Hazardous materials become most hazardous when they are released. The potential risks associated with hazardous material releases heighten the need for risk-based decision making. As a result, hazardous material incident management should reflect site specific planning, training, and exercises that minimize hazardous material impacts and restrict potential chaos.
- Response plans should clearly dictate processes and procedures that minimize hazardous material impacts.
- Training must be aligned with response roles and responsibilities, facility operations, and regulatory requirements. (see Hazard Communication Standard - 29 CFR1910.1200)
- Exercises should include hazardous material release scenarios that allow response team members to collaborate and communicate assigned roles, responsibilities, and required actions in response to one or more site specific scenarios.
“Hazardous Materials” is a general term intended to mean hazardous substances, pollutants, and contaminants as defined by the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The term includes blood borne pathogens and infectious disease as defined by OSHA's Blood borne Pathogens Standard (29 CFR 1910.1030).
The potential for harm to individuals, the environment, or the facility may be escalated due to the release of certain hazardous materials. However, expedient and safe cleanup operations can minimize exposures and limit the impact of an incident. Hazardous substance releases must be removed, contained, incinerated, neutralized, or stabilized with the ultimate goal of making the site safer for people or the environment.
Identifying the potential threats and probable incident scenarios enables proper pre-planning. Response procedures and processes can be incorporated into the site-specific plans to proactively facilitate corrective actions in the event of a hazardous release. The following hazardous material incident management concepts should be considered and incorporated in planning, training, and exercising a response:
- Proper PPE for employees, contractors, and responders
- Specific waste handling procedures and, if applicable, appropriate contractors
- Disposal plan in accordance with any federal, state, and/or local regulations
- Facility-specific disposal locations for different types of materials
- Continuous tracking of hazardous materials quantities to better estimate amount of waste generated
- Methods and procedures for waste collection, segregation, storage, transportation, and proper disposal
- Regulatory review of applicable laws to ensure compliance and appropriate permitting
- Documentation of all waste handling and disposal activities
From the onset of an incident involving hazardous materials, incident managers should establish specific, measurable objectives for functional response activities. Incident Action Plans (IAPs) are used to guide hazardous response activities and provide a concise means of capturing and communicating the incident manager’s priorities, objectives, strategies, protocol, and tactics for both operational and support activities.
The incident manager must manage all resources, both internal and external. Unless, a facility has a dedicated, trained, and certified response team, external responders should be identified for hazardous material response operations support. However, the incident manager must maintain clear communication of response objectives as to eliminate confusion caused by multiple, conflicting directives and authorities.
The level of detail required in IAPs varies with each scenario. However, plans should facilitate the sharing of critical incident status information. Because hazardous material incident parameters may continually evolve, IAPs must be revised on a regular basis (at least once per operational period) to maintain consistent, up-to-date guidance for incoming responders or management.
At each phase of a response, the incident manager should perform critical assessments and specify clear operational objectives to responsible parties, eliminating potential confusion caused by multiple, conflicting directives and authorities. Through proper preparedness planning and cleanup and disposal procedures, hazardous material management planning can limit environmental liability, and as an effect, minimize additional immediate and long-term financial burdens.