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Optimize Industrial Chemical Safety with Post Incident Reviews

Posted on Thu, Mar 24, 2016

Chemical plants and other industrial facilities have site-specific, innate hazards that present unique preparedness and incident response challenges. Immediately after a planned exercise or an unforeseen emergency response, it is critical to conduct post incident reviews, gather insights from participants and witnesses, and identify lessons learned. Incidents and flawed response processes should be utilized to catapult new findings into emergency plans, incorporate new response measures into exercise simulations, and alter training needs as necessary. As a result, lessons learned can be implemented and preparedness improvement work can begin.

Timing of a post-incident review is critical. Response and preparedness discussions should take place while the incident, emergency, or exercise is fresh in the minds of decision makers, responders, regulators, and the public. The following five post incident/emergency management concepts should be presented and thoroughly examined for lesson learned preparedness opportunities.

  1. Unidentified potential risk or hazard: A hazard and vulnerability analysis should be performed, and processes and procedures should be developed and added to the plans.
  2. Management gaps and weaknesses: If the post incident reviews revealed weaknesses or gaps in the organization, the emergency response management structure should be modified and emergency plans revised.
  3. Ineffective policies and procedures: If the policies and procedures fail to address key issues during the incident, policies and procedures need to be modified to address inadequacies.
  4. Lack of response proficiency: If response was faulty due to deficient training, exercising, or planning, these efforts should be amplified and personnel should be familiarized with these modifications.
  5. Planning deviations: If participants successfully diverged from existing processes, procedures, or plans, these areas should be modified to reflect the reality of the performance.

By conducting a post incident critique with employees and responders, managers can evaluate the effectiveness of the response and identify areas that need improvement. Ideally, the incident critique should be moderated by personnel who are:

  • Experienced and knowledgeable in emergency response.
  • Not directly involved in the actual incident.

The following general guideline questions can be used as a starting point for conducting a post incident critique with employees and responders. Specific questioning should be determined by site-specific parameters.

Incident Detection

  • Was the incident detected promptly?
  • How was it detected?
  • By whom?
  • Could it have been detected earlier? How?
  • Were there any additional circumstances that inhibited detection (ex. time of day, noise, severe weather)?
  • Are any instruments or procedures available which may aid in earlier detection?

Notifications

  • Were notifications performed in a predictable time frame?
  • Were personnel notified promptly?
  • Do additional individuals need to be notified? How, and why?
  • Were contacts and contact numbers up to date?
  • Were management notification procedures effective and timely enough to promote effective and actionable responses?
  • Were proper procedures in place and followed in notifying government agencies?

Assessment/Evaluation

  • Was the magnitude of the incident assessed correctly from the start?
  • What means were used for this assessment?
  • What references were used to assist in incident evaluations and statuses?
  • Were environments sources available regarding severe weather, winds, water currents, and/or other variables?
Response Mobilization
  • Was the response plan utilized in effectively mobilizing countermeasures to the incident?
  • If the response plan was not used, what steps were taken to mobilize countermeasures?
  • Were response plans accessible?
  • Was mobilization prompt?
  • Could the response time improve? How?
  • How were resources mobilization and were they effective?
  • Were additional resources were used outside those listed the response plan? Why?
  • Was it appropriate to mobilize company resources and was this promptly initiated?
  • What other company resources are available and have they been identified and used adequately?

Response Strategy

  • Was the initial strategy for response to this incident effective? If not, what needed to be adjusted?
  • Was the response strategy flexible enough to cope with unexpected events?
  • Was there a response plan available to key individuals for reference?
  • Does the plan include clear directions regarding local environmental, economical, or human sensitivities? Do updates need to be addressed?
  • How did changes in strategy evolve during the emergency and how were these changes implemented?

TRP Corp Emergency Response Planning Exercises

Tags: Chemical Industry

Chemical Plant Response Training and Exercises

Posted on Thu, Feb 04, 2016

Chemical plants present unique preparedness and incident response readiness challenges. When all potential hazards are analyzed and evaluated according to their likelihood of causing injury, damage, and severity of the impact, a regulatory compliant, effective, and site specific training and exercise program should be implemented.

Chemical plants are required to conduct and document response training and exercises to satisfy certain EPA and OSHA regulations. The objective of safety and response plan training and exercises is to promote a safe work environment, instill specialized response skills, and improve overall preparedness. Although training and exercises are often considered separate components, these coordinated methods blend to optimize safety and preparedness objectives.

