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Often, the first responders on-scene deter-mine whether a chemical spill or release is an emergency. But how many of you even consider this? If you are called to the scene, is it a foregone conclusion that your involvement is mandatory? Determining whether an emergency exists can be a difficult decision, but it is one that must be made.
Let’s look at the following scenarios. Which are emergencies and require your hazardous materials response team’s service? Responses to these scenarios are provided near the conclusion of this article.
Scenario #1
One quart (one liter) of methyl ethyl ketone (MEK) has spilled from a glass laboratory container onto an open loading dock at the local university on a warm day. Is this an emergency?
Scenario #2
The same spill has just occurred in a small janitor’s closet at the same university during school hours on a weekday. Is this an emergency?
Scenario #3
A small amount of what appears to be a biological material has spilled from a red plastic “bio” bag near a dumpster at the employee entrance/exit at a hospital. Several people have walked by the spill and reported no odor or any side effects. Is this an emergency?
Determining whether a haz mat release is an emergency is important for a number of reasons. Since every hazardous materials spill or release is different, every incident must be assessed to determine whether our involvement as an emergency haz mat response team is warranted. Generally, we do not want to overreact, as this type of response is long in duration, tedious, expensive, inefficient, and possibly unnecessary. Similarly, we do not want to underreact, because this type of response may be dangerous and unsafe, and we could be cited for being negligent. Our aim should be to gauge our response according to the situation.
Hazardous materials incidents may be handled in various ways. One incident may necessitate only that a reconnaissance (recon) team of two properly protected personnel enter the spill or release area to see what has happened or what is happening. This team may also take air or liquid samples while in the spill area. Another incident may require the full Hazardous Waste Operations and Emergency Response (HAZWOPER) [found in OSHA’s Code of Federal Regulations (CFR) section 1910.120] team approach with a designated incident commander, a safety officer, an entry team, a backup team, and a decontamination capability. Still, another incident may require that no action be taken on the part of the haz mat team but that a private contractor be employed. So, our actions as a haz mat response team depend on the incident’s emergency status.
ASSESSING “REAL” SITUATIONS
The criteria for an emergency generally include the following: an unexpected situation or sudden occurrence that is serious and urgent in nature and necessitates immediate action. Do all releases require immediate attention? Are all releases serious or urgent? Consider the following actual situations.
- On a hot and humid summer evening in the mid-1980s, a fully loaded railcar of anhydrous ammonia was noticed to be venting periodically in the rail yards of Nashville, Tennessee. A passerby reported by phone to the local emergency communication center that a white vapor cloud was emanating from the railcar’s dome area. The nearest engine crew, which also happened to be the hazardous materials response team, was called to investigate the problem.
Captain Harry White, the haz mat team leader, knew immediately on arrival what the problem was. His knowledge of railcars and anhydrous ammonia allowed him to make an accurate size-up of the situation. He knew that if a railcar is overfilled with low boiling point compressed gases, such as anhydrous ammonia, it tends to vent periodically because of a high ambient temperature. This venting is through a spring-loaded relief valve that opens at a preset tank pressure and then reseats when the internal tank pressure has been reduced.
Was this an emergency? Was it serious? Did it require immediate action? In White’s assessment, this anhydrous ammonia release was not an emergency, and he downgraded the incident to a single-engine nonemergency. To make this incident a learning experience for his personnel, White had his team members go to the top of the ammonia railcar with him to observe the intermittent release from the relief valve in the dome. As the whole team waited for the ammonia specialists to arrive and offload some product, they all observed from an upwind position the relief valve opening and closing. The whole time, a moderate wind was dissipating the vapors, and there was no effect on the area. Evacuation was not required. White realized that this incident was not a true emergency and turned it into a learning experience. He did not overreact (or underreact) to the situation but responded in a safe and responsible manner based on his training and knowledge.
- In another situation, which occurred in Wisconsin, maintenance workers spilled 400 gallons of paint thinner late one night while cleaning a large paint booth at a large automobile manufacturing facility. The paint thinner was a mixture of toluene, naphtha, and xylene and was a flammable liquid with a flashpoint of 207F. The temperature in the room in which the spill occurred was approximately 707F. Was this an emergency? Did it require immediate action? Was it serious? Hopefully, you answered yes to all of the above!
