ROJECCT DE ESCR API HAL F
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1 INTRODUCTION ................................................................................................................................. 3 2 THE AREA AND THE STRUCTURAL PROJECT ........................................................................................ 3 3 STAGE DIVISION ................................................................................................................................ 7 3.1 Stage 1: R&D, Pilot Plant ................................................................................................................... 7 3.2 Stage 2: Expansion of the Stage I – manufacturing area for commercial use ................................... 9 3.3 Stage 3: New Manufacturing Plant for expanding production........................................................ 11 4 Activity of departments ................................................................................................................... 14 4.1 Management and administration.................................................................................................... 14 4.2 Quality Control ................................................................................................................................ 14 4.3 R&D, PILOT PLANT ........................................................................................................................... 15 4.4 MAINTENANCE ................................................................................................................................ 16 4.5 PRODUCTION ................................................................................................................................... 16 4.6 WAREHOUSE .................................................................................................................................... 16 4.6.1 INDOOR STORAGE AREA .......................................................................................................... 17 4.6.2 OUTDOOR STORAGE AREA ...................................................................................................... 17 4.6.3 LOADING/UNLOADING AREA .................................................................................................. 18 5 EQUIPMENT .................................................................................................................................... 18 5.1 LABS ................................................................................................................................................. 18 5.2 R&D, Pilot Plant – Validation Batches (Stage 1) .............................................................................. 19 5.3 Commercial Manufacturing (Stage 2).............................................................................................. 19 5.4 Building Expansion (Stage 3) ........................................................................................................... 20 6 ............................................................................................................................................................. 21 7 NUMBER OF EMPLOYEES ................................................................................................................. 21 7.1 Parking area ..................................................................................................................................... 21 8 SAFETY ............................................................................................................................................ 22 8.1 FIRE PROTECTION REQUIREMENTS ................................................................................................. 22 8.1.1 Technical report ....................................................................................................................... 22 8.1.2 Conditions of accessibility and viability ................................................................................... 22 8.1.3 Division into compartments .................................................................................................... 22 8.1.4 Ventilation ............................................................................................................................... 22 8.1.5 Overcrowding of environments ............................................................................................... 22 8.1.6 Source of fire ........................................................................................................................... 23 8.1.7 Workers and/or other people exposed to fire risk.................................................................. 23 1
8.1.8 Compensation of fire risk (anti‐fire strategy) .......................................................................... 23 8.1.9 Buildings Resistance to fire...................................................................................................... 23 8.1.10 Division into compartments .................................................................................................... 23 8.1.11 Emergency Exits ....................................................................................................................... 23 8.1.12 Emergency light ....................................................................................................................... 23 8.1.13 Fire Extinguishers..................................................................................................................... 24 8.1.14 Fire Hydrants ........................................................................................................................... 24 8.1.15 Smoke Detection ..................................................................................................................... 24 8.1.16 Emergency management ......................................................................................................... 24 8.1.17 Prevention measures ............................................................................................................... 