While some companies have comprehensive emergency response plans and strategies that address chemical spills, others are just now taking the steps necessary to identify potential chemical spill scenarios and evaluate the impact to employees, the environment and the general public. Sadly, there are other companies that have no plans in place and will do nothing until an incident occurs…bad decision!

If a company stores, uses or transports hazardous chemicals, there is the possibility of a spill. While federal and state regulations mandate minimum spill management and cleanup requirements, it is ultimately the responsibility of the company to keep employees and the general public safe and the environment clean. Companies can better prepare for a chemical spill by providing first responders with information and knowledge to recognizing different types of spills and how to initially respond.

Proper Identification

A spill of hazardous chemicals, mixtures of such chemicals or hazardous waste can be categorized into two distinct groups in terms of their emergency status level:

Incidental Spills – OSHA defines an incidental release or spill as “a release of a hazardous substance which does not pose a significant safety or health hazard to employees in the immediate vicinity or to the worker cleaning it up, nor does it have the potential to become an emergency.” Incidental spills do not require an emergency response, and may be cleaned up by employees working in the area where the spill occurred or by maintenance personnel.

While incidental spills do not require Hazardous Waste Operations Emergency Response (HAZWOPER) trained cleanup personnel, spill response personnel, at a minimum, do need to be trained in OSHA’s Hazard Communication Standard and federal and state hazardous waste regulations, including chemical hazards, the use of appropriate personal protective equipment, and chemical spill cleanup best practices.

Emergency Response Spills – The response to an emergency response spill requires HAZWOPER trained personnel in accordance with 29 CFR 1910.120. An emergency response spill is defined as a spill that requires the response efforts by employees outside the immediate area of the release or by third party responders (fire departments, internal hazmat teams, etc.) to an incident that results, or is likely to result, in an uncontrolled release of a hazardous substance.

Examples of an emergency response spill is a spill that involves flammable, corrosive or toxic substances immediately dangerous to life and health (IDLH).

Assessing Risk

When responding to a spill, employees first should assess the risk surrounding the situation. Initially, they should determine the actual volume of the spilled material. Even a small amount of a highly toxic chemical can meet the definition of an emergency response spill. Other factors that should be considered include:

• Nature of the hazard properties of the material (i.e., flammability, corrosivity, toxicity, etc.)
• Degree of hazard and routes of entry if toxic
• Physical state (powder, granular, liquid, gaseous)
• Physical properties of the materials
• Specific circumstances of the release, including location of the spill, level of ventilation and knowledge and experience of area personnel

Also very important is knowing federal, state and local release reporting timelines and requirements. Failure to complete agency notifications for reportable releases in a timely manner can result in fines and additional regulatory scrutiny.

Expecting the Unexpected

Rarely is a spill expected. A spill occurs only when a system of hazardous material containment fails, usually as a result of a chain of unfortunate events. The potential for chemical spills exists anywhere these materials are stored, used or transported. Even when spills don’t impact persons or the environment, they often lead to business interruptions, equipment damage, as well as other potential for financial impact.

Fully training and equipping a hazmat response team that is capable of quickly and safely managing all types of chemical spills can be a complex process. Training typically includes 24 to 40 hours of combined classroom education and hands-on instruction in practical spill response techniques. In addition, OSHA mandates annual refresher training and frequent drills. The hazmat team must maintain an ongoing state of readiness.

Equipment requirements vary depending upon the nature of the potential emergency response scenarios to which the hazmat team is expected to respond. Typical equipment includes protective clothing, air monitoring equipment, self-contained breathing apparatus, tools and absorbent materials.

Maintaining a hazmat team requires a considerable investment in time. Time must be provided for emergency response planning (including pre-emergency assessment for on-site teams), developing resources for cooperation, annual medical evaluations, developing safety and health programs, performing recurrent training, maintaining personal protective equipment programs, maintaining air monitoring equipment and preparing for decontamination procedures, to name a few.

Outsourcing Emergency Response

The alternative to training employees and purchasing and maintaining response equipment is to outsource emergency response. In most circumstances, outsourcing means identifying and qualifying an emergency response contractor. Qualifying contractors is essential and best performed by an environmental professional experienced in your industry, chemicals used, and processes.

Regardless as to whether you decide to have an in-house emergency response team or outsource these activities, Total Environmental & Safety, LLC (Total) can assist you. Total is capable of not only qualifying emergency response contractors, but also training in-house personnel.