PSM Plans: EAPs for Incidental Spills

The PSM standard requires employers to work with employees when establishing and reviewing plans.

Leaks and spills are sometimes a daily occurrence at facilities. But when the liquids spilled are any of the highly hazardous chemicals listed in OSHA's Process Safety Management (PSM) standard, cleanup sometimes isn't as simple as with other incidental spills.

Because highly hazardous chemicals present a significant safety risk to workers, Emergency Action Plans (EAPs) are a required element of PSM plans. EAPs list the procedures for reporting emergencies, safely evacuating a hazardous area, and responding to both incidental and large spills.

Establishing an Emergency Action Plan
When developing an EAP for the release of highly hazardous chemicals, employers need to determine what actions will be taken when there is an incidental spill at the facility. One of the first steps is to establish whether employees will clean up incidental spills, a trained on-site response team will be utilized, or everyone will evacuate to a safe area and allow an outside response team to handle the situation.

Most facilities use a combination of these actions. However, even if it is determined that the only actions will be to sound an alarm, evacuate all employees to a predetermined safe area, and wait for outside responders to handle the spill, the procedures must be documented in the EAP.

Several OSHA standards require EAPs. When establishing an EAP to meet the PSM standard or any other standard, it is important to consider whether the actions in each individual EAP are consistent and easily understood. Having a wide variety of alarms or evacuation procedures that are specific to each emergency may look great on paper, but if multiple emergency procedures cause confusion or delay evacuation, it may be necessary to review the EAPs to ensure they truly will be effective during an emergency.

Plan Elements
PSM plans must include ways to prevent or minimize damage and injuries that may be caused by spills and releases of highly hazardous chemicals. A main focus of PSM plans is to establish standard operating procedures and other safeguards to prevent spills and chemical releases from happening. Because systems sometimes fail, however, plans also must include procedures for safe evacuation, documentation of how and when employees will respond to incidental spills, as well as other safety and response measures. The PSM standard requires employers to work with employees when establishing and reviewing plans, and creating an EAP affords an excellent opportunity for this collaboration.

The process for responding to an incidental spill is usually not as elaborate as one for responding to a large or emergency spill, but it is still important for the steps to be documented. The EAP first should define which spills are incidental and which are considered to be large or emergency situations. The volume of the spill, its location, and employees' levels of training are important factors to consider.

It is not uncommon for the definition of "incidental" to vary for different types of spills. For example, a damaged 55-gallon drum of virgin lubricating oil in a room that has full containment and no floor drains is certainly a nuisance but is likely considered to be incidental, whereas a 10-gallon spill of a more hazardous liquid may warrant evacuation and require highly trained responders to handle the cleanup.

When personal protective equipment will vary from what is normally worn for normal operations, EAPs should list what items are necessary when responding to a spill. Safety Data Sheets, safety officers, PPE suppliers, and chemical manufacturers are all sources of information for proper PPE selection in spill situations.

Cleanups and Spill Kits
A list of tools, equipment, and products that will be used to clean up incidental spills is another essential EAP element. Elaborate equipment is not always necessary for an effective response. Tools may be as simple as a non-sparking wrench to tighten a fitting, a few absorbent mat pads, and a disposal bag. Some facilities create spill kits that include PPE and necessary response tools, storing the kits in areas where spills are likely to occur. Documenting the location of response kits in the EAP can help facilitate training, routine stock inspections, and auditing.

Steps for cleaning up incidental spills also should be outlined in the EAP so responders have a specific sequence of steps to follow to ensure the spill is cleaned up effectively and safely. The instructions should also be clear about when to respond and when a spill should be handled by an emergency responder. A list of emergency contacts should be maintained as part of the EAP.

Using signage, wallet cards, or other reminders helps to reinforce the safety procedures outlined in the EAP and taught in training sessions.

Training
After spill response procedures are developed and implemented, employees must be trained on their specific roles during a response. The training program should have clear goals and learning objectives to understand the safety and health hazards of the chemicals used at the facility.

For some employees, this training can be incorporated into other existing safety and health programs -– as long as the PSM objectives are met. In addition to emphasizing chemical safety hazards, the program should address safe work practices, proper operating procedures, emergency evacuation, shutdown procedures, and any other process safety needs that are specific to work functions.

Large facilities often benefit from training that is tailored to specific groups of employees. For example, front office staffers need to have a general awareness of hazards and need to know where to evacuate when an alarm sounds, whereas maintenance staff and production workers are likely to have a greater role in response efforts and require a higher level of training and understanding.

Employees who will respond to incidental spills need clear direction about when to respond and when to evacuate and call for trained emergency responders. Anyone responding to large or emergency releases must be trained in accordance with OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard.

Hands-on training and routine drills help employees apply what they've learned and allow all to demonstrate their understanding and competence to complete any task for which they are responsible. Drills also provide a forum for procedures and processes to be evaluated to ensure they will work correctly in an actual emergency. Establishing EAPs and reviewing them periodically will enable employees to respond to incidental spills safely and know when evacuation is necessary.

This article originally appeared in the December 2012 issue of Occupational Health & Safety.

About the Author

Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer, and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA, and DOT regulations and has had more than 100 articles published on a variety of EHS topics. She is a Certified Safety Professional (CSP,) Walkway Auditor Certificate Holder (WACH,) Community Emergency Response Team (CERT) trainer, hazmat technician, serves on the Blair County, PA LEPC, and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS® (468-4647) or by email, karenh@newpig.com.

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