Appendix B B-1

Appendix B: Emergency Response Analysis

Sir Robert Baden-Powell (Chief Scout of the World, 1857 - 1941) used the motto "Be
prepared" and preparedness is possibly the most important requirement in Emergency
Response. The acronym "HAZWOPER" is the name for the OSHA standard - 29 CFR
1910.120: Hazardous Waste and Emergency Response Operations. It impacts two basic
areas of the operating facilities - planning and training, and promotes 3 levels of response
- evacuation, containment, and control.
Central to the concept of Emergency Response is to have an Integrated Communication
System (ICS) with an incident commander being responsible for the command function.
The incident commander is responsible for:
• Assessing the situation
• Establishing goals and procedures so that the situation can be controlled
• Allocating resources for the emergency response.
Such an onerous role cannot be undertaken without pre-planning.
Since on-the-spot and rapid response is required in many companies, the incident
commander and the plant safety officer will likely be one and the same person. The
incident commander will assume command from a first responder who will have been
first at or close to the location of the incident rapidly following occurrence. The first
responder will likely, as much as possible, evacuate the immediate area.

Pre-emergency planning and coordination with outside agencies

The incident commander is responsible for the coordination of emergency response
planning with government agencies such as fire services and hospitals and, in the event of
impacting the surrounding community, the police and emergency management services
(under the National Response System). In essence pre-planning is needed as opposed to
waiting for the event. Such plans require the notification of the applicable authorities of
essential infonnation. Too much, non-relevant infonnation, is likely to confuse, therefore
the pre-emergency planning information passed on to external agencies needs to be
limited to essential information. For example, if certain types of fire extinguishing agents
are incorrect or would cause increased hazards these need to be identified to the fire
services. Also if the Company has chemicals, the toxicological profile for such chemicals
needs to be developed. If the chemicals could undergo combustion or other chemical
reactions this needs to be communicated to the hospital services so that they are prepared
to treat possible injuries.

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 B-2 Appendix B

Personnel roles, lines of authority, training, and communication

An emergency response team must be well organized so that (a) each responder knows
their specific role and (b) each responder can act effectively. Since incidents are
unexpected, the requirements of the team will likely be taxed to the extreme and could at
times, also be life threatening. The concept of applying "military-type" thinking and
organizational approaches is not out of place. Each responder should:
• Know what his or her role should be
• What is expected of them
• Have a number of key plans (probably area specific for a large facility) that have
been rehearsed and simulated beforehand
• Know what do and when to do it is key.
• Know the chain of command regarding decision making.
In theory anyone could be a responder but there is a need to select people in good health,
who have unimpaired faculties such as hearing and eyesight. The reason for this is
twofold: in the first place if someone is in poor health this may limit their ability to move
rapidly and easily in difficult circumstances and, secondly, allowing a person with health
problems to be a responder could also put that person at considerably increased risk.
However the degree of impairment and practical considerations need to be assessed
before a potential responder is not included.

Emergency recognition and prevention

Any facility that is required to perform a Process Hazards Analysis (PHA), such as
HAZOP or other form of PHA should be familiar with the types of process hazards. In
addition the use and distribution of Material Safety Data Sheets (MSDS) should make
personnel familiar with these. The following table shows typical data that needs to be
available on the MSDS.

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 Appendix B B-3

Information typically required for MSDS

SECTION INFORMATION REQUIRED

PRODUCT Product Identifier:

INFORMATION Product Code:
Manufacturer's Name and Address:
Supplier's Name and Address:
Business No.:
Emergency No.:
Business No.:
Emergency No.:
Product Use:

HAZARDOUS Ingredients
INGREDIENTS CAS #
Wt.%
LC50 (ppm)
LD50 (mg/kg)

PHYSICAL DATA Physical State (gas, liquid or solid):

Appearance and Odor:
Odor Threshold (ppm):
Vapor Pressure (mm Hg):
Evaporation Rate:
Freezing/Melting Point (deg C):
% Volatile (by volume):
Density (g/ml):
Specific Gravity:

Vapor Density (Air = 1):

Boiling Point (deg C):
Solubility in Water (at 20 deg C):
pH:
Coefficient of OillWater Distribution:

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 B-4 Appendix B

Information typically required for MSDS

SECTION INFORMATION REQUIRED

FIRE AND Conditions of Flammability:

EXPLOSION Flash Point and Method:
HAZARD Lower Explosive Limit (LEL) (% by volume):
Upper Explosive Limit (DEL) (% by volume):
Auto-ignition Temperature:
Extinguishing Media:
Hazardous Combustion Products:
Explosion Data:
Sensitivity to Mechanical Impact or Static Discharge:

