RBDS Safety Review Risk Reduction Report

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							                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire,
                                 England, SP10 5AA Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836



RBDS Safety Review & Risk Reduction Report
1     RISK ASSESSMENT STRATEGY
                                                                                     RISK IDENTIFICATION
The process of Risk Assessment
combines a series of reviews to                                        RISK ASSESSMENT
identify hazards with a specific risk                                     STRATEGY
classification (low, medium, high and
very high risks) and secondly to apply
a risk reduction process.

The Risk Reduction Process is the
application of standard operating                                    RISK IDENTIFICATION
procedures and/or safety devices (not
relying on the operator) to reduce
medium and high risks to low risk.
Any identifiable “very high risks” stop
the hazard assessment process as
such safety critical equipment design                                  RISK ASSESSMENT
is not appropriate for this type of
assessment which must be replaced
by a higher level HAZOP (Hazard in
Operations) study.

1.1    REVIEWS                                                          RISK REDUCTION

A Hazard Review is completed for
equipment and/or processes with
respect to operator safety while
normal (standard) operations and/or                               RISK ASSESSMENT AFTER
procedures are undertaken.             (A                             RISK REDUCTION
further Risk Review can be completed
to identify risks to product quality i.e.           Figure 1 – Equipment risk assessment review structure
compromise       the   quality   of     a
Pharmaceutical      or   Biotechnology
company product.)

1.2    RISK CLASSIFICATION

As a reference for Risk Classification European Monograph EN1050 is used.
The Risk is then clarified numerically based on the factors of severity,
frequency, probability and avoidance. This operation is performed for each
identifiable risk with the numerical classification as follows:

        1 to 4           =               Low Risk

        5 to 7           =               Medium Risk

        8 to 10          =               High Risk

        11 to 14         =               Very High Risk




Document No: RBDS-009 / Rev. 1              Page 1 of 21                          BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire,
                                 England, SP10 5AA Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




2     RISK IDENTIFICATION

The check list(s) (included) forms a structure for the review and must be
completed as part of the review. These forms are then processed through the
risk analysis matrix to categorise the level of risk.

2.1     CHECK LIST A

Risk Identification stage is completed to review all possible sources of
potential injury or damage to health of operators and personnel in the vicinity
of equipment during operation.

2.2     CHECK LIST B

This Risk Identification stage is for assessment of product quality and security
by review of critical control points (i.e. the risk to product quality from failure
or deviation to out of specification (OOS) limits).

Risk Identification is completed by checklist prompt with a review of listed
items to consider. Both comments on risks and risk production methods are
added to the form.

2.3     RISK ASSESSMENT

Identified risks are processed through the risk analysis estimation form to
categorise (by scoring) risks as low, medium or high.

2.4     RISK REDUCTION

Following risk assessment a process of actions for risk reduction should be
undertaken.

The following actions apply:

•     For all LOW RISKS a Standard Operating Procedure (“S.O.P”) should be put
      in place or a monitoring programme is required to verify continued
      compliance. I.e. At least one additional safe guard, which may rely on the
      operator.

•     MEDIUM RISKS should be reduced to low risk by two additional safe
      guards. One may rely on the operator (S.O.P) but one must be automatic
      or a barrier not relying on operator i.e. a) Procedural, b) Risk Reduction by
      Design.

•     HIGH RISKS should be reduced to low risk by two additional safe guards
      both not relying on operators. i.e. Risk Reduction by Design.

2.5     RISK ASSESSMENT AFTER RISK REDUCTION

•     Finally after the risk reduction methods/procedures are in place an
      assessment is made to verify methods/procedure meet the aim.



Document No: RBDS-009 / Rev. 1              Page 2 of 21                          BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire,
                                 England, SP10 5AA Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836


3    Risk identification Checklist A – Operator Safety

3.1 GROUP 1 – RISKS
Equipment Handling

3.1.1 Risks in physical movement/transfer of RBDS equipment in terms of
      strain injury to operators and movement (run away) on slopes.

3.1.2 Risks from residual hydrogen peroxide remaining in equipment when
      moving/transfer of gas generator.


3.2 GROUP 2 - RISKS
Mechanical Safety

3.2.1 Are there any finger traps on the gas generator or in any connections
      made?

3.2.2 Are there any poor ergonomics in use in the gas generator or making
      connections that may give rise to strain injury?

3.2.3 In the normal product configuration does the operator have access to
      moving parts?

3.2.4 During maintenance and re-calibration is the Service Engineer exposed
      to unnecessary risks, moving parts, excessive loads?

