tap/faucet/spigot)at their base.

Section 6

Storage

A typical1,000 litre IBC

Mau

ser

Key pointIntermediate bulk containers are the most common

type of storage container for dispersants.


Steel-caged HDPE IBCs are typically certified as suitablecontainers for dispersant products (‘UN Packing Group III:Substances presenting low danger’). IBCs are by far themost common storage option for larger dispersantstockpiles. They are cost-effective and provide efficientutilization of storage space, as well as being relativelyeasy to inspect and transport. They have the operationaladvantage of relatively quick product transfer, which is ofparticular benefit to operators of larger-volumedispersant application systems.

Bulk tanks

Bulk storage of dispersant, e.g. in road tankers, ISO tankcontainers or vessel tanks, presents the risks ofevaporation of solvent and the oxidation of surfactant.This is due to most large tanks having breathing tubesthat are open to the air to allow for fluctuations in thevolume of the tanks’ contents due to changes intemperature. In the case of vessel tanks, there is also arisk that the dispersant may become contaminated withseawater.

There is documented evidence that dispersant can bemaintained in vessel tanks for extended periods, whileretaining suitable effectiveness. For example, a marineterminal in the UK has three tugs that were constructedbetween 1993–95, with dedicated tanks for storingdispersant, ranging from 12 to 30 m3 in volume. Thetanks are constructed from epoxy- or paint-coated steel,with a design that is narrow and deep to minimize the

surface area and headspace. The dispersant products inthese tanks has been tested every five years, andcontinued to meet the requirements of the UK efficacytest after more than 20 years. Furthermore, the US study4

referred to on page 9 reported that dispersant sampledfrom 12 bulk tanks, 2 vessel tanks and 3 road trailersacross five locations all maintained a suitable level ofeffectiveness after more than 20 years.

Conversely, there are reports of dispersant having failedeffectiveness tests while stored in vessel tanks. This mayhave resulted from the tanks not having been designedfor dispersant storage, or from contamination of theproducts, or a combination of both. For some dispersantproducts, there may be an increased risk of oxidation inbulk tanks compared to sealed IBCs; this can potentiallylead to the formation of residue.

If dispersant is stored in bulk, care must be taken to avoidmixing different brands of dispersant. If only a portion ofthe product in a tank is used during an incident, thevolume used should be replaced with the same product.

CONSTRUCTION MATERIALS

The dispersant supplier should provide the product in acontainer that is fit for purpose. In most cases theoriginal container will be used for long-term storage andwill only be changed if it shows signs of deterioration ordamage. In some cases, an organization may choose toadopt a replacement procedure for containers.

Section 6Storage

ISO tankcontainers maybe used for bulkstorage.

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For example, the containers used to store the industry-owned Global Dispersant Stockpile (see page 10) arereplaced every five years. This is not a regulatoryrequirement but is carried out to minimize the possibilityof stocks in transit being delayed by freight-forwarders orborder control officials. Note that a replacementcontainer should be of at least the equivalentspecification and quality compared to the original.Consultation with the dispersant supplier is advised toensure that replacement containers are compatible withthe particular brand of product being used.

Some suppliers may list suitable and unsuitable containermaterials in the product’s SDS. UV-stabilized HDPE is nowby far the most commonly used material.

container walls. This ensures that the product remainsunchanged, retaining its effectiveness, reducing containerdistortion due to solvent loss and reducing the risk ofsurfactant oxidation. Some dispersant manufacturers arenow using EVOH-HDPE laminate technology as standardwhen supplying product in IBCs. This will further enhancethe ability to achieve extended shelf lives.

Furthermore, the use of EVOH-HDPE laminates alsoreduces the outward permeation of nitrogen, thusmaking feasible the addition of nitrogen to theheadspace above the liquid dispersant within the sealedcontainer. This nitrogen ‘blanketing’ displaces theheadspace oxygen and thereby eliminates absorption ofoxygen into the dispersant.

Section 6Storage

Key pointUsing EVOH-HDPE laminate technology for

IBC construction greatly reduces permeation and improves the potential to achieve

extended shelf lives.

Key pointNitrogen blanketing can be coupled with

EVOH-HDPE construction to prevent distortion of IBC containers over time.

Vessel tanks, bulk tanks and road tankers are typicallyconstructed from coated steel. The Warren SpringLaboratory studies carried out in the UK during the 1980sand 1990s indicated that storing some dispersantproducts in uncoated mild steel containers may present arisk of corrosion.

