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CHAPTER 2
HEALTH & SAFETY
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Table of contents
INTRODUCTION
Section I: Roles & Responsibilities
Section II: Law & Regulations
Section III: Types of Operations
Section IV: Port AreaHazards & Controls
Section V: X-ray Scanners
Section VI: Examining Containers
Section VII: Clothing & Equipment
Section VIII: Risk Assessment
Section X: Forms/procedures
Annex
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INTRODUCTION
Health and Safety are very important issues in the daily work. Knowing the
possible risks and taking the appropriate action to reduce them should take a
place within the daily work.
This chapter will cover health & safety in all areas including dockside, quays,
container parks and examination sheds where you as custom officer are likely to
be working within the Port. Container parks and examination sheds outside of
the port area are also covered in this chapter.
The rules and regulations referring to health & safety differ per country. That is
the reason that there are now specific rules are mentioned in this chapter. Please
go to your own health & safety officers for specific information.
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Section I
Roles & responsibilities
Responsibilities for Health & Safety can be divided into individual, operator
and managerial. These are laid down in law and failure to meet these
responsibilities may leave an individual liable to criminal prosecution and/or
civil action.
Individual
As an individual you have a legal responsibility for your own and others safety
at work. In general you can satisfy these legal requirements by adhering to laid
down procedures, such procedures include:
co-operating with any instruction given by the Departmentwith regard to health and safety
Departmental Good Practice Guides
manufacturers instructions (for tools and equipment)
safe working practices
proper use, care and maintenance of Personal ProtectiveEquipment (PPE), and to wear any provided
OperatorAny person using or operating any tool or item of equipment must have
received all of the relevant training and must adhere to manufacturer and
departmental operating instructions. It is the individuals responsibility to
ensure that tools and equipment are inspected before use, are used properly, that
faulty tools are not used and that any faults are reported as soon as possible.
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Managerial
Managerial responsibilities are additional to those of the individual and
operator, legally these additional responsibilities apply to anyone who has a
managerial role and in general apply to the following areas:
planning for safe working practice particularly when newworking practices or equipment is introduced
identifying hazards and assessing the risk
identifying and implementing appropriate controls
monitoring and reviewing the controls
ensuring that staff have sufficient training, information andsupervision to carry out their work safely
Managers also have a departmental responsibility to ensure that all accidents
and dangerous occurrences are properly reported, to carry out investigations
into such incidents, and to take steps to avoid any recurrence.
Duties and Responsibilities
Team Member
It is an Individuals responsibility to work safely - do not place yourself or
others at risk by any act or omission.
Do not undertake any task if you have not undergone appropriate training.
Advise your team leader of any training needs.
Do follow any Health & Safety instructions you are given.
Do follow Good Practice Guides.
Do use proper tools and equipment in any task.
Do not use any tools or equipment other than properly approved and supplied.
Do not use any equipment that you have not been trained to use.
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Do make sure you are trained to use any equipment properly
Do ensure that Personal Protective Equipment (PPE) issued to you is
appropriate. If it is supplied for a particular purpose youMUSTuse it. KeepPPE clean and well maintained and replace as necessary. Dirty gloves, overalls,
High Visibility clothing etc. are hazards, do notuse them.
Do report accidents and dangerous occurrences and near misses. Make sure that
you know the procedures for doing this.
Do study the District Risk Assessment, and be aware of any controls.
Do make sure that you know the duties and responsibilities of your managers.
Do raise any new potential risks with your manager or colleagues
Remember that a container port area is a very dangerous place and you should
ensure that younever work alone.
Team Leaders
Do carry out H&S assessments of all tasks, or ensure that a competent person
does this. Seek advice if you are not sure.
Do ensure that any task you undertake or direct has been assessed for Health &
Safety risks.
Do ensure that any staff working under your direction are properly equipped
and trained for the task.
Do ensure that safe working practices/Good Practice Guides are adhered to.