Training: An individual instructional component or instructor-led classroom-based activity with a focus on individual knowledge development sufficient to perform specific roles and undertake prescribed responsibilities.

Exercise: The activity of practicing roles, responsibilities, and/or procedures with a focus on development of individual skills and/or to test and identify deficiencies in plans and procedures.

Chemical plant emergency managers should aim to create an efficient method to track individual training needs and identify team members’ current qualifications. Through proper maintenance of a training portal, individuals will remain at peak optimal response capabilities. Training should include, but not be limited to:

  • Familiarization with Response Plan
  • Individual roles and responsibilities.
  • Plan review training whenever a substantial change or revision is made to the plan that affects organization, procedures, roles and responsibilities, or response capability.
  • Refresher courses, as necessary

OSHA’s HAZWOPER training for general employee may range from “first responder awareness level” to the “hazardous material specialist” level. Each chemical plant under a corporate umbrella may require further specialized training depending on the current operations, unique hazards, location, and associated regulations.

The goal of the exercise program should be to improve the overall readiness and capabilities of emergency response program that encourages:

  • Realistic scenarios
  • Proper training validation
  • Effective emergency plans
  • Identification of action items
  • Operational response capabilities
  • Preparedness to respond to incidents, regardless of the threat or hazard.

To ensure chemical plant employees and response personnel are prepared to respond to an incident in an efficient and effective manner, exercise guidelines should be established as minimum requirements within an emergency preparedness program. Management should ensure that:

  • All aspects of response plans are fully exercised annually (at a minimum) with participation of the appropriate response, incident management, and support teams.
  • Each response plan component is exercised at more frequent intervals, as appropriate, to prepare for the main annual exercise.
  • Notification exercises for each team and response component are verified and practiced at least twice per year. This exercise should involve unannounced checks of the communication procedures, equipment, and contact information.
  • National and local training and exercise requirements should be used to assess the overall preparedness of your response teams.

Companies often utilize the following range of exercise activities in planning and executing their program:

Level 1 Tabletop Exercises: Useful for considering policy issues, and for building team relationships in a low stress environment.
Level 2 Mobilization and/or Notification Exercise: Used to validate mobilization and response times, and verify internal/external notifications and contact information.
Level 3 Limited Exercises: Used to validate mobilization and response capabilities of specific team functions, and the status of integration and coordination among these groups and other company-based response organizations.
Level 4 Full Scale Exercise: Full-scale exercises offer comprehensive validation of current emergency and crisis management system, and should demonstrate a degree of response integration throughout the system.

TRP Corp Emergency Response Planning Exercises

Tags: Training and Exercises, Chemical Industry

The Importance of Response Plan Training for the First Responder

Posted on Thu, Jan 22, 2015

Any employee has the potential to be put in a first responder role in the event of an emergency at the office, jobsite, or facility.  As a result, all employees should be trained in response measures appropriate for site-specific vulnerabilities and identified risks. The rapid mobilization and proficiency of initial actions, as well as response procedure familiarity is essential in order to minimize potential chaos, scenario consequences, and plausible chain-reaction events.

In order to avoid the onset of panic or prolong emergency circumstances, necessary and effective reactive measures should become second nature to any potential initial responder. Familiarity through training and exercises can combat the natural effects of stress in tense situations. Having a well-rehearsed emergency plan enables efficient and effective response coordination, reduces losses, and can limit the impact to employees, the environment, and surrounding community.

Efforts must be made to train non-response team members in initial response actions and the appropriate initiation procedures. Any employee or contractor, upon discovering a significant event or condition that requires urgent response from outside trained personnel, should be trained to take the suggested initial response actions listed below:

Initial Response Actions:

  1. Warn others in the immediate area through verbal communication and/or activate local alarms.

  2. Take immediate personal protective measures (PPE, move to safe location, etc.).

  3. Report the emergency to Security or 9-1-1, depending on company policy.

  4. Implement local response actions (process shutdowns, activate fire protection systems, etc.) if safe to do so, and consistent with level of training and area specific procedures.

Industrial facility employees often encounter unique, site-specific hazards, and potential threats, unlike those in other fields. Specialized training must complement response team roles and responsibilities in order to address these specific vulnerabilities and risks. But despite an industrial setting, not all employees will be assigned to a formal response team.

Employees who may be exposed to hazardous substances are required to be HAZWOPER certified. HAZWOPER, an acronym for the Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Standard, communicates the required training that addresses hazardous 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)).  However, this does not mean that all HAZWOPER certified employees are responsible for terminating a release. According to the standard, the following first responder levels are not trained to terminate a hazardous incident.

