Material Safety Data Requirements for Emergency Planning

Accurate Material Safety Data Sheets (MSDS) need to be available to employees and  potential  responders. There is the potential that the MSDSs will not be useful to local response groups unless they are familiar with the presented information.  Understanding this information will assist responders in assessing hazards assessment for pre-emergency planning or actual response to an emergency.

According to Department of Labor’s Occupational Safety and Health Administration (OSHA)

• The Chemical Sampling Information (CSI) file contains listings for approximately 1500 substances
• The Environmental Protection Agency's (EPA's) Toxic Substance Control Act (TSCA) Chemical Substances Inventory lists information on more than 62,000 chemicals or chemical substances
• Some chemical libraries maintain files of material safety data sheets (MSDS) for more than 100,000 substances.

The number of chemicals is growing on a daily basis. The Chemical Abstract Service (CAS), a division of the American Chemical Society has registered more than 62 million substances. According CAS’s website, “The CAS registry is a collection of disclosed unique organic and inorganic substances, such as alloys, coordination compounds, minerals, mixtures, polymers, and salts, and more than 62 million sequences.”

The Beginning the Hazard Analysis Process, which was originally published as part of the Hazardous Materials Response Handbook (third edition) states, “a first responder might
reasonably be expected to encounter any of 1.5 million of these chemicals in an emergency, with 33,000 to 63,000 of them considered hazardous. To complicate matters, these hazardous chemicals are known by 183,000 different names. Fortunately, not all of these chemicals are equally common.”

OSHA's Hazard Communication Standard (HCS) specifies required information that must be included on MSDSs. The standard states that “chemical manufacturers and importers shall obtain or develop a material safety data sheet for each hazardous chemical they produce or import. Employers shall have a material safety data sheet in the workplace for each hazardous chemical which they use.”

OSHA requires that each MSDS must contain the following sections, written in English:

1. Manufacturer's Name and Contact Information, including emergency numbers and addresses.
2. Hazardous Ingredients/Identity Information, including chemical name, formula, common name, chemical family and associated synonyms. 
3. Physical/Chemical Characteristics, including detailed chemical properties
4. Fire and Explosion Hazard Data
5. Reactivity Data
6. Health Hazard Data
7. Precautions for Safe Handling and Use,  including spill and leak procedures
8. Control Measures, includng special protection information and  precautions

The American National Standards Institute (ANSI) approved an alternative format and published a standard Z400.1-1993, "American National Standard for Hazardous Industrial Chemicals-Material Safety Data Sheets-Preparation."

The following are standards set forth by ANSI. However, OSHA requirements must be included in the MSDS in order to meet compliance requirements.

Section 1. Chemical Product & Company Information
Section. 2. Composition/Information on Ingredients
Section. 3. Hazards Identification
Section. 4. First Aid Measures
Section. 5. Fire Fighting Measures
Section. 6. Accidental Release Measures
Section. 7. Handling and Storage
Section. 8. Exposure Controls/Personal Protection
Section. 9. Physical and Chemical Properties
Section. 10. Stability and Reactivity
Section. 11. Toxicological Information
Section. 12. Ecological Information
Section. 13. Disposal Considerations
Section. 14. Transport Information
Section. 15. Regulatory Information
Section. 16. Other Information

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

 

Hazardous Materials Response Team Training Requirements

A Hazardous Materials (HAZMAT) Response team is comprised of hazardous material experts who specialize in detecting, containing, and removing any release or potential release of hazardous substances in order to control or stabilize an incident. According to the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), a HAZMAT team “is not a fire brigade, nor is a typical fire brigade termed a HAZMAT team. However, a HAZMAT team is often a separate component of a fire brigade or fire department.”

The acronym  HAZMAT refers to any substance (gas, liquid or solid) capable of creating harm to people, the environment, or property. It is often used when discussing the production, transport, use, disposal, cleanup, or emergency response of hazardous materials.

HAZWOPER is one of the training components of a HAZMAT team. The intent of the HAZWOPER standard is to protect workers engaged in "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v)).

According to the HAZMAT Team Planning Guide of the EPA’s Office of Superfund Remediation and Technology Innovation, a HAZMAT Team should be trained to the “Hazardous Materials Technician” level defined by NFPA Standard 472 and HAZWOPER 29 CFR 1910.120.

HAZMAT employees, that may or may not be part of a HAZMAT team, must be trained, at a minimum, in accordance with:

• OSHA, 29 CFR 1910.120(a)(1)(v) Hazardous waste operations and emergency response.
• OSHA Initial training should include Hazard Communication, 29 CFR 1910.1200 requirements (training is part of “Hazard Communication” training or ½ day stand alone)
• PHMSA, 49 CFR §172, Sub part H, Training
• PHMSA, §172.602, Emergency response information

Records need to be maintained for all employees that have been, or will be trained before handling hazardous materials, in accordance with the training requirements set forth in 49 CFR §172.704 and 172.602, and 29 CFR §1910.120 and 1910.1200.

