It’s probably not news to you that working with hazardous waste requires a plan for dealing with disasters. But did you know the EPA requires hazardous facilities to prepare for internal disasters like chemical spills along with external events like an earthquake or wildfire?
As a small- to large-quantity hazardous waste generator, you’re required to have a fully compliant contingency plan, and the lack of one could have dire safety and legal consequences.
Ask yourself: If a disaster struck your facility today, would all your employees know how to react, who to report to, and what steps they should take to mitigate or escape the resulting dangers? If the answer is no, then it’s time to review your disaster contingency plan.
Creating a proper contingency plan is important, but how do you ensure the plan is easy to implement and follow without disrupting your operations?
Here are the steps required to create an effective plan and ensure it is administered effectively.
1. Define what a disaster is
The EPA recommends approaching your contingency plan as a series of “what if” scenarios. What if this chemical stockpile were to ignite? What if an earthquake were to cut power to this critical cooling machinery? What if a fire were to block this doorway? In modern industries, you should also account for electronic and digital concerns, like what if our waste control computers are disabled by a virus?
In a real disaster there’s no time to hold a meeting about whether a disaster is happening, so your plan should thoroughly account for every possibility that’s relevant to your facility and its location. To keep the plan easy to implement, focus first on broad categories that should always trigger a disaster response, like smoke or flames, spills, and extreme weather conditions.
Train your personnel to overreact rather than underreact when reporting these events, so there’s never any question about whether potentially dangerous situations should be evaluated immediately for possible disaster response.
2. Assign emergency coordinators
The EPA and most state regulators require hazardous facilities to have a designated primary emergency coordinator. This coordinator must be available at all times and should be the main contact whenever a disaster is suspected or confirmed.
Your emergency coordinator must be familiar with every aspect of your contingency plan and should serve as the primary point of coordination for any disaster response. The coordinator needs to have full authority to implement any and all aspects of that plan and should be prepared to serve as the main contact for emergency responders and government agencies.
It’s crucial to ensure that every member of the workforce is aware of who the emergency coordinator is, and either has their contact information memorized or knows where to find it immediately. Contact information should include all addresses, along with phone or pager numbers for office, home and travel.
3. Describe the emergency response and containment plan
Federal regulations thoroughly specify the order of events that your emergency coordinator must follow in a possible disaster scenario.
A compliant contingency plan puts two priorities first: identifying and verifying the source of the disaster before activating facility alarms and immediately notifying both facility and governmental authorities.
A disaster response plan should be written to immediately trigger evacuation procedures when the event is confirmed, including any signals or communication that will be used to sound the alarm and notify facility personnel of the evacuation. Your plan must also thoroughly describe the evacuation procedures themselves, including evacuation routes and alternates if the primary routes are blocked.
Once personnel safety and evacuation is underway, the coordinator must focus on determining whether the disaster can be mitigated or brought to a safe conclusion, and should already be in close communication with responding authorities to make those determinations.
It’s critical that each department, team, and area of your facility has its own specific procedures to follow in a disaster plan. From escape routes to notifications and more, responses from personnel can vary widely across your facility, and each specific response should be clearly defined in your written plan and all relevant training.
In a true disaster, response and recovery are likely to last well beyond the initial event, so your plan should also include contingencies for containment and recovery over the ensuing days, weeks and months afterward—always in coordination with governmental authorities.
4. Identify your hazardous waste
Your written plan should also include a thorough list of all the identified hazardous waste in your facility, including a clear layman’s explanation of the specific dangers they might present. Your plan also needs to include estimates of the maximum amount of hazardous wastes on-site at any given time, both to keep personnel mindful of the dangers and to notify authorities of the potential risks.
Finally, your plan must clearly describe any hazardous wastes that may require unique or unusual treatment or response, along with maps showing where dangerous waste may be located throughout your facility, even if those locations only contain the products occasionally.
5. Include plans to prevent hazmat exposure
Your procedures should include clear specifications for training employees about how to properly handle and dispose of hazardous waste, along with defining the specific steps they should take if they’re exposed to hazardous materials in both disaster and regular workday scenarios.
6. Include the location of safety equipment
Every facility that generates hazardous waste is required to have a communication device on-location to notify the authorities and contact facility coordinators. Whether it’s a telephone, two-way radio or other devices, its precise location must be included in your written plan, with clear procedures for who should use the device and when.
Your plan also needs to clearly identify the location of all response material, like fire extinguishers, spill control materials and other decontamination equipment.
Finally, your plan should identify all water supply locations and highlight those that can be used by emergency responders.
Integrating your disaster contingency plan
Once you’ve created your written plan, it must be incorporated into all your training and logistical activities. Ensure the plan meets the federal guideline checklist, then educate all personnel about their role in that plan to reduce your risk and keep your facility running smoothly and safely. If you need help with creating your contingency plan, then schedule a free consultation with us.