Beyond the Rule of Thumb
Survival Tip 32
By Steven De Lisi
It’s the cleanup phase of a hazardous materials incident. The release has been contained, the leak stopped, and it’s time to just mop up spilled materials and go home. The emergency is over. Or is it? For many reasons, some first responders believe it is, basing their decision on nothing more than financial and logistical considerations. Perhaps personnel have been on scene for a considerable amount of time and overtime costs have soared. For volunteer departments, the willingness of some members to remain on scene, as some would say, “to babysit the cleanup,” has waned. There may also be valuable equipment resources that incident commanders are anxious to return to service and expensive heavy equipment contractors whose hourly rates continue to mount as time goes by.
Psychological reasons may also influence their decision. Given that an overdose of adrenaline drives many first responders during the early stages of a hazmat incident, especially those who may have involved fires, explosions, and hurried citizen evacuations, the cleanup operation’s slower pace could lull some into a sense of security that the worst is now over. Yet catastrophe can still strike during the cleanup phase of an incident.
In one instance, a cleanup contractor was attempting to transfer product from an overturned gasoline cargo tank that was resting on an inclined embankment. As the level of the liquid in the tank dropped, the center of gravity of the overturned vehicle shifted; as a result, the tank slid into and damaged vehicles and equipment operated by the cleanup contractor. There had been no effort made to secure the tank prior to the offloading process.
Not long after this incident, two underpowered wrecker-trucks, both with inexperienced operators, were attempting to raise a partially-loaded propane cargo tank that had fallen into a ravine. At one point during the recovery effort, one wrecker began to lift faster than the other, and the tank, now on an angle, came close to slipping out of the supporting cables. In this instance, a crane would have been more appropriate for the recovery operation, yet first responders were reluctant to challenge the cargo tank’s owner, who had balked at the higher cost of using a crane. First responders got lucky on this one.
In a similar situation, a wrecker driver was attempting to upright a bobtail propane cargo tank that had overturned onto the right road shoulder of a narrow road while attempting to make a left turn into a product transfer facility. This was a “soft” rollover with no damage to the tank or fittings, and first responders were confident in their ability to upright the vehicle while still loaded. However, once again, the wrecker driver, summoned by the local police department, was inexperienced. While he was attaching cables to the cargo tank, first responders asked him what his plan was to prevent the tank, once upright, from completely falling to the other side because of the momentum of the liquid moving inside the tank. He indicated that he had not thought of that. First responders then demanded that another wrecker be brought in to assist. A potential catastrophe was avoided.
The best advice for first responders is to become familiar with wrecker companies in their area that have the equipment, training, and experience to complete recovery efforts involving overturned cargo tanks safely. Although the responsible party may resist the need to pay for a more expensive recovery solution, it is first responders who will likely be held accountable if the recovery effort fails and the event turns into a cleanup catastrophe. Remember too that in most states and localities there are no certification or training standards for wrecker operators, so that your only hope of determining whether you can depend on their skills is to become familiar with local operators, hopefully through training programs that you set up involving overturned vehicles. Some trucking companies will donate old cargo tanks for this purpose and it is worthwhile to scour your community for this type of opportunity.
The wrecker companies’ capabilities are not the only ones in question during the cleanup phase of a hazmat incident. The ability of companies that remove spilled material and damaged non-bulk containers such as drums and cylinders is also subject to a wide range of variables, yet unlike wrecker companies, cleanup contractors are usually held to Occupational Safety and Health Administration regulations, including those for “site workers” in the HAZWOPER standard, 29CFR 1910.120(e).
The decision to hire a cleanup contractor usually rests with the responsible party, yet first responders must know whether the contractor and its employees are qualified. Determining these qualifications may involve the contractor providing copies of employee training certificates as well as documentation of adequate insurance and permits for the intended operation.
During one incident, two first responders and a representative from a cleanup contractor hired by the responsible party were seated in a booth at a truck stop restaurant discussing product recovery operations for a minor incident involving approximately 25 gallons of a flammable liquid. When questioned about the qualifications of his company to perform the required cleanup, the representative indicated that he suddenly needed to use the restroom. Although his sense of urgency at the time seemed suspicious, he was allowed to proceed with his request. He never returned to the meeting, and first responders observed him get into his vehicle and quickly leave the scene. A likely catastrophe was averted by the diligence of first responders in asking the right questions.
