Writing an OSHA-Required Emergency Response Plan
HAZARDOUS MATERIALS
Complying with federal requirements for a departmentwide haz-mat plan is not as overwhelming as you might think.
When the Occupational Safety and Health Administration (OSHA) published its Final Rule for Hazardous Waste Operations and Emergency Response on March 6, 1989, significant new requirements were placed on police and fire departments nationwide. One of the major requirements states, “An emergency response plan shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations. The plan shall be in writing and available for inspection and copying by employees, their representatives and OSHA personnel.”
The new regulation allows for use of the local or state emergency response plan, as well as SARA Title III plans, to avoid duplication. According to the Final Rule, the following subjects must be contained in the required plan if they are not addressed elsewhere:
- preemergency planning and coordination with outside parties;
- personnel roles, lines of authority, training, and communication;
- emergency recognition and prevention;
- safe distances and places of refuge;
- site security and control;
- evacuation routes and procedures;
- decontamination;
- emergency medical treatment and first aid;
- emergency alerting and response procedures;
- critique of response and followup; and
- PPE (personal protective equipment) and emergency equipment.
For a department without an existing plan, this directive could postseveral problems. Fortunately, an easy solution is available, since a number of fire departments around the country have produced excellent hazardous-materials operating guides that contain most of the new requirements. The following is a step-by-step account of how the Arizona Department of Public Safety created its emergency response plan:
- We contacted a number of fire departments and obtained copies of their plans. After reading each plan, we determined that the San Francisco Fire Department operates very closely to the way we do. We started with its Hazardous Materials Operating Guide as our basic document and copied it word for word.
- Next we made word and terminology substitutions to reflect our own operations. The obvious areas involved differing rank and position titles, varying department organizational elements, and such regional differences as that of our area’s term “emergency medical treatment personnel” and San Francisco’s name for the same function, “public health service.”
- Then we reread the other documents. Wherever we found a new idea or a procedure that wasn’t covered to the fullest extent in San Francisco’s guide, we added it to our plan. We discovered that there is a great deal of commonality between departments, that their procedures are remarkably similar. An example of some of the differences, however, are contained in the following excerpts from provisions we adopted:
OSHA-REQUIRED EMERGENCY RESPONSE PLAN
“Life safety of all parties is the #1 priority. Lives will not be risked to save property,” from the Fairfax County (VA) Fire and Rescue Department.
“Department personnel shall not directly contact cleanup/disposal agencies. The responsible party should make this contact. The responsible party is to be informed that he/ she is financially responsible for the cleanup/disposal of hazardous materials,” from the Seattle (WA) Fire Department.
“Avoid committing personnel and equipment prematurely or ‘experimenting’ with techniques and tactics. Many times it is necessary to evacuate and wait for special equipment or expert help,” from the Philadelphia (PA) Fire Department.
“Due to inclement weather or other pertinent factors, decontamination at the scene may not be possible. In this situation, the nearest suitable designated structure may be used as the decontamination station for personnel and equipment,” from the Chicago (II.) Fire Department.
“Non-department personnel: Certain hazardous materials incidents may require use of technical personnel, manufacturer’s representatives, shipper or carrier experts, etc., to evaluate hazards and/or perform specific functions inside the Hot Zone. Such operations will only be conducted with the approval of the Incident Commander, and will be under the direct supervision of the Hazardous Materials Unit leader,” from the Prince George’s County (MD) Fire Department.
“REMEMBER, QUICK AGGRESSIVE ACTION HAS NO PLACE AT A HAZARDOUS MATERIALS INCIDENT, and may only lead to unnecessary exposure of personnel. Often times the proper action decided upon may be to take NO ACTION beyond keeping department and civilian personnel at a safe distance. There may be situations where NO ACTION will be the only safe action for first arriving units to take because of lack of proper protective clothing,” from the Boston (MA) Fire Department.
- Next we included items from our state laws and state hazardous-materials emergency response plan that hadn’t yet been covered. Every jurisdiction will have specific requirements that apply to their operations and won’t be covered in anyone else’s documents. For example,
“The Director shall establish a special hazardous materials emergency response organizational unit within the department to function as the initial response element of the hazardous materials emergency management program,” from Arizona Revised Statutes Title 41.
“If the situation is thought to present an immediate threat to health or the environment, report the discovery as an emergency as described in Section XII of the State Flan. If there is no immediate threat to health or the environment, report the discovery to the appropriate state regulatory agency as listed in the state plan,” from the State of Arizona Hazardous Materials Response and Recovery Plan.
- Since there are specific procedures in the OSHA regulations that we want clearly understood, we included some provisions verbatim. Also, NFPA 471, Recommended Practice for Responding to Hazardous Material Incidents, contains some guidelines we wanted to incorporate into the plan. For example, “The ‘senior official’ at an emergency response is the most senior official on the site who has the responsibility for controlling the operations at the site. Initially it is the senior officer on the first-due piece of responding emergency apparatus to arrive on the incident scene. As more
- senior officers arrive (i.e., battalion chief, fire chief, state law enforcement official, site coordinator, etc.) the position is passed up the line of authority which has been previously established,” from OSHA’s 29 CFR Section 1910.120, and
“Ignition sources should be eliminated whenever possible at incidents involving releases or probable releases of flammable materials. Whenever possible, electronic devices used within the hot zone should be certified as intrinsically safe by recognized organizations. Communication devices used within totally encapsulated protective suits do not need to comply with the above as long as the suit remains pressurized,” from NFPA 471.