The Awareness Level:  According to OSHA, the first responders at the “awareness level” must demonstrate competency in areas such as recognizing the presence of hazardous materials in an emergency, the risks involved, and the role they play in their employer’s plan.

Who should be trained? This level is applicable for persons who, in the course of their normal duties, could be the first on the scene of an emergency involving hazardous material. Responders at the awareness level are expected to recognize the presence of hazardous materials, protect themselves, call for trained personnel, and secure the area without engagement.

Individual companies can set their own hourly training requirements; however, employees must be capable of demonstrating the following:

  • What hazardous substances are, and associated risks during an incident

  • The potential outcomes associated with an emergency when hazardous substances are present

  • Ability to recognize the presence of hazardous substances in an emergency

  • Ability to identify the hazardous substances, if possible

  • The role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook

  • Ability to realize the need to make appropriate notifications for additional resources

The Operations Level: Operations level responders meet and exceed the competency level of the awareness responder. Operational responders are trained to respond in a defensive fashion without actually trying to terminate the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.

Who should be trained? These responders are part of the initial response for the purpose of protecting nearby persons, the environment, and/or property from the effects of the release.   Operations may receive additional training in HAZMAT/CBRNE defensive techniques of absorption, damming and diking, diverting, retention, vapor dispersion and suppression. They may also be trained in basic decontamination procedures and PPE.

First responders at the operational level should complete the 8-hour HAZWOPER training course or have had sufficient experience to objectively demonstrate competency in the following areas:

  • Basic hazard and risk assessment techniques

  • How to select and use proper personal protective equipment

  • Basic hazardous materials terms

  • How to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit

  • How to implement basic decontamination procedures

  • The relevant standard operating procedures and termination procedures

For a free download on conducting an effective exercise, click here or the image below.

TRP Corp Emergency Response Planning Exercises

Tags: OSHA HAZWOPER, Facility Response Plan, Response Plans, Facility Management, Disaster Response, Workplace Safety, Chemical Industry, HSE Program

Expert Tactical Response Plan Tips for Oil and Gas Companies

Posted on Thu, Jun 05, 2014

Maintaining accurate and effective response plans requires due diligence. In the oil and gas industry, response planning for a dynamic worst-case scenario with multiple moving parts and various potential trajectories is an ongoing, yet required challenge. However, utilizing web-based, database driven, standardized tactical plan template enables emergency managers to plan for numerous potential impact zones across vastly diverse terrains with multitudes response obstacles. The hazardous nature of the material spilled, the number of responders involved, and the probable impacts requires a pre-planned, coordinated, and swift response effort. A web-based template format allows secured access for various stakeholders, despite their location, maximizing the planning effort for an effective response.  

Tactical response plans contain numerous geographical fixed response actions for the various off-site tracts in the path of an oil spill. These planning tools assist in the implementation of an overall response strategy by minimizing the potential travel distance of a spill.  The tactical planning process identifies the “how” a downstream response will be implemented at a specific location. When spills migrate off site, it is essential to have plans in place that have been developed in cooperation with those in the potential path of a spill. Communication with downstream counterparts lessens spill response anxieties and promotes company/community partnerships.

Through the planning process, information necessary to achieve a successful response is gathered at each downstream response location. The primary objectives of tactical response plans are to:

  • Allow response personnel to prepare for and safely respond to spill incidents
  • Ensure an effective and efficient response despite geographical challenges
  • Identify potential equipment, manpower, and other resources necessary to implement a spill response
  • Outline response procedures and techniques for combating the spill at a specific location
  • Improve regulatory compliance efforts

Because a single oil spill can have a significant or catastrophic impact on downstream environments, it is imperative for emergency managers to cyclically evaluate response processes and maintain the most up-to-date plan possible. Off-site spill responses and containment efforts present unique challenges compared with those within the confines of a specific facility or secondary containment. Downstream spills require a higher level of coordination and communication in effort to minimize impending impacts. Those challenges include, but are not limited to:

  • Response time must be minimal due to spill flow rate and travel distances
  • Potential substantial equipment deployment
  • Waterway access points
  • Coordination and cooperation efforts with private landowners
  • Consequential costs associated with long-term cleanup activities
  • Extensive damage to marine and wildlife habitats, fishing, and/or tourism industries
  • Potential lawsuits

In the event of an emergency, updated paper plans are typically not available from all downstream locations. Web-based planning system software increases accessibility options while improving efficiency, functionality, and effectiveness. A standardized, enterprise-wide, yet customizable tactical plan template provides necessary data for each response site.  The systematic tactical response plan format should consist of customary response policies and procedures, as well as detailed, site-specific data necessary for an effective response.