3.2.5 Are there any trip hazards associated with connections from gas
      generator to other equipment?

3.3 GROUP 3 - RISKS
Electrical Safety

3.3.1 Do operators have access, during normal operations, to mains (high)
      voltage electrical equipment?

3.3.2 Are Service Engineers exposed                        to    unnecessary           risks   during
      maintenance/re-calibration tasks?

3.3.3 Is there any risk of wetting electrical equipment (a) in normal
      operations (b) from other process sources?

3.3.4 Are operators exposed to any electrically heated surfaces (greater than
      400C) during normal operations?

3.3.5 Do any electrical leads provide a trip hazard?




Document No: RBDS-009 / Rev. 1              Page 3 of 21                          BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire,
                                 England, SP10 5AA Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836


3.3.6 Are any extension cables required to make connections to mains
      supply, if so do they present an additional risk?

3.3.7 During power failure does the equipment shut down safely and on
      recovery is start up safe? Consider power failure in each mode of
      operation:-

                Conditioning
                Gassing
                Aeration

3.3.8 Is there risk of fire or explosion due to electrical energy?


3.4 GROUP 4 - RISKS
Chemicals

3.4.1 Are operators exposed to unnecessary risks during loading of
      hydrogen peroxide into gas generator?

3.4.2 Are there any potential residuals of hydrogen peroxide on surfaces
      accessible to operators in normal operations?

3.4.3 Are there unnecessary risks to Maintenance engineers from potential
      contact with hydrogen peroxide during equipment maintenance/repair?

3.4.4 Can hydrogen peroxide accumulate in pipework/tubing which would
      present a risk when removed or accessed by Operators or Maintenance
      engineers. Consider accumulation by H2O2 in pump tubing?

3.4.5 Are hydrogen peroxide bottle(s) stored safely and do not present a risk
      to operators on handling?

3.4.6 Is a spillage procedure in place for safe recovery under failure/fault
      conditions?

3.4.7 Are the necessary warning labels on the equipment as well as on the
      supplied bottles of hydrogen peroxide liquid?

3.4.8 Is fault/failure recovery Personal Protective Equipment (PPE) in place for
      handling spillage and as required during leakage of hydrogen peroxide
      gas?

3.4.9 Can hydrogen peroxide oxidise materials and in the process heat up
      materials so auto-ignition can occur?


3.5   GROUP 5 – LEAK INTEGRITY – HYDROGEN PEROXIDE RELEASE

3.5.1 Risk of loss in leak integrity from RBDS equipment
      a) Gas leakage
      b) Liquid H2O2 leakage




Document No: RBDS-009 / Rev. 1              Page 4 of 21                          BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire,
                                 England, SP10 5AA Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




3.5.2 Risk of loss in leak integrity from a room.

3.5.3 Risk from deviation of pressure (00S) of enclosure when at full
      hydrogen peroxide gas concentration
            a) High pressure
            b) Low pressure

3.5.4 Risk of personnel entering the enclosure during the gassing phase.

3.5.5 Risk of gas penetrating other (adjacent) areas during gassing process

3.5.6 Risk to operator on entering room post decontamination due to high
      H2O2 concentration.

3.5.7 Risk to operator during emergency or system failure.


4     Risk Identification Checklist B – critical control points

4.1    GROUP 6 – PROCESS PARAMETERS – CRITICAL CONTROL POINTS

Leak Integrity

4.1.1 Risk to process from gas generator pre filter(s) integrity failure.

Temperature

4.1.2 Risk to process from deviation (OOS) of H2O2 vaporiser temperature

        a) Over temperature
        b) Under temperature

4.1.3 Risk to process from environmental overtemp

Airflow

4.1.4 Risk to process from deviation (OOS) of gas circulation airflow

        a) During conditioning
        b) During gassing
        c) During aeration (hydrogen peroxide removal)
           • Phase one aeration

Hydrogen peroxide Liquid Flow

4.1.5 Risk to process from deviation (OOS) of hydrogen peroxide flow.

                a) Flow delivery low to vaporiser
                b) hydrogen peroxide bottle runs out before cycle end.
                c) Over fill of vaporiser




Document No: RBDS-009 / Rev. 1              Page 5 of 21                          BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire,
                                 England, SP10 5AA Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836


4.1.6 Risk to process of cooling fan failures
             a) electrical tray cooling

4.1.7 Risk to process of Aeration unit failure / cable failure.

Comms failure

4.1.8 Risk of communication failure & loss of control.


4.2   GROUP 7 – GASSING CYCLE – CRITICAL CONTROL POINTS

4.2.1 Risk of poor gas distribution during gassing cycle

        a) Stirrer fan(s) off or failed during gassing of isolator if applicable.
        b) Nozzle(s) off or failed during gassing of room if applicable.