24 9 PRODUCT HANDLING REQUIREMENTS ............................................................................................. 25 9.1 Risk Analysis ..................................................................................................................................... 25 9.2 Drying Phase .................................................................................................................................... 26 9.3 Pressure in the finishing room......................................................................................................... 26 10 HEALTH AND SAFETY.................................................................................................................... 27 11 ENVIRONMENTAL IMPACT ........................................................................................................... 28 2
1 INTRODUCTION STERLING S.N.I.F.F. Italia S.p.a. was founded in 1976 by current share holders, as a chemical company with limited liability (Ltd) for the production of flavors for the food and pharmaceutical industry. The base is in Corciano, province of Perugia. STERLING S.N.I.F.F. Italia S.p.a. focused exclusively on steroidal products, exports around 95% of its turnover, mainly to the USA, India, EU, Canada and Japan. Sterling S.N.I.F.F. Italia S.p.a. manufactures under Good Manufacturing Practices, and has been regularly inspected by AIFA (Italian Minister of Health) and US Food & Drug Administrator approved since 2002. The purpose of this Project Description Statement is to enable MEPA to take a screening decision and if required, to prepare the Terms of Reference for an Environmental Impact Assessment, in consultation with the Government entities, Non-Governmental Organizations and the public. 2 THE AREA AND THE STRUCTURAL PROJECT Sterling SNIFF Italia S.p.a. has formed a Maltese Company, designated Sterling Chemicals Malta Ltd, with the role of establishing and running the factory in Hal Far industrial Estate, site HHF051X, as approved by MIP as Sterling Chemicals Malta Ltd. The industrial area is already developed, and a number of other companies manufacturing active pharmaceutical ingredients and finished pharmaceuticals are already present in close proximity to the site. The figures below show the exact location on the map. The total area is about 3295 sq. meters. The building will be a brand new construction in order to satisfy all the regulatory and company requirements. This is already covered by MEPA Permit PA 4236/08. Figure 1 ‐ Aerial View 3
Figure 2 – Exact area The factory will be built in accordance with the KNPD 2006 guidelines with the accessibility for disabled restricted to the offices building. Access to the building will be via a main entrance doorway at road level or internally via the car park. The various levels are accessed by means of a passenger lift satisfying the KNPD criteria. The intention of the company is to phase the production of the facilities according to the factory activating/building new departments following a plan of 3 stages. The three distinct phases are described hereunder: 1. Stage 1: Research & Development (R&D). For this Stage STERLING CHEMICAL MALTA Ltd has already obtained the approval from MEPA (PA4236/08). 2. Stage 2: API Manufacturing Plant for commercial use that Sterling Chemical Malta seeks to get approval from MEPA. 3. Stage 3: New Manufacturing Plant for expanding production area that Sterling Chemical Malta seeks to get approval from MEPA. For ease of reference, we are including hereunder the architectural plans of the project highlighting the different work areas departments. 4
Figure 3 ‐ Basement Figure 4 – Level 0 Figure 5 ‐ Level 1 5
Figure 6 – Level 2 Figure 7 – Roof 6
3 STAGE DIVISION The following explains in detail how the operational structure is used in 3 different stages. Each Stage is also indicated through figures. 3.1 Stage 1: R&D, Pilot Plant R&D and Pilot Plant have the function to study, develop and optimize (in lab quantities) new processes. The development is defined by: Development at the plant in Malta and the transfer process from the establishment in Malta to the Italian plant; Development for the customer: a minimum quantity for the customer for the formulation trials, and dossier registration. The following areas will be activated: R&D, Pilot Plant Departments Workable areas Communal ownership Management Offices Indoor parking area Quality Control Office, laboratory, Sampling room Canteen Pilot area 1 Conference room Finishing area 1 Toilets Research and Development Related activities coutyard Utilities Loading/unloading area Repair shop LPG tank area Maintenance all areas in which you need a mechanical and construction repair Indoor raw material storage Liquid Storage wastes (outdoor) Warehouse Outdoor storage infiammable raw materials Solid storage wastes (outdoor) The following figure illustrates the interior layout of the ground floor building and outdoor spaces. 7
Figure 1 Lay out Level zero after stage 1 QC/R&D office QC/R&D lab Finishing area Related activities Storage solid waste storage infiammable LPG Tank Area Pilot area 1 Indoor Warehouse Repair shop Office management raw material and waste (raw material)
3.2 Stage 2: Expansion of the Stage I – manufacturing area for commercial use The company intends, after the regulatory activity, testing and approval of the sample by the customer, to begin the production for commercial use . Commercial Manufacturing Departments Workable areas Level Extension Pilot area 1 Level zero Pilot area 2 Level zero Production Extension finishing area Level zero Utilities Level one Administrative Offices Level one Archive Level one Management Meeting room Level one Training Centre Level one According to the activities that will take place during the first stage, the offices and the archives of the zero level can be immediately used. Therefore it will use the same premises of the Stage 1 with the introduction of new reactors for API production, shown in following figure.