Web-based tactical plans can provide a responder’s perspective of specific short-term actions and details that communicate best site access, assessment tools, and response measures. Tactical spill plans should include the following:

  • Various photographs of each segment (including ground and aerial views, if possible)
  • Maps
  • Latitude and Longitude
  • Land/property owner information
  • Driving directions to the site from main roads
  • Description of potential staging area(s)
  • Specific response tactics for the site location
  • Description of site and applicable waterways
  • Site access specifications
  • Necessary security requirements
  • Waterway flow rates and composition
  • Any critical response information that may be informative to responders
  • Recommended equipment and personnel to implement response strategy
  • Other site specific pertinent issues that may hinder a response

 

Challenged with managing preparedness amongst your various facilites? Download TRP's best practices guide on response planning for large organizations with multi-facility operations.

Multiple Facility Response Planning Company Preparedness Guide DOWNLOAD

Tags: Emergency Preparedness, Response Plans, Oil Spill, Chemical Industry

Best Practices of Stormwater Pollution Prevention Planning and the SWPPP

Posted on Mon, Nov 25, 2013

The purpose of a Stormwater Pollution Prevention Plan (SWPPP) is to identify potential stormwater pollution sources and guide facilities to reduce the potential for pollutants reaching nearby waterways.  Establishing procedures and controls is necessary to accomplish the following SWPPP objectives:

  1. Identify pollutants that may come in contact with stormwater.
  2. Establish measures to prevent pollutants from interacting with stormwater
  3. Establish controls to reduce or eliminate the potential for contaminated storm water being released to the environment.

The Environmental Protection Agency (EPA) defines control measures as “any Best Management Practice (BMP) or other method used to prevent or reduce the discharge of pollutants.” The SWPPP requires that companies identify and document which BMPs will be installed at the facilities. BMPs may include:

  • Schedules of implementation activities
  • Prohibited practices
  • Other management practices
  • Treatment requirements
  • Operating procedures
  • Practices to control industrial stormwater runoff, spillage or leaks, sludge, waste disposal or drainage from raw material storage.

Facilities are not required to have structural best management practices implemented prior to a permit application for permit coverage.  According to the requirements, a facility has one year from the time of submitting a permit application to implement structural best practices. However, the EPA recommends installing structural best management practices as soon as possible.

There are 3 main categories of BMPs. These include:

  • Non-structural BMPs: examples include, but are not limited to:
    • Optimize maintenance practices
    • Control spills and leaks
    • Manage wastes
    • Employee training programs
    • Optimize procedures and operations
  • Simple structural BMPs: examples include, but are not limited to:
    • Move significant materials and activities under cover
    • Store materials in weatherproof containers, shelters, or dumpsters
    • Use temporary shelters, like tarps, on a short-term basis only until permanent structures can be installed
  • Complex structural BMPs: examples include, but are not limited to:
    • Cover materials or operations with canopy or awning type structures
    • Provide curb or slopes designed to prevent stormwater run-on or runoff
    • Create stormwater ponds, sedimentary or wetland treatment systems

The following questions can assist in the evaluation of potential BMPs and implementation:

  • Are the BMPs appropriate for my facility size/industrial activity/significant material?
  • Are the BMPs the most cost effective to install?
  • Is there another BMP that is simpler/more cost-effective that achieves SWPPP goals?
  • Does the BMP require maintenance and is there adequate staffing for required activities?
  • Can BMPs prevent precipitation from coming in contact with operations and/or significant material?
  • Does the facility meet the criteria for ”No Exposure Exclusion”?

The content of the SWPPP will vary depending on site-specific conditions. According to The State of Washington’s Department of Ecology, the following BMPs common in SWPPPs:

Covered Storage:  Chemicals stored outside should be covered so that rainfall does not become contaminated by contact with the chemical containers. The SWPPP should include this as a standard practice at the facility and a map should identify the covered storage areas.

Equipment Maintenance:  The SWPPP should identify equipment that can spill or leak contaminants, such as petroleum products. Provide an inspection and maintenance schedule for each piece of equipment that is identified.

Employee Training:  The first line of defense will often be an onsite employee. With proper training, facility personnel can properly manage stormwater and protect it from contamination.

Site Maintenance:  Grading the site to provide even infiltration of rain and eliminating site debris will minimize contamination of stormwater.