4.2.2 Risk to poisoning the catalyst during gassing cycle, from

        a) Incompatible chemicals
        b) In process coating from process materials

4.2.3 Risk of bio-contamination after gassing cycle due to pre-filter integrity
      failure.

4.2.4 Risk of bio-decontamination not being achieved when room surfaces
      are out of specification (OOS) limits.

4.2.5 Risk of residual hydrogen peroxide gas remaining after cycle end due
      to recesses in room.




Document No: RBDS-009 / Rev. 1              Page 6 of 21                          BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




RISK ANALYSIS
1 to 4     =   Low Risk                                                                   Fig. 2 RISK ESTIMATION TABLE
5 to 7     =   Medium Risk
8 to 10    =   High Risk
11 to14    =   Very High Risk

                                                                                                                                       PROBABILITY

                                                                 Frequency                                         Unlikely to          May occur in
                                                                                                                                         Prob a bility              Very likely
                                 Severity                                                                            occur             normal events                 to occur
                                                                   1
                                                                           Infrequent                                      1                     2                        3
Severity
                                                                   2       Frequent
Would distract or give an
operator cause for concern        1                                                                                                      3            4              5        6
                                                                                                                       1         2

Would cause minor injury
or temporary harm to                                                   1                                               3         4       5            6              7        8
health and/or may
(increase risk) of                2
                                                                       2                                               5         6       7            8              9        10
compromising product
quality
                                                                       1                                               7         8       9           10              11       12
Severe                            3
Would cause injury or                                                  2                                               9       10       11           12              13       14
permanent harm to health
and/or compromise                                                                                                  1                     1            2              1         2
                                                                                                                               2
product quality

                                                                                                                                         Avoidance

                                                                                                                                             1       Avoidable


                                                                                                                                             2       Unavoidable




Document No: RBDS-009 / Rev. 1                                                  Page 7 of 21                                                                     BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




S – SEVERITY                             F - FREQUENCY                                 P – PROBABILITY                                  A - AVOIDANCE
sk Ref       Stage (1)                               Stage (2)                      Commentary                                    Stage (3)
Number       Identified Risk                         Category                                                                     Protection / Solution
and                                                  Low, Medium,                                                                 Risk Reduction Method
Group                                                High Risk from                                                               Reduction Level (1) S.O.P
                                                     Analysis                                                                     Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.1.1           Risks in physical                         Score: ____3____          S=   2      The RBDS equipment is             Reduce risk by applying risk reduction
Equipment       movement/transfer of RBDS                                           F=   1      easy to move and only             level 1.
Handling        equipment in terms of strain              Classification:           P=   1      weighs approximately              (1) S.O.P – Equipment handling and
                injury to operators and                   Low Risk                  A=   1      25 kg, run away on a                  lifting.
                movement (run away) on slopes                                                   slope is a risk

3.1.2           Risks from residual hydrogen              Score: ____5____          S=   2      The hydrogen peroxide             Reduce risk to low by applying risk
Equipment       peroxide remaining in equipment                                     F=   1      bottle can be removed             reduction level 2.
Handling        when moving/transferring the              Classification:           P=   2      but some residual                 (1) S.O.P – H2O2 Handling.
                gas generator.                            Medium Risk               A=   1      liquid remains in the             (2) Reverse pump to drain tubes at
                                                                                                tubing.                               cycle end
                                                                                                                                  Reduce risk by applying risk reduction
3.2.1           Are there any finger traps on the         Score: ____3____          S=2         The connections                   level 1.
Mechanical      Gas generator or in connections                                     F=1         between the gas                   (1) S.O.P. – equipment set-up
Safety          made?                                     Classification:           P=1         generator and
                                                          Low Risk                  A= 1        distributor nozzle may
                                                                                                cause finger traps

3.2.2           Are there any poor ergonomics in          Score: ____1____          S=1         Bending down to                   Apply risk reduction level (1)
Mechanical      use of gas generator or making                                      F=1         load/unload                       • S.O.P. Equipment Set-up
Safety          connections that may give rise to         Classification:           P=1         H2O2 Bottle. Bottles
                strain injury?                            Low Risk                  A=1         needs care.
                                                                                                Connections O.K.




Document No: RBDS-009 / Rev. 1                                                  Page 8 of 21                                                            BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                    A - AVOIDANCE
sk Ref        Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.2.3           In the normal product                     Score: ____1____          S=1         Normal configuration              Apply risk reduction level (1)
Mechanical      configuration does the operator                                     F=1         Does not present risks            • S.O.P for pump tube change,
Safety          have access to moving parts?              Classification:           P=1         Changing consumable                  including instructions for power
                When replacing consumable                 Low Risk                  A=1         pump Tubes is a risk if              off before access.
                parts does the operator have                                                    pumps on – power
                access to moving parts                                                          must be off.