For a free guide that details the world of HAZWOPER training, download A Guide to HAZWOPER Training.

 

Pipeline Safety versus Regulation Overload

On January 3, 2012, President Obama signed the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 into law. The law provides the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) with stronger enforcement tools, doubles maximum fines for safety violations to $2 million, and requires new pipeline safety standards.

Prompted by the deadly 2010 San Bruno, CA gas pipeline explosion that killed 8 people, injured dozens of others and damaged or destroyed more than 100 homes, the new law requires PHMSA to require operators to install automatic or remote-controlled shut-off valves and excess flow valves in new or replaced transmission pipeline.

However, some safety advocates feel the law does not align itself with several key recommendations arising from the 2010 investigations, including stricter leak-detection or integrity management requirements. Additionally, the National Transportation and Safety Board suggested that new automatic valves would be highly beneficial on aging pipelines in highly populated areas. It was stated that the disaster in San Bruno would have been far less devastating if the new valves had been installed. Unfortunately, the cost of replacing valves on existing pipelines is far more expensive than during the initial or replacement phase.

US Transportation Secretary, Ray LaHood stated, “To promote regulatory certainty for the pipeline industry, the new bill prohibits PHMSA during a 2-3 year congressional review period, from issuing regulations establishing leak-detection requirements or expanding integrity management requirements beyond high-consequence areas. However, this restriction would not apply if a condition poses any risk to public safety, property, or the environment.”

According to the PHMSA, The United States currently has approximately 2.3 million miles of pipelines that transport oil, natural gas, and hazardous liquids.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

 

Seven HAZWOPER Training Categories

Employees who may respond to hazardous material emergencies are required by OSHA to have HAZWOPER training.  HAZWOPER, short for the OSHA initiated Hazardous Waste Operations and Emergency Response Standard, communicates the required training associated with operations and potential spills or releases. The intent of the HAZWOPER standard is to protect workers engaged in "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v)).

Paragraph (q) of HAZWOPER lists seven emergency responder training categories that require training under the regulation.

1. Skilled support personnel (q)(4):

• Personnel, not necessarily an employer's own employees, who may temporarily perform immediate emergency support work that cannot reasonably be performed in a timely fashion by an employer's own employees
• Contracted or temporary personnel who will be or may be exposed to the hazards at an emergency response scene
• Require an initial briefing at the site prior to their participation in any emergency response to include:
• Instruction in the wearing of appropriate personal protective equipment
• Chemical hazards involved
• Duties are to be performed
• All other appropriate safety and health precautions provided to the employer's own employees shall be used to assure the safety and health of these personnel.

2. Specialist employees (q)(5):

• Regular job duties include working with and are trained in the hazards of specific hazardous substances
• May be called upon to provide technical advice or assistance at a hazardous substance release incident to the individual in charge
• Receives training or demonstrate competency in the area of their specialization annually.

3. First responder awareness level (q)(6):

• Individuals likely to witness or discover a hazardous substance release
• Trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release.

4. First responder operations level (q)(6):

• Individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release.
• Trained to respond defensively from a safe distance to minimize spreading and prevent exposures, without actually trying to stop the release.

5. HAZMAT technician (q)(6):

• Individuals who respond to releases or potential releases for the purpose of stopping the release.
• Trained to approach the point of release in order to plug, patch or otherwise stop the release of a hazardous substance.

6. HAZMAT specialist (q)(6):

• Individuals who respond with and provide support to hazardous materials technicians.
• Duties, which parallel those of the hazardous materials technician, require a more directed or specific knowledge of the various substances they may be called upon to contain.
• May act as site liaison with Federal, state, local and other government authorities in regards to site activities.

7. On-scene incident commander (q)(6):

• Individuals who will assume control of the incident scene beyond the first responder awareness level.

For a free guide that details the world of HAZWOPER training, download A Guide to HAZWOPER Training.

 

 

Come Rain, Sleet, Snow, or Hail...Are you Prepared for an Emergency?

A few months ago, AccuWeather came out with its long range United States’ forecast through the winter 2011/2012. The prediction was that cold and snowy weather will prevail across a large section of the country. Although snow amounts are predicted to be less than what was experienced last year, ice could be potential problem as far south as Alabama and Georgia. But despite predictions, companies should be prepared to deal with whatever unusual weather events may occur.