Do make sure that tools and equipment areALWAYS inspected before use
Do ensure that any faulty tools or equipment are not used, and that faults are
reported.
Do arrange for proper PPE, tools, and equipment to be provided for staff and
ensure that they receive the appropriate training before using them.
Do arrange maintenance, replacements, repairs and re-training as required.
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Do ensure that all accidents, dangerous occurrences and near misses are
properly reported. Carry out preliminary investigations, take appropriate action
and recommend further action not in your control.
Do liase with outside bodies (Dock Company, shipping companies etc.) on
Health and Safety matters.
Do ensure that Safe Systems of Work are adhered to in all tasks and in the use
of any tools and equipment.
Do co-operate with safety reps.
Do observe your team to ensure they are following safe systems of work.
Remember that a container port area is a very dangerous place and you should
ensure that you never ask your staff to work alone.
Functional Manager
Do ensure proper training and equipment is provided for district tasks, and
maintenance is carried out as required.
Do ensure District Risk Assessments are monitored, reviewed and evaluated.
Do provide assurance on health and safety systems
Do ensure that there is adequate training and deployment of qualified First
Aiders.
Do encourage Health and Safety awareness among staff.
Do liase with other departmental staff on H&S matters.
Do ensure maintenance of adequate and relevant records i.e. assessments,
training, incidents etc.
Remember that a container port area is a very dangerous place and you should
ensure that you never ask your staff to work alone.
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Resources Available for Help and Advice
EXTERNAL
Park/Quay Controller or Shed Foreman:Transit Sheds are not necessarily located within the Dock, they can also be
found at remote locations i.e. industrial estates.
Custom officers should make initial contact with the controller requesting the
sight of a container, the request is based on risk information or a tip-off etc.
The Controller will then contact Custom when the container is ready for
examination. The controller should be approached on arrival to ensure that they
know you are there for evacuation purposes or to ensure that forklift drivers are
aware of your presence. Custom officers should prepare the contents of thecontainer for examination, but sometimes Custom officers checks the seals on
the container first
Port Emergency Services:
The Port Emergency Services should only be notified if the cargo is suspicious
or dangerous, i.e. it is leaking when you open it, or if there is a harmful
substance around an area which needs to be handled during a search i.e. Caustic
Soda packed around cigarettes.
INTERNAL
Health and Safety Advisers (NB: each country will have its own system)
Health and Safety Advisers is a group of advisers who can be contacted for
Health & Safety advice. Your Health & Safety matters are resolved locally, but
if you need further advice you can call, if available, a helpline.
During a physical check it is possible that you encounter certain goods that can
be a danger for Health & Safety.
A few examples:
Firearms and Explosives.
If a firearm or parts of a firearm, explosives etc. are detected, you should
preserve the scene and seek advice.
You must always consider your Health & Safety and that of anyone else first,
whilst at the same time preserving forensic integrity if this is possible.
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CITES.
If live plants and/or animals are discovered you should act promptly as there
may be a high mortality rate for any species taken from its natural habitat and
the stress of travel can be an added factor. You shouldalways think about yourown and your colleagues Health and Safety. There may be the danger of
disease or the risk of sustaining a venomous bite or sting, even the container
used to house the creature/plant that you are examining may pose a Health and
Safety risk!
Environmentally dangerous goods.
These goods are sometimes hard to recognise. If you find any goods that smell
bad, are labelled as dangerous etc., barrels etc. witch are not declared and no
labels, can be very dangerous. You should preserve the scene and seek advice ofa specialist.
You must always consider your Health & Safety and that of anyone else first.
Radiation.
If there is any sign of radiation, you should preserve the scene and seek advice
of a specialist.
You must always consider your Health & Safety and that of anyone else first.
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Resources Available for Help and Advice
Useful Contacts Name Telephone No. Address
Park/QuayController orShed ForemanReport to above regarding
any duties to be undertaken.
Port EmergencyServices -Control Officelocalnumbers - Fire, Ambulance,
Dangerous Goods, Police
etc.
