The term “Shelter-in-Place” (SIP) is becoming more and more popular in emergency response plans and although it is a VITAL part of many response plans, doing it PROPERLY may NOT be as easy as it sounds. In this article, I hope to explain what is required when we claim “shelter-in-Place” as a method to manage exposures during a chemical release and some of the issues we may run into when implementing a SIP protocol.
What OSHA says about SIP…
“Shelter-in-place” means selecting an interior room or rooms within a facility, or ones with no or few windows, and taking refuge there. In many cases, local authorities issue advice to shelter-in-place via TV or radio that employers may follow. In addition, an employer may decide to institute shelter-in-place for particular situations, for example, an explosion in an ammonia refrigeration facility across the street or a derailed and leaking tank car of chlorine on a rail line behind their place of business. The employer must ensure that the shelter-in-place procedures instituted are adequate and suitable for that workplace and will protect the employees. OSHA’s Evacuation Plans and Procedures e-Tool provides some specific shelter-in-place procedures as guidance. If an employer intends to include a shelter-in-place option in their emergency plan, they must:
- Establish and implement procedures within their EAP for alerting employees to shelter-in-place that is easily distinguishable from that used to signal an evacuation.
- Train employees in the shelter-in-place procedures and in their roles in implementing them.
Some things to consider when implementing a SIP at our facilities:
The number one (1) thing that most facilities fail to do when they SIP… ACCOUNT FOR ALL PERSONNEL! I am not sure where this “myth” began, but many facilities believe that SIP somehow eliminates the requirement for ACCOUNTING for personnel. All SIP does is move workers to a sheltered area indoors rather than to the more traditional assembly area outdoors. It is NO WAY exempts any facility from having to account for workers; we MUST still conduct a headcount when SIP is utilized!
The second (2) biggest issue is how facilities ALERT WORKERS to SIP, rather than evacuate to an outside assembly area. OSHA is very clear on this matter; if we are going to have a SIP protocol in our emergency response plan (ERP) and/or emergency action plan (EAP) then we MUST HAVE the means to alert employees that the particular emergency requires SIP rather than evacuating to an outside assembly area. This means we MUST HAVE an ALARM with a DISTINCTIVE SIGNAL that informs workers to SIP. BE CAREFUL relying on the same alarm sound(s) and using an announcement over a personnel address (PA) system to direct workers to SIP vs. evacuate; oftentimes OSHA may not accept the same alarm signal followed by a PA announcement as complying with this requirement.
The third (3) biggest issue we come across is TRAINING. The training issue can be broken into three groups:
1) all unescorted workers on-site (e.g. employees and contractors),
2) workers who IMPLEMENT the SIP procedures, and
3) who makes the decision to SIP vs. evacuating to an outside assembly area
If the facility has a SIP protocol then ALL workers who are UNESCORTED would need to be TRAINED in this protocol. This is really about CONTRACTORS working on-site or any worker who may be left unescorted. These workers MUST understand the alarm tone AND know where the SIP areas are at. We also need to TRAIN those employee(s) who will be IMPLEMENTING the SIP procedures. Many areas are not airtight and these areas usually come with some type of actions the employee(s) must take in order for the area to be used as a SIP location. These procedures MUST be part of the official Emergency Response or Action Plan(s) and be AVAILABLE to the employees IMPLEMENTING the SIP. This means that we may want to keep a copy of the SIP procedures at the actual SIP locations.
NOTE: if you have “X” number of SIP areas, then list these areas in the ERP/EAP, along with a note in the official ERP/EAP that copies of the SIP procedures are maintained at these locations. Then add this to your monthly inspection checklist to ensure that the procedures do NOT grow legs and walk off from the SIP locations! We also want this note in the ERP/EAP so that if we change the SIP procedures we KNOW that there are “X” number of copies outside of the official ERP/EAP so that we can ensure ALL these copies get updated.
Lastly, but certainly not the least of our concerns, is the training for those individuals who will make the DETERMINATION to SIP vs. evacuate to an outside area. Keep in mind this decision will be made VERY QUICKLY in many incidents so this implies that we need to have an ample number of personnel trained to cover ALL TIMES personnel would be on-site (e.g. weekends, holidays, overnight shifts, etc.). If the facility has a response team, the most logical person to make this call is the Incident Commander in control of the emergency. If the facility does not have a response team, then we will need to define who makes this decision and ENSURE they are PROPERLY TRAINED in how to make this decision. They would not have to be trained to the level of an Incident Commander, but they would most likely need AWARENESS LEVEL training and some sort of risk evaluation training so they are well equipped with the tools and knowledge as to when SIP is the safer alternative to evacuation.