3.2.4           During maintenance and re-                Score: ____1____          S=1         With gas generator                Apply risk reduction level (1)
Mechanical      calibration is the Service Engineer                                 F=1         panels open there is              • S.O.P Procedures and manuals
Safety          exposed to unnecessary risks,             Classification:           P=1         risk when powered up -               must be in place with work taken
                moving parts or excessive loads?          Low Risk                  A=1         additional internal                  out by qualified persons.
                                                                                                guards are fitted.

3.2.5           Are there any trip hazards                Score: ____1____          S=1         Only if the power                 Apply risk reduction level (1)
Mechanical      associated with connections from                                    F=1         leads / communication             • S.O.P placement of gas generator
Safety          gas generator to other                    Classification:           P=1         leads are connected                  for connection to
                equipment?                                Low Risk                  A=1         across a means of                    isolator/enclosure/room.
                                                                                                access (gangway) is
                                                                                                there a risk

3.3.1           Do operators have access, during          Score: ____0____          S=0         The equipment is fully            No further action is required
Electrical      normal operations, to mains                                         F=0         guarded for normal
Safety          (high) voltage electrical                 Classification:           P=0         operations
                equipment?                                Not classified            A=0




Document No: RBDS-009 / Rev. 1                                                  Page 9 of 21                                                            BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                   A - AVOIDANCE
sk Ref        Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.3.2           Are Service Engineers exposed to          Score: ____7____          S=3         The equipment                     Apply risk reduction level (2)
Electrical      unnecessary risks during                                            F=1         operates on mains                 (1) S.O.P – Maintenance/calibration
Safety          maintenance/re-calibration tasks?         Classification:           P=1         voltage and is not                    Procedures for use by Qualified
                                                          Medium Risk               A=1         without risk                          persons
                                                                                                                                  (2) Fit internal guarding where
                                                                                                                                      possible
                                                                                                In normal operations
3.3.3           Is there any risk of wetting              Score: ___8____           S=3         the liquid bottles are            Apply risk reduction level (3)
Electrical      electrical equipment (a) in normal                                  F=1         along side the electrical         (1) S.O.P – Equipment set up &
Safety          operations                                Classification:           P=1         tray If the equipment                 operation
                (b) from other process sources?           High Risk                 A=2         was exposed to                    (2) In design, raise high voltage
                                                                                                excessive amount of                   circuits above bottle where
                                                                                                water there would be a                possible.
                                                                                                risk.                             (3) Provide splash proof covering

3.3.4           Are operators exposed to any              Score: ____7____          S=2         Vapouriser will become            Apply risk reduction level (2)
Electrical      electrically heated surfaces                                        F=2         hot >100°C during                 (1) S.O.P – handling / equipment
Safety          (greater than 400C) during                Classification:           P=2         systems normal                        operation
                normal operations? And are                Medium Risk               A=1         operation. Therefore              (2) In design use insulation on
                operators exposed to cold                                                       operator at risk.                     hot/cold exposed surfaces. Label
                surfaces which could cause harm                                                                                       hot surfaces.
                to persons




Document No: RBDS-009 / Rev. 1                                                 Page 10 of 21                                                           BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                    A - AVOIDANCE
sk Ref        Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.3.5           Do any electrical leads provide a         Score: ____8____          S=2         The power &                       Apply risk reduction level (2)
Electrical      trip hazard?                                                        F=1         communications leads              (1) S.O.P – Power connection
Safety                                                    Classification:           P=1         would provide a trip              (2) By design ensure the lead is long
                                                          Medium Risk               A=1         hazard if not correctly               enough to reach a power point
                                                                                                routed.                               with the lead on the floor.



3.3.6           Are any extension cables                  Score: ____4____          S=1         Extension cables should            Apply risk reduction level (1)
Electrical      required to make connections to                                     F=1         be avoided as they                 (1) S.O.P – Power connection, without
Safety          mains supply, if so do they               Classification:           P=1         present risk at the                    extension cables.
                present an additional risk?               Low Risk                  A=1         extension connection
                                                                                                plus they can be an                Note:- By design socket outlets need
                                                                                                additional trip hazard.            to be close to point of use of gas
                                                                                                                                   generator.


3.3.7           During power failure does the             Score: ____7____          S=2         Interruption of the                Apply risk reduction level (2)
Electrical      equipment shut down safely and                                      F=1         gassing process at any             (1) S.O.P – Fault/failure recovery
Safety          on recovery is start up safe?             Classification:           P=2         stage would be a non               (2) On power failure system to fail
                Consider power failure in each            Medium Risk               A=2         validated cycle.                       safe and cycle abort. Operators
                mode of operation:                                                              Additionally if H2O2 is                should be made aware of fault
                Conditioning: Gassing: Aeration                                                 present there are                      condition. There must be a safe
                                                                                                additional risks to                    recovery method/procedure.
                                                                                                operators.