Figure 2 Level one after stage 2 Finishing area pilot 2 Pilot area 2 Pilot area 1
3.3 Stage 3: New Manufacturing Plant for expanding production The company intends to upgrade the manufacturing capacity of the factory completing the building with new dedicated production lines and enlarging the offices with a new office floor: Departments Workable areas Level Offices Level zero New Production area Level zero Production New Finishing area Level zero Utilities Level zero New laboratory of Research and Level two Development Research & Development Pilot plant Level two Utilities pilot plant Level two Maintenance Maintenance office Level two Therefore it will use the same premises of the Stage1 and Stage2 with the introduction of new production area for API production, shown in following figure.
Production plant Stage 3 Figure 3 Level zero after stage 3.
Figura 4 Lay out of level zero for highlighting outdoor workable areas. Solid waste warehouse External flammables warehouse LPG Loading/Unloading
4 Activity of departments 4.1 Management and administration The management role involves not only the coordination, the leader of a group of worker, represented by the human resources available to the company or part of the company (organizational unit) under its responsibility, but also the decision-making planning and management to ensure the achievement of results in line with corporate goals and satisfy stakeholders, ie the entities (individuals or organizations) stakeholders towards the company. Belong to this department employees who work in a office administration, contact customers and suppliers, etc.. 4.2 Quality Control Are prepared by the laboratory QC (and consequently of its analysts) sampling operations of the raw materials, the production intermediates and finished products, In particular, the sampling takes place inside the weighing chamber upon activation of the intake system . In particular, the analyst must label the sample containers should check its appearance and smell, fill in the product label. QC task of recording of samples of the raw materials, the starting materials and packaging materials. E 'task of QC prepare and store the samples against, in particular the amount must be sufficient execution of at least two complete analyzes, against the samples are stored in a special cabinet in which is present a Hygrothermograph for monitoring the temperature and of the' relative humidity. The finished products must be stored for up to one year after the closure of the stability program. And 'the task of the laboratory Prepare standard chemical- physical internal selecting a batch having the highest possible quality characteristics, characterizing by: Identification: by spectroscopic analysis and HPLC; Title using the formula 100 - (purity solvents, ash, Karl Fischer) The analyzes’s results will be subjected to a critical review by the responsible QC. All tests shall be recorded on the appropriate analysis notebooks. In general, the routine analysis involves the following steps: Issuance of the request for analysis; Assigning the Required Number of Analysis; Operations Analysis and preliminary checks (checking the quantity, availability and conformity of reagents, workbenches and equipment to be used); Operations and checks during the analysis: Final operations (replace reagents, clean benches, hand analysis report to the Head QC); Issuance of the judgment of Conformity according to the results of the analysis; Issuance of the certificate of analysis which is the official document accompanying the goods which are outside the company
Each analysis must be carried out faithfully applying the method of analysis into force 4.3 R&D, PILOT PLANT The objective is the development of processes which are going to be performed later in the production plant and to prepare the small quantities that will be used both by our company and by our customers in advanced formulation development trials, dossier preparations and registration. The department of research and development is designed to meet the needs of its customers through multi-step operations such as: Optimization of synthesis processes already underway; New synthesis and development of existing ones; Isolation, characterization and synthesis of impurities; Validation of processes for the synthesis The department in stage 1 consists of a laboratory, pilot plant and a finished area. In stage 3 the entire department will be relocated to one level and the current pilot area 1 will be a production line for commercial use The quantities that will be manufacture are to be considered as “development quantities”. Stage 1 Process areas The process area function is to develop, optimize, synthesize and purify Active Pharmaceutical Ingredients and intermediates with research operations. The following operations will be performed: Solid loading through vacuum or hatch Loading from other reactors, hose connection