As mentioned in the section on Shelf life on page 9, thereis potential for loss of solvent and ingress of oxygenthrough the walls of a container, including throughuntreated HDPE. Fluorine treatment of HDPE provides abarrier that greatly reduces the permeation and loss ofsolvent through the walls of the container. More recently,the development of ethylene vinyl alcohol (EVOH) hasenabled the production of laminates of EVOH and HDPE.These laminates greatly reduce both the loss of solventand the inward permeation of oxygen through the

Equipment used to add nitrogen to an IBC and eliminateoxygen from the headspace above the liquid dispersant.

OSR

L

Key pointHDPE is the most common

storage container construction material.


This further minimizes potential warping or distortion ofthe sealed containers (see page 16). The procedure foradding nitrogen to the headspace is neither complex norparticularly hazardous. It requires the use of pressurizednitrogen in a cylinder with an associated regulator,discharge hose and long-reach blowgun to introduce thegas into the headspace. The operation is undertaken by atrained operator wearing suitable personal protectiveequipment in a well-ventilated area. Approximately 100litres of nitrogen are typically used per IBC.

It is not possible for the body of the discharge valve to bemoulded as part of an EVOH-HDPE-constructed IBC,therefore a fluoro-elastomer seal is used. Evidenceavailable from storage of the industry-owned GlobalDispersant Stockpile indicates that these seals do notdegrade or leak.

STORAGE FACILITIES

The facilities where dispersants are stored will need totake account of the spill risks they are covering.5

Tier 16 stockpile locations might include ports, marineterminals, and aboard dedicated response vessels orstandby vessels for offshore installations. Tier 2 stockpilesmay include dedicated onshore facilities, includinglocations at or near airfields if aerial dispersant applicationis part of contingency plans. Tier 3 stockpiles are invariablydedicated facilities with extensive warehouse space toaccommodate the high volumes of dispersant required.

Direct sunlight, high humidity and saltwater can causedamage to containers, hence their exposure should beminimized as far as possible. It is therefore preferable tostore dispersant indoors, i.e. inside warehouse facilitiesthat provide adequate ventilation. If storage outdoors isunavoidable, adequate shelter/cover should be provided.A product’s SDS may include guidance on storage, andmay incorporate relevant GHS Precautionary Statements(e.g. P234+P235: Keep only in original container. Keepcool and P403: Store in a well-ventilated place) or anequivalent.

Exposure to temperature extremes and fluctuationsshould also be avoided wherever feasible. In locationswhere high or low ambient temperatures areencountered, the use of climate-controlled facilitiesmay be necessary. Temperatures should be kept as lowas practicable, as this will help to achieve extendedshelf lives. Storage temperatures below -10°C mayresult in some separation and layering of dispersantproducts, but this is unlikely to be permanent and willbe resolved when the temperature rises. Storage athigh ambient temperatures may reduce shelf life;wherever possible, the maximum storage temperatureshould be below 30°C.

Section 6Storage

Key pointStorage in ventilated and cool

warehousing is preferred.

OSR

L

Orderly storage of IBCs in a warehouse; the neat rows allowvisual inspections and facilitate emergency response if needed.

5 IPIECA-IOGP (2013). Dispersant logistics and supply planning. Report of the IOGP Global Industry Response Group (GIRG) response to the Macondoincident in the Gulf of Mexico in April 2010, Oil Spill Response Joint Industry Project (OSR-JIP). http://oilspillresponseproject.org

6 IPIECA-IOGP (2014). Tiered preparedness and response. IPIECA-IOGP Good Practice Guide Series, Oil Spill Response Joint Industry Project (OSR-JIP).IOGP Report Number 526. www.oilspillresponseproject.org


Contingency for possible leakage

It is good practice to store dispersant in a location whereany leaks will be contained and not threatencontamination of adjacent land or watercourses. Nationalpollution control regulations concerning imperviousbunding capacity should be observed. In the absence ofsuch regulations, it is recommended that bundingcapacity is at least 25% of the total dispersant volumestored. Where bunding capacity is not available,emergency procedures should be in place to rapidlydeploy drain blockers or plugging mats to preventdispersant leaking into drains or watercourses. It is alsogood practice to maintain one or more spare empty IBCs,a gravity transfer hose, a suitable transfer pump includinghoses and fittings, personal protective equipment and afirst response chemical spill kit, in case of damage tocontainers leading to leaks. This would allow the transferof dispersant from the damaged container safely andwithout delay. It is recommended that spare storagecapacity is maintained at 1% of the total volume held.Any dispersant is likely to make a surface extremelyslippery, and personnel should take care whereresponding to leaks. Specific guidance on first aid andaccidental release measures will be included in aproduct’s SDS.