Health & SafetyAdviser
Firearms andExplosivesofficers
CITES LiaisonOfficer
RadiationProtection Officerand Supervisors
Port Health
H&S Executive
Other Contacts
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Section II
Law & regulations
You will need to be aware of the departmental guidance that you will be
working to on a daily basis. You should familiarise yourself with the good
practice guide Health & Safety. If there is further departmental guidance
available should you require it, you should discuss where to find further
information with your trainer/teamleader/mentor.
Section III
Types of operations
As part of training you should be taken on a tour to your local port, this will
give you an idea about the type of areas that you will need to be aware of in
your daily duties at the Port. Before you embark on your tour please read the
following guide to the general operations that are carried out on a Port. You
should be aware that there are many different health and safety issues around
each area and the various types of cargo. You should also note that whilst you
are on the tour you MUST remain withyour trainer/mentor and adhere to allHealth & Safety instructions.
Quays
Various types of bulk cargo including containers and pallets, are
discharged and moved to and from ships. Some Ports have Quays, which
deal with loose cargo such as scrap metal or grain. The grain is pumped
from the ship directly into silos permanently located on the Quayside,where scrap metal is being moved there is a danger of loose particles
falling from the grabber.
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Parks
Operations involved in the parks include the storage and movement of;
containers which are; pending clearance (import and export), waiting to
be loaded onto a ship, waiting to be produced for exam or waiting for de-vanning. Other operations include the storage and movement of trailers,
some ports have parks, which deal with the storage and movement of
timber.
Sheds
Operations carried out in the sheds include the examination and de-
vanning of containers, some Ports have cold store facilities for examining
frozen or fresh foodstuffs. Pallets are also examined and used in the de-vanning procedures. Examinations carried out in the sheds may also
involve the movement of various types of equipment.
Your trainer or mentor should provide you with a map which shows the Quays,
Parks and Shed areas highlighted, you will need to take your copy of the map
with you to familiarise yourself with the layout of your local Port/Dock.
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All Access Points and Blind Spots
fast moving traffic across path
poor or restricted visibility
noisy
Container Stacks and Lines
to be avoided if possible only go under supervision
restricted visibility
lots of moving traffic
operators restricted visibility
Straddle Carriers
restricted visibility
speed and size
noisy
Rail Lines
lots of traffic
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Lorry Lines
moving traffic
reversing
restricted visibility
Maffi and Skeleton Parks
busy moving traffic
restricted visibility
Forklifts
fast
carrying loads so restricted visibility
can be quiet (electric)
insecure cargo - danger of falling
Straddle Parking Areas
busy
noisy
restricted visibility
drivers finishing their shift (not normal areas to go into)
can be very slippery
General Hazards
uneven surfaces
wet / slippery surfaces
trailing ropes
obstructions
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Controls
Following on from the previous part of this section, where you were asked to
highlight the hazards and risks, you will now be asked to supply the controls
which you can use to minimise the risks to each of the following hazards:
moving traffic
poor or restricted visibility
noise.
List the controls that you think might be appropriate to each of the hazards on
the following page. Write your answers in the space provided.
Hazards Control
Moving traffic
adhere to approved routes and parking areas.
keep to safe walkways
adhere to all normal driving laws and follow portprocedures.
always report your presence if appropriate.
use safe walkways wherever possible
observe and use proper sight and sound signals e.g.
flashing lights and bells.
awareness of limitations of vehicle types (speed, visibility,manoeuvring).
be alert at all times.
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Poor or restricted visibility
all of the above controls for moving traffic.
always wear hi-visibility clothing.
be aware of specific hazards in all of the followingconditions - night, fog, rain, snow and take all necessary
precautions
make sure you know the area and route that you will betaking.
Noise make sure you wear the appropriate ear protection
make sure that you learn important sound signals e.g. acrane moving
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Section V
X-Ray scannersThe use of X-ray scanners is getting more coming.
