Emergency Response Exercises and HAZWOPER Training

A recently released study entitled Staging and Performing Emergencies: The Role of Exercises in UK Preparedness states that comprehensive exercises are essential for an effective response to various types of emergencies. Just as incidents vary in scale, duration, and complexity, training and response exercises need to be inclusive of site specific threats and risks. Authors Dr Ben Anderson and Dr Peter Adey of the report told  Science Omega magazine that there are three core reasons why exercises are beneficial and increase the likelihood of an effective response.

1. Collaboration Rehearsal: Exercises enable separate organizations to collaborate in a real-world simulation of an incident. Organizations that operate separately on a day-to-day basis must collaborate on procedures that would be necessary in an actual emergency. Dr. Anderson states, “Exercises allow organizations the opportunity to work together, both formally, in terms of enabling various protocols or communication procedures to be used, and informally, in terms of getting to know the organizational culture of other bodies”.
2. Test strategies and plans: Exercises allow the various strategic response components to be tested. Through real-world exercise scenarios, companies can evaluate procedures and plans before the real event.
3. Confirm roles and responsibilities: Exercises reveal response competencies. Employees and responders must have a thorough understanding of required roles and responsibilities in order to react effectively, make timely decisions, and perform appropriate actions within high-pressure emergency situations.

Response plan exercises may incorporate on-site operational responders. The typical staffed operational responder is trained for defensive reactions, not to terminate the release. Their main function is to contain the release from a safe distance, keep it from spreading and prevent exposures. The ability to terminate a release may require a higher level of training.

A response effort by trained emergency personnel or other designated responders (i.e., fire brigade, mutual aid groups, local fire departments), would then go into effect. An event that requires outside emergency assistance can be, but is not limited to, an uncontrolled release of a hazardous material, fire, explosion, and serious injury or illness to personnel where there is a potential risk of exposure to blood borne pathogens.

If a facility has hazardous material on-site, HAZWOPER training may be necessary. The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to specific groups of employers and their employees. Employees who are exposed or potentially exposed to hazardous substances, including hazardous waste, are required to obtain HAZWOPER training.

OHSA mandates that individuals who work in the following areas must complete the standard HAZWOPER training.

• General site workers: Individuals, such as equipment operators, general laborers and supervisory personnel, who are engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health.
• Operations crew: Individuals involved in hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations.
• Emergency response operations team: Those directly involved in responding to the releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.

There are various training levels with HAZWOPER. Training levels should reflect the type of work and the potential hazard involved in the work.

• 40-hour HAZWOPER Training: Those individuals directly involved in the cleaning up of hazardous materials, its storage, or its transportation should take the 40-hour HAZWOPER course. The 40 hour course is required for the safety of workers at uncontrolled hazardous waste sites.
• 24-hour HAZWOPER Training: Appropriate training for those who are less directly involved with uncontrolled hazardous waste sites (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying).
• 8-hour HAZWOPER Training: Managers are required to attain the same level of training (either the 40-hour or 24-hour training) as those they supervise, and an additional 8 hours.

There are numerous sources for OSHA-based HAZWOPER training, from community colleges to private consultants. However, companies must insure that the trainer teaches the required material and provides certification to the students. The certification is assigned to the employee, not the employer. Because of this, individuals must receive the full training mandated, not just those areas that are covered at the current work site.

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

 

General OSHA Work Site Requirements Used in Emergency Planning

OSHA provides the following safety regulations that should be incorporated into an overall emergency preparedness program.  These regulations are aimed at workplace safety and may require the adoption or use of one or more practices, or processes reasonably necessary or appropriate to provide protection on the job.

Below is a list is a common, general OSHA workplace requirements. (NOTE: Site-specific operations may require additional compliance measures per industry regulations.)

