If there is one common finding in our PSM/RMP audits it is this single requirement for employees who remain to operate critical plant operations before they evacuate. And when we attempt to explain what is actually necessary to just meet 1910.38(c)(3) we are oftentimes met with downright hostility. It is rare these days that anyone needs to stay behind, but I would say about 25% of the facilities we work with do leave behind some key personnel. Who are these key personnel? OSHA actually mentions some:
(emphasis by me)
The employer should list in detail the procedures to be taken by those employees who have been selected to remain behind to care for essential plant operations until their evacuation becomes absolutely necessary. Essential plant operations may include the MONITORING OF PLANT POWER SUPPLIES, WATER SUPPLIES, and other essential services which cannot be shut down for every emergency alarm. Essential plant operations may also include CHEMICAL OR MANUFACTURING PROCESSES THAT MUST BE SHUT DOWN IN STAGES OR STEPS where certain employees must be present to assure those safe shutdown procedures are completed.
So there are facilities that have a legitimate need to keep some essential employees behind while everyone else evacuates. But just identifying these essential employees by title (NEVER by name) is just the first step in what we need to do. If the situation is so bad that a trained person decided that evacuating the area of the emergency is necessary, but there will be a few employees who will remain behind – should we not have protective measures for these employees who stay behind?
We should also have the means to VERIFY their safety when we are performing the evacuation headcount – NEVER assume they are OK; this means that our head-count procedures MUST include a means to verify these employees are indeed safe and well and capable of fulfilling the functions they stayed behind to perform.
But what kind of protective measures are needed? That all depends on the hazard they are facing. For example, in many of my control rooms where the process handled toxics, we had breathing air systems that would allow the panel operator to be on BA for up to 4 hours (4X’s the amount of time to execute the emergency shutdown SOP(s)). We also had the control room designed and managed as a “safe haven”, meaning it was positive pressurized and isolated from the outside air. These systems were 100% in the PSM/RMP Mechanical Integrity program and Respiratory Protection program and it was all on a 30-day inspection.
We would also have Level B Ensembles for Operators to wear during their fieldwork in executing a manual ESD. They were NOT emergency responders, they were operators who may, during an ESD, come into contact with the HHC/EHS in their duties, and so we provided them AND TRAINED them in that level of PPE so they could carry out their ESD duties per the written ESD SOP.
All of these personnel were included in the EAP and listed by Unit/Process with the duties they were left behind to perform. This was a very controlled scope of work and in NO WAY allowed this personnel to perform “emergency response” duties – they were carrying out emergency operations that are specifically spelled out in their SOP’s and training.
Bottom line, when everyone is evacuating an area due to an uncontrolled hazard and we ask certain personnel to stay behind for certain functions, it is ENCUBMANT of us to ensure these personnel are ACCOUNTED FOR and provided with the necessary safeguards so they can safely carry out their duties in what may be very hazardous situations.