Industrial HazMat Industrial HazMat Response TeamsResponse Teams

A Case StudyA Case Study

Shelly Stephens, PEMShelly Stephens, PEMEH&S Supervisor & EH&S Supervisor &

HazMat Team CoordinatorHazMat Team CoordinatorAmway CorporationAmway Corporation

May, 2009May, 2009

IntroductionIntroduction

Who we areWho we areDefinition of an EmergencyDefinition of an EmergencyBusiness Impact AnalysisBusiness Impact AnalysisHazMat Team ConsiderationsHazMat Team ConsiderationsAmway HazMat Team TodayAmway HazMat Team Today

Who we areWho we are

5050--year Anniversary!year Anniversary!Business in more than 80 countries Business in more than 80 countries worldwideworldwideOver $8 billion in sales in 2008Over $8 billion in sales in 2008Headquartered in Headquartered in AdaAda, Michigan with , Michigan with 4,600 employees4,600 employeesManufacture home care, personal care, Manufacture home care, personal care, & nutritional products& nutritional products

HazMat Team HistoryHazMat Team History

Original Team Formed in 1991Original Team Formed in 199180 Team Members 80 Team Members –– SpecializedSpecializedCapital InvestmentCapital InvestmentReorganized in 2001 as ABG, LLCReorganized in 2001 as ABG, LLC

What is an emergency?What is an emergency?

Incidental ReleaseIncidental Release29 CFR 1910.120029 CFR 1910.1200

Can be absorbed, Can be absorbed, neutralized, or neutralized, or controlled at time of controlled at time of releasereleaseNo potential safety or No potential safety or health hazardhealth hazard

Emergency ResponseEmergency Response29 CFR 1910.120(q)29 CFR 1910.120(q)

Uncontrolled release Uncontrolled release of a hazardous of a hazardous substancesubstanceRequires response Requires response from outside area of from outside area of releaserelease

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““Too MUCH Too MUCH SpilledSpilled””PostersPosters

Defines Defines ““EmergencyEmergency””

by by DepartmentDepartment

What if I have an emergency?What if I have an emergency?

OptionOption

OptionOption

Evacuate employees Evacuate employees and call for and call for assistance.assistance.

Respond with your Respond with your own HazMat Teamown HazMat Team

Business Impact AnalysisBusiness Impact Analysis

Risk Risk -- Severity & ProbabilitySeverity & ProbabilityResponse Time Response Time RequirementsRequirementsResponse Expertise Response Expertise (Level of Response (Level of Response Required)Required)

Business Impact AnalysisBusiness Impact Analysis

CostCostProtection of People & Protection of People & Preservation of PropertyPreservation of PropertyCommunity Community Impact/ReputationImpact/Reputation

How do you decide?How do you decide?

Meet with local fire Meet with local fire departmentdepartment

Benchmark with other Benchmark with other companiescompanies

Research 3Research 3rdrd party party response response organizationsorganizations

How do you decide?How do you decide?

Fire Department Vendor A Vendor B

Quote – Level A response –5 hrs.

Response Time

Equipment Availability

Expertise/Response capability

Personnel Availability

Experience

Response Locations

Research & Gather DataResearch & Gather Data

Operations Level Response TeamOperations Level Response Team

CANNOT respond CANNOT respond offensively to offensively to emergency spillsemergency spillsStill requires Technician Still requires Technician Level response in an Level response in an emergencyemergency

CAN Respond offensively CAN Respond offensively to NONto NON--emergency spills emergency spills CAN respond defensively CAN respond defensively to emergency spillsto emergency spillsCAN conduct CAN conduct DecontaminationDecontaminationLow Cost Low Cost –– Less Less Regulatory RequirementsRegulatory Requirements

Technician Level Response TeamTechnician Level Response Team

Prescriptive response & Prescriptive response & staffing requirementsstaffing requirementsExtensive program Extensive program requirementsrequirementsSignificant capital Significant capital investmentinvestment