Addition/dosing of liquids Distillation/reflux control and unloading Atmospheres (nitrogen, vent, vacuum) operation General inspection of the contents of reactors and some local indicators Reactor unloading, to filters, centrifuges other reactors and drain, hose connection Liquid-liquid separation Pumping and filtration/purification operations, hose connection. Finishing area The Finishing area function is to isolate and dry Active Pharmaceutical Ingredients and intermediates. The following operations will be performed: Filter loading control, hose connection Change of exhaustion sleeve filters in filters Filtered cake washing Filter discharge to drums Loading from drums to driers Discharge from driers to drums Weighing and sampling of drums Stage 2 No changes 15
Stage 3 New R&D lab, pilot plant and finished area of pilot plant in livel 1 4.4 MAINTENANCE The maintenance department, coordinated by the technical department of the company, primarily by repair of mechanical, electrical and building. It is equipped with a repair shop. In stage 3 the technical office will be located on the level 2. Stage 1 Repair shop Stage 2 No change Stage 3 Technical office in the level two 4.5 PRODUCTION Production plant for commercial use is divided in two areas: Production lines Finishing area In stage one, the system consists of reactors, centrifuges, filters and dryers will be available to the department of research and development while in stage 2 will be the first production line and finishing for the generation of active ingredients for commercial use. In stage 3 will be an extension of the production department with new reactors, centrifuges, filters, dryers, etc. Stage 1 No yet built Stage 2 Pilot area 1 Pilot area 2 Finishing area 1 Finishing area 2 Stage 3 New production area New finishing area The services associated with the production (utilities) such as nitrogen, steam, vacuum, compressed air and related equipment are associated with production lines and increase with them 4.6 WAREHOUSE The magazine is structured in such a way as to have available a control office and where the activity is carried administrative and bureaucratic and more premises in which the various 16
operations described later take place. It has three workable areas, Indoor storage area, Outdoor storage area, Unloading/Loading area. 4.6.1 INDOOR STORAGE AREA Indoor storage area is divided in four subareas: Raw materials warehouse; Finished products warehouse; Sampling/weighing room; Packaging room; Raw Material warehouse The Raw materials warehouse function is to stock all the raw materials Prior to the placement of goods in the intended position they must be placed on platforms to avoid any possible confusion between different goods or different lots of the same item. Heavier goods will be placed at the bottom while the goods are to be analyzed by the Quality Control laboratory must be placed in "quarantine area" and then, once approved, transferred to the "approved area". Le merci respinte sono invece trasferite nell’apposita area e identificate mediante l’apposizione dell’etichetta rossa “Respinto” The raw materials product storage holds drums/containers of solid product in pallets stored in shelves at up to six levels. Finished products warehouse The Finished products warehouse function is to stock all the finished product and intermediates. The finished product storage holds drums/containers of finished solid product in pallets stored in shelves at up to six levels. Sampling/weighing room Sampling/weighing operation is performed in this area. In the weighing room takes the charge of raw materials useful for the production, quality control laboratory and to research and development The area must be well ventilated to avoid smells and concentrations of noxious vapours. The area must be kept at room temperature, to avoid hot temperatures affecting product. The sampling activity is to carry out the sampling of raw materials or finished products in order to assess the quality Packaging room In this warehouse will be positioned secondary packaging for packaging and that is those not in direct contact with the products (drums cardboard or aluminum, boxes of paper or cardboard). 4.6.2 OUTDOOR STORAGE AREA Outdoor storage area function is to stock flammable products. The area will be covered and protected. Storage infiammable wastes 17
