scared straight: the frightening prospect of mismanaging a chemical emergency
TRANSCRIPT
5 Common Mistakes to Avoid
Scared Straight:The Frightening Prospect of
Mismanaging a Chemical
Emergency
Meet Your Presenter
Doug Graham, CHMM
Sr. EH&S Consultant &
External Training Manager
Over 20 years training emergency responders
Objective
Learn from the common
missteps of others to ensure you
are well-prepared for a chemical
emergency.
Five Common Missteps
1. Inadequately Trained Discoverers
2. No Cohesive Incident Command Structure (ICS)
3. Faulty Risk Characterization
4. Written Policies with Inappropriate Protocol
5. Missing Engineering Controls/Work Practices
1. Inadequately
Trained Discoverers
The Discovery• Any employee can discover a chemical
emergency
• Emergencies can occur anywhere inside
or outside a facility
• Chances are they will not be an EH&S
professional or designated spill team
member
How will they respond?
Are These Responses?
• Walking through a puddle of unidentified clear liquid
• Pumping backed up sewage into a storm drain
• Ignoring a leaking transformer for months
• Cleaning up a strong oxidizer with organic materials
• Continuing deliveries after discovering a leaking fuel tank
• Removing stretch wrap from leaking hazmat boxes
• Tasting a spilled chemical from a derailed railcar to identify it
It’s up to you to make sure all
of your employees are trained
to respond appropriately.
Necessary Training
Average employees fall into the “Awareness Level” responders category in the OSHA HAZWOPER standard
Key Competencies Required:• Recognize potential safety and environmental emergencies• Know to remove self from area• Know to warn others• Know how to contact emergency coordinator• Be available to be interviewed
Ref: 29 CFR 1910.120(q)(6)(i)
2. No Cohesive Incident
Command Structure (ICS)
No Clear Internal Incident Commander
No Internal Team or Pre-Assigned Duties
Common Problems
Who’s in Charge?Only one person can be in charge of
the incident, all others need to follow
their instructions and must not be
making independent command
decisions.
Internal emergency coordinators need
to be named, be available, and have
alternates.
In the absence of a clear
commander, others will fill the void.
In the absence of a clear
commander, others will fill the void.
Fire Dept (when not necessary) ?
The Discoverer ?
Untrained Upper Management ?
The Strongest Personaility ?
Who’s in Charge?
What Roles Must Be Filled?
Do We Have a Team?Who will be responsible for overall safety?
How will we communicate with each other?
Who will deal with the press and control information?
Who will act as the Liason to outside responders?
How will we control the scene?
Who will oversee and direct the spill contractor?
Who will be responsible for environmental management?
Roles and responsibilities should be
thought through ahead of time and
assigned as needed.
3. Faulty Risk
Characterization
Common Problems
• Hazards versus risks concept not well understood-
specific circumstances of the release not considered
• The “I’ve been working with this stuff for years, I can
handle it” syndrome
• Rushed investigation- all direct and indirect results not
considered, including environmental impact and
compliance
Best PracticesIn the initial phase of an
incident, an effective emergency
coordinator will usually obtain
enough information about the
scene to establish an effective
evacuation zone to keep people
at a safe distance.
This is assuming the coordinator
acts conservatively and fills in
the missing details with a “worst
case scenario” approach.
Exclusion Zone
Support
Zone
After this initial step, the
coordinator needs to do a
detailed risk assessment to
determine the true nature of
the risks to people and the
environment in order to
formulate a plan going
forward, which may take
considerable time and effort.
Best Practices
ExampleA 4-liter bottle of flammable solvent is typically
not much of a threat in a laboratory- it’s often in
a closed container in a fire cabinet and when in
use it may be manipulated under a chemical
fume hood with intrinsically safe equipment
and a built-in fire suppression system.
Fire and health hazards are well controlled in
these routine procedures- the hazards may be
high, but the risk is LOW
• What’s the airborne exposure limit and how does that
compare to concentration in our breathing zone?
• Are there ignition sources close by and what are they- is a
flash fire an imminent possibility?
• Will this chemical react with the surface on which it spilled,
or with spill control materials to give off a gas or other
harmful reaction?
• How should the waste be managed?
• Is it reportable?
Break a bottle of it onto a benchtop which then spills to
the floor and there are many unknowns- the hazards
are the same, but the risk may be high.
• Discoverers may only understand
the hazards in the context of
controlled situations and are not
trained to assess risks.
• If the discoverer caused the
incident, there may be strong
motivation to “fix the problem”
and not report it.