Infiltration:  Infiltration of all or part of the stormwater is preferred. A grassy swale, infiltration trench, or a constructed wetland may provide adequate infiltration for all or most stormwater events. However, when stormwater has become contaminated with pollutants such as oil and grease, treatment may be required before infiltration.

Detention Pond:  At sites that discharge stormwater to surface water, a detention pond will typically be required to control turbidity. Careful attention to pond dimensions and design is necessary to accommodate major storms and provide adequate settling.

 

For a free download of Best Practices for Designing a Crisis Management Program, click the image below:

TRP Corp - Emergency Response Planning Crisis Management

Tags: NPDES, EHS, Regulatory Compliance, Flood Preparedness, Chemical Industry

Phased Compliance of the Hazard Communication Standard Begins Dec 2013

Posted on Thu, Nov 07, 2013

The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The first phase for compliance begins on December 1, 2013. At that time, the HCS will require employees to be trained on the new label elements and the updated Safety Data Sheets (SDS) format.

The revised HCS will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. The goal is to improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals.

Hazard Communication Standard Updates

Two significant changes contained in the 2012 HCS include the revised labeling elements and the standardized format for SDSs, formerly known as the Material Safety Data Sheets (MSDSs). Employees may have already been exposed to the new labels and SDSs on the chemicals in their workplace during the transition phase. However, to ensure workplaces are compliant with the new regulations, it is critical that employees understand the new label and SDS formats.

OSHA requires the following training criteria to be in place prior to December 1, 2013.

Label training must include:

  • Product identifier: The chemical may be identified by the name, code number or batch number. The manufacturer, importer, or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS.
  • Signal word: DANGER and WARNING are the two classes utilized on the labeling. The word DANGER is used for the more severe hazards and the word WARNING is used for the less severe hazards.
  • Pictogram: OSHA has designated eight pictograms to be associated with a hazard category.

OSHA_HCS_pictogram_download.jpg

  • Hazard statement: The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.
  • Precautionary statement: Describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
  • Contact information: Name, address and phone number of the chemical manufacturer, distributor, or importer.
  • Workplace label use: Describes proper storage requirements and first aid procedures
  • Element integration: For chemicals that have multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class. When there are similar precautionary statements, the one providing the most protective information will be included on the label.
 

Safety Data Sheet Format

SDS format and information training must cover the following topics:
  • Standardized 16-section format including the section numbers, the headings, and associated information:
    • Section 1: Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
    • Section 2: Hazard(s) identification includes all hazards regarding the chemical; required label elements.
    • Section 3: Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
    • Section 4: First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
    • Section 5: Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
    • Section 6: Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
    • Section 7: Handling and storage lists precautions for safe handling and storage, including incompatibilities.
    • Section 8: Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
    • Section 9: Physical and chemical properties lists the chemical’s characteristics.
    • Section 10: Stability and reactivity lists chemical stability and possibility of hazardous reactions.
    • Section 11: Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
    • Section 12: Ecological information*
    • Section 13: Disposal considerations*
    • Section 14: Transport information*
    • Section 15: Regulatory information*
    • Section 16: Other information, includes the date of preparation or last revision 

*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15 (29 CFR 1910.1200(g)(2)).

Preparedness and Emergency Management - TRP Corp

Tags: HAZCOM, Training and Exercises, Emergency Management Program, Safety, Workplace Safety, Chemical Industry

The SPCC Plan Hybrid Inspection Program

Posted on Thu, Sep 12, 2013

The Environmental Protection Agency (EPA) estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the SPCC Rule:

A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires SPCC plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.

The SPCC inspection program is designed to detect oil leaks, spills, or other potential integrity or structural issues before a  spill occurs.  The type of inspection program, scope, and frequency will depend on site-specific conditions, spill history, and type of facility. Typically, inspection programs are in accordance with industry standards. However, companies can decide to deviate from industry standards when another approach would be more appropriate or cost effective, based on site-specific factors. The result may be a Hybrid Inspection Program.

The EPA classifies a Hybrid Inspection Program as a customized, site-specific inspection program based on relevant industry standards (in whole or in part) and other good engineering principles. According to the EPA, the components of a Hybrid Inspection Program would likely include frequent visual inspections by the operator, as well as periodic inspections (plus testing as appropriate) by an EPA certified inspector. A company must document environmentally equivalent inspection and testing alternatives, the reason for the deviation, and describe the alternative method in detail, including how it is environmentally equivalent in the SPCC Plan.

