BY STEVEN M. DE LISI
One evening, the fire dispatcher contacted our station to report an unusual odor coming from an unknown substance that was leaking out of a manhole in a nearby neighborhood. Following this brief description of the situation, she stated, “We’re not sure who to send on this, so we’re sending you.” Our response was simply, “Here we go again.”
“When you don’t know who to call, you call the fire department” has become a sort of unwritten social contract with our communities. People rarely contact us unless they’re in trouble, and we just assume we’re responsible to fix whatever is broken. Whether the need to have an answer for every occasion is driven by the public’s perception of our innate abilities or our own sense of pride, it generally works to our advantage, and we leave the scene heroes, with the belief in our own invincibility confirmed once more. Yet, while this approach might work in most instances, some hazardous materials incidents pose special challenges that can very easily put well-intentioned firefighters on the defensive.
Most of us have responded to chemical spills at commercial or industrial facilities and to incidents at residential occupancies. In the latter situations, a homeowner may have broken a mercury thermometer, dropped a bottle of pesticide, or even spilled muriatic acid in his garage. We may have also fielded citizens’ questions regarding old chemicals stored in their attics or basements or had the misfortune of these same individuals bringing the items to the fire station for us to deal with.
Each of these events usually challenges us with proper cleanup and disposal questions, whereas those that involve chemical spills in or near a building also include the age-old query, “Is it safe to go back in?” Remember that, to be defensible, your answer should be based on training, experience, and knowledge of your organization’s legal authority and willingness to deal with these matters.
When evaluating your level of hazardous-materials training and experience, recall that most incidents progress through several phases, including initial efforts to isolate and deny entry to dangerous areas, defensive spill containment, and specific remedies to control a release by sometimes plugging or patching a leaking container. Assisted by a hazardous materials response team or cleanup contractor, most fire departments can perform adequately during these phases, since training consistent with OSHA 29CFR 1910.120 (Hazardous Waste Operations and Emergency Response) and NFPA 472, Standard for Professional Competence of Responders to Hazardous Materials Incidents, usually helps to prepare us for these encounters.
The latter phases of an incident, though, usually involve cleanup, disposal, and the building reoccupancy safety issues following a chemical release. Unfortunately, this aspect of hazardous-materials response can offer well-meaning firefighters dangerous opportunities to exceed their level of training and expertise.
Whether a spill involves a residential occupancy with a worried homeowner, a prominent commercial building with perhaps hundreds of employees evacuated at a cost of thousands of dollars an hour in lost revenue, or the closure of a major highway, certain situations may appear to demand solutions. These demands can present us with moral, financial, or political pressures that can strain the boundaries of our social contract with the community and force us into making uninformed decisions that we may later regret. Personal relationships with the victim can magnify the pressure for a “quick fix.” Remember that while on the scene of an incident, you should view yourself not as a friend of the victim but rather as a representative of a government agency where casual “off-the-record” suggestions for cleanup and disposal (e.g., “If I were you ….”) can come back to haunt you. Remember, too, that traditional quick-fix remedies such as flushing a spill with large amounts of water or covering the spill with sand may simply worsen the problem.
Of course, if you forget the boundaries of your relationship with the victim, provide improper advice on cleanup and disposal, or exceed the legal limits of your authority or if people you allow to reenter a building following a chemical spill soon thereafter experience medical problems, there will no doubt be plenty of lawyers willing to remind you of your misdeeds. Furthermore, if you do operate outside your scope of authority, will your department be willing to defend your decision, or will you suddenly be on your own and out of luck? Always remember that the road to hell is paved with good intentions!
When dealing with the aftermath of a hazardous-materials incident, especially during the cleanup and disposal phase, saying “I don’t know” can be a good thing. However, it does not have to stop there. In fact, for firefighters, the best advice when dealing with these types of events may be “If you don’t know, ask!” Knowing whom to ask, though—and whom to trust—is the difficult part. In addition, knowing the legal limits of your organization is important, since most fire departments do not have regulatory authority over cleanup and disposal issues.
In most instances, this regulatory authority may rest with local or state agencies that deal with environmental quality. Landfill operators who receive forms of hazardous waste, those who transport the waste, and health department officials may also have an interest. Yet, contacting representatives of these organizations outside of normal business hours can prove frustrating, if not impossible, and preplanning may be a means to address this problem.