Means of Egress

• 29 CFR 1910.36:  This standard establishes requirements for the proper design and construction of permanent exit routes. Requirements cover construction materials, opening dimensions, accessibility conditions, capacity and special considerations for exit routes that are outside of a building.
• 29 CFR 1910.37: This standard establishes requirements for exit route lighting, marking and nonflammable material maintenance. It also sets requirements for employee alarm systems and procedures for working during construction, repair or alteration. Maintaining exit route standards will improve the chances for a successful emergency evacuation. 

Medical and First Aid

• 29 CFR 1910.151: To handle potential workplace injuries, employers must ensure that medical personnel and adequate first aid supplies are available. The selection of these resources must be based on the types of hazards in the workplace. Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

Employee Alarm Systems

• 29 CFR 1910.165: The employee audible or visual alarm system shall provide distinctive warning (for necessary emergency action, as called for in the emergency action plan, or for reaction time for safe escape from the workplace, the immediate work area, or both.

 Fire Prevention Plans

• 29 CFR 1910.39: A fire prevention plan must be in writing, be kept in the workplace, and be made available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees. This plan requires employers to identify flammable and combustible materials stored in the workplace, and ways to control workplace fire hazards. Completing a fire prevention plan and reviewing it with employees reduce the probability that a workplace fire will ignite or spread.

Portable Fire Extinguishers

• 29 CFR 1910.157: Employees who use portable fire extinguishers can often put out small fires or control a fire until additional help arrives. Before an emergency occurs, employers must decide whether employees are authorized (through training) to use fire extinguishers or must immediately evacuate (29 CFR 1910.38). Employers may exempt themselves from most of the portable fire extinguisher requirements if they develop an Emergency Action Plan in compliance with 29 CFR 1910.38.

Fire Brigades

• 29 CFR 1910.156: This section applies to fire brigades, industrial fire departments, and private or contractual type fire departments. It does not apply to airport crash rescue or forest fire fighting operations. When an employer establishes a fire brigade to respond to workplace fires, it must meet organizational, training, and personal protective equipment requirements.

Process Safety Management of Highly Hazardous Chemicals

• 29 CFR 1910.119: This section focuses on preventing or minimizing consequences from a catastrophic release of toxic, reactive, flammable or explosive chemicals. Processes are covered by this standard when they involve quantities of highly hazardous chemicals equal to or greater than those listed in Appendix A, they involve flammable liquid or gas quantities greater than 10,000 pounds, or they involve the manufacture of explosives or pyrotechnics.

Permit-required Confined Spaces

• 29 CFR 1910.146: This standard requires practices and procedures to protect employees working in permit-required confined spaces. The standard requires an evaluation to determine the existence of permit-required confined spaces, the implementation of a written permit space program, and the establishment of rescue and emergency procedures.

Hazard Communication

• 29 CFR 1910.1200: The Hazard Communication Standard is intended to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees. The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets, and employee training.

 

Workplace Emergency Action Plans

The commonplace term “emergency action plan” is widely used by both the private and the public sector.  Specialized emergency action plans used in the public sector may relate to dams, flooding scenarios, educational facilities, severe weather responses, special events, etc. However, the Occupational Health and Safety Administration’s (OSHA) has specialized requirements for the development of site-specific emergency action plans (EAP) for certain employers and their worksites. OSHA requires a verbal or written emergency action plan based on the number of employees that are physically present in a facility at any time of the working day.

The regulation (29 CFR 1910.38), states that employers with 10 or fewer employees do not have to create a written emergency action plan. However, employers are still required by OSHA to communicate an EAP to staff. An emergency action plan must communicate the following minimum requirements:

• Procedures for emergency evacuation, including type of evacuation and exit route assignments (29 CFR 1910.38(c)(2))
• Procedures to be followed by employees who remain to operate critical operations before they evacuate (29 CFR 1910.38(c)(3))
• Procedures to account for all employees after evacuation (29 CFR 1910.38(c)(4))
• Procedures to be followed by employees performing rescue or medical duties (29 CFR 1910.38(c)(5))
• Means of reporting fires or other emergencies (29 CFR 1910.38(c)(1))
• The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.(29 CFR 1910.38(c)(6))

According to OSHA, the purpose of an emergency action plan (EAP) is to facilitate and organize employer and employee actions during workplace emergencies. Preventative emergency measures are necessary to minimize emergencies, however plans should be place to ensure employees’ safety in case an emergency scenario occurs.

