Each employer must address actions that workers will take when there is an unwanted release of highly hazardous chemicals. Employers will need to decide: if they want workers to handle and stop small or minor incidental releases; whether they wish to mobilize the available resources at the plant and have them brought to bear on a more significant release; or whether they want their workers to evacuate the danger area and promptly escape to a preplanned safe zone area and allow the local community emergency response organizations to handle the release; or whether the employer wants to use some combination of these actions. Employers will need to select how many different emergency preparedness or lines of defense they plan to have, develop the necessary plans and procedures, properly train workers in their emergency duties and responsibilities, and effectively implement the selected plans and procedures (29 CFR 1910.119 Appendix C).
One effective way for medium to large-sized facilities to enhance coordination and communication during emergencies, both for on-site operations and with local community organizations, is for employers to establish and equip an emergency control center. The emergency control center would be sited in a safe zone area so that it could be occupied throughout the duration of an emergency. The center would serve as the major communication link between the on-scene incident commander and plant or corporate management as well as with local community officials. The communication equipment in the emergency control center should include a network to receive and transmit information by telephone, radio or other means. It is important to have a backup communication network in case of a power failure or if a means of communication fails. The center should also be equipped with the plant layout and community maps, utility drawings (including fire and water), emergency lighting, appropriate reference materials such as a government agency notification list, company personnel phone list, Superfund Amendments and Reauthorization Act (SARA) Title III reports and safety data sheets, emergency plans and procedures manual, a list of emergency response equipment and their location(s), mutual aid information, access to meteorological or weather condition data and any dispersion modeling data (29 CFR 1910.119 Appendix C).
Emergency Action Plans and Incident Prevention Planning
- To prepare for any contingencies, an emergency action plan (EAP) establishes procedures to prevent fatalities, injuries, and property damage (IAFC, 2008). An EAP (29 CFR 1910.38) is a workplace requirement when another applicable OSHA standard requires it, for example, 29 CFR 1910.119 (PSM standard).
- The host employer for a facility that must implement the requirements of the PSM standard is responsible for training its workers, this includes additional training to workers who provide emergency response actions covered by OSHA’s Hazardous Waste Operations and Emergency Response standard, 29 CFR 1910.120(q). The host employer must also review the facility’s emergency shutdown and response procedures with workers and clearly communicate EAPs to contractors. Contract employers are responsible for ensuring that their workers are instructed in potential fire, explosion, or toxic release hazards related to their jobs.
- Employers at a minimum must have an EAP, which will facilitate the prompt evacuation of workers when an unwanted release of highly hazardous chemical occurs. This means that the employer will have a plan that will be activated by an alarm system to alert workers when to evacuate and that workers who are physically impaired will have the necessary support and assistance to get them to the safe zone as well. The intent of these requirements is to alert and move workers to a safe zone quickly. Delayed or confusing alarms are to be avoided. The use of process control centers or similar process buildings in the process area as safe areas is discouraged because these structures may not be properly sited and may not be designed to withstand over-pressures from shockwaves resulting from explosions in the process area (29 CFR 1910.119 Appendix C).
- If the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119(n)) applies to the facility:
- The employer must establish and implement an EAP for the entire plant in accordance with the provisions of 29 CFR 1910.38. In addition, the EAP must include procedures for handling small releases of hazardous chemicals.
- At a minimum, employers must implement the requirements of 29 CFR 1910.119 for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards (Section III).
- Employers must address the actions that workers will take when there is an incidental release of highly hazardous chemicals in the process area. If the employer wants workers to evacuate the area, then the EAP will be activated. For outdoor processes where wind direction is important for selecting the safe route to a refuge area, the employer should place a wind direction indicator (such as a wind sock or pennant) at the highest point that can be seen throughout the process area. Workers can move in the direction of cross wind to upwind to gain safe access to the refuge area by knowing the wind direction (29 CFR 1910.119 Appendix C).
- If the employer wants specific workers in the release area to control or stop minor emergencies or incidental releases, these actions must be planned for in advance, and procedures developed and implemented. Appropriate equipment for the hazards must be provided, and training conducted for workers that will perform the emergency work before they respond to handle an actual release. The employer’s training program will address the training needs of workers that are expected to handle incidental or minor releases (29 CFR 1910.119 Appendix C), and must include the training requirements of the Hazard Communication Standard (HCS, 29 CFR 1910.1200).
- Employers covered by the 29 CFR 1910.119 standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120(a), (p), and (q) (the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard; CPL 02-02-073)). Preplanning for releases that are more serious than incidental releases is another important line of defense to be used by the employer. When a serious release of a highly hazardous chemical occurs, the employer – through preplanning – would have determined in advance the actions that workers will take. The evacuation of the immediate release area and other areas (as necessary) would be accomplished under the EAP. If the employer wishes to use plant personnel such as a fire brigade, spill control team, a hazardous materials team, or to have workers render aid to those in the immediate release area and control or mitigate the incident, these actions are covered by 29 CFR 1910.120. If outside assistance is necessary, such as through mutual aid agreements between employers or local government emergency response organizations, these emergency responders are also covered by 29 CFR 1910.120. The safety and health protections required for emergency responders are the responsibility of their employers and of the on-scene incident commander. Responders may be working under very hazardous conditions and therefore the objective is to have them competently led by an on-scene incident commander and the commander’s staff, properly equipped to do their assigned work safely, and fully trained to carry out their duties safely before they respond to an emergency. Drills, training exercises, or simulations with the local community emergency response planners and responder organizations are ways of attaining better preparedness. This close cooperation and coordination between plant and local community emergency preparedness managers will also aid the employer in complying with the Environmental Protection Agency’s Risk Management Plan criteria (29 CFR 1910.119 Appendix C).
- The fire prevention and protection requirements in 29 CFR 1910.252(a) must be implemented and documented in the hot work permit, prior to beginning any hot work operations (29 CFR 1910.119(k)(2)).