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What it means:
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employer must address what actions employees are to take
when there is an unwanted release of highly hazardous
chemicals. Every employee, including outside
contractors, has a specific responsibilities
during any evacuation. The level of documented
training needed for compliance is directly equal
to the level of responsibility. Employers
will need to decide if they want employees to handle and
stop small or minor incidental releases. Whether they
wish to mobilize the available resources at the plant
and have them brought to bear on a more significant
release. Or whether employers want their employees to
evacuate the danger area and promptly escape to a
preplanned safe zone area, and allow the local community
emergency response organizations to handle the release.
Or whether the employer wants to use some combination of
these actions. Employers will need to select how many
different emergency preparedness lines of
defense they plan to have and then develop the necessary
plans and procedures, and appropriately train employees
in their emergency duties and responsibilities and then
implement these lines of defense.
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Employers
at a minimum must have an emergency action plan which
will facilitate the prompt evacuation of employees when
an HHC release occurs. This
means that the employer will have a plan that will be
activated by an alarm system to alert employees when to
evacuate and, that employees who are physically
impaired, will have the necessary support and assistance
to get them to the safe zone as well. The intent of
these requirements is to alert and move employees to a
safe zone quickly. Delaying alarms or confusing alarms
are to be avoided.
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| HHC
incidental releases in the
process area must be addressed by the employer as to
what actions employees are to take. If the employer
wants employees to evacuate the area, then the emergency
action plan will be activated. For outdoor processes
where wind direction is important for selecting the safe
route to a refuge area, the employer should place a wind
direction indicator such as a wind sock or pennant at
the highest point that can be seen throughout the
process area. Employees can move in the direction of
cross wind to upwind to gain safe access to the refuge
area by knowing the wind direction.
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| If
the employer wants specific employees in the release
area to control or stop the minor emergency or
incidental release, these actions must be planned for in
advance and procedures developed and implemented.
Preplanning for handling incidental releases for minor
emergencies in the process area needs to be done,
appropriate equipment for the hazards must be provided,
and training conducted for those employees who will
perform the emergency work before they respond to handle
an actual release. The employer's training program,
including the Hazard Communication standard training is
to address the training needs for employees who are
expected to handle incidental or minor releases.
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| Preplanning
for releases that are more serious than incidental
releases is another important line of defense to be used
by the employer. When a serious HHC release occurs, the employer through
preplanning will have determined in advance what actions
employees are to take. The evacuation of the immediate
release area and other areas as necessary would be
accomplished under the emergency action plan. If the
employer wishes to use plant personnel such as a fire
brigade, spill control team, a hazardous materials team,
or use employees to render aid to those in the immediate
release area and control or mitigate the incident, these
actions are covered by 1910.120, the Hazardous Waste
Operations and Emergency Response (HAZWOPER) standard.
If outside assistance is necessary, such as through
mutual aid agreements between employers or local
government emergency response organizations, these
emergency responders are also covered by HAZWOPER. The
safety and health protections required for emergency
responders are the responsibility of their employers and
of the on-scene incident commander.
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| Responders
may be working under very hazardous conditions and
therefore the objective is to have them competently led
by an on-scene incident commander and the commander's
staff, properly equipped to do their assigned work
safely, and fully trained to carry out their duties
safely before they respond to an emergency. Drills,
training exercises, or simulations with the local
community emergency response planners and responder
organizations is one means to obtain better
preparedness. This close cooperation and coordination
between plant and local community emergency preparedness
managers will also aid the employer in complying with
the Environmental Protection Agency's Risk Management
Plan criteria.
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| One
effective way for medium to large facilities to enhance
coordination and communication during emergencies for on
plant operations and with local community organizations
is for employers to establish and equip an emergency
control center. The emergency control center would be
sited in a safe zone area so that it could be occupied
throughout the duration of an emergency. The center
would serve as the major communication link between the
on-scene incident commander and plant or corporate
management as well as with the local community
officials. The communication equipment in the emergency
control center should include a network to receive and
transmit information by telephone, radio or other means.
It is important to have a backup communication network
in case of power failure or one communication means
fails. The center should also be equipped with the plant
layout and community maps, utility drawings including
fire water, emergency lighting, appropriate reference
materials such as a government agency notification list,
company personnel phone list, material safety data sheets, emergency plans and
procedures manual, a listing with the location of
emergency response equipment, mutual aid information,
and access to meteorological or weather condition data
and any dispersion modeling data. |
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