Emergency Response: Expectations versus Reality

Do you know the difference?

Introduction

• In working with facilities utilizing Highly Hazardous Chemicals, it has become apparent that there is a need to impress on these facilities the importance of having a thoroughly developed plan for Emergency Action (Evacuation) and Emergency Response (Stopping the release).

Current State of Emergency Response

• More and more facilities, even very large ones, are opting to “evacuate and let the professionals handle the problem”.

• Driven by an aversion to legal liability for responding employee safety.

• Attempt to mitigate responsibility for responding employee safety could result in increased public responsibility.

Community Perspective

• The residents in your community have a right to expect you to keep them safe.

• They may, or may not, know that you have a “Highly Hazardous Chemical” at your facility.

• They may, or may not, know the full ramifications of a large, uncontrolled release.

• Regardless of their knowledge, they do have an inherent right to expect you to keep them safe. They have an inherent right to expect that you have done everything you can do to keep your system safe. They have an inherent right to expect that you have done everything possible to stop a release of Ammonia.

Emergency Planning Commission

• First of all let us consider what the required elements of a community emergency response plan are.

• Identification of facilities and transportation routes of extremely hazardous substances

- Major highways or streets that have highly hazardous chemical traffic

- Railroads with highly hazardous chemical carrying cars• Description of emergency response procedures, on and off

site

- Who is going to respond? (Fire department, Hazmat team, facility employees)

- Are facility employees trained to assist?

Emergency Planning Commission

• It is up to you to lead in the development of these procedures.

• It is up to you to plan an annual review or mock release exercise.

• Designation of a community coordinator and facility emergency coordinator(s) to implement the plan

• -What is the name, address and phone number of your community emergency coordinator?

• -Who is your facility emergency coordinator? (Is he doing the coordination?)

• -It is your responsibility to ensure that they know about the ramifications of an ammonia release at your facility.

Responsibilities for Facility Personnel

• Who, in your facility, is going to do the calling?• Who are you going to call and in what order?• Description of how to determine the probable affected area

and population in that area that will be affected by releases• Who is in charge of off-site evacuation if necessary? (Police,

fire department, plant employees?)• Do these people have the equipment, manpower and the

training to effective?

It is up to you to inform them of the hazards and equipment needed.

Responsibilities for Local Responders

• Description of local emergency equipment and facilities and the persons responsible for them

• Do your local responders have the equipment necessary to respond to a release?

• Do they understand the importance of maintaining, and replacing, that equipment as necessary?

Emergency Responders: Information Needed

• Personnel who respond to chemical spills, HAZMAT, Fire Departments, Emergency Medical Teams will most likely do all they can to assist you in your time of need. There are some things that need to be considered when you decide to rely on outside help.

• You must give them all the information you can:

-Several operators that they spend time with and get to know on a first name basis

-Facility plan view reviewed before it is needed

-System P&IDs with critical valves highlighted and tagged (We’ve done too good of a job selling the King Valve as the magic cure all solution)

-Location of access to the roof if needed

-Plans for venting interior rooms etc.

Emergency Responder Training at Your Facility

• You need to train with them at your facility.• Create a realistic situational scene with lights and

sirens actuating• Create as realistic of a scene as possible. Find out

who can handle the pressure and keep a cool head in the chaos.

There are no acceptable excuses for not doing mock releases. NONE!! Every plant has a slow or downtime. Plan ahead and get it done. The day of a catastrophic release is a terrible day to begin practice.

Sample Fire Department Coordination Training Form

Maintain Documentation with Responders

Issues to Avoid

• Now let’s take a look at the task of Emergency Response to a chemical release. Issues we most likely need to encounter include:

-Chaos from people evacuating the facility

-Temporary helper not knowing where the assembly areas are

-Roll call takers not knowing who is working this particular day

-Everyone assuming Someone is making the call for assistance and in reality No One does the calling.

-Fire department shows up and everyone is running around but nobody tells them what happened or where to go.

-Police show up and are told to evacuate a four block wide area downwind of the facility. The one man police department has no clue how to go about this since No One has ever told him how to this type of an evacuation.

-Roll Call takers conclude that three people are missing and assumed inside.