An EAP should be part of an overall emergency management program, elevate the state of response awareness, and create an atmosphere of response readiness. Before implementing an emergency action plan, employers must designate and train employees to assist in the safe and orderly emergency evacuation of employees. Employers should also clearly communicate command structure during an emergency to minimize confusion. In order to customize an EAP, employers should include the following:

• Responses to specific potential emergency scenarios
• Communications processes
• Training in emergency action plan specifics
• Floor plans highlighting evacuation routes, emergency exits and fire fighting equipment
• Potentially hazardous features and on-site emergency systems

Specialized industries may require additional planning elements per associated regulations. However, employers should ensure that the emergency action plans address the following OSHA requirements:

Employee alarm system. An employer must have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in 29 CFR 1910.165.

Training: An employer must designate and train employees to assist in a safe and orderly evacuation of other employees. Additional training measures can include:

• Individual roles and responsibilities
• Threats, hazards, and protective actions
• Notification, warning, and communications procedures
• Emergency response procedures
• Evacuation, shelter, and accountability procedures
• Location and use of common emergency equipment
• Emergency shutdown procedures.

Reviews: An employer must review the emergency action plan with each employee covered by the plan:

• When the plan is developed or the employee is assigned initially to a job
• When the employee's responsibilities under the plan change

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

 

Regulatory Compliance Management and the Price of Non-Compliance

The increasing number of stringent regulatory compliance standards compounds the complexity of industrial operations. Most companies believe they have the regulatory compliance component of their business under control. However, agencies such as OSHA, EPA, and DOT, continue to inspect and fine companies for non-compliance for a variety of infractions. 

A bill put forth to Congress entitled “Providing Assistance with the Paperwork from Excessive Regulations Act of 2012” was referred to the Committee on Oversight and Government Reform and the Committee on Small Business. While the bill is aimed at small businesses, the title highlights the “excessive” number of regulations that may be applicable to one facility. 

If government regulations are applicable to operations, companies need to prioritize compliance in order to minimize financial burdens resulting from fines, negative public perceptions, and potential government mandated shutdown of operations. Every month, audits and enforcement mandates are issued from various federal and state agencies that oversee industrial facilities. Costly non-compliance fines continually result from the lack of an implemented, thorough, or effective regulatory compliance programs.

Below are examples of the price of non-compliance for the first eight months of 2012. The list is comprised of a wide array of companies from various regulatory agencies (dates are by citation, not occurrence).

January

• EPA: Collected a penalty of $25,347 from an oil company in Pennsylvania for alleged violations of oil spill prevention regulations at an oil storage facility
• OSHA: Proposed penalties of $148,000 in fines to a chemical company in Nebraska for 25 safety violations, 14 of which relate directly to OSHA's standard regulating the process safety management of highly hazardous chemicals.

Feburary

• DOT: The U.S. Department of Transportation announced it has resolved a record number of enforcement cases against pipeline operators over the last three years
• OSHA: Cited chemical company $ 139,000 for eight repeat and 13 serious safety and health violations at its Delaware facility. Proposed penalties resulted from an inspection that was initiated as part of OSHA's Site-Specific Targeting Program for industries with high injury and illness rates.

March

• EPA: Handed down a $1.2 million civil penalty to a power company for significant violations of the Clean Water Act, Chemical Bulk Storage Regulations, and Navigation Laws. A transformer explosion resulted in thousands of gallons of petroleum entering New York’s Hudson River.

April

• OSHA: Cited an Atlanta based company for three repeat, three serious, and two other-than-serious safety and health violations at one of its plastics manufacturing facility. The proposed penalties totaled $71,000.
• PHMSA: A fine of $251,170 was given to an energy company for serious violations regarding a pump/compressor related equipment failure.