Depending on a facility’s specific latitude and longitude, a site-specific risk analysis for severe weather should be conducted for each facility, and plans should be prepared accordingly. Specific weather planning checklists can be developed for blizzards, floods, ice, tornadoes, earthquakes, and hurricanes. Despite the weather situation, many common best practices can be implemented into a weather planning checklist including, but not limited to the following action items:

• Monitor news and weather reports on television or radio (with battery backup)
• Alert personnel  on-site that severe weather is approaching and communicate specific expectations and responsibilities
• Be aware of the site specific dangers posed by wind, ice, snow falling from equipment and buildings, and mediate if possible
• Identify product release dangers posed by heavy snow, flooding, wind, or ice falling on exposed piping

• If applicable, insulate and protect any exterior water lines or piping
• Identify and contract companies to assist in extreme weather events, such as snow, water, or tree removal services
• Obtain basic necessary weather-related equipment (snow shovels, ice scrapers, rock salt, tire chains, backup generators, cooling stations)
• Ensure that vehicles have a full tank of gas and are functioning properly
• Ensure flashlights are in proper working order and have additional batteries on site
• Monitor precipitation accumulation on or around any tanks, sheds or buildings
• If appropriate, leave water taps slightly open so they drip continuously to prevent pipes from freezing
• Identify and understand response techniques when responding to product spills that may flow under ice or snow, or within flood waters
• Establish and maintain communication with onsite and offsite personnel
• Monitor or limit vehicle traffic
• Maintain building temperature at acceptable levels and understand safety measures if using space heaters or generators
• Notify supervisors if a power failure occurs or if a facility is otherwise unable to operate due to weather circumstances

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

 

Biology, Fear, and Emergency Response Planning

Pilots, medical professionals, military personnel, and emergency responders must be prepared to deal with the “fight or flight” biological phenomenon. Competency in emergency response procedures is necessary for those who may encounter hazardous situations in their jobs, in order to avoid the onset of panic in a crisis situation.

Stressful situations activate the body's sympathetic nervous system (SNS) to mobilize hormones that results in increased heart rate and blood pressure, dilated pupils, rapid release of adrenaline, and other effects. Once various hormones reach certain levels, a state of panic can ensue. The parasympathetic nervous system (PSNS) must engage in order to counteract these hormones. In order to maintain or restore a sense of calm, the brain must engage in instinctual, known, and familiar processes.

Emergency procedures need to become second nature in order to combat the natural affects of stress in a crisis situation. Panic can ensue quickly if an individual is not prepared with reactive and effective measures. The four steps in the emergency response planning process identifies way to limit risk prior, during, and after an emergency, thereby making the stress of a crisis manageable to those  trained in the process.

1. Mitigation: Crisis prevention through the identification of structural and non-structural risks can prevent hazards and eliminate or reduce the effects of emergencies or disasters. Once risks are identified, solutions and planning can be implemented to limit effects of a disaster.

2. Preparedness: The ability to provide a rapid and systematic response through established and effective procedures allows employees to react instinctively accordingly to the crisis or emergency. Trained employees are better suited to handle a crisis without panic than those that have no training.

3. Response: The rapid mobilization of emergency response services is imperative to limit the effects and potential chaos of an ongoing disaster. Having a well-rehearsed emergency plan enables efficient and effective response coordination, and reduces loss of property, and impact to the environment and  surrounding community.

4. Recovery: After the threat to human life has passed, the response mode transforms into disaster recovery. Companies should utilize this window of opportunity for mitigation in order to limit future risk.

Of course,  the level of required  training must be consistent with the potential for crisis situations, in order to battle the effects of the Sympathetic Nervous System. However through preparation, knowledge, and proper training, personnel will  likely rely on ingrained instinct rather than be overloaded with emotion in the event of an emergency.

1. “ Brain Activity during a Panic Attack”; http://www.selfgrowth.com/articles/brain_activity_during_a_panic_attack.
2. “How You Learn Physical Skills: instinct, deliberate action, and trained response, human mind affects autonomic system”; http://kschang.hubpages.com/hub/How-You-Learn-Physical-Skills-instinct-deliberate-action-and-trained-response.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

 

SPCC and Oil Contingency Plans

40 CFR Part 112, requires that certain facilities develop and implement oil spill prevention, control, and countermeasure, or SPCC Plans.

SPCC Plans ensure that facilities establish sufficient containment and/or other applicable countermeasures to reduce the potential for oil spills to reach navigable waters. However, oil spills typically result from accidents or human error, which can occur at any place, time, or location. SPCC plans can often be confused with oil spill contingency plans, which typically address response measures after a spill has occurred.

Once a spill occurs, the best approach for containing and controlling the spill is to respond quickly and in a well-organized manner. According to the EPA, a contingency plan "looks at all the possibilities of what could go wrong and, “contingent” upon actual events, has the contacts, resource lists, and strategies to assist in the response to the spill." A spill contingency plan is required as part of the SPCC Plan if a facility is unable to provide adequate secondary containment.