Advice on cleanup and disposal is often available from the manufacturer of the spilled product. Do not hesitate to make this call, since for most chemical spills, your inquiry on how best to handle the incident would likely be one of many the manufacturer receives on a weekly basis. Many companies will have someone available 24 hours a day to respond to these requests. Their telephone numbers, if not found on the container (or shipping papers for transportation incidents), may be available from the Chemical Transportation Emergency Center (CHEMTRECT) at (800) 424-9300. This research may take some time, but it is time well spent.
Another way to contact manufacturer representatives is to determine the city in which the company is located and then call directory assistance for that city’s emergency dispatch center. The dispatchers there may have telephone numbers for contacting representatives of the manufacturing facility during normal business hours and after hours.
Typical questions posed during cleanup generally range from “How clean is clean?” and “How clean is safe?” to “How long will cleanup take?” If you are unsure if a building is safe for reentry, vacating and securing the property may be sound advice. Sure, it may seem like overkill for what appears to be a minor chemical spill, but the effects of a release inside a building are sometimes unpredictable, especially when the substance may have contaminated HVAC filters or soaked into carpeting or a concrete floor.
Moreover, using chemical occupational exposure limits for residential occupancies is impractical, since these values are generally intended for healthy adults in a workplace setting and do not take into account possible allergic reactions from people exposed to the product. Remember, too, that we routinely condemn buildings with fire or structural damage, so why should we treat hazardous-materials spills any differently? Al-though spending a night in a motel might be inconvenient for a homeowner, your decision to vacate and secure the property might just allow you to sleep a lot better when you return home or to the station.
Should a fire department or haz-mat team ever conduct cleanup operations? Perhaps, but remember this depends on your having the correct information, legal authority, training, equipment, and experience. So, if you decide not to perform cleanup, then who will? The answer often rests with local cleanup contractors, some of whom specialize in small spills, including those involving school chemistry labs. Some contractors may also employ industrial hygienists who have the necessary training, credentials, and experience to deal with questions of environmental issues and safe reentry into a previously contaminated building. Again, knowing who is available in your area and how to contact them any time of the day or night is critical.
There will undoubtedly be questions regarding the cost of hiring a cleanup contractor. While we may naturally feel the urge to limit the incident’s expense and not to “blow the event out of proportion,” especially for those involving residential occupancies, remember that you didn’t create the problem, so don’t inherit any liability by cutting corners. In addition, some insurance companies may cover the cost of cleanup and disposal, and it is worthwhile for the property owner to investigate this possibility. Regardless of whether or not the property owner can afford to pay, fire departments should refrain from making contact with cleanup contractors, since the bill might then wind up on the fire chief’s desk. Instead, provide the property owner or the insurance company representative with suggestions of whom to call and then allow them an opportunity to make the necessary arrangements with a contractor of their choice.
For those situations in which the property owner or the fire department has cleaned up a spill, resist the urge to remove the material from the site. Although taking a small amount of contaminated absorbent or a broken container back to the fire station and throwing it in the dumpster might seem simple enough, these same items may satisfy the definition of a hazardous waste. As such, various federal regulations such as the Resource Conservation and Recovery Act (RCRA) and the Department of Transportation (DOT) regulations (49CFR, parts 171-179) may apply.
According to the RCRA, a hazardous waste includes those materials that can “pose a substantial present or potential hazard to human health or the environment when improperly treated, transported, or disposed of, or otherwise managed.” The RCRA also states, “A transporter must refer to both RCRA and to DOT regulations to ensure compliance when transporting hazardous waste.” In cases where we remove hazardous wastes from the scene, we may meet this federal definition of a “transporter” and, as always, there may be additional state and local hazardous waste regulations that apply.
Remember, when dealing with the aftermath of a hazardous materials incident, “If you don’t know, ask!”
STEVEN M. DE LISI has been a hazardous-materials officer with the Virginia Department of Emergency Management Technological Hazards Division since 1997. He is responsible for directing initial state response to hazardous-materials emergencies in 16 counties and four cities in metro Richmond and the surrounding region and working with local government and state agencies in developing hazardous-materials emergency response programs. Previously, he served for five years as a regional training manager for the Virginian Department of Fire Programs and for 10 years with the Newport News (VA) Fire Department. He has an associate’s degree in police science and a bachelor’s degree in governmental administration and is pursuing a master’s degree in public safety leadership.