September 2016 — Hazardous materials spills, including biological, chemical, and radiological materials, pose a serious risk if not promptly identified and properly responded to by the individuals, staff, and/or emergency response staff. Although most building and property managers will likely rely on the expertise of the local fire departments and their HAZMAT teams, some may choose to have their own select staff officially trained for these responses. The complexity and detail of the plan will, of course, depend upon the physical characteristics and volume of materials being handled, their potential toxicity, and the potential for releases to the environment. Preparing for an effective response to a spill hazard involves all of the following actions:
- Review material safety data sheet (MSDS) documents or other references for recommended spill cleanup methods and materials and the need for personal protective equipment (such as a respirator, gloves, and protective clothing).
- Acquire sufficient quantities and types of appropriate spill control materials to contain any spills that can be reasonably anticipated. The need for equipment to disperse, collect, and contain spill control materials (such as brushes, scoops, and sealable containers) should also be reviewed.
- Acquire recommended personal protective equipment and training in its proper use. For example, if an air-purifying respirator or self-contained breathing apparatus is needed, personnel must be enrolled in the Respiratory Protection Program and attend annual training and fit testing.
- Place spill control materials and protective equipment in a readily accessible location within or immediately adjacent to the areas where chemicals are used.
- Develop a spill response plan that includes:
- names and telephone numbers of individuals to be contacted in the event of a spill
- evacuation plans for the room or building, as appropriate
- instructions for containing the spilled material, including potential releases to the environment (for example, through floor drains)
- inventory of spill control materials and personal protective equipment (PPE)
- means for proper disposal of cleanup materials (in most cases, as hazardous waste), including contaminated tools and clothing
- decontamination of the area following the cleanup
Minor, Moderate, and Major Spills
Another important aspect of a chemical spill response plan is to determine what constitutes a minor, moderate, and major spill. Minor spills generally involve small quantities of chemicals or larger quantities of less toxic substances. Those chemical spills defined as a minor spill can generally be handled by the individuals who created the incident, such as a maintenance worker spilling a small amount of a solvent—that is, assuming that this person has had the first-responder awareness training required for the handling of minor spills. Initial response involves containing the spill, isolating the immediate area, using PPE, and performing proper cleanup and decontamination as necessary. It is critical to identify what response procedures are appropriate and what procedures are inappropriate. When in doubt, the individual creating the spill should contact the appropriate response personnel.
Moderate spills involve larger quantities of chemicals or small amounts of more hazardous substances. Moderate spills require a response by one or more individuals who have special training and equipment. For instance, a small mercury-containing thermometer would create a small spill. However, traditional cleanup methods may in fact create a bigger problem by spreading and tracking the mercury throughout a larger area than where the spill occurred. Impressing on general employees that they are not qualified to clean up small mercury spills (or training them on what not to do) is just as critical as their knowing what to do during chemical spills.
Major spills involve large quantities of materials that trigger regulatory reporting and a full response from internal and/or external response teams. Major spills will typically involve larger-scale evacuations that may go well beyond the property boundaries. Major spills require HAZWOPER trained staff and the activation of the emergency response plan.
Internal and External Response
Emergency planning involves the development of an appropriate level of response from internal and potential external sources. Assessing resources necessary to respond to spills requires an evaluation of both internal and external personnel, organizations, and agencies. Most minor and moderate spills can be addressed with internal resources. However, some moderate and most major hazardous material releases will require a coordinated effort of both internal and external resources. The emergency plan must be communicated with external response agencies and often supplemented with the use of external response contractors.
Building management will require some level of internal expertise in order to be able to identify the extent of a hazardous material release and provide a coordinated response. An emergency preparedness plan assists in the recognition of chemical hazards and requires an assessment of resources necessary to respond to emergency situations. Sometimes these responses will be internal; other times, they will be coordinated with external resources.
The details of how and when responses will involve external resources will be defined in the emergency preparedness and response plan. It is important to note that evaluating internal and external resource requirements are beneficial regardless of the emergency type. If the managers have a sufficient level of expertise, they will be able to quickly make the judgments about handling an emergency in a timely, effective manner. If a situation is not one that he or she can readily assess, the manager should have a key contact or two to call on for a quick answer. If there is no one readily available, the manager can make a conservative decision and do a debrief afterwards on lessons learned.
Incident Command Systems: Defining Roles and Responsibilities
Most emergencies are best handled with the initiation of an incident command system (ICS), which organizes the structure of a response. The ICS is also used by external responders who may be involved with a larger response scenario. The ICS is a standardized, on-scene, all-hazards incident management approach that allows for the integration of facilities, equipment, personnel, procedures, and communications operating within a common organizational structure. It also enables a coordinated response among various public and private jurisdictions and functional agencies and establishes common processes for planning and managing resources.
Another advantage of the ICS is that it is flexible and can be used for incidents of any type, scope, and complexity. ICS allows its users to adopt an integrated organizational structure to match the complexities and demands of single or multiple incidents. Generally a senior response team member who is designated as the building’s incident coordinator is responsible for the site-specific ICS. This individual will size up the situation and determine the appropriate response personnel required for the hazardous material release. This may involve the use of internal or external responders, including skilled responders and specialists, depending on the need.
Each response plan will be unique to that organization. However, it is critical to develop an incident command structure to make sure that roles and responsibilities are clear and that necessary resources are available before an incident occurs.
This article is adapted from BOMI International’s course Environmental Health and Safety Issues, part of the RPA, FMA, and SMA designation programs. More information regarding this course or the new High-Performance certificate courses is available by calling 1-800-235-2664. Visit BOMI International’s website, www.bomi.org.