Elements of an SPCC Plan include:

• Professional Engineer Certification
• Discussion of conformance with federal regulations
• Facility description, plot plan, and contacts
• Potential spill volume and flow rates
• Inspections, tests and record keeping processes
• Personnel training requirements
• Loading/Unloading and transfer details
• Discharge prevention measures
• Security Measures
• Recovered material drainage and disposal methods
• Bulk Storage tanks details
• Secondary containment locations and volumes
• Discharge notification information and procedures

Elements of a Contingency Plan include:

1. Hazard identification
1. Types of oils stored
2. Transport details
3. Extreme weather conditions
4. Response equipment and personnel details
2. Vulnerability analysis
1. Identification of resources and communities potentially affected by a spill
3. Risk assessment
1. Comparing the hazard and the vulnerability for a specific site(s) to determine potential controls, prevention, and necessary repairs
4. Response actions
1. Description of actions required in the event of a spill.

Although "prevention is the best medicine", companies should investigate each spill to determine how future occurrences can be eliminated.

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

 

Top Five Reasons to Use Web-Based Business Continuity Plans

In business continuity, the concept of identification of critical business processes and equipment is often discussed. However, the ability to access important documents is often overlooked. Some companies even choose to store emergency response plans in binders. What would you if you experienced a catastrophic loss and could not access these important documents?

Numerous companies that have business continuity plans are evolving from paper-based e plans to web-based planning systems to ensure access to critical information during an  emergency. Disasters and emergencies can instantly eliminate any trace of hard copy plans that are not properly backed-up and accessible off-site. Companies could lose access to the necessary information and tools that enable recovery of critical business processes.

A business continuity plan identifies the critical processes and how to recover these processes following loss of infrastructure. Some of these critical processes rely on specific data. By transitioning from paper-based business continuity plans to a web-based approach, companies have the ability make the plans more accessible to both internal and external stakeholders.

Some benefits of a web-based business continuity system include:

1. Efficiency: Eliminates repetitive updates of duplicate information within  multiple plans.

2. Instantaneous Updates: Revised information is immediately available to all stakeholders.

3. Accessibility of plans: In the event of an emergency, updated paper plans are typically not available from other locations. Although some companies  post electronic plans to their intranet, which  can be accessed remotely, the process of updating these plans is time-consuming and inefficient. In addition, a catastrophic event may render company servers inaccessible.

4. Superior functionality: Web-based plans can provide hyperlinks, forms libraries, simplified interfaces, and other tools designed to improve functionality for plan users.

5. Multi-purpose data: Typically, business continuity plans share common data with emergency response and other plan types. Web-based, database driven plans utilize one database to manage this information, effectively leveraging plan revision efforts to all plans that utilize that data.

For tips and best practices on designing a crisis management program, download Best Practices for Crisis Management.

 

Emergency Management Planning for 2012

2012 offers immense growth in the area of cloud, social, and mobile computing, according to Gartner Inc., a leading information technology research and advisory company.  These methods of information sharing and communications are predicted to have explosive growth and continue to change the way business is conducted. This technological trend of information sharing and rapid communication should be effectively incorporated in the area of Emergency Response, Incident Management, and Planning.

Smart phones, tablets and other devices continue to gain in popularity and use. By embracing the predicted trend, companies can incorporate comprehensive emergency and incident management processes and strategies with an effective stakeholder management system. In the midst of a response, companies need to be able to identify, prioritize, communicate, and engage both responders and stakeholders effectively. Through the use of advancing technology, companies can limit damaging rumors, misinformation, and adverse public perceptions that can result from an emergency or crisis situation.

Within most companies, the transition to cloud, social, and mobile computing will require budget reallocations. According to Garnet's 2012 predictions, monies typically allocated for technology departments may be managed outside the IT budget. Managing VP and Gartner Fellow Daryl Plummer, says that "IT has to change itself to become a broker of services rather than just a provider of technology to their business." It is clear that in order for Emergency managers to keep up with common-place communication methods, EHS budgets need to address how to incorporate cloud, social, and mobile computing into emergency planning and response. Utilizing a designated budget to outsource a consultant that can bridge the knowledge of EHS professionals and Emergency Management requirements with company technology departments may prove to be a more cost efficient and effective method than in-house transitions.

By embracing technology and rapidly changing communications methods, emergency planners can establish enhanced tools and procedures for coordination and communication with responders and stakeholders to effectively manage emergency and crisis situations.

For a sample Emergency Response Checklist, download our helpful and informative guide.

 

Happy Holidays from TRP Corp.

Happy Holidays from the entire TRP Corp team!

And...a wonderful 2012 too!

We hope to continue to provide you with informative and helpful articles in the coming year! Watch for our next blog post on January 5, 2012!