Stacking

Steel-caged IBCs are designed to be stacked to maximizestorage efficiency. The supplier or containermanufacturer should provide recommendations onstacking weight restrictions. In practice, stacking up to aheight of three steel-caged IBCs provides storageefficiency while allowing convenient visual inspections ofall units. Purpose-built shelving may allow stacking to aheight of four IBCs or higher. Ideally, IBCs should bestacked in neat rows, such that all units can be visuallyinspected. Units should have their discharge valves andfront labels facing outwards. Consideration will also needto be given to emergency mobilization of stocks, i.e. theability to rapidly access and move containers using aforklift or pallet truck. Older stocks should ideally be themost accessible, so that they can be used first during anincident.

Onward transportation to a port or airport duringdeployment to an incident is likely to involve roadtransportation. Transport vehicles, such as flatbed trucksor trailers, have weight restrictions that usually preventsteel-caged IBCs from being stacked during transport. Itmay be useful to cover IBCs during transportation ifextended exposure to strong sunlight is anticipated.

Section 6Storage


VISUAL CHECKS

Unless national regulation requires otherwise, thefollowing recommendations are made.

A general visual inspection of stockpiles is recommendedat least every month. This would typically involvepersonnel walking between and around the containers toidentify any signs of small leaks or damage to the IBCs orother containers. Labels should be checked for legibilityand replaced if deteriorating.

The inspection should also include an observation of anyabnormal appearance and colour of the product wherethis is feasible, e.g. through the walls of translucent IBCs.Dispersants are generally clear liquids. A product’s colouris described in its SDS (e.g. orange, brown or amber).Over time, a product may take on a hazy or darkerappearance, usually indicating the presence ofsuspended particulate or flocculent. The presence of fineparticulates does not necessarily hinder the effectivenessof the product or its ability to pass through spray systems.Observed abnormalities might indicate a need for furtherinvestigation and a possible need for testing.

Containers that are in poor condition may not be suitablefor safe transportation. This would compromise theoperational effectiveness of a stockpile, as well as riskdeterioration of the product.

A record should be made of each inspection, typically aspart of a wider planned maintenance system for aresponse stockpile. It may be useful to includephotographs of IBCs and any dispersant samples takenfor testing. These images can create an historical libraryof appearance, against which future inspections can becompared. Depending on the scale and nature of anyidentified damage or abnormality, decisions should bemade on container replacement and the need for thecontents to be retested for effectiveness. An example ofa visual inspection checklist is provided in Annex 1 onpage 22.

Every two to three years, each IBC should be given athorough external visual inspection for cracks,warping/deformation, corrosion of the steel cage,abnormalities with the discharge valve and camlockfitting (if present) or any other damage. This inspectionmay require the movement of containers to allow all-around checks. Limited warping of HDPE IBCs isacceptable, although it should be noted that this canpotentially lead to cracking of the HDPE, particularly atthe corners, and should therefore prompt a detailedexamination of the IBC to check for signs of possiblecracks. The visual inspection should also include a checkon the product’s appearance and colour. As previouslymentioned, it may be useful to take photographs to allowcomparisons with earlier checks; photographs should becross-referenced to individual storage units.

Section 7

Maintenance

AMO

SC

Example of colour variation of the sample productwithin a stockpile.

Key pointRegular visual checks can identify storage

units that may need replacement, or product that may require retesting.


STOCK CONTROL

A maintenance record should include batch numbersand dates of dispersant manufacture. This will allowstocks to be utilized in order of age, so that older stock isdeployed first. To facilitate this, the maintenance recordshould be accessible to an organization’s emergencyresponders and incident management team (IMT). TheIMT’s logistics function should be aware of dispersantstock control procedures.

If dispersant is used during an incident, it is good practiceto retain a small sample of all batches used. These couldprovide evidence of the effectiveness and possiblytoxicity of the batches, if a subsequent challenge is madeby regulators or others.