It is recommended that formal container test records or reports be retained for the life of a container under the Hybrid Inspection Program. When implementing a Hybrid Inspection Program, the EPA recommends the following elements:

Inspection elements for shop-built tanks:

  • Visually inspect exterior of tank
  • Evaluate external pitting
  • Evaluate “hoop stress and longitudinal stress risks” where corrosion of the shell is present
  • Evaluate condition and operation of appurtenances
  • Evaluate welds
  • Establish corrosion rates and determine the inspection interval and suitability for continued service
  • Evaluate tank bottom where it is in contact with ground and no cathodic protection is provided
  • Evaluate the structural integrity of the foundation
  • Evaluate anchor bolts in areas where required
  • Evaluate the tank to determine it is hydraulically sound and not leaking

Inspection elements for field-erected tanks:

  • Evaluate foundation
  • Evaluate settlement
  • Determine safe product fill height
  • Determine shell corrosion rate and remaining life
  • Determine bottom corrosion rate and remaining life
  • Determine the inspection interval and suitability for continued service
  • Evaluate welds
  • Evaluate coatings and linings
  • Evaluate repairs for risk of brittle fracture
  • Evaluate the tank to determine it is hydraulically sound and not leaking.

When industry standards do not apply to a container or the container is outside the scope of the standard, a PE does not need to provide and certify an environmental equivalence justification. However, specific inspection protocols must be described in the SPCC Plan, and records of inspections and tests must be maintained for three years. Containers included outside the scope of industry standard can include, but are not limited to:

  • Containers storing oils that have a specific gravity greater than 1.0
  • Oil containers operated at elevated temperatures
  • Animal fat or vegetable oils (AFVOs) containers

Regional EPA representative(s) conduct both announced and unannounced inspections at facilities. A copy of the facility’s SPCC Plan with site-specific inspection procedures should be available for inspector(s) to review at all times. Additional documentation,  including operating procedures, spill prevention measures, personnel training, drainage discharges, and spills should be provided to inspector(s), as well as site plans for tankage, diversionary structures, and drainage patterns.

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Tags: SPCC, Oil Spill, Training and Exercises, Regulatory Compliance, Chemical Industry

Terrorism, Security Planning, and Emergency Response Plans

Posted on Mon, Aug 19, 2013

In early August, the U.S. government took proactive measures to protect 22 embassies and consulates from terrorist activity by closing those facilities. In response to terrorism intelligence, U.S State Department spokesperson Jen Psaki stated, "This is not an indication of a new threat stream, merely an indication of our commitment to exercise caution and take appropriate steps to protect our employees, including local employees and visitors to our facilities."

The State Department statement highlights the needs for security planning for private, public, government, and industry facilities. Response planning should address applicable threat and risk assessments results and incorporate security measures and appropriate procedures to protect facility employees and visitors. Two key factors that must be considered in security planning include the specific nature of the threats and the available warning time allotted.

The move by the State Department reflected these two prime security response factors. "Once you take targets away, it buys you additional time to try and disrupt, to identify the cell, the operators in country and the region, and work with your partners in the region to try and ... get them in custody or disrupt the plot," she said. "So, some of this operationally is about buying time."

While many facilities may not be targets of a specific terroristic threat, facilities must be prepared to respond to such an event.  Companies should incorporate appropriate, site-specific responses to counteract the four major weapons associated with a terrorist attack. Specific roles and responsibilities of facility personnel, law enforcement, fire officials, and other first responders should be clearly described, reviewed, and updated as necessary.

Below details the FEMA identified four main weapon types most likely to be used by terrorists and associated response actions:

1. Conventional weapons (bombs and other explosive devices): The goal is to place inhabitants in a protected space and/or increase the distance from the potential explosive area. The following actions should be considered:

  • Use basement areas
  • Move to interior hallways away from windows
  • Shut off gas utilities
  • Evacuate personnel
2. Chemical weapons (poisonous gases, liquids, or solids): The following actions should be considered:
  • Secure doors/windows
  • Turn off all ventilation, including furnaces, air conditioners, vents, and fans
  • Seek shelter in an internal room
  • Make decisions based on reliable information from public safety officials on the location of the chemical release and wind speed and direction
  • Develop reunification procedures that minimize the penetration of airborne substances
  • Communicate with medical personnel (intervene as appropriate or instructed)

3. Biological agents These agents are organisms or toxins that have the potential to incapacitate people, livestock, and crops. They can be dispersed as aerosols, airborne particles or by contaminating food and water. These agents may not cause symptoms for days or weeks following an exposure. The following actions should be considered:

  • Mitigate exposure (includes getting everyone into buildings)
  • Secure avenues of penetration to include closing doors/windows and shutting down the heating ventilation, and air conditioning systems
  • Develop reunification procedures that mitigate risks
  • Develop a recovery plan in light of the highly contagious nature of these weapons
  • Communicate with medical personnel

4. Nuclear weapons (potential exposure to radiation) The overarching concern is to get individuals to a protected space or to increase the distance from the blast area. FEMA recommends taking shelter immediately as the three protective factors include distance, shielding, and time. Issues for consideration include, but are not limited to:

  • Potential magnitude
  • Emotional implications
  • Contamination
  • Casualties
  • Unavailability of emergency resources
  • Need for long-term sheltering
  • Hazard analysis (proximity to nuclear power plant, military installation, chemical plants)
  • Identification of at-risk persons or populations
  • Safe evacuation procedures and routes
  • Short-term and long-term recovery
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Tags: Emergency Response Planning, Security plans, Terrorism Threat Management, Chemical Industry

Advanced HAZWOPER Training Supports HAZMAT Responses

Posted on Mon, Aug 05, 2013

The intent of the OSHA’s HAZWOPER standard (Hazardous Waste Operations and Emergency Response ) 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)).  Employees who may be exposed to or respond to hazardous material emergencies are required by the Occupational Health and Safety Administration (OSHA) to have specific HAZWOPER training.  

There are various OSHA training levels of HAZWOPER that are commensurate with the type of work and the potential involvement with hazardous materials. The HAZMAT technician and the HAZMAT specialist are to have significant knowledge of HAZMAT situations and can assist the incident commander in response assessments. Both the technician and specialist levels are required to initially complete, at a minimum, the 24-hour training HAZWOPER training. However, technician level responders vastly outnumber specialist level responders, and are the most frequent personnel in handling HAZMAT incidents.

Trained HAZMAT technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. These individuals assume a more aggressive role than an operational level first responder in that they are trained to approach the point of release in order to plug, patch, or otherwise stop the release of a hazardous substance. HAZMAT technicians may not be classified as scientific experts; however, most have an understanding of chemistry that may range from basic to advanced.

The HAZMAT technicians must demonstrate competency in the following areas:

  • Implementation of the employer's emergency response plan.
  • Classification, identification and verification of known and unknown materials through the use of specialized equipment.
  • Functioning within an assigned role in the Incident Command System.
  • Selecting and using proper specialized chemical personal protective equipment provided to the hazardous materials technician.
  • Hazard and risk assessment techniques.
  • Performing advanced control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.
  • Understanding and implementing decontamination procedures.
  • Understanding termination procedures.
  • Understanding basic chemical and toxicological terminology and behavior.

On average, HAZMAT technicians complete 40-hours of training. Certified technicians new to a site must receive appropriate, site-specific training before site entry and have appropriate supervised field experience at the new site. Equivalent training includes any academic training or the training that existing employees might have already received from actual hazardous waste site experience.

The HAZMAT specialist receives the highest level of HAZWOPER training. The specialist typically responds with and supports the duties of hazardous materials technicians. These individuals’ duties parallel those of the technician; yet require a greater knowledge of the various substances they may be called to contain. HAZMAT specialists often act as a site liaison with Federal, State, Local and other government authorities in regards to site activities.

The HAZMAT specialist must demonstrate competency in the following areas:

  • Implementation of their employer’s emergency response plan.
  • Classification, identification and verification of known and unknown materials by using advanced survey instruments and equipment.
  • Knowledge of the state emergency response plan.
  • Selecting and using proper specialized chemical personal protective equipment provided to the hazardous materials specialist.
  • Detailed hazard and risk assessment techniques.
  • Performing specialized control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available.
  • Implementing decontamination procedures.
  • Developing a site safety and control plan.
  • Understanding chemical, radiological and toxicological terminology and behavior.

The Specialist responder typically has an in-depth and highly advanced level of knowledge in chemistry, biology or some other discipline of science. According to FEMA the HAZMAT specialist is responsible for:

  • Providing ongoing monitoring of local environmental conditions during operations.
  • Providing an initial and ongoing survey for presence of hazardous materials at search and rescue sites.
  • Implementing defensive mitigation practices when indicated.
  • Directing emergency decontamination procedures for any task force member or victim.·
  • Providing assistance to medical personnel for  chemical exposure and injuries.
  • Documenting all related information.
  • Adhering to all safety procedures.
  • Accountability, maintenance, and minor repairs for all issued equipment.
  • Performing additional tasks or duties as assigned during a mission.
  • Ensuring MSDS are provided for all hazardous materials carried or used by the task force.
  • Ensuring all specialized equipment is maintained and calibrated according to the manufacturers’ specifications.