Because health & safety instruction various per type of X-ray scanner type, it is
necessary to check with your local management for specific instruction.
Section VI
Examining containers & trailers
On the following pages you will find some pictures of the containers and
trailers that you may come into daily contact with. Each picture includes a brief
description of its structure, design and intended purpose. You should take
general precautions with any type of container, however as well as general
hazards there are some specific hazards associated with some containers and
trailers.
Fumigated containersBefore you enter a container! Some containers are fumigated with a toxic gas.
This is no part of the cargo but is added to exterminate bugs etc.
Containers under fumigation should carry a hazard warning sign but this is not
always the case.
If there is a hazard warning label on the container you should ask for a
statement that the container is free of gas.
If you discover any sign that a container is or has been under fumigation. Do
not touch or remove any fumigation chemicals and keep well away from
containers when fumigation operations are being carried out.
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The most used gases are:
Sulphuric Fluoride SO2F2
Methyl bromide CH3BR
Phosphorous Hydroxide PH3Formaldehyde H2CO
This is a notice you may find in a container, if you find it, you could be in
danger.
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CONTAINER /TRAILER TYPES SPECIAL HAZARDS / RISKSBULK CONTAINER
Especially for dry bulk cargoes, e.g. malt
Three manholes for filling in the roof of
each container.
FLAT CONTAINER
Especially for heavy loads and over-width cargo.
Strong bottom construction with fixed endwalls
(which allow bracing, lashing and stacking).
HARDTOP CONTAINER
Especially forheavy loads, overheight cargo, loading
from above, e.g. by crane. The hardtop steel
roof can be easily moved by handling gear.
HIGH CUBE CONTAINER
Especially for light, voluminous cargo and
overheight cargo
Risk of collapse if it is not secured
Risk of falling cargo
Risk of falling cargo
Manual Handling risk is increased byits height volume
Risk of falling cargo
If loaded by top hatches, DO NOT
OPEN THE DOORS
Risk of falling cargo
Oxygen depletion from cargo
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INSULATED CONTAINER
Especially for cargo, which needs constant
temperatures above or below freezing point.
Temperature is controlled by ships/terminals
cooling or clip-on-unit.
OPEN TOP CONTAINER
Especially for:
overheight cargo, loading from above, e.g. by
crane loading from door side, e.g. with cargohanging from overhead tackle
PLATFORM
Especially for heavy loads and over-sized cargo.
Strong base construction.
REFRIGERATED CONTAINER
Especially for cargo, which needs constant
temperatures above or below freezing point
cold, wet slippery floor
Risk of falling cargo
roof not fixed
often bulk loaded cargo (grain etc.)
risk of falling cargo
Moving machinery parts, inside and out
Cold wet and slippery surface
Interior fittings hooks, racks
Cold cargo
Heavy doors
Exhaust and other fumes Electricity hook up cables, points Diesel tank
Risk of falling cargo
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TANK CONTAINER
Especially for liquid chemicals for portable
liquids (e.g. spirits). See Good Practice Guide for
Dangerous Goods labels
VENTILATED CONTAINERS
Especially for Cargo which needs ventilation.
Natural ventilation is ensured by openings in the
top and bottom longitudinal rails. The labyrinthconstruction of these ventilation openings
TRAILER
Especially for transporting cargo. The
sides of the trailer are not rigid. cold, wet, slippery floor
risk of falling cargo
cold, wet slippery floor
Risk of falling cargo
The fact that ventilation is required mayindicate that the cargo is hazardous
hazardous cargo
previous cargo may have beenhazardous
toxic fumes
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Controls
Now that you have identified some of the hazards, you should now consider
what procedures or controls you should take in order to minimise the risks.
Please write in the space provided, what you think the control are to the hazardslisted on the following page.
You should compare your answers with the answers provided after this task and
discuss them with your trainer. You should also note that the list given is not
exhaustive.
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Your answer should include the following, however you should be aware that
this list is not exhaustive.