Section 7Maintenance

AMO

SC

QR code labelused to identifysampledcontainers andto recallinspection,sampling andtesting data on-site at any time.

Above: an example of IBC deformation caused by loss of solvent;the product remained effective, but this can be prevented bythe use of EVOH-HDPE laminated technology.

Right: an example of visible residue formed during storage; inthis case the residue remixed on pumping and did not affect thespraying equipment or product effectiveness.

OSR

L

OSR

L


CONTAINER REPLACEMENT

If dispersant needs to be transferred from one containerto another (e.g. if a container is damaged or if periodicIBC replacement is required), it is recommended that thisis done using gravity rather than pumping, where feasible.Gravity transfer reduces the potential entrainment of airinto the product, which could affect the dispersant qualityduring long-term storage. Where EVOH-HDPE laminateIBCs are used as replacements, a nitrogen blanket may beadded to the headspace prior to sealing, to enhance thepotential shelf life of the product.

DOCUMENTATION

It is important that key information and inspection/testing records are maintained. This information istypically incorporated within a database and is likely toencompass:

l safety data sheet details;

l replicate label information;

l a schedule for inspections and testing;

l a record of dates and personnel undertaking visualinspections, for both general and individual unitchecks;

l notes of damaged or leaking containers and actionstaken;

l referenced photographs stemming from visual checks;and

l sampling and retesting results—including any failures;note that dates of retesting may be added to the labelaffixed to the storage container.

Section 7Maintenance

Key pointThorough inspection and retesting records

should be maintained.

Steel drums showing signs of deterioration after 25 years. Theywere stored inside but occasional roof leaks caused water topool on them which encouraged corrosion.

An 18-year-old plastic drum with deformation presumed to bethrough loss of solvent. Inset shows a resulting crack, whichultimately led to a leak in the drum.

Splitting necks were observed on25% of this stockpile of plasticdrums after 10–20 years instorage. The specific cause wasnot known, but such damagecould have an adverse impact onthe product as it is likely tobecome exposed to the air.


In most jurisdictions, the dispersant product approvalprocess includes laboratory testing for efficacy andtoxicity; a biodegradability test may also be stipulated.7

Some jurisdictions require periodic efficacy retesting. Noknown regulations mandate retesting for toxicity andbiodegradability.

A dispersant stored in optimal conditions should not loseeffectiveness to a significant extent. Studies undertakenin the UK by Warren Spring Laboratory for the Institute ofPetroleum and others in the 1980s indicated that thegreatest factor in the potential deterioration of dispersanteffectiveness over time relate to non-optimal storage.This could include damaged or corroded containers, lossof solvent through the container walls and permeation ofoxygen into the product, all of which may be exacerbatedby high humidity, high temperature and exposure todirect sunlight. Following the storage guidance in thisreport can eliminate or greatly mitigate against thesefactors. It is noted that the original work undertaken byWarren Spring Laboratory suggested a five-yearly efficacyretesting period for dispersant. Subsequent experiencewith stored products has indicated that an initial period of10 years prior to retesting is acceptable, unless visualinspections or changes in physical properties indicateotherwise.

It is prudent to undertake retesting to ensure that nodeterioration has occurred that would render theproduct’s effectiveness unacceptable. There arevariations in national efficacy retesting requirements; thefollowing guidance may be used in the absence of suchregulatory stipulations.

PHYSICAL PROPERTIES

Initial retesting may be made on the density and viscosityof a product, and the results compared with themanufacturer’s values for these parameters, e.g. asreported in the product’s SDS. The manufacturer mayprovide a range of acceptable values or a single value.Any measurements outside of the reported range, or asignificant change from a single value for either thedensity or viscosity, is likely to precede or indicate apossible reduction in product efficacy. Measurements ofthese physical properties are relatively straightforward;they can be performed on-site and do not require theservices of a certified laboratory. Records of all testsundertaken, together with the results, should be includedin the stockpile’s database and documentation.

A sample for testing can be obtained using a disposablesample ‘thief’ (a glass or plastic tube that can be blockedwith a thumb) or pipette, accessing the product via the topopening of an IBC, drum or tank. A sample thief may be usedto sample near the middle of the IBC to get a representativesubsample (i.e. not from near to the top or bottom of thecontainer). It may be advantageous to use an agitator/mixer set at relatively low speed, prior to taking the sample.

