Depending on the quantity and nature of the hazmat spill, there are a number of reporting and notification requirements that must be enacted in a limited amount of time.

Controlling the Situation: Actionable Steps to Help Mitigate Hazmat Incidents

Accidents happen, but taking proactive steps ahead of an accident ensures your facility is prepared and reduces the chances of a larger incident from occurring.

Accidental hazardous material spills can happen anywhere at any time. According to OSHA, more than 43 million American workers are exposed to hazardous chemicals each year. With so many people coming into contact with hazardous materials, safely containing chemical spills has never been more important.

While it is nearly impossible to eliminate hazmat incidents altogether, having an actionable plan in place that prepares all involved parties (e.g., workers, first responders, etc.) to properly manage an emergency situation will help prevent additional issues from occurring. Through a better understanding of the hazardous materials released and specifics on the best way to react when an incident occurs, risks can be minimized and remediation simplified.

As we enter into a new year, now is a good time to review your hazmat spill response procedures and make sure all necessary elements are being met. The following outlines some best practice approaches to help you and your employees continue to best react to a hazmat spill.

Before a Spill: Drafting a Proactive Response Plan
It should come as no surprise to those in the industry that it's often the facilities without a plan that incur the worst hazmat incidents. All spills are different, and while it's impossible to foresee the specifics around a potential incident, having a spill response plan in place ahead of time can help avoid injuries, lessen the environmental impact, and reduce the potential financial risk.

It's important for employees to think logically about hazmat spills. If handled properly, a spill may be nothing more than a brief nuisance. However, if handled improperly, a spill can seriously disrupt work and cause bodily harm or property damage. A spill response plan should help employees decipher between the smaller spills that require minimal response and the larger incidences where emergency procedures need to take place immediately.

A written hazmat spill response plan should detail what initial steps must be taken when a spill occurs, instructions for how to respond to the spill cleanup and information around residue disposal. Specific elements of the plan should include:

  • Emergency contact information (both internal and external)
  • List of appropriate protective clothing and safety equipment and materials required for spill cleanup (e.g., gloves, respirators, etc.), along with an explanation of their proper use
  • Directions for evacuation zones and procedures
  • Information about fire suppression equipment, including where it is and how to use it
  • Locations of disposal containers for spill cleanup materials
  • Information about any first aid procedures that might be required

It's important that the plan be reviewed and updated regularly with any new information. This is especially true if any new chemicals have been introduced to the facility. If it's been a while since you last reviewed your spill response plan, now it is the time to address it.

During a Spill: Knowing What Hazards Are Present
OSHA's revision of the Hazard Communication Standard (HazCom) under the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) introduced substantial format changes in the way hazardous information is communicated to users. Safety data sheets (SDSs) now follow a strictly ordered, 16-section format. Additionally, labels also look quite different with six standardized elements that now include more specific language depending upon the chemical classification.

By now, employees should be fully trained on the changes brought about by GHS and able to comprehend what hazards are present based on the information provided. Comprehend is the key word here. It is not enough for employees to just recognize hazard symbols; they also must know what they mean and how to safeguard themselves and others from those hazards.

Employees also should know where information is located on the SDSs, especially the specific sections that detail the exact steps to take when a spill occurs. Under the GHS format, the two sections which contain hazmat spill information include:

  • Section 5: Firefighting Measures. This section provides information about how to fight fires caused by the chemical. Key information includes recommendations of suitable extinguishing equipment and information about extinguishing equipment that is not appropriate for a particular situation. Some chemicals can react violently to water, so before using a chemical to extinguish and flames, it’s important to refer to this information first. Other important information in this section includes hazards – like combustion – that develop when the chemical burns, and recommendations on special protective equipment or precautions for firefighters.
  • Section 6: Accidental Release Measures. This section gives details on the appropriate response to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people and the environment. This section may also include recommendations that help users distinguish between responses where the spill volume has a significant impact on the hazard. Other information includes the use of PPE and personal precautions (e.g., removal of ignition sources, providing sufficient ventilation, etc.), emergency evacuation procedures, containment methods and materials, and cleanup procedures.

There is often limited time to be spared during a hazmat spill, so figuring out how to contain and clean it needs to happen fast. Ensuring employees are familiar with where cleanup information is located on SDSs is a critical step to preventing additional disasters from occurring.

After a Spill: Launching the Reporting and Notification Process
Depending on the quantity and nature of the hazmat spill, there are a number of reporting and notification requirements that must be enacted in a limited amount of time. Some reports require follow-up within 24 hours, while others require more immediate attention. There are many different factors that go into what reports must be submitted. Unfortunately, these requirements tend to be confusing and often overlap, providing a separate challenge to companies following any fallout from the initial spill incident.

Substances designated as "extremely hazardous" under the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 must be reported to state and local authorities in addition to meeting federal reporting requirements. Depending on the scope and location of the spill, other reporting requirements might also apply, including the National Response Center (NRC) and Department of Transportation (DOT).

Having the tools to quickly and comprehensively complete any necessary reports is critical. Today's electronic EHS management solutions not only help with identifying what reports are required based on the spill situation, but also aid in filling out the reporting forms, ensuring that you stay compliant with regulatory requirements and avoid penalties for failing to report to all of the proper authorities.

Accidents happen, but taking proactive steps ahead of an accident ensures your facility is prepared and reduces the chances of a larger incident from occurring. Time is often a critical factor, and the improper mitigation of hazmat spills can result in elevated cleanup costs, increased liabilities, and significant fines. With careful planning, you can greatly reduce the chances of additional incidents occurring, which can make all the difference when a spill occurs.

This article originally appeared in the March 2016 issue of Occupational Health & Safety.

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