-How many different chemical spill response procedures does your safety program have?
In my experience, unless the facility has highly hazardous materials or is a Large Quantity Generator with a required Contingency Plan, programs tend to default to two standard procedures.
The two categories are often called different things…
- Controlled vs. Uncontrolled
- Manageable vs. Unmanageable
- Incidental vs. Emergency
…but the general idea is that employees can safely address one type of spill, while the second type requires a specialty team or outside support.
How Do You Define the Threshold Between Spill Response Procedures?
Regardless of your naming system, the challenge is clearly defining the threshold between the procedures.
This is because the threshold is not always intuitive and varies from chemical to chemical. A one-gallon spill of a particular material may be comfortably handled as an incidental spill, while a one-gallon spill of another chemical may qualify as a serious emergency. Further complicating matters are cases in which the same volume of the same chemical fall into different spill cleanup categories. An example of a context-driven scenario would be a flammable liquid spill contained in a chemical fume hood vs. a flammable spill located near an open flame or ignition source.
For facilities with large chemical inventories, the possible combinations of chemicals, volumes, and contexts create a staggering number of potential scenarios. Given this challenge, how do you even begin to train and prepare employees for the spills they may encounter? Is a vague description of two types of spills enough?
What Do the Regulations Say?
Contributing to the challenge is the fact that the regulations themselves don’t provide much in the way of definitive guidance. OSHA’s official FAQ definition, which references the HAZWOPER Standard, can be found here, but the general synopsis is:
The definition of an incidental spills is:
- Hazardous, but;
- Limited in quantity and toxicity
- With limited exposure potential
- While posing no or limited safety threat, health hazard, or adverse effects to employees or others in the vicinity
As a former scientist who seeks definitive numbers and guidance, the use of “limited” has always frustrated me. This is because the definition of “limited” is context-dependent. A facility using hundreds of gallons of a material has very different perception of “limited” than a facility using milliliter quantities. However, the underlying hazards and exposure potential remains the same for equal size spills.
With these challenges in mind, how can we be more specific?
Improving Your Chemical Spill Response Procedures
While every chemical spill represents a unique challenge, proactive measures can prepare for emergencies and protect employees.
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Define Your Capabilities Before a Spill Occurs:
The more you can do in advance of a spill, the safer and more efficient your response will be. Instead of simply presenting the two spill definitions and appropriate responses, provide specific examples of spills your program can and cannot handle. To do this effectively, you will need to consider your specific chemical inventory, cleanup supplies, PPE, and level of training to develop a guidance document for your most hazardous materials.
For instance, after reviewing your inventory and available cleanup materials, you may determine that you have the ability to address a one liter spill of flammable material outside a fume hood, a four liter spill of flammable material inside a fume hood, but no more than half a liter of corrosive materials in any context. You may also develop a list of materials that automatically trigger an emergency spill response (regardless of volume) if they spill outside of a fume hood or other ventilated enclosure.
Note that these threshold values need to be based on more than simply your ability to contain and absorb the spill. Highly volatile and/or toxic materials create hazardous fumes and working conditions that may fall outside the scope of your program’s standard training.
One possible strategy for determining threshold volumes for these materials is to reference the Excepted Quantities list published in the IATA DGR. This list can provide a rough frame of reference for commonly used chemicals.
A few common examples include:
Ethanol – 1 L
Methanol – 500 ml
Acetic Acid – 500 ml
Nitric Acid (<20%) – 500 ml
Diethyl Ether – 300 ml
You may find that your program is capable of safely handling spills greater than these volumes in certain contexts, but this resource can help provide a frame of reference when evaluating response strategies.
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Pursue Advanced Training
OSHA defines five training levels for emergency hazardous materials response:
First Responder – Awareness Level:
Individuals are trained to initiate appropriate emergency response procedures after witnessing or discovering a hazardous spill or release. All employees handling hazardous materials must have annual training at this level.
First Responder – Operations Level:
Individuals are trained to respond to a spill or release and make decisions to prevent the spread or further release of the material or potential exposure. This level requires 8 hours of specialized training (called FROL training), plus “awareness level” competency.
Hazardous Materials – Technicians:
Individuals are trained to actively respond and take steps to stop and clean up the released material. This level requires 24-40 hours of specialized training at the “operations level” (called HAZWOPER training).
Hazardous Materials – Specialists:
Individuals are trained to serve as subject matter experts for a specific substance requiring response and containment. This level requires a minimum of 24 hours of specialized training at the “technician level”.
On-Scene Incident Commanders:
Individuals are trained to assume control of larger or highly hazardous spill or release scenes. This level requires a minimum of 24 hours of specialized training at the “operations level”. Additional, individuals must demonstrate competence implementing the incident command system and employer, local, and state emergency response plans.
Common Applications of These Trainings
Most safety programs don’t need to consider the Specialist or Incident Commander designations, but most benefit from having representative with FROL and/or HAZWOPER training.
FROL Training provides a basis for emergency response decision-making. During an emergency, the FROL-trained individual can make decisions for the company about whether outside assistance is needed. In most cases, outside support is generally provided by the local fire department and a contracted hazardous waste vendor. Emergency Coordinators and Chemical Hygiene Officers at facilities with hazardous chemical inventories are ideal candidates for FROL training.
HAZWOPER Training is generally specific to programs with onsite emergency response teams. In these cases, hazardous materials response is part of the employees’ job description. Training includes how to assess, approach, contain, and cleanup potentially hazardous material, as well as how to use required PPE and survey equipment.
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Plan and Hold Chemical Spill Response Drills
The best way to assess readiness is by practicing emergency response procedures in non-emergency situations. Because of this, it’s a good idea to incorporate drills into the overall safety program. Unannounced spill scenarios, refresher training exercises, and “safety week challenges” are all productive strategies.
Regardless of the approach, these drills are a fantastic way to identify areas for program improvement. Additionally, you may find that they are great team-building exercises as well.
If you have questions about chemical spill response procedures or would like help planning productive response drills, please contact us at info@spotlightsolutions.com or spotlightsafetyinc.com to schedule a free consultation.