A common practice is to randomly select 10% of thecontainers in a batch for physical property retesting.These test results can then be used as a preliminaryscreening tool, wherein samples from containers found toexceed the manufacturer’s acceptable density or viscosityvalues can then undergo efficacy retesting (described onthe following pages).

Section 8

Retesting

7 IPIECA-IOGP (2014). Regulatory approval of dispersant products and authorization for their use. Report of the IOGP Global Industry Response Group(GIRG) response to the Macondo incident in the Gulf of Mexico in April 2010, Oil Spill Response Joint Industry Project (OSR-JIP).http://oilspillresponseproject.org

Key pointRetesting of the density and viscosity of a product may be

used to screen or identify product in containers/batches that should then be retested for efficacy.


EFFICACY

Periodic retesting

For non-bulk storage in IBCs, unless defined differently byapplicable national regulation, it is recommended that theinitial efficacy retesting is carried out after 10 yearsprovided that the product has remained sealed in itsoriginal containers. Subsequently the product should beretested every five years. The test should be carried outon at least 10% of samples from numerically referencedbatches that have been stored in the same locationunder the same conditions (e.g. 1 in every 10 IBCs in abatch should be retested). After sampling, if EVOH-HDPElaminate IBCs are in use, a replacement nitrogen blanketshould be introduced into the opened containers toreplace the oxygen in the headspace above the productprior to resealing.

Discretionary retesting should be carried out on storedunits that display damage or abnormalities noted underthe visual inspection regime.

Test methodology

The volume of dispersant needed for laboratory testing isrelatively small (only a few millilitres or less) and can beobtained using a disposable sample thief or pipette asdescribed under Physical properties on page 18. It maybe more practical to obtain a few tens of millilitres whensampling. Samples should be put into suitable small glassor HDPE bottles with Teflon™ caps/seals and labelled witha unique reference number linking them to the containerfrom which they were sampled.

The laboratory test methodology for efficacy shouldmirror that used for the original product approvalwherever possible. Where a test methodology is notstipulated by regulation, consideration should be given tousing simple and widely recognized tests, e.g. the rotatingflask, baffled flask or EXDET test protocols.8 Eachlaboratory method uses different levels of mixing energy,none of which can accurately simulate the complexmixing scenarios and energies encountered in the marineenvironment. Approved or certified laboratories shouldbe utilized for efficacy retesting whenever feasible.

Section 8Retesting

8 See NRC (2005). Oil Spill Dispersants: Efficacy and Effects. National Research Council of the National Academies, the National Academies Press,Washington D.C. www.nap.edu/openbook.php?record_id=11283

Key pointRetesting after an initial 10 years and then every 5 years

is recommended for dispersant stored in IBCs or equivalent containers.

A laboratory test can differentiate between good and poorproducts but does not replicate real-world open-waterconditions.

Kara

gand

a St

ate

Uni

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ity

Where dispersant product is stored in steel drums, theremay be heightened concerns that the containers are atrisk of deterioration due to corrosion, particularly in hotand humid climates such as in the tropics. Deteriorationof containers may ultimately lead to loss of solventand/or oxidation of surfactant, with resultant reductionsin product efficacy. It is recommended that an initialefficacy retest of dispersant product stored in steelcontainers is carried out after five years, and subsequentretests every three years. This applies to batches, in thesame manner as for dispersant stored in IBCs (see above).If a regular visual inspection regime, reflecting thatdescribed under Visual checks on pages 15–16,unequivocally indicates that there is no deterioration ofthe drums, it is acceptable to revert to the testing regimeas used for IBCs.

For bulk storage tanks, it is recommended that a sampleis tested every five years from the date the tank is initiallyfilled.


Section 8Retesting

SUMMARY OF AN EXAMPLE INSPECTION AND TESTING REGIME (AMOSC)

The Australian Marine Oil Spill Centre (AMOSC) maintains multiple stockpiles of dispersant for use by the oil andgas sector and to support Australia’s national dispersant capability. The maintenance regime used to ensureoperational readiness of AMOSC’s stockpiles includes efficacy testing of dispersant using the EXDET laboratory test.This is a testing protocol designed to allow the comparison of oil dispersion effectiveness from different dispersantformulations and for individual dispersants against test oils, within the parameters of the test. EXDET is designed toprovide robust, evaluative results that are not strongly influenced by either excessive or minimal mixing energy.