A detailed risk assessment should
be made by a qualified EH&S
professional, not the discoverer.
4. Written Policies with
Inappropriate Protocol
“Employees may clean up
incidental spills”
The statement itself is not the problem, after all, an incidental
spill is one which cannot threaten people or the environment.
The problem is that the statement empowers the discoverer
to make their own determination as to what is “incidental” vs.
what is an “emergency”. This determination should only be
made by a qualified coordinator or designee as we discussed
with risk assessments. Individual employees will arbitrarily
decide what is incidental using
unpredictable subjective
criteria and motivations.
“Employees may clean up spills
under xxx quantity”
This statement seems to fix the problem of the first
statement- we’ve clarified the meaning of the word
“incidental”. But if we remember the risk assessment phase
of a response, hazard as well as circumstances determine
risk- in this statement the employer’s addressing neither.
Using a sole factor, such as quantity to
determine risk is never a good idea.
Quantities vary wildly depending upon
“perceived threat”.
“If the spill is an emergency,
then call . . . ”
This statement is the opposite of the first,
but effectively says the same thing, that is,
the discoverer makes the determination as
to whether or not the incident is an
“emergency” (non-incidental), which
presents the same problems.
“For all chemical spills, call 9-1-1”
Now it looks like we’ve found a solution to the problems with
the first three policies- don’t allow the discoverer make a
determination, just make the call. There are four major
problems with this policy.
1) The employer has removed the possibility of the incident being
managed, or at least initially managed, internally. Not every
incident that threatens human health or the environment poses a
public safety threat or can’t be controlled by the employer and
therefore require the services of the local fire department.
2) Employees will probably not follow this policy anyway. Human
nature dictates that for an employee to call 9-1-1 or pull an alarm,
they will need to conceive the incident as really, really bad, so
don’t expect them to take this action other than in extreme
circumstances.
What will likely happen with this approach is employees will not
call and then left with no alternative, they will arbitrarily decide
upon their own course of action.
“For all chemical spills, call 9-1-1”
3) In the unlikely event that this policy is followed and the incident
could have been managed internally, the arriving fire department
may have some choice words regarding the employer’s lack of
internal coordination. Additionally, the fire department will have
been looking for an employee designated as a technical contact
(Liason Officer), the lack of which can very much change the
nature of the department’s response.
“For all chemical spills, call 9-1-1”
4) If this policy was chosen due to a missing internal incident
command structure, it will be quickly discovered that there are
many tasks which the fire department will not perform for the
employer- these may include notifications, air monitoring, spill
clean-up, regulatory reporting, etc.
“For all chemical spills, call 9-1-1”
“For all chemical spills, pull
the fire alarm”
This policy will have the same issues as the 9-1-1 call, but may have two additional problems-
1. No context for the arriving fire department and;
2. A non-directional evacuation which could put employees in the wrong location relative to the risk area.
“For all chemical spills, call
Acme Environmental Services”
Just like the last policy, the employer is
attempting to outsource the management
of the incident. However, unlike the
involvement of the fire department where
the department will assume incident
command, a contractor cannot.
The role of a spill response contractor is to
perform tasks which go beyond the
capability of the employer, not manage the
incident
• Discoverers may only
understand the hazards in
the context of controlled
situations and are not
trained to assess risks.
• If the discoverer caused
the incident, there may be
strong motivation to “fix the
problem” and not report it.
A detailed risk assessment should
be made by a qualified EH&S
professional, not the discoverer.
Employees should report all
chemical spills to the internal
Emergency Coordinator
5. No Engineering
Controls/Work Practices
Emergency Prevention
Having appropriate engineering controls/work
practices will decrease likelihood of emergency
Don’t focus solely on practices and
infrastructure required by regulation.
Common Prevention
MethodsSecondary containment around chemicals
Use of shatter-proof glass lab bottles
Use of rubber container carriers
Intentionally limiting container sizes
Chemical storage segregation by compatibility
Common Prevention
MethodsRestricting chemicals to certain areas
Monitoring bulk chemical delivery
Avoiding use of high risk material handling equipment
Performing vulnerability assessments
Conclusion
Final ThoughtsIn summary, employers are well advised to self-examine
emergency response issues related to employee training,
anticipated employee roles and responsibilities, written
polices and plans, as well as spill prevention infrastructure.
Too often, the emphasis is on one, and not
all of these elements, or policies and
procedures are academic rather than being
grounded in understanding human nature
and exercising common sense.
QUESTIONS?