EHS Management, Emergency Preparedness and Response

It’s National Preparedness Month—Ensure Your Plans Cover a Variety of Workplace Emergencies

Depending on your region of the country, there can be a wide variety of emergencies you need to plan and prepare for—floods, hurricanes, and wildfires. All are complicated by an ongoing public health emergency: the coronavirus disease 2019 (COVID-19) pandemic. You also may need to prepare for accidents or emergencies involving the substances and processes at your facility.

Emergency planning

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Despite the variety of potential emergencies, the planning processes is simple if incredibly detailed. You need to identity the potential emergencies at your facilities or worksites, develop a written plan, and assign roles and responsibilities. Once you’ve made a plan and assigned responsibilities, you’ll need to train your employees to implement your plan when a disaster strikes. Often, you can tap resources in your community like local, county, or state public health departments, law enforcement, fire and emergency medical services, and hazardous materials response teams. You also may be able to consult your Local Emergency Planning Committees (LEPC); although required for chemical hazards planning at the local level, some LEPCs consider all hazards part of their planning process.

Outbreaks in the Workplace

Before the current pandemic, the National Institute for Occupational Safety and Health (NIOSH) found that infectious disease outbreaks in the workplace were poorly understood and more study was necessary to understand how to prevent and control them. Addressing workplace infectious disease outbreaks takes a h3 safety culture and a multidisciplinary approach involving engineers, epidemiologists, industrial hygienists, and physicians, NIOSH said in 2019.

Many employers found their facilities shut down under state stay-at-home orders issued at the beginning of the COVID-19 pandemic. Reopening across industries has required screening employees for symptoms, rearranging desks and workstations to achieve 6-foot social distancing, closing or rearranging break rooms, and requiring employees to wear face coverings. Some facilities have had to increase ventilation due to aerosol transmission of the SARS-CoV-2 virus that causes COVID-19. They also have had to inspect heating, ventilation, and air conditioning (HVAC) and water systems for legionella growth.

hurricane

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Hurricanes, Tropical Storms

Depending on your facility’s location, you should already have planned and prepared for an active hurricane season. The National Weather Service predicted an above-normal 2020 Atlantic hurricane season. Areas on the Atlantic Coast, near the Gulf of Mexico, and even in parts of the Southwestern United States are vulnerable to hurricanes. These storm systems often have circulating air and sustained wind speeds of 74 miles per hour or higher. The h3est hurricanes can have wind speeds exceeding 155 miles per hour.

The Atlantic hurricane season runs from June 1 to November 30, peaking between August and October, according to the National Oceanic and Atmospheric Administration’s (NOAA) National Hurricane Center. The Eastern Pacific hurricane season runs from May 15 to November 30.

While coastal areas are susceptible to risks of hurricanes that include flooding, storm surges, rip currents and h3 winds, and tornadoes, tropical storms can continue inland, bringing heavy rains and flooding.

Your hurricane plans may need to include:

  • Developing an evacuation plan to ensure workers can get to safety in case of a flood or hurricane—during the pandemic, the Centers for Disease Control and Prevention (CDC) recommends that those evacuating to public shelters bring at least two cloth face coverings for each person and, if possible, hand sanitizer;
  • Establishing a chain of command and designating emergency functions during a flood or hurricane that should include a list of names, titles, departments, and telephone numbers of employees who can be contacted for additional information or explanations of employee duties under the plan, such as who must remain to continue critical plant operations; and
  • Stockpiling emergency supplies in case workers need to “shelter in place,” having enough food, water, and other supplies for each worker to last at least 72 hours; and
  • Establishing security staff procedures for search-and-rescue tasks until emergency responders arrive, as well as cleanup and recovery procedures regardless of whether recovery and cleanup are performed by contractors or facilities staff.

Working conditions can change drastically due to a hurricane. Workers may be exposed to a new set of hazards, including carbon monoxide, electrical hazards, fallen trees and debris, and mold. Diesel- and gasoline-powered generators should only be used outdoors to prevent exposure to carbon monoxide, a colorless, odorless, poisonous gas. Cleanup crew members should wear protective gloves, along with eye, fall, foot, head, and hearing protection, when using chainsaws and chippers to clear downed trees.

Instruct your workers to keep a safe distance from damaged or downed power lines. Only trained electrical utility workers should perform repairs on damaged or downed power lines.

Excess moisture and standing water following natural disasters such as floods, hurricanes, and tornadoes can contribute to the growth of mold inside buildings. People with allergies, asthma, or other breathing conditions may be especially sensitive to mold.

Wet items and surfaces should be cleaned with detergent and water to prevent mold.

Porous, noncleanable items, including carpeting and carpet padding, ceiling and floor tiles, drywall, insulation, upholstery, and wallpaper, may need to be removed. These items can remain a source of mold growth.