Document No: RBDS-009 / Rev. 1                                                 Page 11 of 21                                                            BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                   A - AVOIDANCE
sk Ref        Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.3.8           Is there risk of fire or explosion        Score: ____5____          S=2         The gas generator must            Apply risk reduction level (2)
Electrical      due to electrical energy.                                           F=1         be constructed of                 (1) S.O.P – Electrical safety tests.
Safety                                                    Classification:           P=1         materials that do not             (2) No combustible materials. Multi
                                                          Medium Risk               A=1         present risk or                       earthing and earthed power
                                                                                                support combustion.                   supply.

3.4.1           Are operators exposed to                  Score: ____5____          S=2         The hydrogen peroxide             Apply risk reduction level (2)
Chemical        unnecessary risks during loading                                    F=1         bottle has a vented top           (1) S.O.P – Use of PPE (personal
Hazard          of gas generator?                         Classification:           P=1         fitted when loading to                protective equipment) plus
                                                          Medium Risk               A=1         gas generator hence a                 spillage procedure
                                                                                                bottle dropped                        By design ensure the bottle is
                                                                                                presents risk.                        always fully supported and easy
                                                                                                                                      to load.

3.4.2           Are there any potential residuals         Score: ____6____          S=2         The bottle pick up                Apply risk reduction level (2)
Chemical        of hydrogen peroxide on                                             F=1         coupling presents a               (1) S.O.P – Pump tube changing +
Hazard          surfaces accessible to operators          Classification:           P=2         risk. The pump tubes                  PPE.
                in normal operations?                     Medium Risk               A=1         during replacement                (2) By design use self-sealing
                                                                                                present a risk                        couplings.

3.4.3           Are there unnecessary risks to            Score: ____6____          S=2         During parts change of            Apply risk reduction level (2).
Chemical        maintenance engineers from                                          F=1         any of the H2O2 liquid            (1) S.O.P - for all H2O2 parts change
Hazard          potential contact with hydrogen           Classification:           P=2         circuits engineers are at         (2) By design ensure H2O2 can be
                peroxide during equipment                 Medium Risk               A=1         risk.                                 drained from system before parts
                maintenance/repair?                                                                                                   change




Document No: RBDS-009 / Rev. 1                                                 Page 12 of 21                                                           BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                   A - AVOIDANCE
sk Ref        Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.4.4           Can hydrogen peroxide                     Score: ____6____          S=2         If the pump tubes are             Apply risk reduction level (2)
Chemical        accumulate in pipework/tubing                                       F=2         disconnected in wrong             (1) S.O.P – Pump tube changing /
Hazard          which would present a risk when           Classification:           P=1         sequence H2O2 can                     maintenance procedures
                removed or accessed by                    Medium Risk               A=1         become trapped and                (2) Use of personal protective
                operators or maintenance                                                        spill out on final                    equipment (PPE) gloves and safety
                engineers. Consider                                                             disconnection.                        glasses.
                accumulation by H2O2 in pump
                tubing.

3.4.6           Are hydrogen peroxide bottle(s)           Score: ____7____          S=2         Bottle of H2O2 must be            Apply risk reduction level (2)
Chemical        stored safely and do not present                                    F=2         stored to suppliers               (1) SOP – Handling H2O2/Storage.
Hazard          a risk to operators on handling?          Classification:           P=2         recommendations. Any              (2) Bottle storage to meet COSHH
                                                          Medium Risk               A=1         residual H2O2 on the                  requirements for laboratory safety
                                                                                                outside of a bottle                   in handling/storing hazardous
                                                                                                would present a risk to               chemicals.
                                                                                                operators

3.4.7           Is a spillage procedure in place          Score: _____6___          S=2         With open bottles of              Apply risk reduction level (2)
Chemical        for safe recovery under                                             F=2         hydrogen peroxide                 (1) S.O.P – Spillage Procedure
Hazards         failure/fault conditions?                 Classification:           P=1         handled during bottle             (2) Operator use of PPE (Personal
                                                          Medium Risk               A=1         loading procedure – a                 Protective Equipment, gloves and
                                                                                                fault/failure recovery                safety glasses.
                                                                                                procedure must be in
                                                                                                place




Document No: RBDS-009 / Rev. 1                                                 Page 13 of 21                                                           BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                    A - AVOIDANCE
sk Ref        Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.4.8           Are the necessary warning labels          Score: ____6____          S=2         Warning labels must be            Apply risk reduction level (2).
Chemical        on the equipment as well as on                                      F=2         fitted so that operators          (1) S.O.P – Check warning labels in
Hazards         the supplied bottles of hydrogen          Classification:           P=1         are constantly made                   place
                peroxide?                                 Medium Risk               A=1         aware of risks.                   (2) Fit warning labels in clear and
                                                                                                                                      visible places – country specific.