May

• EPA:  An Oregon chemical manufacturer failed to report the use of toxic chemicals at its facility. The violation of the Community Right-To-Know laws resulted in a penalty of $58,200.
• EPA: According to a consent agreement, a frozen foods company will pay over $84,000 to settle hazardous chemical reporting violations at one of its facility.

June

• OSHA: Penalties totaling $199,800 were presented to a vinyl manufacturer for a total of 30 safety and health violations; including three repeat violations for failing to properly ground electrical equipment and a lack of machine guarding.
• EPA: A TSCA complaint resulted in a proposed penalty of $202,779. The complaint alleged that that the company had violated the 2006 IUR rule for 13 chemical substances.

July

• USCG:  Charged an international shipping company $1 million in criminal fines, served probationary status, and required to pay $300,000 to the Department of Wildlife and Fisheries after the Coast Guard inspection revealed undocumented internal transfers and discharges of oily waste into the ocean.
• PHMSA:  Proposed a record $3,699,200 in fines to one company. The agency listed 24 violations of hazardous liquid pipeline regulations, including failure to fix corrosion problems in the damaged pipe joint discovered 10 years prior.

August

• PHMSA: Violations of federal pipeline safety regulations resulted in fines totaling more than $2.4 million for one company. Two employees were killed when pipeline repairs caused leaking crude oil to ignite.
• EPA:  Fined an oil company $15,052 for failing to maintain and fully implement an oil spill prevention plan (SPCC). Negligence contributed to a release of approximately 1,500 gallons of used motor oil from a tanker truck at one facility. As part of the agreement, the company will spend $10,575 to upgrade equipment.

September

• OSHA:  Cited a chemical company for 14 safety and health violations following an inspection. The company faces proposed penalties of $104,000

Effective technology can be inexpensively utilized to monitor continually evolving regulatory requirements. While some companies may use Excel spreadsheets to manage these requirements, this approach is typically burdensome and ineffective. As companies grow and operations grow, spreadsheets can be overwhelming and time consuming. Operators should consider utilizing database technology to ensure enterprise-wide compliance on multiple government agency fronts.

Key concepts for managing regulatory compliance from a corporate perspective include, but are not limited to:

• Database Technology -
• Each applicable regulatory requirement can be hyperlinked to associated site-specific information for each facility.
• A database will minimize task repetition generated when multiple agencies have regulations that are related to the same subject matter.
• Updating evolving regulatory information can be effectively managed across multiple facilities with the use of a central database.
• The ability to search a database for key words and phrases associated with regulations will minimize maintenance time.

• Compliance Consultations - Identify and utilize corporate resources or outsource compliance expertise to minimize the uncertainty of evolving regulations.
• Facility-Specific Regulations - Identify mandatory operational and submission requirements for each facility associated with each regulatory agency.
• Tasking - Assign compliance tasks, frequencies, due dates, persons responsible, and document completion actions.
• Identify Best Practices - Apply best practices and potential mitigation measures related to compliance.

Regulatory non-compliance has proven to be expensive, time consuming, and potentially dangerous to company employees and the surrounding communities. An effective compliance management process can result in an efficient and integrated program that optimizes the efforts of company stakeholders, and improves compliance.

 

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

 

Integrated Contingency Plan - The "One Plan" for Regulatory Agencies

In 1996, the National Response Team published the Integrated Contingency Plan (ICP) Guidance in an effort to provide facilities with the means to comply with multiple federal planning requirements required by various regulatory agencies by consolidating them into one emergency response plan. 