Workers cleaning or removing water-damaged items and surfaces need protective clothing and personal protective equipment (PPE). These include nonporous gloves and protective eyewear, along with N-95 respirators, long pants, long-sleeved shirts, and waterproof boots. Before distributing respirators, workers must be medically evaluated and fit tested for respirator use and trained in respiratory protection.

If the area to be cleaned is larger than 10 square feet, the EPA has specific mold remediation guidelines.

Wildfires

Wildfires can spread quickly, particularly in the dry conditions of the Western United States. Safety hazards, of course, include wildfire smoke inhalation. Last year, California adopted an emergency temporary wildfire smoke standard. The California Division of Occupational Safety and Health (Cal/OSHA) is seeking to establish a permanent wildfire smoke standard.

Under the temporary standard, all employers must protect workers from wildfire smoke when the air quality index (AQI) for airborne particulate matter two and one-half microns or less in width (PM 2.5) is 151 or greater and when employers should reasonably expect that employees could be exposed to wildfire smoke.

Requirements include reducing wildfire smoke exposures by relocating workers to an indoor location with adequate air filtering or an outdoor location where the AQI for PM 2.5 is 150 or lower. Respiratory protection is mandatory if the AQI for PM 2.5 exceeds 500.

OSHA recommends that employers have a wildfire evacuation plan in place before one occurs to help avoid confusion and prevent injuries. An effective evacuation plan should include:

  • Conditions that will activate the plan;
  • Chain of command, defining emergency functions and who will perform them;
  • Specific evacuation procedures, including routes and exits;
  • Procedures for accounting for personnel, customers, and visitors once an evacuation is initiated;
  • Equipment for personnel, and
  • Procedures for training workers and reviewing the plan with workers.

WildfireOSHA also suggests that employers create a safety zone around their businesses, removing combustible material and reducing the volume of vegetation to a minimum within a 30-foot zone of buildings. Employers also should clear branches and shrubs within 15 feet of chimneys or stovepipes and remove vines from the walls of buildings, according to OSHA. Frequently mowing grass or replacing vegetation with less flammable species can provide better protection against spreading wildfires.

In addition to the 30-foot safety zone, OSHA recommends creating an additional secondary 70-foot safety zone, increasing the distance between a building and vegetation to increase the level of protection.

Following a wildfire, workers may be involved in a variety of response and recovery operations, but OSHA cautions employers that some operations, such as cleaning up spills of hazardous materials, search and rescue, and utility restoration, should only be conducted by workers who have the proper equipment, training, and experience.

Hazards for wildland firefighters include carbon monoxide and other respiratory hazards, heat stress, heavy equipment, and unstable structures, along with slips, trips, and falls.

Chemical Plants, Refineries in a Disaster

Chemical facilities must take special steps to prepare for natural disasters. For example,flooding caused by heavy rain from Hurricane Harvey in 2017 disabled a refrigeration system at the Arkema Chemical Plant in Crosby, Texas. The plant manufactures organic peroxides, which are reactive chemicals that are inherently unstable. Failure of the plant’s refrigeration system prompted a weeklong evacuation of more than 200 people living within a 1.5-mile radius of the facility. As the temperature at the plant increased, the peroxides began to spontaneously combust.

The first combustion took place less than 72 hours after flooding began. Two more refrigerated trailers used to store organic peroxide products began to combust days later. A total of 21 emergency responders had to seek medical attention following exposure to smoke from the Arkema Crosby facility.

The U.S. Chemical Safety and Hazard Investigation Board (CSB) issued a safety alert for chemical facilities for the 2020 hurricane season. The CSB recommended that chemical facilities review guidance—“Assessment of and Planning for Natural Hazards”—developed by the Center for Chemical Process Safety (CCPS) in the wake of the incident at the Arkema Crosby facility.

The CSB recommended that chemical plants and oil refineries rely on established start-up procedures and safety systems and check process equipment thoroughly.

Employers also must develop emergency response plans for ongoing operations, as well as seasonal natural disasters. For example, OSHA issued penalties of $128,004 for violations at a Fort Valley, Georgia, farm, including failing to develop an emergency response plan for handling an accidental or uncontrolled release of anhydrous ammonia in an ammonia refrigeration system for fruit storage and water cooling or provide first responder operations training for hazardous materials technicians. The employers also failed to provide an early warning system to detect anhydrous ammonia leaks; develop and implement an emergency response plan; and adequately train workers to respond to a potential release of anhydrous ammonia.

As in the Fort Valley, Georgia, farm example, you must comply with OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120) regardless of whether a release of hazardous substances may be unexpected or there is a substantial risk of one. Employers must prepare emergency response and cleanup workers so that they can act quickly and respond in a safe manner during an emergency.

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