3.4.9           Is fault/failure recovery Personal        Score: ____6____          S=2         As a minimum gloves               Apply risk reduction level (2).
Chemical        Protective Equipment (PPE) in                                       F=1         and goggles should be             (1) S.O.P – Spillage, leakage procedure
Hazard          place for handling spillage and as        Classification:           P=2         available. It is                  (2) PPE – Gloves and goggles - Face
                required during leakage of                Medium Risk               A=1         recommended in                        mask with 40:1 reduction
                hydrogen peroxide liquid?                                                       addition to have a face
                                                                                                mask (charcoal filter
                                                                                                type) available

3.4.10          Can hydrogen peroxide oxidise             Score: ____5___           S=2         The exothermic (heat)             Apply risk reduction level (2)
Chemical        materials and in process heat up                                    F=1         reaction is an issue on           (1) S.O.P – Materials selection for
Hazard          materials so that auto-ignition           Classification:           P=1         finely divided materials.             gassing.
                can occur?                                Medium Risk               A=1         It is important materials         (2) By design ensure system has no
                                                                                                used do not support                   combustible materials.
                                                                                                combustion.




Document No: RBDS-009 / Rev. 1                                                 Page 14 of 21                                                             BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                    A - AVOIDANCE
Risk Ref      Stage (1)                                  Stage (2)                  Commentary                                    Stag (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.5.1           Risk of loss in leak integrity from       Score: ____3____          S=2         The gas generator is              Apply risk reduction level (1)
Leakage         RBDS equipment (a) Gas leakage                                      F=2         located within the room           • S.O.P gas generator leak tests
- H2O2          (b) Liquid H2O2 leakage                   Classification:           P=2         and hence any leakage
Release                                                   Medium Risk               A=1         will be contained within
                                                                                                the gassing enclosure

3.5.2           Risk of loss in leak integrity from       Score: ____7____          S=2         Doors and openings in             Apply risk reduction level (2)
Leakage         a room if applicable.                                               F=2         room are not generally            • S.O.P room sealing
- H2O2          Risk of leakage into an adjacent          Classification:           P=2         leak tight as they rely           • Install room gas analyses to
Release         area (room) with access to                Medium Risk               A=1         on controlled air                    automatically stop gassing if
                operators                                                                       leakage and pressure                 detected in adjacent areas
                                                                                                differential protection

3.5.3           Risk from deviation of pressure           Score: ____3____          S=2         If the room HVAC were             Apply risk reduction level (1)
Leakage         (OOS) of enclosure when at                                          F=1         started the room could            • S.O.P. - leak detection
- H2O2          optimum hydrogen peroxide gas             Classification:           P=1         positively pressurise
Release         concentration                             Medium Risk               A=1
                a) High pressure
                b) Low pressure




Document No: RBDS-009 / Rev. 1                                                 Page 15 of 21                                                            BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                   A - AVOIDANCE
Risk Ref      Stage (1)                                  Stage (2)                  Commentary                                    Stag (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.5.4           Risk of personnel entering the            Score: ____7____          S=3         As a room is a normally           Reduce risk by applying risk reduction
Leakage         enclosure during the gas phase                                      F=1         accessible area there is          level (2)
- H2O2                                                    Classification:           P=1         a risk that people may            1. S.O.P. on Room Sealing &
Release                                                   Medium Risk               A=1         try to enter during                   distribution of warning signs
                                                                                                gassing.                          2. Locking / sealing of all accesses to
                                                                                                                                      area during gassing


3.5.5           Risk of gas penetrating other             Score: ____3____          S=2         If the room has an air            Reduce risk by applying risk reduction
Leakage         (adjacent) areas during gassing                                     F=1         handling system which             level (1)
- H2O2          process                                   Classification:           P=1         is located in another             1. S.O.P. on room sealing &
Release                                                   Low Risk                  A=1         area or feeds other                  monitoring of equipment
                                                                                                areas which cannot be
                                                                                                isolated then the risk of
                                                                                                leakage exists.

