DOSH Directive John McFadden Field Consultation Manager Agenda DOSH Directive Definitions Examples Enforcement Consultation 3 Reactive Interactions Rick McFarland, Arkansas Democrat-Gazette Conditions? Uncontrolled Release Large Quantity Releases Small Releases that could be highly toxic Potentially Contaminated Individuals Airborne Exposure >PEL Hazardous Substance Section 101(14) CERCLA Biological Agents USDOT Title 49 Part 172 Hazardous Wastes WAC CSB Reactive Hazard Investigation 167 incidents since fatalities 5 fatalities per year (average) 50 incidents with public impact 6 In WA State Equilon Atlas Foundry 2008 Tacoma WA Initial explosion Safety devices did not close Middletown, CT ICS LocationDateFatalities 1 Channelview TX7/5/ Charleston SC6/17/919 3 Sterlington LA5/1/918 4 Lodi NJ4/21/955 5 Allentown PA2/19/995 6 Port Neal IA12/13/ Severe Reactive Chemical Incidents 15 Where Do Reactive Incidents Occur? Source: CSB CSB Investigation of Reactive Incidents Type of FacilityPercent of Incidents Chemical Manufacturing70% + Storage, Handling, Consumer Sites Nearly 30% 16 Where Do Reactive Incidents Occur? Source: CSB CSB Investigation of Reactive Incidents Transfer Equipment 5% Reactor 25% Storage Equipment 22% Other Process Equipment 22% Separation Equipment 5% Unknown 8% Storage Drum 10% Waste Equipment 3% Does Emergency Response under WAC apply to hazardous waste sites? Conflict? More stringent rule applies Terrorist events? What will enforcement do? Review Emergency Response Plan (ERP) Enforcement cont. Incomplete plans Serious or General? Enforcement guidance cont. Evaluate Incident Command System Implementation of Emergency Response Plan Hazard Assessment for PPE WAC Post-emergency response How do we prepare? Consultation Industrial Hygiene Safety Risk Management OR (509)