It's Monday morning, 6 a.m. The employees of ABC Co. have just punched in, and the sound of machines starting up fills the air. The delivery log shows that a bulk shipment of sulfuric acid arrived Friday afternoon, which means that the underground storage tank is full and ready for the day's production.
When a pump is turned on to begin delivering the acid to a processing tank, the initial pressure of the acid running through the pipeline causes a loose fitting to give, creating overspray. Fortunately, no one is in the area near the release, and the pressure drop activates the emergency evacuation alarm just as it is supposed to do alerting employees to exit the building.
As all employees are accounted for at the assembly point, the spill team gears up and enters the building to assess the damage and plan their response. A meter reading shows that nearly 200 gallons has been released, and the first entry team confirms the location of the spill adding that it is spreading quickly.
Planning
Knowing what to do when spills happen is essential to employee safety as well as minimizing harm to the environment. Planning, training and drilling are the keys to helping everyone know what to do and when to do it when an emergency does arise.
Even if the employee's only action is to leave the building by a designated route, a plan needs to be created to ensure that person's safety. After the plan has been created, training and drilling are the only way to ensure the plan will work, and that every employee truly understands what to do in the event of an actual emergency.
The Environmental Protection Agency requires facilities to create and maintain written plans on how to respond to spills and other emergencies. EPA allows facilities the option of evacuating everyone and calling in a professional response team or local resources to clean up spills. If these options are chosen over having employees trained to handle spills, contingency plans must clearly state who these outside resources are and their obligations.
Some materials aren't hazardous in a traditional sense (toxic, ignitable, corrosive or reactive), but they can still be detrimental to the environment or hazardous to employees in sufficient quantities, and contingency plans should still be created. For example, a tote of pasteurized egg whites may not seem like a big hazard, but if the tote is damaged, the spilled egg white will cause floors to become very slippery. If the egg whites get into a floor drain that leads to a waterway, water quality could also become impaired.
Training
By law, the Occupational Safety and Health Administration requires employers to train employees on hazards in the workplace (29 CFR 1910.1200). In addition, if employees will respond to spills, they must be trained to be aware of the dangers the spill presents and how to respond in a safe manner.
OSHA specifies several levels of response training necessary for various employees. Commonly referred to as HAZWOPER, the amounts and levels of training can be found in 29 CFR 1910.120.
Although spills are fairly common, no two are the same. An oil spill at the loading dock will likely be handled a bit differently than an oil spill in a processing area. Although this is the case, the following steps can be taken during any spill response.
1. Identify the spill. Train employees not to rush into unknown situations, even if they see a co-worker lying on the floor. All too often, "Good Samaritans" trying to rescue someone become victims themselves, compounding response efforts.
The first step to spill response is to identify the spilled material. In some instances, this is easy. If an employee sees a forklift driver puncture a drum on the receiving dock that is clearly marked "lubricating oil," it stands to reason that the liquid spilling out is lubricating oil.
However, if the punctured drum is a waste material on the shipping dock, the forklift driver has passed out in the seat, and the only thing that can be made out on the drum from a safe distance is UN 1230, it may take several minutes until the employee contacts someone who is able to identify this liquid as methyl alcohol.
Although knowing what has spilled is essential for safety and proper response, employees need to be trained not to endanger themselves in order to identify a material. Tasting or deeply inhaling should never be suggested as methods of identifying a substance.
Employees may only be able to acknowledge that there has been a spill. Reassure them during training that this is enough, and that they should not put their health or their lives in danger to provide a positive identification.
2. Notify. Train employees whom they should contact when they see a spill. Even if they can't identify the spill, they need to know who to tell so that identification can be made and response can be started.
This notification may also take the form of pulling an alarm to alert everyone to evacuate. If alarms are to be activated, be clear in training about when the alarm should be pulled. The nature of chemicals at a facility may help determine the actual scope or need for evacuations, but some examples are:
- Any time a spill is seen.
- Any time a spill cannot be identified.
- When a spill is a certain size.
- When the spill response team will be needed.
- When something "smells funny."
Chances are, with the oil spill mentioned above, the forklift driver may already be initiating response efforts, and just needs more help to get it taken care of quickly. It's unlikely the entire facility needs to evacuate. But the methyl alcohol spill poses a number of problems: first aid-trained responders will be needed to care for the driver, employees may need to be evacuated, etc. By notifying the proper people, these efforts can be coordinated and initiated.
In addition to notifying internal personnel, those responsible for handling the spill may need to notify outside authorities if a reportable quantity has been spilled (see 40 CFR 302.4 for a list of chemicals and reportable quantities,) or if the spill is hazardous and enters a storm drain or otherwise causes harm to the environment.
3. Protect responders. When a spill has been properly identified, choosing personal protective equipment (PPE) is simplified, allowing response to begin more quickly. If the spill cannot be identified, train workers to assume the worst and wear the highest level of PPE that would be necessary for any situation in the facility.
Even though it may take some time to coordinate these efforts and don the proper gear, this step is critical to ensuring the safety of the response team. Even if someone is injured, responders who rush in without the proper protection can become victims as well.
As part of the facility's response plans, use Material Safety Data Sheets (MSDSs) and chemical-resistance guides for chemicals used at the facility to help determine what PPE will be necessary in a spill situation. Planning this ahead of time will save time during an actual emergency. Obtain adequate supplies, and stock this gear in a location that will be accessible to responders. If everyone evacuates when an alarm sounds, this may mean having an outdoor storage locker or trailer for this equipment because it may not be safe for responders to cross through the loading dock to access their equipment in the back corner of a warehouse.