The storage of hazardous and flammable waste liquids in tank is deposited on containment basins. The storage area is open-air but sheltered by a steel roof to protect waste from the elements (rain, excessive heat, etc.).The inner surface of the catchment area will be coated with a quartz layer that guarantees the impermeability; the same flooring will be sloping in the direction of collection wells arranged at the ends of the basin itself. Within the basin there will be curbs to support the pallets. Storage solid wastes This area will be dedicated for the storage of non-hazardous waste materials such as paper, cardboard, plastic, glass, metal that will be closed in container In this area one will find the dedicated container for hazardous solid waste such as activated carbon or contaminated tank. Storage inflammable raw materials The type of storage is equal to that of the liquid wastes. 4.6.3 LOADING/UNLOADING AREA This activity involves operations monitoring compliance, quantity, integrity, cleanliness and identity of the goods from external suppliers resulting in unloading by means of conveyor. The activity will include the labeling of the different lots, the demands of analysis and sampling, and finally the storage of the goods. 5 EQUIPMENT The following chapter describes the general equipment that will be installed in the labs, scale up plant, production plant and utilities area. 5.1 LABS Counter flow laminar hood analytical HPLC analytical GC analytical KF ultrasonic bath Rotavapor electrical vacuum drying oven rotary vacuum pump immersion refrigerator Karl-Fischer particle size analyser-Malvern analytical IR conductimeter polarimeter analytical UV automatic titrate muffle furnace Accessories (flexible PTFE hoses, glassware, individual protective devices, precision balances, heating plates, portable instruments to measure pH, temperature and clothing) 18
HVAC system for laboratory air treatment plant + filter group 5.2 R&D, Pilot Plant – Validation Batches (Stage 1) Glassed steel pilot reactor Teflon pilot reactor, nominal capacity 10 l Accessories (flexible PTFE hoses, quick connections, individual protective devices, balances, clothing, industrial furnishing, ecc.) 3 Reactors Dryer 1 Buckner Filter Vacuum pumps group Stainless steel (AISI 304) blow-down tank Polypropylene scrubber with filling media, liquid reservoir and circulating pump Filter for compressed air Air compressor, reservoir capacity 500 l, nominal displacement 40 m3/h Package refrigerating chiller (+5°C) Package refrigerating chiller (-25°C) Active carbon filter Air treatment plant + filter group – Pilot Plant Air treatment plant + filter group – Finishing Area L1 Air treatment plant + filter group – SAS Boiler 1 Nitrogen Tank Cooling tower 1 Cooling tower 2 5.3 Commercial Manufacturing (Stage 2) Glassed steel pilot reactor, Teflon pilot reactor Accessories (flexible PTFE hoses, quick connections, individual protective devices, balances, clothing, industrial furnishing, ecc.) 3 Reactors Dryer 1 Buckner Filter Vacuum pumps group Stainless steel (AISI 304) blow-down tank Polypropylene scrubber with filling media, liquid reservoir and circulating pump Filter for compressed air Air compressor, reservoir capacity 500 l, nominal displacement 40 m3/h Package refrigerating chiller (+5°C) Package refrigerating chiller (-25°C) 19
Active carbon filter Air treatment plant + filter group –Pilot Plant Air treatment plant + filter group – Finishing Area L1 Air treatment plant + filter group – SAS Boiler 1 Nitrogen Tank Cooling tower 1 Cooling tower 2 4 Reactors Hastelloy manual discharge centrifuge, Ø 1250 mm + waste water discharge section 1 Hastelloy manual discharge centrifuge, Ø 1250 mm + waste water discharge section 2 Dryer 2 Boiler 2 Air treatment plant + filter group – L1 Air treatment plant + filter group – Finishing Area L2 5.4 Building Expansion (Stage 3) Glassed steel pilot reactor Teflon pilot reactor Accessories (flexible PTFE hoses, quick connections, individual protective devices, balances, clothing, industrial furnishing, ecc.) 3 Reactors Dryer 1 Buckner Filter Vacuum pumps group Stainless steel (AISI 304) blow-down tank Polypropylene scrubber with filling media, liquid reservoir and circulating pump Filter for compressed air Air compressor, reservoir capacity 500 l, nominal displacement 40 m3/h Package refrigerating chiller (+5°C) Package refrigerating chiller (-25°C) Active carbon filter Air treatment plant + filter group – Pilot Plant Air treatment plant + filter group – Finishing Area L1 Air treatment plant + filter group – SAS Boiler 1 Nitrogen Tank Cooling tower 1 Cooling tower 2 4 Reactors Hastelloy manual discharge centrifuge, Ø 1250 mm + waste water discharge section 1 Hastelloy manual discharge centrifuge, Ø 1250 mm + waste water discharge section 2 Dryer 2 Boiler 2 Air treatment plant + filter group – L1 Air treatment plant + filter group – Finishing Area L2 20
5 Reactors Hastelloy manual discharge centrifuge, Ø 1250 mm + waste water discharge section 3 Dryer 3 6 This section has been omitted. 7 NUMBER OF EMPLOYEES The project will implement new full-time employment on a shift basis as follows: Stage 1 7 persons Stage 2 6 persons Stage 3 7 persons Total 20 persons The following skill levels are required: Executive & administrative; Managers; Technicians; Engineers; Semi-skilled; Unskilled; 7.1 Parking area A car park at street level is being provided catering for 21 parking spaces including one for exclusive use by persons with disability as per KNPD guidelines. Total number of employees envisaged up to stage 3 is 20 persons, which will be spread out in two shifts such that at any one time the maximum number of employees on the premises will be 15. Two spaces are being reserved for visitors. 21