Although HAZMAT specialists are required to initially pass the 24-hour HAZWOPER training, most specialists have completed university-level courses. A HAZMAT specialist often holds a four-year Bachelor of Science degree in engineering, chemistry, biology, or other science related field.  It is not uncommon for a specialist level responder to have an advanced degree.

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Tags: OSHA HAZWOPER, Training and Exercises, Workplace Safety, HAZWOPER, Chemical Industry, OSHA HAZWOPER standard training

Neither Flight or Flight - Shelter In Place Emergency Plan Procedures

Posted on Thu, Feb 21, 2013

In January 2013, a Florida chemical plant experienced a hazardous chemical release. As a result, a loud area warning horn reverberated throughout the community, indicating that a release had occurred. The prevailing winds put homes and schools in the path of the vapor plume. The surrounding schools ordered a shelter-in-place and response procedures were initiated. “When they hear that horn, they (the schools) go into shelter mode. We then verify what has taken place,” said Santa Rosa County Superintendent Tim Wyrosdick.

Evacuation and Sheltering-in-Place are the primary protective actions used to remove personnel from hazards. While employee evacuation is a typical warranted reaction for an emergency response, it may not be the best option if reaction time is limited or during a hazardous chemical release.  Weather-related emergencies or incidents involving chemical, biological, and radiological releases may result in a shelter in place order. Often times during a release or extreme weather, employees are safer to remain indoors rather than attempt to evacuate the area.

It is important to determine the characteristics of a release and/or the current meteorological conditions to determine if the shelter-in-place procedures should be activated. Site-specific criteria, such as building characteristics and shelter-in-place vulnerabilities should be identified and mitigated, if possible. The preparedness process should predetermine shelter-in-place criteria, procedures, assembly points, and routes. However, an Incident Commander should determine if personnel should shelter-in-place or evacuate based on facility circumstances and/or hazardous materials involved.

Just as with an evacuation order, a shelter-in-place activation and implementation is not an instantaneous process.  Sheltering-in-place requires time, employee compliance, training, and exercising. Additionally, buildings selected as the shelters must be able to withstand meteorological conditions, such as a tornado, and/or hazardous fumes infiltration.

The following are general shelter-in-place procedures; however, facilities should institute site-specific measures according to operations, facility structure(s), geographical vulnerabilities, threats and/or hazards.

  • Close the facility to incoming personnel and provide shelter for those visitors at the site.
  • Account for employees within the shelter.
  • Shut and lock all windows and doors.
  • Shut down, seal and/or disable systems that automatically conduct air exchange including all heating, ventilating, and air conditioning systems in all buildings.
  • Limit egress to one door or area of the building.
  • Tape all doorways to minimize airflow.
  • Instruct occupants to gather in the center of a room with minimal ventilation, away from doors and windows.
  • If there is danger of glass breaking from explosion or extreme weather, close the window shades, blinds, or curtains to minimize potential impacts to bystanders.
  • Maintain contact with emergency contacts and have the phone available if you need to report a life-threatening condition. Be sure to have a hard-wired telephone in the room(s) you select. Cellular telephone equipment may be overwhelmed or damaged during an emergency.
  • Gather essential disaster supplies, such as nonperishable food, bottled water, battery-powered radios, first-aid supplies, flashlights, batteries, duct tape, plastic sheeting, and plastic garbage bags if it is determined that the shelter-in-place order will exist for an extended duration.
  • Listen to the radio, watch television, or use the Internet for further instructions from local officials/emergency response team or until you are told all is safe or to evacuate by the Incident Commander. Local officials may call for evacuation in specific areas at greatest risk in your community.
  • Contact employees who are absent to alert them of the shelter-in-place status.
  • If possible have employees, customers, clients, and visitors to call their emergency contact to let them know where they are and that they are safe.
  • Communicate when the all-clear message is received.

An Emergency Response Team can be responsible for keeping sheltered employees informed of the situation as it unfolds. Typically, emergencies that require sheltering-in-place will not last more than three to five hours. However, managers may wish to keep extra water and small amounts of non-perishable food on hand in the event the emergency goes beyond 12 hours.

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

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Tags: Facility Management, Extreme Weather, Workplace Safety, Chemical Industry