Although this was clearly an emergency, the workers did not realize it. A supervisor told them to proceed with cleanup operations so that production would not be interrupted. None of the workers had on chemical protective clothing or self-contained breathing apparatus, and no monitoring instruments were used to characterize the environment. Instead, workers used canister masks and normal cotton coveralls and cleaned the spill with an air-operated vacuum and absorbents. Fortunately, no one was hurt, and the incident ended without any further problems.
Because Murphy’s Law, which says “What can go wrong will go wrong,” is rampant at all hazardous materials incidents, it is surprising that nothing happened at this incident. Incidents like these also illustrate the power of complacency over common sense and show how it compromises personnel safety. It is no wonder that the United States Occupational Safety and Health Administration (OSHA) promulgated mandatory training within its HAZWOPER document.
Both of the above incidents involved hazardous materials, but they were handled differently. In the ammonia incident, the product and its hazards were well known, and an accurate size-up was formulated. It was determined not to be an emergency and was handled appropriately. In the second incident, which was determined not to be an emergency by on-site personnel, the product’s hazards were overlooked, and an accurate size-up was not performed. The paint thinner spill was a true emergency; a tragedy was a mere spark away, and the responders were oblivious to the danger!
ALL RESPONDERS MUST COMPLY WITH HAZWOPER
All haz mat responders must comply with the HAZWOPER regulation. Even in non-OSHA states, public responders must comply with this law indirectly through a redundant United States Environmental Protection Agency (EPA) law found in EPA 40 CFR, part 311. HAZWOPER also offers clarification in defining emergencies: An emergency is defined as “a response by employees from outside the immediate response area or by other designated responders (mutual-aid groups, local fire departments, and so on) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance.”
The definition continues, saying that “responses to incidental releases where the substance can be absorbed, neutralized, or otherwise controlled at the point of release by employees in the immediate release area or by maintenance personnel are not considered to be emergency responses within the scope of this standard.” Finally, “responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical explosion) are not considered to be emergency responses.”
This definition should help clarify when a hazardous materials release is an emergency, especially from a legal or enforcement aspect. If emergency response groups are called to assist in a haz mat release, it most likely is an emergency, at least initially; however, keep the last sentence of the above definition in mind.
For industrial personnel, a haz mat release may be an emergency in the sense that it requires immediate attention, but if the person who witnessed the release can control or clean it up quickly, it may not be an emergency. This is always a judgment call by the employee, and it should be based on previous training. Training for these specific situations can be derived from HAZWOPER, found in 29 CFR 1910.120, and from the Hazard Communication Standard (HAZCOM) found in 29 CFR 1910.1200.
To receive more clarification on this issue, OSHA has issued “interpretive quips” or IQs to better define and guide agencies toward compliance on HAZWOPER issues. These IQs, responses to specific questions, come from letters and memorandums from OSHA and represent OSHA’s policies. To receive these documents, call Federal OSHA at (202) 219-8271 or the Federal OSHA Consultation Service at (202) 219-7242. Access to the above is also available on the worldwide Web at
OSHA’S DETERMINANTS
OSHA’s IQs are based on the following six qualitative or subjective determinants and three quantitative or objective/numerical determinants.
Qualitative Determinants
Any of these six criteria can assist in determining if an incident is an emergency. A release is an emergency if
- the release poses a life- or injury-threatening situation,
- employees must evacuate the area (not to be confused with a precautionary evacuation),
- the situation requires immediate attention because of danger (i.e., a gasoline spill with a flammability hazard),
- the release causes a high level of exposure to a toxic substance,
- the situation is unclear-data are lacking or unknown, and
- the employer has made the determination beforehand through planning.
Quantitative Determinants
These criteria, as a result of airborne concentrations, can assist in the determination of an emergency:
- the release poses or potentially poses immediately dangerous to life or health (IDLH) conditions,
- the hazardous substance release exceeds or could exceed 25 percent the lower explosive limit (LEL), and
- the release exceeds the permissible exposure limit (PEL) by an unknown proportion.
Note: Without the ability to conduct air monitoring, such situations must be declared emergencies.
COMPANY DETERMINANTS
Finally, some companies have set predetermined emergencies based solely on the quantity spilled or released. One company that packages starting fluids and sterilizers has set the following guidelines for its personnel:
- If the spill size is from zero to five gallons, the employee witnessing the spill should be able to safely clean up the spill based on previous training and with his issued protective clothing.
- If the spill size is from five to 55 gallons, the facility haz mat team will respond to mitigate the release.
- If the spill size is more than 55 gallons, the facility will be evacuated, and emergency responders from the community will be notified along with a private contractor.
