- By Kirk Abbott
- Sep 01, 1999
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Stringent requirements of regulatory agencies such as the Occupational Safety & Health Administration (OSHA) and the U.S. Environmental Protection Agency (EPA) have provided the basis for an ever-soaring safety and health awareness for workers and the environment. Increased awareness has led to strong demand for accident pre-planning. Pre-planning is interpreted by safety and health professionals to include both emergency response planning and training. For an effective program, these two have to be implemented and followed.
The written health and safety program
Emergencies in the workplace can range from toxic gas releases and chemical spills to employee violence and sabotage. These incidents may occur at any time without any prior warning. Preparing for them is a challenging, but essential task. Specific industries, facilities and operations require guidelines for the preparation of mandated programs. Affected businesses include oil-related industries; chemical manufacturers; mining; airports; laboratories; warehouses and flammable storage facilities; and response industries such as firefighters, emergency medical services and healthcare facilities. For these industries, OSHA has developed guidelines for preparing a safety and health program, which must in turn be periodically updated and made available to all affected employees, contractors and subcontractors.
For example, under the hazardous waste operations emergency response standards (29 Code of Federal Regulations (CFR) Part 1910.120), OSHA requires that each employer develop a written health and safety program that includes:
- An organizational workplan;
- Site evaluation and control;
- A site-specific program;
- An information and training program;
- A personal protective equipment (PPE) program;
- Medical surveillance program;
- Decontamination procedures; and
- An emergency response program.
The emergency response program is a vital part of the safety and health plan for its importance in protecting employees, the public, the environment and facilities from unnecessary damage or injury. According to OSHA standards, employers must have the program ready for all types of possible emergencies before carrying out operations. The program must be in writing and available for inspection and copying by employees, their representatives, OSHA personnel and other governmental agencies with relevant responsibilities. The only exception to this is if the employer has fewer than 10 employees. In this situation, the employer must verbally communicate the plan to his or her employees.
Working hand-in-hand with EPA
EPA requires, under the Clean Air Act Amendments of 1990, Section 112(r), that employers submit a risk management plan (RMP). The purpose of the plan is to inform the public about potential hazards in facilities, to develop a dialogue between these facilities and the community, and to ensure that the public is adequately protected from accidental releases.
The RMP is based on OSHA's process safety management (PSM) program, developed to protect employees inside facilities where there is a potential for accidental releases. OSHA's PSM and EPA's RMP should go hand-in-hand. A copy of this subsection of this standard may be obtained from EPA at www.epa.gov/oar/caa/caa112.txt.
Elements of a basic emergency response program
Response actions during an emergency situation depend a great deal on planning for the situation. Planning is an integral part of the emergency response program, and is usually initiated by upper management. The planning responsibility, however, falls solely on the safety individual(s) on-site. Each site has its own unique characteristics. Therefore, each plan should accommodate only one specific site. At a minimum, the plan should incorporate six elements:
- Emergency escape procedures and emergency escape route assignments;
- Procedures to be followed by employees who must remain to perform (or shut down) critical facility operations before the facility is evacuated;
- Procedures to account for all employees after an emergency evacuation has been completed;
- Rescue and medical duties for those employees assigned to perform them;
- The preferred method for reporting fires and other emergencies; and
- Names or regular job titles of individuals or departments to be contacted for further information or explanation of duties under the plan.
The purpose of the plan is to cover the designated actions that employers and employees must take to ensure employee safety and protection from fire and other emergencies. The plan should address all types of potential emergencies, including chemical releases. Therefore, material safety data sheets (MSDSs), available for all chemicals, should be studied to determine all possible dangerous conditions. MSDSs describe in detail the hazards that a chemical may present, list precautions to take when dealing with the substance, and outline emergency and first aid procedures. These procedures should be studied and prepared for before an actual incident occurs.
The employer must provide provisions for those employees who are to remain to deal with the emergency situation, to account for all personnel after an emergency evacuation has been completed and to rescue affected employees.
In addition, the emergency action plan must also include the site's topography, layout, prevailing weather conditions, and procedures for reporting incidents to local, state and federal governmental agencies. An emergency action plan must be a separate section of the site safety and health plan, but compatible and integrated with the disaster, fire and emergency response plans of local, state and federal agencies.
The emergency action plan (Subpart E-29 CFR 1910.38 - Employee Emergency Plans And Fire Prevention Plans) also specifies that the employer must establish an employee alarm system. If the employee alarm system is used for alerting fire brigade members, or for other purposes, a separate, distinctive signal must be used for each purpose. The employer must also establish evacuation methods.
The provisions of general emergency action and fire plans must be integrated and compatible with emergency planning requirements of a particular OSHA standard, such as the hazardous waste operations and emergency response standard (HAZWOPER) (29 CFR 1910.120). Under that standard, employers must develop an emergency response plan for emergencies to address the following:
- Pre-emergency planning;
- 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 procedures;
- Emergency medical treatment and first aid;
- Emergency alerting and response procedures;
- Critique of response and follow-up; and
- Personal protective and emergency equipment.