By creating a single comprehensive integrated contingency plan, emergency managers can;

• reduce the need for multiple plans
• minimize administrative costs
• simplify plan reviews
• minimize discrepancies across various plans
• streamline response directives from one source

An ICP does not exempt facilities from applicable regulatory planning requirements pertinent to releases of oil and non-hazardous substances. Multiple federal agencies endorse the use of an ICP as a means to incorporate statutes and regulations, include requirements for emergency response planning. A particular facility may use an ICP to incorporate one or more of the following applicable federal regulations:

• EPA
• Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements), 40 CFR part 112.7(d) and 112.20-.21
• Resource Conservation and Recovery Act Contingency Planning Requirements, 40 CFR part 264, Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52.
• Risk Management Programs Regulation, 40 CFR part 68

• Department of Transportation/Pipeline and Hazardous Materials Safety Administration
• RSPA Pipeline Response Plan Regulation, 49 CFR part 194
• US Coast Guard, Facility Response Plan Regulation, 33 CFR part 154, Subpart F

• Occupation Safety and Health Administration (OSHA)
• Emergency Action Plan Regulation, 29 CFR 1910.38(a)
• OSHA's Process Safety Standard, 29 CFR 1910.119
• OSHA's HAZWOPER Regulation, 29 CFR 1910.120

Facilities may also be subject to state emergency response planning requirements that is not included in the National Response Team ICP Guidance. Facilities are encouraged to coordinate development of their ICP with relevant state and local agencies to ensure compliance with any additional regulatory requirements.

National Response Team is composed of 16 Federal agencies having major responsibilities in environmental, transportation, emergency management, worker safety, and public health areas is the national body responsible for coordinating Federal planning, preparedness, and response actions related to oil discharges and hazardous substance releases

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

 

OSHA Tank Fire Prevention - Hot Work Mitigation Measures

Two contractors were welding atop a 10,000-gallon slurry tank when hot sparks ignited flammable vapors inside the tank, causing an explosion that killed one contractor and seriously injured another. The Chemical Safety Board (CSB) determined that the November 9, 2010 incident was caused by the increased temperature of the metal tank, sparks falling into the tank, or vapor wafting from the tank into the hot work area.

As a result, the CSB set forth new recommendations regarding “hot work”, which is defined as welding, cutting, grinding, or other spark-producing activities. Recommendations include:

• Enforce safety procedures for hot work permits and ensure explosion hazards associated with hot work activity are recognized and mitigated.
• Revise corporate procedures to require all process piping and vent piping be positively isolated before authorizing any hot work.
• Require air monitoring for flammable vapor inside tanks and other containers where hot work is to be performed.

Advanced planning, safe work procedures, and mitigation measures can help prevent tank fires and explosions caused by hot works activities. The Occupational Safety and Health Standard (OSHA), 1910.252(a)(3)(i), states that “No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers until they have been cleaned so thoroughly as to make absolutely certain that there are no flammable materials present or any substances such as greases, tars, acids, or other materials which when subjected to heat, might produce flammable or toxic vapors. Any pipe lines or connections to the drum or vessel shall be disconnected or blanked.”

According to OSHA, possible mitigation measures for hot work include:

• Perform hot work in a safe location, or with fire hazards removed or covered
• Use guards to confine the heat, sparks, and slag, and to protect the immovable fire hazards.
• Do not perform hot work where flammable vapors or combustible materials exist. Work and equipment should be relocated outside of the hazardous areas, when possible.
• Make suitable fire-extinguishing equipment immediately available. Such equipment may consist of pails of water, buckets of sand, hose, or portable extinguishers.
• Assign additional personnel (fire watch) to guard against fire while hot work is being performed. Fire watchers are required whenever welding or cutting is performed in locations where anything greater than a minor fire might develop
• Monitor the atmosphere with a gas detector. If a flammable or combustible gas exceeds 10 percent of the lower explosive level (LEL), the work must be stopped. Identify the source of the gas and repair the leakage.

Although mitigation measures can limit the potential for hot work accidents, companies should create a fire pre-plan to reduce response times and improve the effectiveness of a response in the event of a fire.