Special hazards Controls
Manual Handling
proper assessment - task, load, working environment,individual capability
minimise need for manual handling
mechanical aids
safe systems of work - planning, layout, etc.
sufficient time/resources for task
use of dock/operator labour where applicable
training (Back Pack etc., Enhanced training asavailable)
proper techniques
PPE
minimise distance and load (planning)
Door opening/closing
use of Dock staff to open/close where applicable
use of door checkstraps
PPE
extension bar for door handle if appropriate
Slippery and unclean floors or surfaces
establish and maintain cleanliness routine
report all spillage, hazards
avoid the area if possible
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Specific Hazards Controls
Poor Stowage
checkstraps for door opening
special assessment/safe system of work
PPE
Adequate heating, lighting and ventilation
maintenance regime, report deficiencies
use of auxiliaries (lights, heaters, fans)
PPE / thermal clothing if appropriate
Physical exam of crates, packages
manual handling - proper techniques
safe surface, proper height/ suitable environment
PPE especially gloves, eye protection
proper use of tools (knives, bars, etc.)
Use of tools
always use the proper tool for the job
only use officially provided tools
familiarity with and understanding of equipment itsuses and limitations
follow manufacturer/supplier instructions
always inspect before use
never use faulty or damaged tools - report and obtainreplacements
proper planning
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Specific Hazards Controls
Working Platforms and Raised Bays
approved access points only
ensure locked/stable
NEVER work underneath
authorised operators only
PPE
be aware of risk of trips/falls
use dock labour if possible
guard against moving traffic/collisions
Fork Lift Movements
know and stick to safe system of work
proper planning
sight & sound signals
warning signs
communication
Space restrictions
proper planning, safe systems of work
remove possible obstructions
PPE
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The following is a list of procedures or controls that you should take to
minimise the risk to any of the general hazards that may be involved the
physical examination of containers or trailers (including underside & top).
DO NOT be tempted to examine a container outside of an approved site
DO NOT walk or climb on the top (unless it is a Tanktainer and a securewalkway is provided)
Use mobile ladders that are provided
Ensure that fixed or overhead facilities are in a safe condition
Beware of loose objects, debris or dust on the top of the container or its cargo,use PPE including eye protection
Remember to use PPE!!
Exterior fittings on reefer units etc. are to be used by trained personnel only
Beware of moving parts and electricity e.g. fans
Remember the proper use of tools
Never work underneath a container unless it is secured on a frame specificallyprovided for the purpose
Never walk or work under container suspended by a straddle carrier or forklift
Be aware of various types of fixture and fittings, especially in reeferse.g. fans, ducts, hooks
Be aware of slippery floors and the cold, check the flooring for security andsafety
Be aware of any residues, even in empty containers
Be aware of sharp, raised, abrasive objects and surfaces
Ensure there is adequate light and ventilation
Carry out as much research as possible to identify the cargo and take thenecessary precautions
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H&S Foodstuffs Examination
Be aware that there are particular hazards and concerns in examining any raw or
processed foodstuffs. Many raw farm products imported to the EU will comefrom Third World countries, where the hygiene and safety regimes are not the
same as those applied in the EU.
Processed, packaged goods, ready for retail sale, should be treated as a final
product, and any packages opened for examination should be properly
destroyed.
Raw, unprocessed goods such as grains and pulses are likely or possibly to have
been treated with insecticides or other chemicals prior to shipment. They may
be infested by insects such as weevils or mites, especially if they have not beentreated, or they may be affected by rot which could induce fungal growth.
You may also come across bulk importations (tanks, containers etc) of products
destined for the human or animal food industry. These tanks are likely to be
sealed, and breakage of the seal may render the product condemned or
commercially worthless. In such circumstances the Department may be liable
for substantial compensation claims.
