Emergency Response Checklist

By Chris Leney

            The current hype surrounding the potential disasters that could be caused by Y2K has overshadowed the awareness of emergencies that occur on a daily basis.  While managers and consultants prepare to battle the upcoming computer difficulties, many are not spending adequate time preparing for more common incidents such as fuel and chemical releases.  There are several basic tasks that must be addressed during a hazardous materials emergency and it takes advanced planning to deal with them in a controlled manner.

Internal Communications

When a driver or facility calls at 3 a.m. on a Saturday, where does the call go?  Will your dispatcher or night manager know who to contact for assistance?  A 24 hour number, preferable toll-free, needs to be made available to employees with risk of an off site spill.  It is vital that a pre-arranged call list be readily available to every person that will be in the information loop.  It is not enough to merely post it, a few times a year a mock drill should be run to verify that all of the numbers are valid.

Also, there should be redundancy built into the loop in the event that the incident happens in less than ideal circumstances.  In a recent event, lightening struck a communications tower and  temporarily disrupted all pager traffic in the local area.  Local private hazmat crews were forced to use alternate technology until the pagers were restored.  Had a major emergency occurred, and the responsible party only had pager numbers in their system, they would have been unable to reach a crew for help.  For all vital persons on the call list, keep multiple numbers available.

External Communications

The same rules of practice and redundancy apply to external communications.  For fixed facilities, it is a good idea to know your local fire department and attend the local emergency planning committee meetings.  When an incident occurs, having a relationship with these groups will make the process flow more smoothly.

You should have a 24-hour number to reach your state emergency hotline and/or environmental agency.  For companies which have offsite exposure in multiple states, such as many trucking, intermodal, and rail companies, you must have the ability to contact the regulatory agencies in each state that your fleet covers.  It may be necessary for companies like these to seek outside help in the form of consultants or spill management companies since the state contact numbers and reporting requirements vary greatly.

In the event of a large release, or one in which evacuations, highway closures, or injuries are caused by the released material, you must also notify the National Response Center at 1-800-424-8802.

Other external contacts to consider are the product manufacturer, MSDS databases, and in cases where the spill is substantial, the press.  The product manufacturer and MSDS resources can be extremely valuable and should be available around the clock.

Last year in Florida, a leaking container was discovered in a trailer which was loaded with hazardous materials.  The shipping papers which accompanied the load were vague and did not give a clear indication of the exact chemicals in the load.  The product manufacturer was not immediately available and the MSDS was not located quickly.

The local fire department arrived on site and established exclusions zones, evacuated a trailer park, and set up a decontamination area for the firefighters which entered the trailer. Once they entered the trailer, they discovered a one-gallon plastic pail of cleaner which was basically a bleach solution.  Had the manufacturer been consulted prior to the entry, or if the MSDS had been made available to the first responders quickly, the incident would have been a small affair.   In the end, it cost the transporter over $27,000 to reimburse the fire department for their manpower, equipment and expendables.

Press releases may be necessary in some events, and as with all other aspects of emergency response preparedness, there must be a plan in place prior to the spill.  One person from your company must be designated to make any public statements, and no one other than that individual should talk to the press. Be clear, brief, and be honest about the size and scope of the release. If your company has a large exposure, it would be wise to send your designated individual to formal training for public speaking.

Private Spill Contractors

The vast majority of release cleanups will involve a private response company which is hired by the responsible party. If you are responsible for emergency response at a fixed facility, it is a fairly simple task to find and retain a contractor in advance. Most state environmental agencies can provide you with a list of certified contractors. Use that list to contact and interview potential contractors and then attempt to execute a contract.

By having the contract in place in advance of an incident, valuable time can be saved and in many cases preferred rates are given to clients under contract.  Always check your contractor’s insurance documents, personnel training records, references and be sure they have 24-hour availability.

For companies with off site exposure, it is much more difficult to pre-screen contractors.   Waiting until a spill happens, and then relying on the local police or fire to provide you with the names of contractors can be an expensive experiment.  Without a contract, and without knowing the contractor background, you can easily be burned by high rates and poor performance.

The state lists can be used to establish a network of contractors, but it is a difficult task to maintain a long list which is accurate over time.  This may be another area where outside resources are needed.  If this is your situation, try contacting a spill management company or even your insurance carrier to find out if they maintain a contractor database.

Closure Parameters

There is a current trend of state environmental regulatory agencies to use risk based closure standards when evaluating a site for final closure.  Be aware that no matter which standard a state utilizes, you must establish the closure parameters before the cleanup is completed.  In other words, if a state will require analytical results which are below the method detection limits of a certain test method, the contractor can be directed to conduct the appropriate field screening and collect the correct samples.

Other agencies will only require analytical results to be below a preset action level or even field screening results which are documented to be below the action level.  In some cases, visual and olfactory field screening is all that is necessary.  In any case, without a cleanup work plan based on the closure parameters, unnecessary work or not enough work may be done.

Assuming it was a reportable incident, once the field work is completed and the waste has been disposed, a final written report will need to be submitted to the state regulatory agencies.  The report must detail all of the pertinent information including responsible party contact information, chemical information on the substance released, what actions were taken, which cleanup criteria was used, and cradle-to-grave waste tracking documentation.

It is also a good idea to include photographs, copies of analytical results, and field notes which include observations and field screening results.  These reports may be prepared and submitted by the responsible party, except in a few states such as Massachusetts and Nevada which require a certified third party to document the site conditions and prepare the final report.  It may be a good idea to use a source such as the contractor or a consultant to prepare the report if your company does not have a qualified individual on staff.

Keep in mind that the many details involved with managing an emergency have not been detailed here, since this is merely an overview of the general tasks.  The short version is that a contingency plan must be in place, and be practiced, so that when a spill does occur, your response executes in a quick, planned, controlled manner.