Case Study
Acme Hydrocarbons Ltd is a medium sized specialty chemical manufacturer owned by a large multinational group, Worldwide Chemicals Incorporated. Of the 150 personnel working on the company’s site 40 are employed by contractors. The contractors are mostly long-term and cover specific functions such as catering, security and maintenance. The site uses large quantities of cooling water for its manufacturing process and operates three small cooling towers serviced by 10 million litre’s surface water reservoir. One of the cooling towers is little used but is available on standby. The cooling system is operated and maintained by a specialist contractor, Flow Systems Ltd. The site does not require a license under the Control of Major Hazards Regulations 1999 as amended operates continuously, on a three shift system but closes for an annual holiday during the first two weeks of July each year. A plan of the site is shown in Figure 1.
The Site Manager, Ivor Plant has recently received a formal letter from a local HSE Inspector following a routine visit to the site. Mr Plant was absent on sick leave on the day of the visit and the Inspector was shown around the site by the Chief Engineer, Fred Cross. Due to the nature of the Inspectors concerns, Mr Plant sent a memo (Document 1) to your line manager, Patrick Smith (Worldwide Chemicals UK Health Advisor) who has asked you to liaise with Mr Plant and offer appropriate advice. Attached to the memo is a copy of the letter from the HSE Inspector (Document 2)
Questions
- Explain with reference to relevant case law the statutory responsibility placed on Acme Hydrocarbons Ltd and the Contractor Flow Systems Ltd with respect to ‘Item 1’ of the HSE Letter (Document 2)
- Critically analyse the data provided in ‘Document 3’ and with reference to other information provided and researched, draw conclusions to the current risk of exposure to legonnela bacteria.
- Draft a reply to the HSE Inspectors letter (including an outline plan of actions the company intends to take) that is likely to convince the Inspector that no further enforcement is necessary.