3.5.6           Risk to operator on entering              Score: ____3____          S=3         If the sensor within the          Reduce risk by applying risk reduction
Leakage         room post decontamination due                                       F=1         room fails there is a             level (1)
- H2O2          to high H2O2 concentration                Classification:           P=1         risk to the operator on           1. S.O.P. on Room entry & cycle run to
Release                                                   Low Risk                  A=1         entry to the room.                   include secondary monitoring




Document No: RBDS-009 / Rev. 1                                                 Page 16 of 21                                                           BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                   A - AVOIDANCE
Risk Ref      Stage (1)                                  Stage (2)                  Commentary                                    Stag (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

3.5.7           Risk to operator during                   Score: ____8____          S=3         If the operator has               Reduce risk by applying risk reduction
Leakage         emergency or system failure                                         F=1         cause to enter the room           level (3)
- H2O2                                                    Classification:           P=1         during a gassing cycle            • By design operate equipment from
Release                                                   High Risk                 A=1         to correct an                         outside of the enclosure
                                                                                                emergency there is a              • By design equipment automated
                                                                                                risk to the operator.                 action to shut down if operator
                                                                                                                                      control lost
                                                                                                                                  • S.O.P. on Personnel Protection
                                                                                                                                      Equipment including breathing
                                                                                                                                      apparatus


4.1.1           Risk to process from gas                  Score: ____5____          S=2         The generator is in the           Apply risk reduction level (2)
Leakage         generator pre-filter(s) integrity                                   F=1         room and so will not              • S.O.P filter changes and routine
- H2O2          failure                                   Classification:           P=1         induce contamination.                monitoring.
Release                                                   Medium Risk               A=1         If the R2 unit’s filter           • By design allow routine pre-filter
                                                                                                fails then there is a risk           change and integrity test.
                                                                                                of contamination.




Document No: RBDS-009 / Rev. 1                                                 Page 17 of 21                                                           BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                   A - AVOIDANCE
Risk Ref      Stage (1)                                  Stage (2)                  Commentary                                    Stag (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

4.1.2           Risk to process from deviation            Score: ____8____          S=3         Over temperature may              Apply risk reduction level (3)
Process         (OOS) of H2O2 vaporiser                                             F=1         trip the power. Under             • By design automatically monitor
Parameter       temperature                               Classification:           P=2         temperature may not                  temperature and control liquid
Deviation       a) Over temperature                       High Risk                 A=2         vaporise H2O2with risk               flow.
                b) Under temperature                                                            of explosion in extreme           • By design employ thermal cut-outs
                                                                                                concentration and                 • S.O.P. on cycle failure and
                                                                                                (OOS) temperature                    equipment recovery
                                                                                                conditions

4.1.3           Risk to process from deviation            Score: ____7____          S=2         During any cycle phase            Apply risk reduction level (2)
                (OOS) of gas circulation airflow                                    F=1         (OOS) deviation would             Automatically
                a) During conditioning                    Classification:           P=2         compromise gassing                • S.O.P. Equipment calibration
                b) During gassing                         Medium Risk               A=2         cycle efficacy and                • By design automatically monitor
                c) During aeration (hydrogen                                                    associated product                   and control airflow
                    peroxide removal)                                                           quality
                    • Phase one aeration
                    • Phase two aeration




Document No: RBDS-009 / Rev. 1                                                 Page 18 of 21                                                           BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                   A - AVOIDANCE
sk Ref        Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
and                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

4.1.4           Risk to process from deviation            Score: _____8___          S=3         Failure of any part of            Apply risk reduction level (3)
Process         (OOS) of hydrogen peroxide flow                                     F=1         the of the hydrogen                 Automatically
Parameter       a) Flow delivery low to vaporiser         Classification:           P=2         peroxide flow delivery            • Monitor performance of H2O2 liquid
Deviation       b) hydrogen peroxide bottle               High Risk                 A=2         would compromise the                 flow
                    runs out before cycle end                                                   gassing cycle and                 • Abort the gassing cycle in event of
                c) Over fill of vaporiser                                                       potentially the product              (OOS) deviation in H2O2 flow A) + B)
                                                                                                                                     + C)
                                                                                                                                  • S.O.P. H2O2 Circuit calibration

4.1.5           Risk to process of cooling fan            Score: ____6____          S=2         Cooling fan failure               Apply risk reduction level (2)
Process         failures                                                            F=1         would allow the system            • S.O.P. Equipment calibration
Parameter       a) Electrical tray cooling fan            Classification:           P=1         to overheat and may               • Abort cycle for any (OSS) deviation
Deviation                                                 Medium Risk               A=2         over time cause cycle                resulting in system overheating
                                                                                                failure. Would also
                                                                                                cause electrical tray not
                                                                                                to be bio-
                                                                                                decontaminated