REACTIVITY DATA Unstable: [ ] yes [ ] no

If unstable, under which conditions?
Incompatible Materials:
Hazardous Polymerization: [ ] yes [ ] no
If yes, under which conditions?
Hazardous Decomposition Products:

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 Appendix B B-5

Information typically required for MSDS

SECTION INFORMATION REQUIRED

TOXICOLOGICAL Routes of Entry/Exposure:

PROPERTIES / [ ] Skin Contact
HEALTH HAZARD [ ] Skin Absorption
DATA [ ] Eye Contact
[ ] Inhalation
[ ] Ingestion
LD50:
LC50:
Effects of Acute Exposure to Product:
Effects of Chronic Exposure to Product:
Exposure Limits:
Irritancy of Product:
Sensitization to Product:
Reproductive Toxicity:
Carcinogenicity:
Teratogenicity:
Mutagenicity:
Names of Toxicologically Synergistic Materials:

FIRST AID Inhalation:

MEASURES Skin:
Eyes:
Ingestion:

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 B-6 Appendix B

Information typically required for MSDS

SECTION INFORMATION REQUIRED

PREVENTIVE Engineering Controls:

MEASURES Personal Protective Equipment:
Gloves (type of material):
Eye Protection:
Respiratory Protection:
Clothing:
Storage Requirements:
Handling Procedures and Equipment:
Leak/Spill Clean-up:
Waste Disposal:
Special Shipping Information:

PREPARATION Prepared by (Group, Department, etc.)

INFORMATION Phone #:
Preparation Date:

Safe distances and places of refuge

Safe distances and places of refuge will largely depend on the type of incident or release.
For toxic releases sheltering in buildings may offer some protection provided the
emissions are not lengthy in time. With thennal radiation buildings can offer protection
provided they are not likely to themselves become flammable. Explosions are hard to
protect against: below ground basements, constructed of concrete can offer protection
provided that they do not offer an ingress potential for heavier than air toxic or
flammable materials.
It may be argued that there needs to be protection against at least the worst credible
release case scenario applicable to the external surrounding community.

Site security and control

In the event of an incident it becomes essential to limit access to only essential personnel.
There are two main reasons: firstly the incident site can be a considerably more
hazardous location than it was previously and, secondly, important evidence as to the
nature of the incident may be destroyed and/or contaminated from a forensic standpoint.

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 Appendix B B-7

It will be necessary to rope off the area around the incident location and, possibly, post
security guards or security personnel to prevent ingress of undesirables and souvenir
hunters.

Evacuation routes and procedures

Site layouts on newer plants, say within the last 10 to 20 years, are likely to be better
from an escape perspective than older plants where the original design objective was to
minimize piping by minimizing spacing. A well-designed new plant should normally
have at least two alternative escape routes from most locations. Well-designed walkways,
stairs and alleys should be wide enough to accommodate firemen or rescue workers
wearing full self contained breathing apparatus (SCBA).
Well-designed evacuation routes and procedures consider not only the egress of people
but also the ingress of rescue workers, firemen and first aid personnel. Exit signs should
be posted and evacuation exercises, based upon fire and emergency drills should be
performed on a regular basis.

Decontamination
It is important that incident responders are not threatened by contamination or by the
toxic effects of the chemical hazards to which they are responding. For example, many
companies, such as oil refineries, preclude people with beards onsite since, in the event of
a sour gas release, containing the highly toxic hydrogen sulfide, the SCBA face mask
would not make an adequate seal.
As well as the information included in the MSDS it is necessary to determine how
effective the protective equipment will actually be and what methods of decontamination
(showers etc.) should be used. Also if a responder is affected how should they be treated?
Should they be given oxygen etc.?
Some chemicals, such as concentrated sulfuric acid, can be incredibly corrosive,
dissolving clothing instantly, so the effectiveness of protective gear needs evaluating.

Emergency medical treatment and first aid

Hazardous materials incidents can rapidly overwhelm the available ambulance corps and
a hospital's trauma resources, yet prompt response is essential in saving lives. An
understanding of availability of medical and medical transportation capabilities needs to
be understood, upfront. The incident could also impact the local community.

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 6-8 Appendix B

Facilities that use hazardous substances should assist with the provision of antidotes and
treatment materials for use by local medical practitioners. The facility should be aware of
the hazards and traumas that could occur with an incident.