8 SAFETY 8.1 FIRE PROTECTION REQUIREMENTS 8.1.1 Technical report Dangerous substances Because of the nature of Sterling’s steroidal chemistry, in case of fire it is more appropriate to use powder instead of water as a mean of fire extinguishing (some exothermic reactions could be activated by the presence of water). Stage 1 The quantities involved are very low because of the nature of the stage 1 (R&D and pilot plant). Stage 2 and Stage 3 The multipurpose manufacturing area, including the indoor and outdoor warehouse, is at this stage active. In all manufacturing areas dangerous and inflammable substances are used, however, the quantities involved are low because these are stored outside, in the open air warehouse. In steroids production lines there are some dangerous substances, which are inserted in some reactors. Dangerous substances and the others which are necessary to the production, are stored in minimum quantities in the warehouses and sent to the appropriate production line. 8.1.2 Conditions of accessibility and viability The areas, where the discussed activities are performed are accessible by Fire Department vehicle and have a minimum width greater than 4 m and have no headroom restrictions. 8.1.3 Division into compartments The buildings is divided into compartments in order to minimize the fire risk and its eventual propagation. The choice of compartments has been made focusing the attention to environment safety compatibly with productive needs and local regulations. 8.1.4 Ventilation Mechanical ventilation plant is used to avoid the dispersion of dangerous substances in the production area during the charging and discharging of the reactors. For the finishing and filtration room there is an appropriate UTA that, besides controlling the ventilation levels, also controls the humidity and the temperature, and maintains the environment in a slight overpressure to avoid outside contaminations. 8.1.5 Overcrowding of environments Rooms in the production areas are only accessible to the workers. People who are external to the company are only allowed to access the office areas. 22
8.1.6 Source of fire Inside the building the following possible sources of fire are considered: - Electric plant - Charge and discharge operations It must be said that this probability is remarkably low because the electric plant will meet ATEX standards. Regarding charging operations, the quantities of dangerous goods are kept to a minimum and everything happens under controlled conditions. 8.1.7 Workers and/or other people exposed to fire risk During the working operations the principal risks are in the pouring of substances, an operation that happens outside, in the weighing area of the inflammable storage. During charging of the reactors, the risk decreases drastically because handled quantities are smaller and use a vacuum loading system. In the management of the plant and in the exercise of activities, in the interest of safety, the following standards will be observed: Use, control, maintenance of temperatures according the instructions provided by the suppliers; Electric plant to conform to the current technical regulations; Control and maintenance of electric and mechanical equipment; Installation, control and maintenance of the necessary fire garrison; Training of staff regarding the rules of safety behaviour, basic emergency procedures and on the use patterns; Maintenance of a high quality level of the work environment (cleaning, tidy up, etc.). 8.1.8 Compensation of fire risk (anti-fire strategy) The fire-fighting strategy is based on the following points: 8.1.9 Buildings Resistance to fire The warehouse areas will be built with a resistance to fire of at least REI120. 8.1.10 Division into compartments The building is divided into compartments separated by fire rated walls and doors. 8.1.11 Emergency Exits Different compartments have emergency exits as necessary to guarantee the evacuation to a safe outdoor area. During the day to day running of the plant, the staff must make sure that the Fire Exit routes are maintained clear at all times. 8.1.12 Emergency light Inside the building and near the emergency exits there will be automatic emergency lights which will be activated in the event of a fire or power failure, indicating the safe way out of the building. 23