You should ALWAYS consider examination of unprocessed foodstuffs as
potentially hazardous, for the reasons laid out below;
some may be allergens or respiratory sensitisors
some may be intrinsically poisonous
Some may be infested by;insects,
reptiles,
crop diseases, such as weevils, mites or Colorado Beetle, snakes,
sometimes found in esparto grass, bananas or ergot (damp grain or
pulses)
ethnic foods may be encountered, particularly from someAfrican, Indian or Caribbean areas. BE AWARE that these are
likely to be loaded in recycled boxes and crates, and lacking
uniformity, may be unstable within the container
This list is not exhaustive, and you should enquire about local traffic and trends.
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Custom officers should also be aware that we have a duty to the general public,
the trade and to our employer. When foodstuffs are selected for examination,
care should be taken to avoid any contamination, or cross-contamination. If
necessary, disposable outer clothing should be available. If there is any doubt,err on the side of caution. Seek advice from experienced colleagues, Port Health
etc. before proceeding with examination.
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Section VII
Clothing and equipment
Reducing risks by adhering to health and safety procedures also involves
wearing and maintaining all protective clothing and equipment which is
provided, you should ensure that you use only those items of clothing, tools and
equipment provided by Customs & Excise. You must also make sure that you
comply with the law and regulations involved in using PPE by:
following the instructions given with each item
keeping each item clean and well maintained, usingrecommended cleaning advice
if the use by date has expired,do not use
only using the item as recommended by the manufacturer
using only the items provided, do not use personal items
ensuring the equipment fits you properly
A few examples of special clothing you could use.
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Some examples of tool you could use
The correct equipment makes your job easier to carry out.
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Section VIII
Risk assessment
Prior to each examination a local risk assessment should be undertaken to
decide how the examination should be conducted, or whether the examination
should take place at all. However, It is not the aim of this section to show you
how to complete a risk assessment form.
It gives you an example of a risk assessment.
For example, an empty tank container may have previously contained a
hazardous substance. Before attempting to conduct an examination any risks
should be identified by researching its history to find out what cargo was
previously contained within it. If research is not possible extra caution, using
all possible controls, should be taken prior to the examination.
On the following page you will find an example of a risk assessment form,
however you should be aware that these forms are subject to local variations.
You should ask your health & Safety officer for the, in your area used, specific
risk assessment form and procedure.
Section IX
Health and safety forms
As well as understanding how to identify risks, using controls and safe systems
of working to minimise the risks, you also need to be aware of the procedures
you should use in the unlikely event of an accident or near miss occurring.
The Line Manager/team leader and the individual each have responsibilities for
completing the forms and sending them to the appropriate department.
Ask you own Health & Safety officer or your team leader how the proper
procedure works.
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GOOD PRACTICE GUIDE CHAPTER 2- HEALTH &SAFETY
RISK ASSESSMENT FORM (page 1)
Date of record creation Case Officer
Vessel Container No. Goods Origin
Comments/ Reasons for interest
Health & Safety Assessment
Assessment Officer:
Team
Safety Assessments ExternalIs area around Container/Trailer
FREE OF TRAFFIC YES / NO SECURE YES / NO
ADEQUATELY LIT YES / NO STABLE YES / NO
FREE FROM OVERHEAD
HAZARD
YES / NO ADEQUATELY
VENTILATED
YES / NO
ANY HAZARD LABELS YES / NO Type
Safety Assessment: Internal
Cargo Description:
Cargo Hazard Assessment
BAGS CARTONS PALLETISED
SACKS BARRELS MACHINERY
DRUMS CRATES LOOSE
LOADED
OTHER
Hazards IS LOAD STABLE (UNLIKELY TO MOVE) YES / NO
if no, reason:
Glass Chemicals FRAGILE
Dirty Flammable Heavy
Infested Slippery Wet
Bulky Unwieldy Sharp Corners/
edges
Other
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IS ALL REQUIRED SAFETY EQUIPMENT/CLOTHING ISSUED OR AVAILABLE
YES / NO
IF NO, REASON:
Handling equipment required / desirable / used:
X-ray Van
Forklift TruckOther
Other
Comments / Conclusions: