Managing Compliance: Going Beyond ‘Be Prepared’

While some companies have comprehensive emergency response strategies in place, others just now are taking the steps necessary to review possible threats, analyze potential impacts and create expanded versions of their existing plans.

If a company stores, uses or transports hazardous materials, there is the possibility of a chemical spill. While federal regulations require employees to be trained to properly manage chemical spills, it is the responsibility of an owner to keep employees safe when doing so. Companies can better prepare for a chemical spill and increase the safety of employees during an incident by providing potential first responders with basic information on recognizing different types of spills and how to respond.

PROPER IDENTIFICATION

Any incident involving the spill or release of hazardous chemicals, mixtures of such chemicals or hazardous waste can be categorized into three distinct groups in terms of their emergency status level:

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

Incidental spills — 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 may be cleaned up by employees working in the area where the spill occurred or by maintenance personnel.

While incidental spills do not require HAZWOPER-trained cleanup personnel, 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 regulations.

Emergency response spills — An emergency response spill, however, requires the intervention of spill cleanup specialists to contain and remove the spilled material safely. An emergency response spill is covered in 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. It is important to note that a HAZWOPER-trained team must manage these spills.

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

Examples of emergency response spills include spills involving high levels of toxic substances and situations immediately dangerous to life and health (IDLH). If area employees are not certified to don appropriate respiratory protection, a spill that exceeds the ceiling permissible exposure limit also would require an emergency response.

ASSESSING RISK

When responding to a spill, employees first should assess the risk surrounding the situation. For instance, they should determine the actual volume of the spilled material. Even a very small spill of a highly toxic chemical could cross the emergency response threshold. Other factors that should be considered during the risk assessment 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 of the materials; and
• Specific circumstances of the release, including location of the spill, level of ventilation and knowledge and experience of area personnel.