This standard requires that employees affected by the plan must rehearse regularly as part of the overall training program for site operations. The plan must be reviewed periodically and be amended as necessary to keep it current with changing site conditions.
The requirements also specify that an employee alarm system be installed to notify employees of an emergency situation. Employees must be trained to recognize the need to stop work activities if necessary, to lower background noise in order to speed communication and to begin emergency procedures. Based upon the information available during an emergency, the employer must evaluate the incident and the site response capabilities and if necessary, proceed with the appropriate steps to implement the site emergency response plan.
Chain of command
Since the command function is so vital, employers must also establish backups for the lead individual. Emergency response team coordinator duties should include:
- Assessing the situation and determining whether it requires activation of the emergency procedures;
- Directing all activities in the emergency area, including the evacuation of personnel;
- Initiating the calls to emergency services, such as the fire departments and emergency medical assistance; and
- Directing shutdown procedures for plant operations.
In an emergency situation, panic and confusion are usually a real and constant threat. Establishing a chain of command will help minimize the negative effects. Personnel in a facility must know who has authority to make decisions in an emergency. Therefore, management and upper administration should select a person who is competent, knowledgeable and responsible for emergency command. In larger corporations, the responsible person is usually part of the hierarchical chain of individuals within a structured team.
During major emergencies, the communication infrastructure of the site may be completely immobilized. This may include telephones and other methods of wire communication. Under these circumstances, an alternative communication method is required. Each facility should have an alternative communication method that is operable at all times, regardless of the severity of the situation. This will be used to contact employees for evacuation purposes, emergency services (rescue, fire etc.) and local authorities. The alternate communication method may be an audible alarm or light, an amateur radio system, a public address system or a portable radio system. These systems must be supplied with alternative power in case the main power to the facility is cut off.
If an emergency occurs during off-duty hours, key personnel specified in the plan should be contacted, such as the plant physician, plant manager and emergency coordinator.
All employees present at the facility should be accounted for during emergencies. This can be done by setting up a sign-in board at each building or location in the facility. Employees should sign-in before entering, and sign-out before leaving the area. Using this system, the emergency response team should be able to determine the location of each individual. Police and the emergency response team should be notified of any missing person(s).
A drill should be performed at least annually and the results reported by the emergency response coordinator. The plan should be updated accordingly.
Before implementing the emergency action plan, the employer must designate and train a sufficient number of people to assist in the safe and orderly evacuation of employees. Employers must also review the plan with each employee covered by the plan when the plan is developed, whenever the employee's responsibilities or designated actions under the plan change, and whenever the plan is changed.
Employers should also review the plan carefully with employees to ensure they know and understand their emergency assignments, in order to provide employees with the highest possible protection during an emergency.
Employees must be trained to use the alarm and communication systems, and know the difference between each particular alarm as specified by the plan. They should also have an up-to-date set of phone numbers to contact in case of emergencies.
All employees must be trained on the written plan, how to get information and what to do in case of an emergency. They should be trained as per the requirements of the Hazard Communication standard (29 CFR 1910.1200). This standard incorporates handling chemicals, labeling, MSDSs and emergency actions to be performed. In addition, they should be trained on the different types of personal protective equipment (PPE), when they are required to be used, how to wear and use them, maintenance, and storage requirements.
Training should include the proper use of fire extinguishers, shutdown procedures, first aid and CPR, evacuation procedures, search and emergency rescue procedures, and trauma consultation. These training programs should be provided initially when the plan is developed, for all new employees, and annually thereafter. Training should also be provided if a new procedure or piece of equipment is introduced into the work environment.
In a medical emergency situation, only a few seconds can make the difference between life and death. Therefore, if the closest medical facility is more than four minutes away, the employer should ensure that one or more employees are adequately trained in first aid and CPR. Eye wash and shower stations should be made available in close proximity to locations where there is a potential for chemical splashes. Employees should be trained to use this equipment as well.
In case of an emergency, it is always advisable to secure the facility to prevent any unauthorized access to vital records, files and equipment. Vital records should be protected by storing them in fire-resistant safes. Duplicating these records and storing them in a separate location is also a good idea.
Accidents do occur, but when they do, it is always best to be prepared for them. Pre-planning and training can mean the difference between a minor emergency and a major disaster. In these situations, not only property and production are at risk, but also lives and limbs. Pre-planning for emergencies can, and does, save lives.
National Oceanic and Atmospheric Administration's oil spill emergency response and planning
OSHA 3152: Hospitals and Community Emergency Response - What You Need to Know
Centers for Disease Control and Prevention - Emergency medical services response to hazardous materials incidents
OSHA Regulations (Standards - 29 CFR): Hazardous waste operations and emergency response. - 1910.120
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This article originally appeared in the 09/01/1999 issue of Environmental Protection.