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Approved Handler for Class 3.1C substances

In the Hazardous Substances (Classes 1 – 5 Controls) Regulations 2001 (as amended), Table 2 of Schedule 3 indicates the quantity of flammable substances that activate Approved Handler requirements.  Given that Class 3.1C is not listed as a hazard classification that triggers the Approved Handler requirement, when if ever, is an Approved Handler for a Class 3.1C substances required?

Reg 58 of the Classes 1 – 5 Controls Regs requires the person in charge of a place to establish a Hazardous Area Zone (HAZ) for Class 3.1C substances when the quantities detailed in Table 3 of Schedule 3 are exceeded.  These quantities are:

100 L (closed)
25 L (decanting)
5 L (open occasionally)
1 L (if in open containers for continuous use)

The existence of a HAZ requires a person in charge to reduce the likelihood of unintended ignition of 3.1 substances in accordance with Regulation 60.  Regulation 60 in turn provides various methods of achieving this.  If the person in charge chooses to use the methods specified in Regulations 63(4), 65, 67 or 69 an Approved Handler is required even though the substance has a Class 3.1C classification.

NB: The regulations mentioned describe controls to limit the percentage of vapour in air or percentage of oxygen in the air. This can be either together with controls on sources of ignition or not. Ignition sources include electrical (to be controlled by way of AS/NZS 2430.3:1997), earthing requirements for ancillary equipment or contact with hot surfaces.

As all Jet-A1 aircraft refuelling facilities require the Person in Charge to comply with electrical zoning and the HSNO / CAA earthing requirements, the advice provided above by the Environmental Risk Management Authority (ERMA) on the need for Approved Handlers applies.


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