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Be Prepared For Environmental Emergencies! No Organization Can Afford To Be Unprepared

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Response / Training

Suddenly, what seemed impossible becomes a reality! You have an environmental emergency. The event escalates into a runaway condition. You call 911! The emergency services choose not to enter the area unless there is a rescue. You call in your response contractor and learn that your own people have more knowledge and expertise than your retained professionals. Then, out of frustration, your internal response team with in-house resources stabilizes the event. Seven of your people go to the hospital where they spend the night isolated in the morgue because they are believed to be contaminated with chemicals. Production has come to a halt, wages must be paid and the invoices are coming in.

The advantages of site-specific training, developing an Environmental Management System (EMS) or adopting the ISO 14000 standard for emergency response would have paid dividends.

Be Prepared for the Unexpected!

Plan for the unexpected. Community emergency response services such as the fire departments, may not feel comfortable risking their people by entering the scene of an incident before they are satisfied that a proper ‘size-up’ has been done. As the lead agency responsible for your safety and site-safety, the fire department may not even let you enter your facility. The fire crews, not being familiar with your risks and hazards, may not be able to assess the situation in a timely manner to prevent escalation or mechanical damage.

Contracted responders may not have the understanding, capability, equipment and resources to effectively mitigate the situation - they may even be learning at your expense. Contractors may insist on money up front because the insurance company may not honour the invoices without challenge and investigation. (Check with your insurance company’s claim department to insure that your selected contractor provides an acceptable service.)

An effective Environmental Management System (EMS) provides for reviews of an organization's activity, identifies gaps and determines the degree of impact that may occur. It can help prevent many events from occurring in the first place. First-hand advice from the workers and responders who have been on the front line during an event will help to make informed decisions when developing emergency response plans, preventive maintenance plans and standard operating procedures.

No public or private sector organization can afford to be unprepared and unprotected. Your organization should be prepared to manage the response activities, provide support to emergency services, access resources and communicate effectively.

Initial response personnel may be on the scene or the first to arrive. These could include workers, supervisors and internal response team members. They can reduce the loss to life, property and the environment by acting in a timely manner, staging and selecting response supplies, personal protective equipment, etc. Pre-planning could prevent a routine incident from becoming a major emergency.

To obtain the ultimate insight and capability required for planning, training and response, effective response teams consist of individuals from different disciplines who understand ‘the same language’. The most knowledgeable persons on the site may be those who know they don’t know everything.

It is important to understand that every response team and team member has a specific level of confidence and competence when responding to an event. Training and practice will require a common-sense approach, flexible guidelines and location-specific exercises to develop self-reliance and capability. This will help determine and address the hierarchy of the emergency.

Preparedness may incorporate contracting the services of off-site response contractors. Decide whether you require a routine service such as a vacuum truck to pump a contained spill or an emergency service with response team capability to respond, contain, retrieve and dispose of spilled product. Today, many contracted services are responding as emergency responders when routine service or advice over the phone will suffice. Often there are unjustified equipment, increased waste volumes, and excessive numbers of responders for the task. This escalation is reflected in the invoices. Following are some examples.

  • Over 40 fire fighters spent 10 hours to incompletely neutralize a partial drum of a 70% nitric acid solution in a closed head drum that had finished reacting prior to neutralization. An experienced response team which treats nitric acid on a daily basis was not allowed on the site to assist or to take over until the fire department had completed its task. The response organization was retained to dispose of the several drums at a reasonable cost. This is an example of where the confidence level of the person in charge is much higher than the competence level. The total invoice included almost fifteen hours of standby and the disposal of five to six drums.
  • Seven litres of 80% acetic acid (concentrated vinegar) spilled in an institution, cost $15,000.00. A response crew member had to be shown how to correctly use the monitoring equipment by the facilities safety officer. The readings were misinterpreted and the fire crew was called back to the scene where they were ordered to strip for decontamination. A vacuum truck was brought in and the volume of waste taken for disposal grew to 2,500 litres.
  • A few grams of a herbicide /pesticide product were pulled from a disposal bin. The owner of the product, identified the product’s stability, misleading information in the material safety data sheet, and level of dress worn to work with this product on a day to day basis. Apparently, the contractor ignored the owner’s advice and chose to suit-up seven people in level A disposable suits to do the work. According to the owner the invoice was approximately $20,000.00.
  • Recently, a training company handled one bottle of dried picric acid, one bottle of picric acid solution with dried picric around the cap, a leaking and failing container of blended acids stored in a steel drum, and developed the response protocol for a dip tank containing a concentrated solution of nitric and hydrofluoric acid. These situations were handled as part of routine training programs.

The difference between the companies is knowledge experience and training. Unfortunately, many experienced responders have retired or moved up the ladder of large corporations. Some newer responders are gaining their experience and confidence through NFPA 472, awareness, operation and technician level of training. The NFPA training standard should be viewed as an international competency standard for fire fighters, as the ISO 14001 (4.4.7) standard is for industry’s emergency preparedness and response. The two standards may overlap but they don’t mix when it comes to assessing industrial needs.

Fire departments are to protect people, property and when possible the environment. The fire fighter’s standard (NFPA 472) does not challenge the misleading information of a material safety data sheet, nor does the standard provide the expertise about how to take blends of unknown chemicals and determine an action plan to mitigate the situation. NFPA driven, contract responders may not have the expertise to fulfil your needs.

Caution: When selecting response contractors to help minimize your liabilities, be sure they have the equipment to do the job, the capability to problem-solve worst case scenarios and the knowledge and training to do the job.

Inexperienced teams are demonstrating low levels of capability in the following areas:

  • Advising clients how to use on-site resources to reduce the impact until they arrive, (most advice is from a guide book or MSDS);
  • Assessing actual risks and hazards and preparing for consequential reactions;
  • Recognizing or verifying ineffective MSDS information;
  • Putting thought and effort into working clean to minimize decontamination, unwarranted chemical reactions and high response bills;
  • Following standard operating procedures in blind faith;
  • Becoming frustrated as they discover that their training has not provided them with the expertise to assess a critical situation such as a run-away-reaction.

With more organizations developing Environmental Management Systems (EMS) or adopting the ISO 14000 standards and involving their technical people in emergency planning, routine spills are being effectively handled in-house. Personnel are now being trained to document and assess response contractor’s activities to help reconstruct events, as well as justify invoices.

Organizations that have decided to contract or retain the services of an outside response company should reconsider this process by determining their needs and assessing the capability of the individuals on the contractor’s team who will be showing up to handle an event.

Cliff Holland, Spill Management Inc.

Spill Management Inc.
45 Upper Mt. Albion Rd. Stoney Creek, Ontario L8J 2R9
Phone: 905-578-9666 Fax: 905-578-6644
Web Site: http://www.spillmanagement.ca
E-mail: spillman@on.aibn.com

This article originally appeared in Environmental Science & Engineering