Other companies use approximately 25 gallons to delineate between an incidental spill and an emergency. It would be prudent for emergency haz mat team personnel to know these spill delineations for the companies in their response districts so that if called to a specific company, they will have some idea of the size of the spill before arrival.
What does all of this information mean to us? Determination as to emergency status at an incident is important for a number of reasons. First, it provides a focus for all responders to get into the right frame of mind. This focus should alert everyone to the serious nature of the incident and to the need for preventing injuries. Obviously, the determination as to emergency status should be decided early into the incident. Some haz mat response teams have even included in their checklists a cue to decide if an incident is an emergency.
Second, if the incident is not an emergency, our presence may not be required. The incident may be handled by a contractor or other trained and equipped personnel already on-scene. Also, the company that transports the spilled material or the facility at which the spill occurs may have a designated contractor who will respond to the scene. A company may be very surprised, or even perturbed, to receive a bill for services rendered by an emergency response team, especially when the services were not required or requested. Let’s leave spill cleanup to the people who are in the cleanup business. (Keep in mind, however, that some haz mat response teams conduct minor spill cleanup as a form of public relations.)
Third, if the release does not require an emergency team’s service, it may be prudent to go back into service should another emergency occur. The next release just may be a real emergency!
RESPONSES TO BEGINNING SCENARIOS
To reinforce the concepts in this article, let’s take a final look at the scenarios presented earlier and make a determination as to the emergency status and whether the services of a haz mat team are warranted.
Scenario #1
A one-quart spill of MEK would probably not constitute an emergency because it is a small quantity, the area is probably well ventilated, the material is not considered very toxic, and the amount would probably evaporate very quickly. This would probably be considered an incidental spill and could be safely cleaned up with appropriate gloves and other equipment. This spill could safely be handled by personnel with HAZCOM training. Compare this spill to an acetone spill in your own garage. What would you do at your home?
Scenario #2
This spill presents many different hazards the first spill did not. It would be considered an emergency for the following reasons: Airborne vapor concentrations may exceed the PEL for MEK, which would be a hazard to students and staff. Vapors may concentrate above the LEL, resulting in a fire or explosion hazard, especially in an unvented room. The solvent may absorb through the skin, which could cause injury to anyone who comes in contact with the material. The MEK may react with other chemicals or materials in the closet, which could create other hazards.
Scenario #3
This incident would most likely be considered an incidental response. Interviews need to be conducted with the people who walked by the spill. If they saw vapor or smelled anything, there may be an airborne hazard, which could make it an emergency that requires an evacuation for safety. Get some history on where the bag came from and what could be inside. At a fixed facility, someone must know about the bag, even if you have to call people at home. The spill may be something other than a biohazard. Most likely, because of strict performance-based laws, the materials in the bag will be of a bio background, such as blood or other body fluids or even body parts or used dressings. This could then be cleaned up by properly trained and equipped staff wearing bloodborne pathogen body protection. The haz mat team can go home!
In summary, a hazardous materials release is an emergency if it is life- or injury-threatening, if people need to be evacuated, if fire or explosion is possible, if high levels of toxins are possible, or if the situation is unclear or unknown. On your next incident, decide if it is an emergency, and act accordingly. If the situation is not an emergency, your haz mat team’s service may be unwarranted. Keep in mind all of your previous training, your experience, and your limitations. If you feel untrained or unprepared to make such a decision, call someone with more in-depth skills to make the assessment. Do not forget your resources, and err on the side of safety if in doubt. Finally, in the interest of safety, remember Murphy’s Law and its companion, O’Brien’s Law. O’Brien said that Murphy was an optimist!
References
- OSHA 29 CFR 1910.120, “HAZWOPER.”
- “Emergency Response Determinants Confirm Situation Status,” Thomas K. Wray, HAZMAT World, Aug. 1993, 70,71.
- “Working Smarter With Less,” Stephen L. Hermann, Fire Chief, Aug. 1990.
DAVID F. PETERSON, a 20-year veteran of the fire service, is a lieutenant in a career fire department and owner of Americhem Safety & Environmental, LLC, a training and consulting firm in Janesville, Wisconsin. Previously, he was a training officer and hazardous materials response team member. He is an adjunct instructor at the National Fire Academy and the Emergency Management Institute and a frequent lecturer. He is the founder and a past president of the Wisconsin Association of Hazardous Materials Responders, Inc.