If you are not sure what certificates to ask for from the contractor, contact representatives from your local occupational safety and environmental safety offices and request their assistance. Remember that if you don’t contact these individuals up front and someone gets hurt at the scene, you’ll have plenty of time to talk to them later, probably in court with lots of high-paid lawyers in attendance.
First responders should also thoroughly review the cleanup contractor’s action plan, ensure that all contractor employees are integrated into the event’s incident command system, and are fully briefed on the first responders’ expectations and steps to take in an emergency occurring during cleanup. Don’t just let these guys go to work until you are fully comfortable with what is about to take place. Ask plenty of questions up front to avoid potentially deadly and costly surprises later on. If emergency responders are providing assistance to cleanup contractor employees, these employees’ actions can jeopardize your personnel’s safety.
Inspect the type and condition of contractor’s protective clothing and ensure that adequate safeguards are in place in the event of equipment failures (e.g., hose fittings coming loose, hoses bursts during product transfers). First responders may have to construct berms to contain any potential loss of product. Although a thorough review of cleanup operations is time consuming, this is time is well spent since it can sometimes mean the difference between life and death and reduce the potential for an environmental disaster.
Response time is another consideration regarding cleanup contractors. Although this in itself will not create a catastrophe involving injuries and property damage, a delay in completing cleanup operations can exacerbate associated problems such as road detours, citizen evacuations, and business closures. On some occasions, a cleanup contractor will underestimate its response time just to get the job, knowing full well that they can never meet their stated time frame. A one-hour response time can easily turn into several hours, partly because most contractors don’t have people on call waiting for an incident to occur. Instead, their employees are likely working on nonemergency sites, such as tank cleaning or removal, and must first wrap up their work before they can respond.
Sometimes the “one-hour” response time is met, but only by a field representative who, although experienced first responders him what is needed, elects to come to the scene so that he can determine firsthand the equipment and personnel needs. Although the contactor may be justified in his decision to assess the incident, this nonetheless delays the cleanup operation. Never rely on the “one-hour” response time when calculating when a road will reopen or when citizens can return home. You will almost always be wrong and you, not the cleanup contractor, will be the bad guy in the eyes of the community.
Of course, some first responders don’t feel the need to use a cleanup contractor and instead elect to complete cleanup themselves. In one instance, first responders found an abandoned compressed gas cylinder along a roadside. Their solution was to have a local public works department representative take the cylinder to the landfill using a pickup truck. Not the safest move, especially without knowing the cylinder’s contents and its potential to explode during handling. When questioned as to why they chose to move the cylinder, their responded that they handle cylinders all the time and this situation was no different.
During another incident, first responders were at a residence where a small bottle of pesticide concentrate had broken on a concrete floor in the basement. They were attempting to perform cleanup of the material themselves with guidance from the manufacturer. However, they soon realized that in the event their cleanup efforts were insufficient, they would likely be held liable for any injuries that occurred to the occupants. Remember that as first responders at the Hazmat Operations level, you don’t have the training or equipment to perform risky cleanup operations. Of course, Hazmat Technicians and Specialists will obviously possess more training and more sophisticated equipment, yet cleanup of chemicals goes beyond the generally accepted practice of “stopping the release” associated with emergency response operations. Furthermore, cleanup invites greater risk, and despite those who may claim that cleanup is part of a hazmat team’s service to its community, the financial and legal liabilities of government agencies performing these types of operations must be seriously considered.
Click here for more info on Steven De Lisi’s book, Hazardous Materials Incidents: Surviving the Initial Response.
Steven M. De Lisi retired after a fire service career spanning 27 years that included serving as a regional training manager for the Virginia Department of Fire Programs (VDFP) and, most recently, as the deputy chief for the Virginia Air Guard Fire Rescue. De Lisi is a hazardous materials specialist and as an adjunct instructor for VDFP. He continues to conduct hazardous materials awareness and operations-level training programs for fire suppression and EMS personnel. De Lisi began his career in hazardous materials response in 1982 as a member of the hazmat team with the Newport News (VA) Fire Department. Since then, he has also served as a hazardous materials officer for the Virginia Department of Emergency Management; in that capacity, he provided on-scene assistance to first responders involved with hazardous materials incidents in an area that included more than 20 local jurisdictions.