- The next step was the most challenging, since we needed input from the field to see what we’d gotten wrong or had overlooked. During this step the plan went through three drafts, and we had several occasionally heated meetings to hammer out the new provisions. It must be recognized that not just the chiefs have good ideas, and that, ideally, plans are made by the people who have to execute them. These new changes were then incorporated. They included:
“This is the final stage of the incident. As the shipper, spiller and/or owner are responsible for recovery and cleanup, the Arizona Department of Public Safety will not actively participate in this stage without permission of the Incident Commander, and [then only if) extenuating circumstances exist” and “The warm zone surrounds the hot zone and is also a restricted area. The level of personal protection required in the warm zone will usually be less than that in the hot zone.”
- The plan was then fielded to look for cumbersome or inapplicable provisions. As we found these small glitches, we made notes and incorporated the field experience in the final version, after testing it for several months. The final document was distributed and forwarded through the department process for publication as an official agency procedure.
- Since we wanted to be able to
OSHA-REQUIRED EMERGENCY RESPONSE PLAN
- attribute each provision of the plan, we footnoted all changes from the basic San Franciso Fire Department operating guide. Thus our final plan has 83 footnotes that literally show the source of every word it contains. We plan to continue this practice so that we can document how each part of the plan evolved.
- The final plan is issued in looseleaf form, with each paragraph numbered for easy reference. We organized the plan into the following sections:
INTRODUCTION
Purpose—development of standard operating procedures and listing of responsibilities.
Definitions of hazardous-materials spills or incidents.
Compliance with OSHA requirements for written emergency response plan.
Promulgation and review dates. RESPONSIBILITY
Functions of duty office and hazardous-materials unit as provided by state law and interagency agreements.
Critical containment and recovery stages—severity of danger; methods of containment; shipper/carrier responsibility.
Use of private contractors and state employees; reporting procedures for immediate threats.
ACTIVATION
Department notification of categories of spills or releases initiation and reporting procedures prescribed by state interagency agreement.
SCENE MANAGEMENT Agency relationships—coordination of resources; support of local and county government.
Incident command system—OSHA requirements; senior official responsibility; inhalation hazard and required respiratory protection and
monitoring; designation of safety official.
HAZARDOUS-MATERIALS INCIDENT
CLASSIFICATION
Levels of incidents and definitions; defining criteria; examples of typical incidents.
- Level I —minor incident handled by first responders: hot zone required; lack of IDLH conditions; cargo tank incidents not requiring off-loading.
- Level II—major incidents that may not require outside agencies: overturned highway cargo tanks; train derailments not involving hazardous-materials tank cars.
- Level III—local disaster: beyond the capabilities of local jurisdictions and resources; may last days and require extensive evacuations.
RESPONSE
- Level I—initial dispatch; use of hazardous-materials unit.
- Levels II & III —hazardous-materials unit; ambulance and paramedics; command post vehicle dispatch.
HAZARDOUS-MATERIALS UNIT PERSONNEL
Purpose—compliance with state law; location and composition.
Capabilities—knowledge of risks and outcomes; material identification.
Medical surveillance program—mandatory for hazardous materials unit; examinations; OSHA compliance; physician determination.
Diagram—location of hot, warm, and cold zones; command post; access control points, decontamination, staging area; weather factors.
PROTECTIVE CLOTHING
Purpose—positive-pressure breathing apparatus; limitations; hygiene.
Levels A, B, C, & D —EPA definitions; breathing apparatus; boots, gloves, protective clothing.
Structural firefighting clothing—definition; lack of chemical protection; conditions when allowable; nonuse of leather.
Identification of material—airborne
contamination; determination of proper protective clothing; basis for decisions.
OSHA compliance—permissible exposure limits; positive-pressure breathing apparatus; mandatory Level A protection; decreasing protection.
TERMINATION OF INCIDENT
Incident commander—duties, determinations; scene restoration.
Responsible party—cost of operation; responsibility for cleanup; notification; private cleanup contractors.
INCIDENT ANALYSIS AND REPORTS
Postaction review —incident commander and hazardous-materials unit; possibly not conducted at scene.
Postincident assessment (critique) — scheduling; attendance; visual supporting material; objective.
Reports—incident report; after-action report; “lessons learned.”
Incident site log—material description; names and job assignments of personnel; entry/exit times; chronological record; exposure records.
FIRST-RESPONDER FUNCTIONS
Arrival procedures—approach direction; vehicle location; smoke; assessment from a distance; “worst case” considerations.
Material identification—presence of fire; apparent release; placards; labels; verbal information; DOT guidebook.
Technical assistance—fire and police; industry; hazardous-materials unit; poison control center; medical personnel.