8.1.13 Fire Extinguishers In every compartments there will be powder extinguisher, type 21A 144BC, one for about every 100 sq.m., at least. Extinguishers, pointed out by appropriate notices, are located in strategic points, such as near the fire exits, and areas that are considered as high risk zone. Every fire-fighting garrison will be adequately indicated by appropriate notices. 8.1.14 Fire Hydrants As previously explained, because of the nature of Sterling’s steroidal chemistry, in case of fire it is more appropriate to use powder instead of water (some exothermic reactions could be activated by the presence of water). In any case, outside of each building, near fire exits, there is a network of ring fire hydrants. Furthermore, there is a hydrant installed in the offices area. Position and number are such as to guarantee the covering of every area; the ring network is fed by the main reservoir. The fire hydrant system is supplied by a motor pump installed outside the building. All the fire fighting garrisons will be sign-posted adequately. 8.1.15 Smoke Detection Furthermore, a smoke detection system will be put in place (to comply with UNI) which covers both the production areas which house the reactors and the filtering areas, and the utility zone at the first floor. 8.1.16 Emergency management the following will take place: - a worker will be appointed head of security - a plan for the actualisation and the control of the safety measures is to be implemented, with a particularly regard to: measures to prevent the occurrence of fire and its propagation (prohibition, exercise precaution, controls); control and maintenance of fire fighting garrison (extinguishing equipment, exit paths, etc.); procedures to follow in case of fire, through the elaboration of a emergency and evacuation plan; information and education of the staff. 8.1.17 Prevention measures The prevention plan will be brought to the attention of the staff, focusing on the most common fire dangers, with particular reference to: storage and manipulation of inflammable goods; rubbish and combustible waste storage; usage of free flames or heat generation equipment; 24
usage of electric plant and equipment; specific risk areas; Furthermore, regular control will be carried out to guarantee: the keeping of a safe environment; the availability of exit paths; the visibility of safety notices; the safety of electric plant. 9 PRODUCT HANDLING REQUIREMENTS 9.1 Risk Analysis In the loading of starting materials, the workers put the reactor under vacuum by the opposite circuit. Considerable quantities of liquid starting materials are aspirated from their container assembled to a fixed line with a flexible pipe and loaded in the reactor placing the localized suction exactly on the entrance of the container. In case of use of little quantities of liquid starting materials, workers use a membrane pump. The solid is loaded from the hatch, placing the localized suction on it. To avoid the spreading of vapours and/or powders in the work environment, the localized suction must be used by the proper placing of the aspirant arm in cases as follows: On the opening of drums and/or cistern during the charging and/or discharging of solvents and/or bitterns. On the opening of reactors (generally the hatch) during the charging of solids and/or liquids. On the opening of reactors (generally the hatch) during the drawing of samples of the reaction mass. On any other possible vapours and liquids source which could spread in the work environment. The use of the localized suction doesn’t exclude and doesn’t replace the use of P.P.D. (Personal Protective Devices) by the single worker. Vapours and possibly powders which could escape from drums and/or cistern during the charging of solids are aspirated by the mobile appendix of capitation located in the various point of the plant and sent to the scrubber. Emissions which originate from the two manifolds of the vacuum and the normal emissions produced in the heating or reaction phase, are conveyed in a third collector, and go to the abatement column too. The condensate is then discharged by falling in drums or cistern using an aspiration mouth. The aspiration system will always remain in function, even when there is no processing ongoing, so possible residual vapours could be aspired without spreading in the environment, avoiding the rise of diffused emissions and guaranteeing total care of workers’ health. 25
To keep work environments as clean as possible, operators must clean the pipes, samplers, utensils, and other equipment after their use, demonstrating the execution of these operations by filling in the appropriate documentation. They also have to verify integrity and cleaning of the materials to use, as well as the availability, integrity and cleaning of P.P.D. and the functionality of machinery and equipment after every use. 9.2 Drying Phase Drying of solid and damp product takes place in the finishing rooms. This operation takes place in a room with a light overpressure where there is a dryer under vacuum fitted with a water system circulation heating jacket. During the drying, the product is kept at a constant temperature of 70°C and under vacuum by an opposite group for vacuum. Vacuum