CAN respond offensively CAN respond offensively to ALL emergency spills to ALL emergency spills Reduce response time, Reduce response time, resulting downtime, and resulting downtime, and impact on environmentimpact on environment

Tech Level Regulatory ComplianceTech Level Regulatory Compliance

Medical Surveillance Medical Surveillance Program Program 29 CFR 1910.120(q)(9) & (f)29 CFR 1910.120(q)(9) & (f)

Air Monitoring Air Monitoring 29 CFR1910.120(h)29 CFR1910.120(h)

Decontamination Decontamination 29 CFR 1910.120 (k)29 CFR 1910.120 (k)

Training Training 29 CFR29 CFR 1910.120 (q)(6)(iii)1910.120 (q)(6)(iii)

Written PlansWritten Plans

PPE Program PPE Program 29 CFR 1910.120 (g)29 CFR 1910.120 (g)

Respiratory Protection Respiratory Protection Program Program 29 CFR 1910.13429 CFR 1910.134

Vehicle LicensingVehicle LicensingEnvironmental Environmental Compliance: waste Compliance: waste management, management, RQRQ’’ss, , waste & storm Water waste & storm Water discharge, air qualitydischarge, air quality

Tech Level Capital InvestmentTech Level Capital Investment

PPE/PPE/SCBASCBA’’ssDeconDecon EquipmentEquipmentAir Monitoring Air Monitoring SorbentsSorbentsPlugging/Patching tools & Plugging/Patching tools & equipmentequipmentCommunications EquipmentCommunications EquipmentChemical Information Chemical Information ResourcesResourcesVehicle/trailerVehicle/trailer

Tech Level HazMat TeamTech Level HazMat Team

1910.120 (q) Personnel Requirements

1910.120 (q) Functional Requirements

1 Incident Commander 4 Responders (buddy system) 1 Safety Officer 1 Advanced First Aid

Incident Command System Evaluation/Use of PPE Decontamination Monitor Critique Site Security

Staffing/Team ConfigurationStaffing/Team ConfigurationWhat the regulations requireWhat the regulations require……..

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StaffingStaffingTrainingTrainingProgram Program ManagementManagementResponse Response HistoryHistoryChallengesChallenges

Amway HazMat TeamAmway HazMat TeamStaffingStaffing

One Team with One Team with Interchangeable PartsInterchangeable Parts

First Shift Second Shift Third Shift Weekends/Holidays

3 IC’s10 Responders

2 IC’s4 Responders(Support from first shift)

2 IC’s4 Responders(Support from first shift)

Rotational1 IC4 Responders(All Team page and support from Ada Fire Department)

Incident Commanders & Responders: Paid Incident Commanders & Responders: Paid VolunteersVolunteersSafety Officers: EH&S Safety ProfessionalsSafety Officers: EH&S Safety ProfessionalsFirst Aid: MFR Trained Security StaffFirst Aid: MFR Trained Security Staff

Amway HazMat TeamAmway HazMat TeamProgramsPrograms

Initial TrainingInitial TrainingAnnual Refresher TrainingAnnual Refresher TrainingFit Testing/Respiratory Protection ProgramFit Testing/Respiratory Protection ProgramSafety Training Programs (Lockout/Safety Training Programs (Lockout/TagoutTagout, , Bonding & Grounding, etc.)Bonding & Grounding, etc.)Equipment testing & maintenanceEquipment testing & maintenance

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13 13 -- Emergency Emergency ResponsesResponses55 55 -- NON Emergency NON Emergency ResponsesResponses20 20 -- IC ConsultationsIC Consultations

Response HistoryResponse History20022002--20082008

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Cost/Time/Certifications for keeping Cost/Time/Certifications for keeping equipment working, maintained, inspectedequipment working, maintained, inspectedManaging staff movements between shiftsManaging staff movements between shiftsKeeping staff trained and engagedKeeping staff trained and engagedConsistent & reliable communicationsConsistent & reliable communications

ChallengesChallenges

Industrial HazMat Industrial HazMat Response TeamsResponse Teams

A Case StudyA Case Study