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Emergency Planning for Key Regulatory Agencies

Posted on Mon, Jun 04, 2012

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.

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Tags: OSHA HAZWOPER, OSHA, EPA, Oil Spill, Regulatory Compliance