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

 

Emergency Planning for Key Regulatory Agencies

In today’s environment, government regulators have much more scrutiny of  emergency  response planning for industrial facilities. The most widely applicable regulations are those under the realm of the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA). Additional agency regulations, such as those mandated by the Department of Transportation’s PHMSA or the Department of Homeland Security may apply to specialized types or locations of facilities, but EPA and OSHA regulations pertain to most industrial sites. By ensuring the EPA and OSHA requirements are met, shared information can be used to comply with additional requirements.

EPA:

• Facility Response Plan (FRP) -  Requires an owner or operator of a facility that could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines to prepare and submit a facility response plan.
• Resource Conservation and Recovery Act (RCRA) - The primary governing law that oversees the generation and containment of solid and hazardous waste.
• Spill Prevention Control and Countermeasure Plans (SPCC) – Requires developing site specific plans for oil storage facilities that describe spill prevention and response procedures.  .
• National Pollutant Discharge Elimination System (NPDES) - Permitting program designed to control water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.
• Emergency Planning and Community Right to Know (EPCRA) - Establishes requirements for federal, state and local governments, Indian tribes, and industry regarding emergency planning and "Community Right-to-Know" reporting on hazardous and toxic chemicals to enable a more effective emergency response planning process.

OSHA:

• Emergency Action Plan (29 CFR 1910.38(a)) - and Fire Prevention Plans (29 CFR 1910.38) - Requires plans to facilitate and organize employer and employee actions during workplace emergencies. A written plan is required for facilities that have at least ten employees that are present at a facility at any time.
• Hazard Communication  (29 CFR1910.1200) – Requires communication of information to employees who may be exposed to hazardous chemicals in the workplace.
• Hazardous Waste Operations and Emergency Response (29 CFR 1910.120) - Requires protecting 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. It applies to all employers who have their employees respond to an emergency situation where a hazardous substance may exist.
• Process Safety Management (29 CFR 1910.119) - Identifies procedures for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.

Implementing a regulatory tracking management system can eliminate redundancies across converging compliance specifications. It can be extremely beneficial and time saving for organizations that have multiple applicable regulatory requirements.

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

 

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.

 

FEMA's Plan for the Future - Strategic Foresight Initiative

The Federal Emergency Management Administration (FEMA) released the Strategic Foresight Initiative in hopes to assist the emergency management profession better plan for the future.

The Strategic Foresight Initiative, derived from over 500 members of the emergency response community, addresses nine areas that will affect the future of emergency management:

1. Changing role of the individual in disaster preparedness
- Increased empowerment of the individual through availability of information
- Lack of trust in government authorities
- Changing definition of community from the traditional geographic community to a virtual community

2. Climate change
- Heightened weather patterns (ex: more flooding rains, intense storms, droughts)

3. Critical infrastructure
- Aging transportation, communication, energy, and health care infrastructure may create additional emergency situations

4. Evolving terrorist threat
- Availability of technical and scientific knowledge may increase terrorist access to “high consequence” weapons

5. Global interdependency
- Emergency managers may take on greater role in Emergency Management internationally
- A more global role for American emergency managers could have major resource and capability implications

6. Technological innovation and dependency
- Our communications, energy, and transportation infrastructure are all heavily dependent on technology
- This dependency creates a significant vulnerability to cyber-attack, particularly if our reliance creates single points of failure within our systems

7. Universal access to and use of information
- Access to real time information will continue to increase as social media and advances in technology create new patterns of communications
- Citizens are becoming both producers and consumers of information
- Legitimacy and accuracy of information must constantly be questioned and verified

8. U.S. demographic shifts
- Potential increasing populations, ethnic diversity, and larger percentage of senior citizens will create additional planning challenges

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

 

OSHA's Interpretation for Fire Emergency Planning

According to the Occupational Safety and Health Administration (OSHA), regulations mandate the minimum number of workers required for operations in environments that are immediately dangerous to life and health (IDLH). These minimum personnel requirements numbers should be reflected in fire emergency planning and training.