In addition to suits, boots, gloves and respiratory protection, detection equipment and monitors may also be necessary for responders to determine the nature of a spill. If these devices have a lifespan or require batteries, create a schedule for regularly checking this equipment as well as any PPE stored and not used on a regular basis.
4. Life Safety. Ask any trained spill responder: they'll tell you that life safety is the first priority, and so it should be. If anyone is injured in the spill area and needs assistance, spill responders are trained to make recovering them their first goal.
This is often a difficult task. Responders may be in full gear and may need to carry in supplies to transport victims. Because this gear is awkward and responders don't typically perform these functions regularly, be sure that training incorporates these elements. Schedule drills often to make sure teams know how to perform this function quickly and efficiently.
5. Contain the spill. The first step for responders who will actually perform clean up operations is to contain the spill. The smaller the area, the less space that has to be cleaned up and decontaminated. Containing the spill means stopping it from moving any further. The most common method of doing this is to place either absorbent or non-absorbent dikes around the perimeter of the spill.
Pay attention to floor drains or storm drains in the area: these may need to be covered to prevent the spill from entering wastewater processing areas or waterways. Even if the spill has already started entering these drains, it is still a good idea to cover them or divert the spill from them to minimize the extent of the damage.
6. Stop the source. If the source of the spill has not stopped leaking, responders should next try to stop the source of the leak. This could mean rolling a drum so that the hole is on top, patching over a seam that has leaked, or finding and turning off emergency valves. Often, this step can happen at the same time as the spill is being contained.
Consider common situations at the facility, and stock supplies such as wrenches, patches, plugs and other tools with spill response supplies. Because PPE is often bulky and restrictive, having the right tools on hand is even more essential than it is in normal operations.
Also consider stocking pumps and spare tanks or containers to pump out the contents of a damaged container or tank. If the source cannot be stopped, these spare containers could also serve to catch the liquids so that the material can be used instead of wasted.
Train workers to use these tools, if they are different from tools used during normal operations. As with other supplies, check on the condition of this equipment regularly.
7. Clean up the spill. With victims transported out of the spill zone, the perimeter of the spill clearly defined and the source of the spill stopped, responders can begin cleaning up the spill, working from the outside of the spill toward the center. Responding in this manner helps keep workers cleaner, and helps ensure that the entire spill has been cleaned up.
Absorbent mats, socks and pillows can be used to soak up liquids, and vacuums can be utilized on larger spills. Some facilities may even choose to neutralize small spills.
Determine which methods will work best in your facility and outline them in the response plan. Multiple options may be necessary. If equipment such as forklifts, bulldozers and pumps would be needed, note these in the plans and train responders to use them.
As response materials are used, train workers to put spent materials in bags or containers to facilitate recycling or disposal. If containers are used, be sure that training includes moving these containers in the PPE that will be worn during an actual response to ensure the PPE allows enough dexterity for the tasks to be accomplished.
Provide regular drills for responders so that they are properly trained on different methods of responding to spills at the facility. Consider inviting local
HAZMAT response teams to drill with on-site responders. Drilling with outside teams helps those teams be aware of the layout and hazards at a facility, so if they are called upon to assist in an emergency, they are more familiar with the facility and will be better able to assist and minimize damage. Their insight may also be valuable to on-site responders.
8. Decontaminate. After the spill has been contained and cleaned up, decontamination begins. This includes thoroughly cleaning the area where the spill occurred, cleaning tools and equipment, and cleaning responders.
Responders should be trained to set up decontamination facilities even before entering for response. This is especially important if there are victims, because these persons will need to be decontaminated prior to triage and treatment.
In addition to training responders to set up decontamination operations, train safety officers to be aware of the personnel working on the decontamination lines, especially if these people are wearing bulky PPE. Decontaminating responders and tools can be fairly labor intensive, and these workers can become fatigued easily.
9. Paperwork. After a spill, complete any necessary paperwork. This may mean filing reports with federal, state or local authorities &endash; depending upon the nature and scope of the spill. Know the regulations that apply to the facility and the chemicals being stored. A 20-gallon spill inside may not require reporting, but a 10-gallon spill of the same liquid that enters an outdoor storm drain may.
Review what happened during the response. What went well? What didn't? Did the written plans work? If not, do they need to be amended? Amending the plans now will help things go more smoothly in the future.
10. Restock. Determine what supplies were used during response. Restock PPE, absorbents and any other materials that were spent as soon as possible. An empty spill kit won't do much good if the same thing happens again next week.
Be Prepared
As every Boy Scout is taught, it pays to be prepared. Taking the time to create spill response plans, training employees on how to implement them, and holding regular drills to make sure the plans will actually work at the facility will help ensure that in an actual emergency, the plans work flawlessly. Employees will be kept safe from the hazards of the spill, responders will be kept safe during response, and harm to the environment will be minimized.
Karen D. Hamel is a technical specialist for New Pig Corp. She is a graduate of the University of Pittsburgh and has more than 10 years of experience helping EHS professionals find solutions to their environmental, health and safety issues. She is HAZWOPER technician level certified and is currently the chairperson of the Blair County, Pa. LEPC. She can be reached at 1-800-HOT-HOGS (468-4647) or by e-mail at [email protected].