-Two operators are overcome with ammonia in trying to stop the initial release. They come out of the building gasping for air.

-Nobody has set up a decontamination site yet so everybody scrambles for a water hose.

Ammonia Release

Issues to Avoid

-Somebody makes a call for an ambulance.

- The only available water is now inside the building which has been evacuated.

-The Fire Department sets up and secures the affected part of the building.

-Since it is only 30 minutes until the shift is over, people are sneaking back into the building to get lunch boxes and keys for their cars. Nobody thought about building security before.

-The Fire Department evaluates the situation and calls for the Hazmat Team.

-Somebody notices the water chemical technician’s car in the parking lot. He cannot be located on site. Operators say they saw him going to the condenser sump tank to do water checks just before the release started. Two operators start putting on respirators as they walk toward the engine room to look for the chemical salesman. They have to be restrained.

Issues to Avoid

-The ambulance arrives with blaring sirens. The EMTs are in a hurry to get the contaminated operators to a hospital for treatment. -No One advises them as to the possibility of ammonia gassing off of the victim. A mile and a half down the road, they stop the ambulance and bail out. Ammonia gassing off of the victims has the EMTs gasping for air.-Nobody told them this might happen.-The Hazmat team arrives about 45 minutes after being called. They assess the situation and ask for plan view drawings and P&IDs. The person charged with taking them out of the plant wasn’t working that day.

-Nobody else thought to take them along out when evacuating.

Issues to Avoid

• News media arrives. They start to interview evacuated employees who are more than willing to have their 15 minutes of fame. They make statements like “Yes, we smell ammonia several times a week” not knowing the ammonia smell is occurring when the bathrooms are being cleaned.

• The Hazmat team sets up. You have figured out which valve will probably stop the release if is closed. You try to explain where this valve is to a Hazmat person who has no understanding of refrigeration terminology. He goes in but there are three vessels sitting side by side, and he can’t remember which valve, on which tank, to close. He comes out, gets clarification, and gets ready to go in just as the bell alerts him that his air tank is low. If you had someone SCBA trained, the release would be stopped. Management didn’t understand the potential problems that not having someone SCBA trained could cause.

Chaos

Safe Management

• Safe management includes taking steps to both prevent accidental releases of the extremely hazardous substances and to minimize the consequences of any accidental releases that may occur.

• At the same time, you are responsible for ensuring effective emergency response to any releases at your facility. If your local public responders are not capable of providing such response, you must take steps to ensure that effective response is available (e.g., by hiring response contractors).

OSHA Definition

• OSHA defines emergency response as “a response effort by employees from outside the immediate release area or by other designated responders ... to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance.”

• This definition excludes “responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel” as well as “responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure).”

• Thus, if you expect your employees to take action to end a small leak (e.g., shutting a valve) or clean up a spill that does not pose an immediate safety or health hazard, this action could be considered an incidental response and you would not need to develop an emergency response program if your employees are limited to such activities.

OSHA / EPA Definition Clarification

• However, due to the nature of the regulated substances subject to EPA’s rule, only the most minor incidents would be included in this exception.

• In general, most activities will qualify as a response due to the immediacy of the dispersion of a toxic plume or spread of a fire, the volatilization of a spill, and the threat to people on and off site.

• As a result, if you will have your employees involved in any substantial way in responding to releases, you will need to develop an emergency response program. Your emergency response procedures need only apply to “response” actions; other activities will be described in your maintenance and operating procedures.

Developing an Emergency Plan

• In order to develop an emergency action and/or response plan the following steps may be taken:

(1) Decide who will be responsible for developing and implementing the emergency action or response plan.

(2) Decide how your facility will deal with unwanted ammonia releases.

(3) Choose personnel for your emergency organization.

(4) Develop incident discovery procedures.

(5) Develop emergency evacuation procedures.

(6) Develop procedures for external notifications.

(7) Develop procedures for specific emergencies including unwanted ammonia releases.

(8) Train and equip employees for their emergency duties and responsibilities.

(9) Set up a mechanism to conduct drills.

(10) Document the emergency plan.

(11) Coordinate the emergency plan with off-site responders

Conclusion

• Proper Planning in Emergency Response is key

• Coordinate with local responding agency• Maintain documentation

Thank you!

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