Numerous standards apply, and should be reviewed for employees who work in IDLH conditions. OSHA refers to the following standards:

1. Hazardous Waste Operations and Emergency Response (HAZWOPER), 29 CFR 1910.120

HAZWOPER requires that operations in hazardous areas shall be performed using the buddy system in groups of two or more. (1910.120(q)(3)(v)).  In addition, paragraph 1910.120(q)(3)(vi) states that "back up personnel (at least two or more) shall stand by with equipment ready to provide assistance or rescue." Thus, there must be at least four individuals at the site. One of the two individuals outside the hazard area can be assigned to another task, provided that the second assignment does not interfere with the performance of the standby role.

HAZWOPER standard defines the buddy system and IDLH as follows:

Buddy system means a system of organizing employees into work groups in such a manner that each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency.

IDLH or Immediately dangerous to life or health means an atmospheric concentration of any toxic, corrosive or asphyxiant substance that poses an immediate threat to life or would cause irreversible or delayed adverse health effects or would interfere with an individual's ability to escape from a dangerous atmosphere.

2. Fire Brigades, 29 CFR 1910.156 and Respiratory Protection, 29 CFR 1910.134

The Fire Brigade regulation covers emergency operations involving interior structural fire fighting. According to OSHA, it is universally recognized that conditions present during an advanced interior structural fire create an IDLH. Because fire brigades vary in type, function and size, the OSHA requirements are performance oriented to provide enough flexibility for the employer to organize a fire brigade which best reflects the needs of the workplace. The Fire Brigade regulation does not directly address the minimum number of fire fighters required when engaged in operations presenting an IDLH atmosphere. However, the Respiratory Protection standard states that failure to have four employees at an interior structural fire, would be a violation of 1910.134(g)(4).

3. NFPA Standards: 1500-1992, Fire Department Occupational Safety and Health Program and 600-1992, Standard on Industrial Fire Brigades

Amendment 6-4.1.1 of the NFPA 1500-1992 states: "At least four members shall be assembled before initiating interior fire fighting operations at a working structural fire."

A working structural fire is defined as follows: Any fire that requires the use of a 1 and 1/2 inch or larger fire attack hose line and that also requires tee use of self-contained breathing apparatus for members entering the hazardous area."

OSHA states that the terms interior structural fire fighting and working structural fire are similar in nature. Consequently, four persons (two inside and two outside), each with protective clothing and respiratory protection are essential for the safety of those performing this work inside a structure.

Chapter 5-3.5 of the NFPA 600-1992, specifies requirements for the number of members to be involved at the scene. Requirements in chapter 5-3.5 are similar to those in NFPA 1500-1992, Sections 6-4.3 and 6-4.4, and states a minimum of four members on the scene before beginning to fight interior structural fires: two inside as a team, operating in the hazardous area; two outside the hazardous area, where one is standing by and another may be performing another function, such as managing the incident, as long as its performance does not interfere with the second outside person's ability to assist in the event of an emergency.

NOTE: This standard does not address the number of persons necessary to staff a fire apparatus leaving a station before on-scene evaluation has occurred. That is a matter to be determined by each local fire fighting unit.

4. Section 5(a)(1) of the Occupational Safety and Health Act of 1970 which is intended to apply to operations where IDLH conditions exist or potentially exist in the following situations:

a.     Emergency response to uncontrolled releases of a hazardous substance or substances;
b.     Emergency operations covering interior structural fire fighting.

Any citation or Section 5(a)(1) must meet the requirements outlined in the Field Inspection Reference Manual (FIRM), Chapter III, and may be issued where there is a hazard which cannot be abated by compliance with a specific OSHA standard.

The NFPA national consensus standards serves as guidance as to what is generally recognized as hazardous in the industry.  Therefore, a citation for violation of the General Duty Clause shall be issued when it is documented that only one person conducted interior structural fire fighting operations or when less than two persons were standing by when interior structural fire fighting operations were being conducted. A Section 5(a)(1) citation may not be issued for incipient stage interior fires or for exterior fire fighting operations conducted during advanced interior structural fires.

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