Preparing Spill Response

No place is free from the potential for an emergency response spill if hazardous materials are present.

WHETHER a company stores, uses, or transports hazardous materials (hazmat), there is always the potential for a chemical spill. And beyond regulatory requirements that all employees are trained to handle chemical spills, it is also the responsibility of an owner to keep employees safe when doing so. Below are answers to some of the most commonly asked questions about emergency response spills, as well as some tips on how companies can be better prepared in recognizing different types of spills and how to respond.

Any incident involving the spill/release of hazardous chemicals, mixtures of such chemicals, or hazardous waste that requires the intervention of spill cleanup specialists to contain and remove the spilled material safely is an emergency response spill. A HAZWOPER-trained team (29 CFR 1910.120) must manage these spills. Every leak or spill should be evaluated to determine whether it has crossed that threshold beyond which any spill cleanup must be performed by specifically trained and equipped personnel.

1. What are the different types of hazmat spills?
Releases (spills) can be categorized into three distinct groups in terms of emergency recognition:

  • Releases that are clearly incidental.
  • Releases that may be incidental or may require emergency response, depending upon circumstances.
  • Releases that clearly require emergency response.

Emergency recognition must be employed to distinguish between "incidental spills" and those requiring emergency response. OSHA defines an incidental release or spill as "a release of a hazardous substance which does not pose a significant safety or health hazard to employees in the immediate vicinity or to the worker cleaning it up, nor does it have the potential to become an emergency." Incidental spills do not require an emergency response, and therefore do not require HAZWOPER-trained cleanup personnel. They may be cleaned up by employees working in the area where the spill occurred or by maintenance personnel.

Incident spill response personnel do need to be trained in Hazard Communication and to use appropriate personal protective equipment consistent with the federal or state OSHA standards under which they are regulated. Incidental spill responders may absorb, neutralize, or otherwise control a spill, so long as doing so does not expose them to significantly greater risk than is posed by routine handling or use of the hazardous material.

2. What is an emergency response spill?
Some spills will clearly require emergency response. Examples include high levels of toxic substances, situations immediately dangerous to life and health (IDLH), and fire or explosion hazards exceeding 25 percent of their lower explosion limit. If however, area employees are not certified to don appropriate respiratory protection, a spill that could potentially exceed the ceiling permissible exposure limit would also require an emergency response.

An emergency response spill is defined by 29 CFR 1910.120 as follows: response efforts conducted by employees outside of the immediate area of release or by other designated responders (fire departments, internal hazmat teams, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance.

There is no single factor upon which this determination may be made, beyond the initial assessment as to whether or not the spilled material is hazardous. A key factor, however, is the actual volume of the spilled material. A very-small-volume spill is obviously less likely to pose a significant risk to personnel than a large spill of the same material and is unlikely to escalate into an emergency response. Even a very small spill of a highly toxic chemical with physical properties that would provide a potential for exposure, such as a respirable hazard, could cross the emergency response threshold.

Factors that must be considered in this risk determination include:

  • Nature of the hazard properties of the material (i.e., flammability, corrosivity, toxicity, etc.),
  • Degree of hazard and routes of entry if toxic,
  • Physical state (powder, granular, liquid, gaseous),
  • Physical properties, and
  • Specific circumstances of the release must be considered. These include the location of the spill, the level of ventilation, and the knowledge and experience of area personnel.

3. Where do emergency response spills typically occur?
Emergency response spills have the potential to occur anywhere: at hospitals and power plants, in hardware stores, and highway accidents. No place is free from the potential for an emergency response spill if hazardous materials are present.

Rarely is an emergency response spill expected. A spill occurs only when a system of hazardous material containment fails, usually as a result of a chain of unfortunate events. The potential for chemical spills exists anywhere these materials are stored, used, or transported, and unforeseen chemical spills can threaten employees, customers, and the general public. Even when personnel are safely evacuated from the spill zone, emergency response spills often lead to serious business interruption, facility or environmental damage, as well as other potential for financial impact.

4. How should I prepare for emergency response spills?
Emergency response preparedness and planning is a very detailed and costly program that involves equipping and training a hazmat team:

  • Training typically includes 24 to 40 hours of combined classroom education and "hands-on" instruction in practical spill response techniques. OSHA mandates annual refresher training, and prudent EHS managers recognize the need for frequent drilling to maintain team readiness.
  • Equipment requirements vary depending upon the nature of the potential emergency response scenarios to which the hazmat team is expected to respond. Typical equipment for even a modest team would include protective clothing, air monitoring equipment, self-contained breathing apparatus, tools, and absorbent materials that can cost thousands of dollars. In addition, maintaining a hazmat team requires a considerable investment in time.
  • Time must be provided for emergency response planning (including pre-emergency assessment for on-site teams), developing resources for cooperation, annual medical evaluations, developing safety and health programs, performing recurrent training, maintaining personal protective equipment programs, air monitoring equipment maintenance, and preparation for decontamination procedures.
  • Another consideration is that staffing an in-house emergency response team is acceptance of sole legal responsibility, not only for the trained personnel but for the effectiveness of the response and subsequent cleanup.

5. What are the alternatives to in-house emergency response staffing?
The alternative to training, equipping, and maintaining an emergency response team is to outsource emergency response, should a significant spill of hazardous materials occur. Local government may provide an outsource alternative through emergency response teams hosted by fire departments or county or parish environmental agencies. Though this approach may serve a company's needs, it is prudent to confirm the availability and willingness of local agencies to assume responsibility for cleaning up hazardous substance spills.

In most circumstances, outsourcing means identifying and qualifying an emergency response contractor (or perhaps two or three, to ensure availability) to respond on an on-call basis to spill events. Qualifying contractors is essential and best performed by an environmental professional aware of appropriate criteria and experienced in such evaluations. Alternatively, many companies contract with environmental, health, and safety information providers that pre-qualify local emergency response contractors and provide a call center to manage emergency responses, interact with regulatory agencies, and perform subsequent reporting in the event of an emergency response spill.

6. What are the criteria to consider when selecting an outsourced provider?
When selecting a call center outsource for spill response, remember these useful tips:

  • Find a center that handles a very large number of spills on a regular basis. It is likely the personnel will have a knowledge base of similar incidents that can be leveraged when responding to the user's spill; this is also an advantage in the related reporting tasks afterwards.
  • Remember the importance of user profiles with user procedures so the responder may be familiar with the unique needs of the environment.
  • Spill response personnel also must have immediate access to a rich MSDS database.

7. What reporting of the spill is required?
Release reporting requirements vary based on the location of the spill, the nature and volume of material spilled, and the activities associated with the spill event. Federal, state, and local agencies mandate reporting requirements that can be quite involved. These include but are not limited to EPA, which requires immediate reporting of a release of a chemical defined under CERCLA as a "hazardous substance" that meets or exceeds the reportable quantity (RQ). EPA also mandates reporting of spills under EPCRA, which requires reporting to state and Local Emergency Planning Committees (LEPCs) should the EPCRA thresholds be exceeded. In addition, should a facility have a transportation issue on a public highway, the Department of Transportation may require that the spill be reported to the National Response Center.

In summary, preparing to deal effectively with a significant spill of hazardous materials is good business, but the implementation of an in-house emergency response team can be very costly and time consuming. Many companies are not willing to take on the additional responsibilities and cost for such a program. For these firms, a wise alternative may be found in environmental, health, and safety information service providers that offer emergency response management and spill reporting 24/7/365.

Whatever the selected approach--internal team development or outsourced assistance--the key to success in the event of a hazardous materials spill is preparation.

This article originally appeared in the July 2003 issue of Occupational Health & Safety.

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