Whenever a company stores hazardous substances and materials, there is always the potential for a spill. Taking precautions in an effort to minimize spills is a company's best defence. Recognizing different types of spills and responding appropriately to spills is key to ensuring the hazards of spills are minimized and worker safety is protected.
Types of spills
In terms of recognition, spills can be categorized into three distinct groups:
1) Releases that are clearly incidental,
2) Releases that clearly require emergency response, and,
3) Releases that may be incidental or may require emergency response, depending upon circumstances.
Workers must be able to distinguish between 'incidental spills' and 'emergency response spills.' An incidental release or spill is a release of a hazardous substance that 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 therefore do not require trained professionals for cleanup. These spills are typically managed by employees working in the area where the spill occurred or by maintenance personnel.
An emergency response spill is any event involving the spill or release of hazardous substances or materials, mixtures containing such substances or materials or hazardous waste that requires the intervention of spill cleanup professionals or an internal spill response team, including spills that are harmful to humans and/or the environment in which they live.
Every spill should be evaluated to determine whether professionals are required and if regulatory reporting is necessary. An initial assessment of the spill should be conducted to determine the substance spilled. Is the material hazardous? How much of the substance has spilled? A small volume spill is obviously less likely to pose a significant risk to workers than a large spill of the same material and is less likely to escalate into an emergency response. However, even a very small spill of a highly toxic chemical could cross the emergency response threshold.
The following are some factors that must be considered in the risk assessment:
* Nature of the hazard properties of the material (i.e., flammability, corrosivity, toxicity, etc.),
* Physical properties of the material and its potential for exposure (i.e., respiratory hazard, for example),
* Degree of hazard and routes of entry, if toxic,
* Physical state (powder, granular, liquid, gaseous), and,
* Specific circumstances, such as the location of the spill, the level of ventilation and the knowledge and experience of personnel.
Incidental spill response personnel should be trained in hazard recognition and/or hazard communication and in the use of appropriate PPE. Incidental spill responders may absorb, neutralize, or otherwise control a spill of a familiar hazardous substance/material, so long as doing so does not expose them to significantly greater risk than the routine handling or use of that material. Consider the amount of material you anticipate might spill at one time and determine your storage limitations. Stock your absorbents and neutralizers in locations that will provide easy access and train your employees on these locations and on use of all absorbents. Absorbents can be a costly part of your spill response preparation. Therefore, it is important that your employees know when and how to use absorbents. Most absorbents and neutralizers have Materials Safety Data Sheets (MSDS), so don't forget to add these MSDSs to your management system.
If workers are unable to determine whether the spill is incidental or whether they are qualified to clean it up, they should err on the side of caution and contact emergency responders.
For larger, emergency response spills, preparing an emergency response assistance plan (ERAP) is an important step and often required depending on the types of hazardous substances or quantity of hazardous substances your company handles or transports. In addition, employee training and testing of the plan are critical to its success in an actual emergency.
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 PPE programs, air monitoring equipment maintenance, and preparation for decontamination procedures.
Preparing to deal effectively with a significant spill of hazardous substance/material is good business, but an in-house emergency response team can be very costly and time consuming.
The alternative to an internal team is to outsource emergency response. Outsourcing means identifying and qualifying an emergency response contractor (or perhaps two, to ensure availability) to respond on an on-call basis to emergency events. Qualifying contractors is essential and best performed by an environmental professional aware of appropriate criteria and experienced in such evaluations. Alternatively, many companies contract with environmental, health, and safety information providers that pre-qualify local emergency response contractors and provide a call centre to manage emergency responses, interact with regulatory agencies, and perform subsequent reporting as necessary. In either case, the spill responders should have a knowledge base of similar incidents that can be leveraged when responding to your spill. It's important to provide a site-specific profile including the relevant internal procedures and the MSDSs for the materials you use. You should also have a contract agreement in place to ensure the responder understands your needs and expectations.
Whichever the selected approach -- internal team development or outsourced assistance -- the key to success in the event of a hazardous substance or material spill is preparation.
Jeff Kacirek is a Certified Hazardous Materials Manager with extensive experience in managing and responding to emergency situations. At 3E, he manages a team of spill specialists that advise clients on chemical spills, emergency response management and hazardous waste management.