What does SIP really mean and what areas can we claim SIP?
We come across a lot of emergency response plans that claim SIP, but in fact, do nothing more than provide four walls and a roof to protect workers. In a few cases, the four walls and a roof may be adequate, but this would be in VERY FEW cases. In most cases, personnel will need to take SPECIAL actions to make an area a SAFE SIP area. First and foremost we need to be able to ISOLATE the area from the outside air! This means we should have the ability to QUICKLY ISOLATE HVAC systems so that they do not draw in outside air. This isolation in many cases will involve MORE THAN just turning off the HVAC unit(s) for the area. The SIP procedures may also need to include a means to seal the room’s windows, doors, and ductwork. Of course, if all this is needed then we will need to add the necessary equipment to take these actions to the EAP/ERP response equipment list; keeping in mind this list needs to be SPECIFIC to EACH SIP area, as some SIP areas may need a ladder to reach ductwork, windows or door seals!
Using “positive pressure” as means to make an area safe for SIP is a high tech way of meeting the needs of the SIP occupants, but it does bring into play several safety and compliance concerns:
1) where do we get the CLEAN FRESH air to maintain a positive pressure?
2) the blower that is used to maintain the positive pressure MUST BE on a preventive maintenance and testing schedule as a critical piece of equipment,
3) the blower MUST have an adequate emergency power supply that can ENSURE the blower will operate when power has been lost to the facility and this emergency power supply MUST meet the time demands for the worst-case scenario (by this I mean we may need more than a 15-minute back-up power source!), and
4) if the facility has a covered process under OSHA’s PSM or EPA’s RMP standards then the facility MUST HAVE the design specifications of this ventilation system (e.g. the number of air exchanges and the minimum psi for the “positive pressure” rating, source of fresh air, etc.).
The SIP areas MUST have the means to communicate to personnel OUTSIDE the SIP area. Often times facilities claim that radios will be used, but the one area that we can often find NO RADIOs is the SIP area for the administrative staff! If radios are to be the means of communication, then radios MUST BE stationed in the SIP areas. NEVER ASSUME that someone with a radio will arrive at all the SIP areas!!! These radios should be on chargers to ensure they will be charged at the time of the emergency, they should be included in the ERP/EAP emergency equipment list, and on the monthly equipment inspection list. TEST to ensure the radios will NOT be hampered by the act of sealing up the SIP area or that their signal will simply reach the base radio! Fixed phone lines are another way we can have communication lines to outside the SIP area, but just remember these phones would be part of our ERP/EAP and any changes to the phone system that would IMPACT the phones in the SIP areas would need to undergo a MOC! BE VERY CAREFUL thinking that cell phones will ALWAYS be available and/or that they will ALWAYS work from within the SIP area! Bottom line… TEST the communication method(s) to ensure they will function in the SIP area as needed!
The last flaw we see in SIP plans is probably the one with the greatest potential for a serious injury or death! In many PSM/RMP plants where the HHC/EHS is a toxic or poison, the control room for the process is equipped with breathing air systems that allow operators to remain in the control room for extended periods of time during an uncontrolled release. However, we often find these breathing systems not being inspected, operators who are now “full-time control room operators” being taken out of the respirator program and therefore not being medically evaluated, fit-tested or trained annually, and no evidence of any type of risk assessment surrounding the design, installation, and use of the breathing air system. Bottom line, if we plan to use a breathing air system in our SIP plan, we need to assess how many users there will be, how much air will be needed based on the length of time needed to implement the emergency shutdown procedure(s); as well as looking at the toxic’s and poisons involved, as many of these HHC’s/EHS’s will REQUIRE more than just breathing air! What type of PPE for the body will be needed? Have operators tried using their keyboards and panel buttons wearing the gloves they will be donned in? Are air-lines long enough to allow the freedom of movement needed for operators to do all they must do? The ONLY way to know if our control room SIP and breathing air system will ACTUALLY work as intended is to conduct a DRILL using the system! Keep in mind that COMMUNICATIONS are often the leading issue in an emergency and with the control room operators donned in supplied-air respirators – COMMUNICATIONS will be hampered to some degree; how much will depend on the users of the SAR’s and their level of expertise with the SAR’s and communication system(s).
These are just a few of the implementation concerns that should be considered when implementing a “Shelter-in-Place” protocol at a facility. As you can see, implementing such a program may indeed be MORE WORK than not having a SIP protocol; but if the facility needs one, we MUST ENSURE that it is designed, implemented, and managed PROPERLY!
If you have questions or concerns about your SIP plans or actions, feel free to contact me privately or you can post your question(s) in the comment section below and seek advice/opinions from others within the SAFTENG network.