pumps deliveries are conveyed in the abatement. On completion, the finished product is placed in double polyethylene bags and aluminium drums. The entire area is conditioned by an opposite treatment unit which consists of a section to deal with emission, one to deal with distribution and another one for expulsion. In fact, the external air which is introduced into the finishing room is adequately filtrated, temperature regulated, and at constant humidity. The air is sent back outside after passing through a series of absolute filters for the complete elimination of any dust. In order to work in the finishing room in conditions of maximum security, operators will have internal procedures which determine the moving of products and staff inside the room, the maintenance of filters and the control of the pressures. It is obligatory that inside the finishing room, the opening of each door will be preceded by the closure of the previous door to minimise losses in pressure. 9.3 Pressure in the finishing room In the carrying out of proper work, in full compliance with the standards of good manufacturing, and to avoid any possibility of contamination, a system of differences in pressure is created between the various rooms that constitute the finishing area. To guarantee work conditions in the finishing room, and to enable full compliance with the standards of good manufacturing, one of the key issues is to have a highly efficient ventilation system. For this purpose is essential that the installed filters are efficient, and therefore, do not present anomalies, breakings, saturations or other issues which wouldn’t allow satisfactory work conditions. For this reason, daily control and periodical change of filters is necessary. 26
10 HEALTH AND SAFETY During working time, workers have the duty to leave their own clothes in the lockers located in the changing room and to wear suitable work clothes (overalls, shoes, semi face pack or full face pack with universal filters for organic powders and vapours, and glasses for protection from chemical agents). In the production department workers wear disposable Personal Protective Devices (full overalls, overboots, cap, muffs, gloves) from the moment are in contact with finished products, intermediates and starting materials, both solid and liquid. Disposable-P.P.D. must be changed when workers handle finished products or different intermediates and in the loading of starting materials for different process, in order to maintain a high level of cleanliness and personal care, reducing to a minimum any possibility of contact with chemical substances. All the employees are requested to undergo appropriate training before commencement of works to ensure the correct use of P.P.D. and execution of working procedures in order to reduce and possibly eliminate any possibility of accident. 27
Acquatic ASPECT Atmosphere environment ENVIRONMENTAL AREAS DEPARTMENTS gases fine dust pollutants IMPACT Emissions layer and / or hazardous air Producing odors Increase of gases Water consumption harmful to the ozone Increased amounts of Increase of greenhouse 11 ENVIRONMENTAL IMPACT Using machinery and x x x construction equipment x x Waste x Structure maintenance x MAINTEINANCE Plant maintenance Transport (Staker) Storage of raw materials Weighing WAREHOUSE x x x Using transport Management and x production of waste Transforming raw x x x PRODUCTION materials into product ENVIRONMENTAL IMPACTS x Using paper using toner OFFICIES Sampling of raw materials and finished products x x Chemical analysis QUALITY CONTROL Storage of raw materials LABORATORY x Chemical analysis Production of product x x AND samples RESEARCH Supply and storage of raw LABORATORY DEVELOPMENT materials
Soil utilization x x x x x Water discharged into sensitive receptors Alteration of surface water budgets and / or x underground Soil and subsoil Soil contamination to relapse dust and other x contaminants Use of soil x x Alteration of the chemical / physical / x biological soil Soil contamination to relapse dust and other Flora and fauna contaminants Use of soil Disruption of ecosystems and ecological networks Ecosystems Reduction of surface quality and biological ecosystems 29
Impact on the x landscape Alteration of the Landscape historical / social / x economic Changing the noise x x x x x x x x x x climate around the site Alteration of the level of vibrations in the Climate noise and surrounding site vibration Changing the noise climate in the x x x x x x x workplace Alteration of the level of vibration in the working environment Consumption of x x x x x x x x x x x x x x x electricity Energy resources Consumption of fuels x x x Consumption of water Impact of light sources Electromagnetism x in the site Production of non- x x x x x x x x x x hazardous waste Waste Production of x x x x x x x x x hazardous waste 30
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