Protection measures—upwind/uphill for personnel and vehicles; distance; avoid contact; avoid action until hazards known.
Site management—rescue; isolation; evacuation; control; exposure.
“No action” decision—safety of any actions; product identification, avoid dangerous commitment; inappropriateness of quick, aggressive action.
APPENDICES:
HAZARDOUS-MATERIALS UNIT FUNCTIONS
Purpose—technical assistance; equipment; incident commander direction.
Assessment—material properties; dispersive energy of material; potential harm; monitoring.
Objectives—meetings; references; technical experts; coordination with other agencies; advising incident commander; advanced control and containment; SOPs.
OSHA compliance —unit training; procedures for incidents; unit purpose.
ON-SCENE ACTIONS
Incident commander —immediate steps; relaying information; notification of appropriate agencies.
Identification—necessity; barring entry; “worst case” assumption.
Technical assistance —reference books; department assets; poison control centers; industry; Chemtrec.
Hazardous-materials unit — control within the safety perimeter; equipment.
Monitoring—flammable atmosphere, determination around complete perimeter; quantifying atmospheres; IDLH conditions; periodic monitoring of situations and their requirements.
Personal protection —inadequacy of duty uniform; taping procedures; upwind location of unprotected personnel.
Incident considerations—safety of responders and public; property and environmental damage; rescue; isolation; control; exposures.
Injured persons—minimize contact; transfer point; contamination; examination of persons who may have been exposed. _
Evacuation—control zones; relocation of evacuees; personnel available to assist; DOT recommended distances.
Containment—small area; no flushing; diking; contaminated runoff.
Isolation —elimination of ignition sources; eating and drinking; alarm system.
COMMAND POST
Location —upwind; cold zone; safe distance.
Function—staffing; incident commander role; hot zone command.
Public information—appointing public information officer; coordinate all information releases.
STAGING AREA/RESOURCE POOL
Location—proximity; increase in incident intensity; entry route.
Function —equipment and personnel reporting; rally point; uncommitted assets.
Wind information—velocity and direction; reporting method.
HAZARDOUS-MATERIALS INCIDENT
CONTROL ZONES
Variable factors—properties of material and container(s); wind and weather; geographic features of area; dispersion patterns.
Hot zone—maximum hazard; access control; decontamination line; minimum number of personnel; barricades.
Warm zone—lower level of protection; restricted entry location; staging.
Cold zone—public exclusion; access route; emergency evacuation.
Support personnel—specialized job functions; specific assignments.
Safety officer—OSHA requirements; duties; logs; IDLH conditions; suspension of operations; relationship with incident commander.
Safety team —rescue or backup; personal protective clothing; line-ofsight.
Security—hot zone integrity; utilization of law enforcement personnel; location; protective equipment.
Control officer—duties in warm zone similar to hot zone; safety officer; log; security.
Emergency medical treatment personnel-triage; communication; decontamination; hospital coordination.
Protective clothing—determine appropriate level (A, B, C, or D).
Resources—fire department and law enforcement; technical experts;
HAZARDOUS MATERIALS
OSHA-REQUIRED EMERGENCY RESPONSE PUN
special equipment/apparatus; cleanup contractor.
Site management—hot zone control with barricades; warm zone identification and control; direct supervision of all hot zone operations. Release control—safety of personnel paramount; avoid contact; ignition sources; confining released product; secure container. Decontamination —establish area; personnel; equipment; apparatus; medical evaluation and follow-up. Termination —interface with cleanup personnel; critique.
Duties—appropriate assignment of duties; command of unit; personnel safety.
LEVELS OF PROTECTION AND PROTECTIVE GEAR (extract of Appendix B, 29 CFR Section 1910.120) Selection of equipment—identification of material; properties of protective equipment; selection process.
Guidelines—Levels A, B, C, and D; complete inventory of items; designation of optional items; specific circumstances dictating equipment.
USING OPERATING GUIDE AND ACKNOWLEDGMENTS Derivation—based on San Franciso Fire Department Hazardous Materials Operating Guide.
Sources—Fire departments of: Prince George’s County, Seattle, Fairfax County, Houston, Philadelphia, New York, Boston, Chicago, Denver, Los Angeles (City and County), Phoenix.
Composition —inclusion of OSHA requirements; NFPA.
Changes —regional terms; specific job titles; minor editing for clarity.
DECONTAMINATION Procedures—standard operating procedures; minimize contact; clothing and equipment; monitoring for effectiveness; location.
Personal protective clothing—cleaning and laundering; replacement; disposal; use of detergent-water solutions.
CHECKLISTS
Fixed facility; highway; rail; decontamination; safety officer.
Modification of Prince George’s County checklists.
DEFINITION OF TERMS
Definitions of 32 key terms and sources of definitions (specific department, NFPA, DOT, etc ).
GOVERNOR’S EMERGENCY FUND
Function of Division of Emergency Services—update governor’s emergency proclamation; coordinate fund disbursement; financial records.
Scene procedures—initial response elements of state government; state on-scene coordinator; requesting funds.
State contract —state purchasing office; private cleanup contractors.