Recently, one of our subscribers asked the following question:
Emergency Preparedness and Response
No one wants it to happen, but an emergency, natural or manmade, can strike at anytime, 24/7. What’s more, it need not be a major, nationally-televised incident, such as a hurricane, earthquake, or act of political terror. An event as common as a local building fire can present just as large a challenge to you. These resources will help you create a plan for handling such crises, whatever their scope, and to carry it out in a way that best protects your employees and your company.
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As a hazardous waste generator, are you prepared in the event of an emergency? Does your facility have a “contingency plan”? Both large quantity generators (LQGs) of hazardous waste and small quantity generators (SQGs) of hazardous waste must comply with certain specific emergency preparedness and prevention procedures. These procedures involve use of response equipment and personnel in the event of a fire, explosion, or release. While LQGs must have a “contingency plan” in place, SQGs must have at least one emergency coordinator employed at all times.
The EPA has issued its first biannual update of its work on a proposal for a final rule that would subject facilities holding hazardous substances to the same requirements applying to facilities holding threshold amounts of oil. The update indicates that the proposal is still in its early stages, and therefore, any views on what form a final rule will take would be premature. Hazardous substances differ from oil in many ways, including how they are handled, what they are intended to accomplish, how an accidental spill affects the public and the environment, and how such a spill is best controlled. However, given that any final action will be promulgated under the same section (indeed, the same phrase) of the Clean Water Act (CWA) that is the basis for EPA’s oil Spill Prevention, Control, and Countermeasure (SPCC) program, there is no reason to assume at this early date that the expected final rule will differ in major ways from the existing SPCC requirements.
On January 18, 2015, Peter Jonsson and Carl-Frederik Arndt, graduate students at Stanford University, were riding their bikes across campus at about 1 a.m. As they rode through an alley, they saw something disturbing: a man on top of a woman next to a dumpster. The woman was unconscious. The two students yelled at the man, who tried to run away. One of the students stopped him, while the other went to check on the woman.
On April 17, 2013, a 60-ton stockpile of fertilizer-grade ammonium nitrate (FGAN) exploded at the West Fertilizer Company (WFC) in the middle of downtown West, Texas. The fire and explosion killed 15 people—12 twelve emergency responders and 3 members of the community—caused injuries to 260 more people who required medical treatment, and damaged more than 150 buildings off-site. One of the key recommendations to come out of the U.S. Chemical Safety Board’s (CSB) investigation of the incident is to improve emergency planning and response capabilities.
When a 900-gallon melt tank containing hexane and ethanol overpressurized and exploded in December 2015 at a food additive manufacturing facility in Newark, Ohio, owned by Arboris®, LLC, the U.S. Occupational Safety and Health Administration (OSHA) faulted the employer’s process safety management (PSM) for failing to prevent the explosion. But even when the fireball erupted, the injuries suffered by four employees were not necessarily inevitable. With better emergency preparedness, OSHA concluded, the employer could have prevented or minimized the workers’ injuries.
At the Arboris® plant in Newark, Ohio, workers were adding hexane to a process that produced sterols—a natural compound produced by pine trees—for use in foods such as spreads, bread, milk, and yogurt. Unfortunately, the employer’s process safety management (PSM) program failed at many points to identify and correct potentially disastrous issues with the process. As a result, a tank at the facility overpressurized and exploded, injuring four workers.
Is an ounce of prevention really more effective than a pound of cure? According to the U.S. Occupational Safety and Health Administration (OSHA), that’s certainly the case for Arboris®, LLC, a food additive manufacturing facility in Newark, Ohio. A 900-gallon melt tank at the facility containing hexane and ethanol overpressurized and exploded in December 2015. The resulting fireball injured four workers, including two contractors.