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Emergency Preparedness for Process Safety - 3/18/2010

Emergency Preparedness

Emergency Preparedness is a critical component of Process Safety Management programs. Each employer must address what actions employees are to take when there is an unwanted release of highly hazardous chemicals. Emergency preparedness is the employer’s third line of defense that will be relied on along with the second line of defense, which is to control the release of chemical. Control releases and emergency preparedness will take place when the first line of defense to operate and maintain the process and contain the chemicals fails to stop the release. In preparing for an emergency chemical release, employers will need to decide the following:

  • Whether 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;
  • Whether employers want their employees to evacuate the danger area and promptly escape to a preplanned safe zone area, and then 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 or third lines of defense they plan to have, develop the necessary emergency plans and procedures, appropriately train employees in their emergency duties and responsibilities, and then implement these lines of defense.

Employers, at a minimum, must have an emergency action plan that will facilitate the prompt evacuation of employees when there is an unwanted release of a highly hazardous chemical. This means that the employer’s plan 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 a safe zone. The intent of these requirements is to alert and move employees quickly to a safe zone. Delaying alarms or confusing alarms are to be avoided. The use of process control centers or buildings as safe areas is discouraged. Recent catastrophes indicate that lives are lost in these structures because of their location and because they are not necessarily designed to withstand overpressures from shock waves resulting from explosions in the process area.

When there are unwanted incidental releases of highly hazardous chemicals in the process area, the employer must inform employees of the actions/procedures 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 employers should place a wind direction indicator, such as a wind sock or pennant, at the highest point visible throughout the process area. Employees can move upwind of the release to gain safe access to a refuge area by knowing the wind direction.

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 in advance and procedures developed and implemented. Handling incidental releases for minor emergencies in the process area must include pre-planning, providing appropriate equipment for the hazards, and conducting training 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, identify, and meet the training needs for employees who are expected to handle incidental or minor releases.

Preplanning for more serious releases is an important element in the employer’s line of defense. When a serious release of a highly hazardous chemical 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 employees to render aid to those in the immediate release area and to control or mitigate the incident, refer to OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. If outside assistance is necessary, such as through mutual aid agreements between employers and local government emergency response organizations, these emergency responders are also covered by HAZWOPER. The safety and health protection required for emergency responders is the responsibility of their employers and of the on-scene incident commander.

Responders may be working under very hazardous conditions; 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 also will aid the employer in complying with the Environmental Protection Agency’s Risk Management Plan criteria.

An effective way for medium to large facilities to enhance coordination and communication during emergencies within the plant and with local community organizations is by establishing and equipping an emergency control center. The emergency control center should be located in a safe zone so that it could be occupied throughout the duration of an emergency. The center should serve as the major communications link between the on-scene incident commander and plant or corporate management as well as with local community officials. The communications 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 communications network in case of power failure or if one communication means fails. The center also should be equipped with the plant layout; community maps; utility drawings, including water for fire extinguishing; emergency lighting; appropriate reference materials such as a government agency notification list, company personnel phone list, SARA Title III reports and material safety data sheets, emergency plans and procedures manual; a listing the location of emergency response equipment and mutual aid information; and access to meteorological data and any dispersion modeling data.


 

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