AMOSC’s dispersant stockpiles are routinely inspected for visual changes, and dispersant batches are sampled andsent to the laboratory for efficacy testing. Results are returned as a percentage of oil dispersed—noting that theselaboratory results only apply to the EXDET test.

Based on the results, performance criteria are used to determine the frequency in which additional testing isrequired in the future. Where performance is below 49%, consideration of disposal and/or replacement ofdispersant is recommended.

EXDET laboratory test results’ classification

Dispersability classification% oil dispersed

Excellent

Good

Average

Poor

Unsatisfactory

>80

60–79

45–59

30–44

0–29

Dispersant effectiveness testing schedule

Visual inspection Dispersant effectiveness testing

Test frequency Test frequency Test result (% efficiency)

5 years

2 years

Stock may need to be replaced

100% to 70%

69% to 50%

49% to 0%

Once every three years

A jurisdiction typically sets a pass mark for an efficacytest as part of the initial product approval process.Recognizing the investment made in dispersantstockpiles, it is accepted that some loss of efficacy ispermissible. For example, in the UK the pass mark forretesting is accepted as 75% of the original minimum.Thus, where the original minimum pass mark for productapproval in the UK is 60%, the retest pass mark is 45%using the same methodology.

A summary of an example inspection and testing regimefor dispersants is presented below, courtesy of theAustralian Marine Oil Spill Centre (AMOSC).

Key pointResults from different test methodologies are not directly

comparable and should not be extrapolated to describepotential effectiveness during real-world dispersant use.


Dispersants are relatively expensive products. The onlyreason that stockpiles are likely to be considered fordisposal is if they have deteriorated to an extent thatrenders the product’s effectiveness unacceptable. Wherean operation has viable dispersant but no longer requiresit, it is likely that the stock can be transferred to analternative operation.

It may be possible for some manufacturers toreconstitute a returned product. However, if stocks arecondemned, a framework of national industrial orhazardous waste regulations is likely to apply. It isrecommended that the dispersant supplier ormanufacturer is consulted for advice on disposal. It ispossible that the only viable final disposal option isincineration, which will invariably require the services ofapproved waste handing companies.

If condemned stocks of dispersant are disposed of, or if acontainer is damaged but the dispersant remainseffective and is transferred to a new container, theresulting empty containers should be taken to anapproved waste handling site for recycling or disposal. Ifcontainers need to be managed on-site, the emptycontainers should be washed, with the wash watercollected and treated. Clean empty containers may bedisposed of or recycled following the site’s wastemanagement policy.

Section 9

Disposal


The following are generic examples of checklists, whichmay be utilized to support a consistent approach to visualinspections of dispersant stocks. Results will typically berecorded in a database.

Annex 1

Annex 1: Visual inspection checklist

Table A1 Monthly or more frequent checklist (walk through stockpile)

Anytown

Product A, 30,000 litres, stored in IBCsProduct B, 20,000 litres, stored in IBCs

Location:

Dispersant:

02-06-yyyy

01-07-yyyy

03-08-yyyy

dd-mm-yyyy

dd-mm-yyyy

J. Smith

P. Jones

P. Jones

None

None

None

None

None

None

Good

Good

Good

IBC unit 1234-5678 label peeling.Replacement label affixed.

Good

Good

DateName ofinspector

Leaksobserved?

Container damageobserved?

Labelintegrity?

Warehouse conditionand housekeeping

Table A2 Detailed checklist for a visual inspection carried out every two-and-a-half years (for each container)

Anytown

Product A

xx-xxxx-xxxx

xxxx-xxxx

N/A

Any phase changes visible?

Any residue visible?

Colour abnormalities visible?

Any warping of IBCs?

Condition of IBC metal frames; any damage or corrosion?

Condition and legibility of label?

Location:

Dispersant:

Batch number:

Container unit number:

Previous container unitnumber (if relevant):

Checks:


The GHS identifies physical, health and environmentalhazard classes, and provides detailed guidance onwhether a substance or mixture qualifies as hazardous.For each class, numbered categories indicate the hazardseverity, with category 1 being the most severe. In somecases, there are subcategories (e.g. A, B, etc.) which canbe used by authorities that require more than onedesignation within that category. Examples of two classesand their categories, which may be associated withdispersants, are given in Table A3. Other classes whichmay be associated with dispersant products include‘specific target organ toxicity—single exposure’,‘respiratory or skin sensitization’ and ‘hazardous to theaquatic environment’. Reference should be made to aproduct’s SDS for a full identification of the hazards.

