A facility should develop an emergency response plan that SPECIFICALLY addresses release scenarios developed from their PHAs and historical accident information. The potential releases identified in the PHAs should be used in preparing the emergency response pre-plans. Planning and preparation should include:
1)identifying populations, systems and environments that may be impacted,
2) specific procedures for employees to follow to stop further chemical releases and/or mitigate the effects of the substances released,
3) identify emergency response equipment that is available for response activities and state whether the equipment is located at the facility or its location within the community.
At a minimum, the plan should cover the following:
1) Anticipation of the types of releases that may occur from the process
2) Mitigation process(s)
3) Notification process to local responders
4) Local responder involvement
5) Coordination with Local Officials
The topics listed above is a GENERAL overview! If the facility has an emergency response team, OSHA compliance (1910.120(q) REQUIRES the ERP contain the following sections/information:
- Pre-emergency planning and coordination with outside parties
- Personnel roles, lines of authority, training, and communication
- Emergency recognition and prevention
- Safe distances and places of refuge
- Site security and control
- Evacuation routes and procedures
- Decontamination
- Emergency medical treatment and first aid
- Emergency alerting and response procedures
- Critique of response and follow-up
- PPE and emergency equipment
The facility should open communications with local emergency planning and response officials, including the local emergency planning committee (LEPC), if one exists. Involvement in the activities of the LEPC can have positive effect on the facility’s emergency response program. The facility should provide the LEPC with draft versions of any emergency response program related to local emergency planning efforts. The facility should coordinate with the LEPC, local response organizations, local hospitals, police and other response organizations upon completion of the emergency response plan for the facility.
All employees need to be trained on recognizing circumstances which are “out of the norm” (i.e., how to immediately recognize that an accident is occurring), as well as what to do in the event of an accident. This training would be specific to the facility and include relevant SOP’s and emergency plans.
Once plans have been developed, training needs identified and met, and equipment has been identified and obtained; the owners and operators should conduct periodic exercises to ensure that the plan is adequate to address the identified emergency scenarios.
The owners and operators should include local and state emergency response and management agencies in the planning process as well as in exercises designed to test and evaluate the emergency response plan. Because much of the specific knowledge and skills necessary to handle hazardous chemicals resides at the facility and may be lacking in the response community, the owners and operators may decide to provide training specific to the hazardous chemicals and mitigation techniques to state and local response personnel.
Depending on the hazards of the chemical and the potential impact of a chemical release, the facility should evaluate the need for and the effectiveness of warning systems, evacuation procedures, and/or shelter-in-place procedures that protect employees. The facility should plan mock emergencies to practice procedures on a regular basis to test workers’ ability to perform in the event of an emergency.
Bottom Line… although EPA/OSHA do not use the term “pre-plan”, in essence this is what they are coming to expect. This especially holds true if the facility is covered by PSM or RMP. If there is an RMP for the facility, a GREAT starting point is to use the WCS and ARS. EPA fully EXPECTS that a facility can respond to their WCS. This does not mean an “Offensive” type response with personnel, but that if evacuations will be needed that the facility has worked with the community officials to ensure that evac plans and capabilities are adequate should an evacuation be necessary. Also if shelter-in-place wil be called for, the facility needs to ensure that neighbors (including businesses) know how to “shelter-in-place”. I have one client in a very small town that they have recently learned they are on their own! There is no LEPC, only a small volunteer FD, a private EMS service, very limited medical facilities, etc. They are paying for a notification system and trying to put together a community drill. It is proving very difficult!