4.1.6           Risk to process of Aeration unit          Score: ____2____          S=1         If aeration units fail to         Apply risk reduction level (1)
Process         failure / cable failure                                             F=1         start, the gas contained          • S.O.P. Equipment set-up and test
Parameter                                                 Classification:           P=1         within the enclosure
Deviation                                                 Medium Risk               A=2         will not leak but will
                                                                                                present a risk to the
                                                                                                operator on removal




Document No: RBDS-009 / Rev. 1                                                 Page 19 of 21                                                           BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                   A - AVOIDANCE
Risk Ref      Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
And                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices
                                                                                                                                  Apply risk reduction level (1)
4.1.7           Risk of communication failure &           Score: ____2____          S=1         Comms failure would               • S.O.P. Equipment set-up and test
Comms           loss of control                                                     F=1         cause loss of
failure                                                   Classification:           P=1         equipment control,
                                                          Low Risk                  A=2         cycle will abort

4.2.1           Risk of poor gas distribution             Score: ____8____          S=3         Effective gassing cycles          Apply risk reduction level (3)
Product         during gassing cycle                                                F=1         rely on good gas                  • S.O.P Equipment set-up and test
Quality -       a) Stirrer fan(s) off or failed           Classification:           P=2         distribution                      • Preferred digital signal to start
Gassing             during gassing of isolator if         High Risk                 A=2                                              from gas generator
Cycle               applicable                                                                                                    • Minimum – Supervisor confirms
Deviation       b) Nozzle(s) off or failed during                                                                                    start
                    gassing of room if applicable                                                                                 • Minimum – Supervisor confirms
                                                                                                                                     continued operation at end of
                                                                                                                                     cycle

4.2.2           Risk to poisoning the catalyst            Score: ____5____          S=2         All catalysts can be              Apply risk production level (2)
Product         during gassing cycle, from                                          F=1         poisoned so risks must            • S.O.P – use of compatible materials
Quality -       a) Incompatible chemicals                 Classification:           P=1         be considered                       in processes
Gassing         b) In process coating from                Medium Risk               A=1                                           • Protect catalyst with pre-filter
Cycle               process materials
Deviation




Document No: RBDS-009 / Rev. 1                                                 Page 20 of 21                                                           BIOQUELL (UK) LTD
                                 BIOQUELL (UK) Ltd, 34 Walworth Road, Andover, Hampshire, England, SP10 5AA   Registered No. 2520270
                                 Tel: + (44) (0)1264 835835 Fax: + (44) (0)1264 835836




       S – SEVERITY                                F - FREQUENCY                             P – PROBABILITY                                    A - AVOIDANCE
Risk Ref      Stage (1)                                  Stage (2)                  Commentary                                    Stage (3)
Number        Identified Risk                            Category                                                                 Protection / Solution
And                                                      Low, Medium,                                                             Risk Reduction Method
Group                                                    High Risk from                                                           Reduction Level (1) S.O.P
                                                         Analysis                                                                 Reduction level (2) S.O.P. + Safety
                                                                                                                                  Device
                                                                                                                                  Reduction Level (3) Two Safety Devices

4.2.3           Risk of biological contamination          Score: ____0____          S=0         After cycle, rooms is             Apply risk reduction level (1)
Product         after gassing cycle due to HEPA                                     F=0         bio-decontaminated so             • S.O.P – Routine filter integrity
Quality -       filter integrity failure                  Classification:           P=0         no bio-agents can be                 testing
Gassing                                                   Medium Risk               A=0         drawn into the room as            • Routine pre-filter replacement and
Cycle                                                                                           equipment already in.                test. If filter at risk of damage
Deviation                                                                                                                            provide second backup pre-filter


4.2.4           Risk of biological                        Score: ____5____          S=2         If surfaces are ‘soiled’          Apply risk reduction level (2)
Product         decontamination not being                                           F=1         contaminated or                   • S.O.P – cleaning – pre-gassing
Quality -       achieved when room surfaces are           Classification:           P=1         over/under                        • Studies – pre-gassing surface
Gassing         out of specification (OOS) limits         Medium Risk               A=1         temperature the                      temperatures
Cycle                                                                                           gassing cycle efficacy            • Define boundaries of temperature
Deviation                                                                                       will be compromised                  deviation

4.2.5           Risk of residual hydrogen                 Score: ____4____          S=2         Stagnant areas within             Apply risk reduction level (1)
Product         peroxide gas running after cycle                                    F=1         the room present                  • S.O.P – equipment set-up
Quality -       end due to recesses in room               Classification:           P=1         possible residual
Gassing                                                   Low Risk                  A=1         hydrogen peroxide
Cycle                                                                                           pockets and hence risk
Deviation                                                                                       to operators




Document No: RBDS-009 / Rev. 1                                                 Page 21 of 21                                                            BIOQUELL (UK) LTD

						
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