Scared Straight: The Frightening Prospect of Mismanaging a Chemical Emergency

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

dgraham@triumvirate.com

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?