By Gregory Havel
According to established risk management principles (especially those promoted by Gordon Graham), high-risk, low-frequency events are the most likely to cause harm to emergency services responders; this is because of the nature of the events (high-risk) and because responders do not encounter them often (low frequency). Most of the problems with these events occur when we need to make an immediate response to the event, when we have no “discretionary time.”
We can reduce the urgency of these situations by training for them and by planning for events that are in locations known to be hazardous. This preincident planning provides us with information about a location, its hazards, the types of events that can happen there, and what will be the most effective response to these events when they happen.
In preplanning, we are assembling the basic information on a location and its hazards and making preliminary response decisions before we are dispatched in a stress-free environment with complete discretionary time. With this plan in place, the incident commander has all of this preliminary information before his on-scene arrival, thus he can make more reliable decisions on scene under less stress.
Single-family residences, small retail businesses, fast food restaurants, and small office buildings are common enough that standard operating procedures or suggested operating guidelines—combined with a one-page preplan for the business address—will be sufficient for most incidents.
A big-box retail store, a shopping center, or even a convenience store (photo 1) with retail sales, fast food, and vehicle fuel may require a more complex preincident plan because of the size or complexity of the location and the multiple hazards that are present.
(1) Photos by author.
The Occupational Safety and Health Administration (OSHA) has a standard titled Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119 and 29 CFR 1926.64. This standard was designed to reduce the risk to employees and contractors working in complex facilities that process, transport, or store certain highly hazardous chemicals (photo 2).
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This standard’s value has proven effective over the past 25 years, and its procedures are being adopted by industry for manufacturing plants (photo 3), chemical processing facilities (photo 4), and health care facilities to which the original standard does not apply.
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OSHA’s Process Safety Management of Highly Hazardous Chemicals in summary:
- The plan for implementing process safety management is the employer’s responsibility, with required employee participation.
- Process safety information must be gathered, including the hazards of the chemicals used or produced by the process, the technology of the process, and the equipment in the process; and the results of deviation from the procedures including their effects on employee safety and health.
- A process hazard analysis must be conducted, that is appropriate to the complexity of the process, and that identifies, evaluates, and controls the hazards involved in the process. This hazard analysis includes identifying the hazards of the process, identifying any previous incidents in the process, engineering and administrative controls applied to the hazards, consequences of failure of engineering and administrative controls, facility site factors, human factors, and an evaluation of the possible safety and health effects of the failure of controls on employees.
- The employer must establish a system to address the findings and recommendations from the hazard analysis, resolve them in a timely manner, document the actions taken, and communicate the actions to employees whose work may be affected.
- The employer must update and revalidate the process hazard analysis at least every five years and retain the documentation of hazard analyses for the life of the process.
- The employer must prepare detailed written operating procedures that cover start-up, normal operation, emergency shutdown, emergency operations, and start-up after emergency shutdown. They must also include the hazards of the chemicals and processes, the consequences of deviation from the written procedures, potential health hazards of exposure, control measures, safe work practices, control of hazardous energy (lock-out/tag-out), and safety systems that are in place. These procedures must be reviewed and recertified annually and at any time that the process or equipment changes.
- The employer must provide training on the processes, equipment, chemicals, and safe work practices to each employee before being assigned to work as well as doing so with documentation of the training and the method used to verify understanding of the materials presented.
- The same operating procedures and training requirements apply to the employees of a contractor who is hired to work on or around the process or its equipment.
- The employer is required to establish a procedure to manage changes in chemicals, equipment, or processing (except for the replacement of mechanical parts with equivalent parts).
- All incidents and injuries associated with the process must be investigated within 48 hours and documented, including actions taken to prevent recurrence.
- The employer must establish and implement an emergency action plan for the entire plant as required by 29 CFR 1910.38. This emergency action plan must include procedures for handling small releases.
Emergency action planning requirements for schools, detention facilities, and health care facilities (photo 5) are covered by a wide range of state and federal laws and regulations, consensus standards, and the rules of the independent commissions that certify some of these for operation. All of these agencies require emergency plans as well as periodic review and recertification of them. Most of the agencies also require periodic exercises in the use of the emergency plans.
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The risk managers at most facilities that have done this detailed planning will be happy to work with emergency services planners to ensure that their plans will work well together. This can also set the stage for a joint “disaster drill” that meets the facility’s requirement to exercise its emergency plan as well as the requirement for emergency responders to participate in this kind of exercise annually.
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Gregory Havel is a member of the Town of Burlington (WI) Fire Department; retired deputy chief and training officer; and a 35-year veteran of the fire service. He is a Wisconsin-certified fire instructor II, fire officer II, and fire inspector; an adjunct instructor in fire service programs at Gateway Technical College; and safety director for Scherrer Construction Co., Inc. Havel has a bachelor’s degree from St. Norbert College; has more than 35 years of experience in facilities management and building construction; and has presented classes at FDIC.
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