LABELLING

Guidance on labelling forms part of the GHS; specificnational regulations may also apply. Several GHS labellingelements are described below.

Signal words

The signal words used in the GHS are ‘Danger’ (used forthe more severe hazard categories, typically categories 1and 2) and ‘Warning’ (typically used for less severecategories). If the signal word ‘Danger’ applies, the signalword ‘Warning’ should not appear on a label.

Hazard statements

A hazard statement is a phrase assigned to a hazard classand category that describes the nature of the hazard and,where appropriate, the degree of hazard. A unique GHShazard statement code can be used for referencepurposes but should not be used to replace thestatement on labels or within an SDS.

Annex 2

Annex 2: The Globally Harmonized System ofClassification and Labelling of Chemicals (GHS)

Table A3 Examples of two GHS classes and their categories

GHS CLASS CATEGORIES

Skin corrosion/irritation

Serious eye damage/eye irritation

Category 1 (skin corrosion)

May be subdivided into 1A, 1B and 1C

Category 2 (skin irritation)

Category 3 (mild skin irritation)

Category 1 (serious eyedamage/irreversible effects on the eye)

Category 2 (eye irritation/reversible effects on the eye)

May be subdivided into 2A and 2B


Precautionary statements

A precautionary statement is a phrase that describesrecommended measures that should be taken tominimize or prevent adverse effects resulting fromexposure to a hazardous product, or from improperstorage or handling of a hazardous product.

A unique GHS precautionary statement code can be usedfor reference purposes but should not be used to replacethe statement on labels or within an SDS. Examples aregiven in Table A4.

Annex 2The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

Table A4 Examples of GHS precautionary statements

GHS PRECAUTIONARY STATEMENT

P305+P351+P33

P337+P313

P302+P352

P332+P313

P280

P264

P234+P235

P403

IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easyto do. Continue rinsing.

If eye irritation persists: Get medical advice/attention.

IF ON SKIN: Wash with plenty of water/soap.

If skin irritation occurs: Get medical advice/attention.

Wear protective gloves/protective clothing/eye protection/face protection.

Wash hands thoroughly after handling.

Keep only in original container. Keep cool.

Store in a well-ventilated place.


Pictograms

A pictogram is a graphical composition comprising asymbol within a border. All pictograms used in the GHSconsist of a square, set at one of its points, with a hazardsymbol at its centre. Examples of GHS classifications andlabelling requirements which might be associated withsome dispersants are given in Table A5. Others may alsoapply and reference should be made to a product’s SDS.

Older labelling systems or national systems may also beencountered as the GHS is not yet universally adopted(see examples on the right).

Annex 2The Globally Harmonized System of Classification and Labelling of Chemicals (GHS)

Table A5 Examples of GHS classifications and labelling

CLASSIFICATION LABELLING

Class Category Pictogram Signal word Hazard statement

HAZARDSTATEMENT

CODE

Serious eye damage/eye irritation

Skin corrosion/irritation

Specific target organtoxicity—singleexposure

Hazardous to theaquatic environment,short term (Acute)

1

2

3

4 (nopictogram)

Danger

Warning

Warning

(no signalword)

Causes seriouseye damage

Causes skinirritation

May causedrowsiness of

dizziness

Harmful toaquatic life

H318

H315

H336

H402

��

Harmful/irritant (now replaced by the GHShealth hazard exclamation mark)

US National Fire Protection Association (NFPA)Red = flammability, blue = health, yellow = instability, white = special hazard. For each coloured diamond: 0 = not significant, 1 = slight, 2 = moderate, 3 = high, 4 = extreme and * = chronic

Examples of older/national labelling systems that may stillbe encountered

IPIECA is the global oil and gas industry association for environmental and social issues. It develops, shares andpromotes good practices and knowledge to help the industry improve its environmental and socialperformance, and is the industry’s principal channel of communication with the United Nations.

Through its member-led working groups and executive leadership, IPIECA brings together the collectiveexpertise of oil and gas companies and associations. Its unique position within the industry enables its membersto respond effectively to key environmental and social issues.

MEMBERS

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IPIECA also has an active global network of oil and gas industry associationmembers. Please refer to the IPIECA website for a full list.

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