Emergency alerting and response procedures

The facility needs to create a simple method of alerting and mustering the emergency
response team and this method needs to be outlined in detail in the emergency response
plan.
Different types of alarms, sirens and warning signals can be used to denote different
types of emergencies. The emergency response team and facility personnel need to be
fully aware what each of them mean and during practice drills, performed on a regular
basis, they can be learnt. Companies can also have specific telephone codes so that
specific alerting situations can be initiated.

Critique of response and follow-up

After a response has been initiated, a critique is required. This should be completed by all
members of the response team to assesses:
• Type of response (Drill, Fire, Release, Other)
• Any problems with the plan
• Performance of Site Personnel, Emergency Response Team
• Treatment of exposed personnel on-site, off-site
• Adequacy of communication systems, power & lighting systems
• Recommendations for changes to equipment, procedures and any other issues.
The incident commander should report the incident to the appropriate Corporate, Local,
State (or Provincial) and Federal authorities.
After the incident the inventory of emergency response equipment should be checked
and, if necessary, restocked. Also the emergency response team needs to be polled
regarding the adequacy of the equipment: if necessary upgrade the equipment.

Personal protective equipment (PPE) and emergency equipment

The inventory of PPE and emergency response equipment and materials should be
checked and listed. There should be instructions on how the PPE and equipment and
materials are to be used, their limitations, and in what situations emergency responders

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 Appendix 8 8-9

should use them. The incident commander needs to be aware of the PPE available and
training requirements (e.g. as with SCBA) needed for their use. Responders may need
training to meet HAZMAT technician & specialist levels to use the equipment.

Usage of Local and State plans

To avoid duplication organizations may use the local emergency response plan or the
state emergency response plan or both as part of their emergency response plan.
Community emergency response agencies need to be integral components of the
community emergency response plan. The community-wide emergency response plan
should spell out specific roles and responsibilities for various organizations or agencies,
and will state which function each agency is expected to play in the event of an
emergency.

HAZWOPER training
This is given at 5 different levels:
• First responder - awareness level for evacuation
• First responder - operations level for containment
• Hazardous materials technician level for control
• Hazardous materials specialist level
• Incident commander level
In general, the incident commander must have an understanding of and ensure the
compliance of relevant regulations/guidelines, such as:
• OSHA 29 CFR 1910 Subpart I (1910.132-138): Personal Protective Equipment
• OSHA 29 CFR 1910.1000: Hazard Communication
• OSHA 29 CFR 1910.146: Confined Space Entry
• ASTM E260: Standard Practice for Reporting Opinions of Technical Experts
• ASTM E860: Standard Practice for Examining and Testing Items That Are or
May Become Involved in Products Liability Litigation
• ASTM 1020: Standard Practice for Reporting Incidents

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 B-10 Appendix B

Incident Command System (leS)

An ICS helps to apply resources to incidents in an efficient and effective manner and
should include the following:
• Common terminology: Use of a common vocabulary to preserve coordination
between agencies.
• Modular organization: This can enhance coordination by clarifying the roles of
individuals.
• Integrated communications: This involves the use of standardized signals or
procedures for radio, telephone, and visual transmission.
• Unified command structure: This is intended to ensure that all agencies are
involved in the decision-making processes. A unified command structure is also
useful.
• Consolidated action plans: To ensure that all agencies involved are properly
integrated.
• Manageable task loads: To ensure that the responsibilities are so distributed to
avoid overloading of specific individuals or groups.
• Pre-designated incident management facilities: This requires the command post
to be physically located at an upwind location. The command post should be
stocked with emergency response equipment and house the emergency response
services.
• Comprehensive resource management: A centralized control helps to coordinate
various activities within and among agencies effectively and efficiently.

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Appendix B B-11

Ref. References and Suggested Reading

No. (Note: Internet URLs current at date of publication)

1 "Hazwoper Incident Command: A Manual for Emergency Responders", D.M. Einolf

http://www.amazon.com/exec/obidos/tg/detail/-/0865876126/104-6841845-
7225S50?v=glance

2 "A Basic Guide for Users - Canadian WHMIS Version", Canadian Centre for
Occupational Health & Safety

http://ccinfoweb.ccohs.ca/help/msds/msdsCDNGUID E. htm I

3 "CPL 02-02-059 - CPL 2-2.S9A - Inspection Procedures for the Hazardous Waste
Operations and Emergency Response Standard, 29 CFR 1910.120 and 1926.65,
Paragraph (q): Emergency Response to Hazardous Substance Releases", US Dept.
of Labor

http://www.osha. gov/ pi s/oshaweb/owad isp. show_docu ment?p_ta ble = DI RECTIVE

S&p_id= 1572#index

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