USING COMMUNITY RIGHT-TO-KNOW DATA
Passage of the Superfund Amendments and Reauthorization Act of 1986 (SARA Title III) was heralded by the fire service as legislation that was long overdue. We welcomed the “community right-to-know” mandate that finally would give emergency responders (and area residents) access to information about the hazardous materials on the industrial sites in our jurisdiction.
First responders here in California likewise were pleased with the passage of Assembly Bills 2185, 2187, and 2 189 requiring businesses, schools, universities, and governments who use, store, or otherwise handle hazardous materials to disclose specific information on the haz mats on site to a local “administering agency” —a city or county public fire department, a city or county public health department, the county emergency services office, a police department, a sheriffs department, or even a public works department.
DATA STILL NOT AVAILABLE
It is now some seven years after the first of these laws was passed, and some Fire department responders (both engine and truck company first responders and advanced level hazmat teams) still do not have sufficient and accurate information when responding to fixed facility hazardousmaterials incidents—while the information may he available, it may not be readily accessible. In California, the information on hazardous materials is submitted in the form of a business plan that has been certified for accuracy. Outside the state of California, the same business plans are required under similar state statutes, the Uniform Fire Code, or SARA.
The disclosure notice required in California must include general information about the facility, the names and telephone numbers of emergency contact persons, chemical inventory information, general facility site maps, and maps showing the hazardousmaterials storage areas. These requirements now are part of the California Health and Safety Code. Article 80 of the 1988 Uniform Fire Code also provides for the same types of reporting requirements.
On the federal level, SARA Title III (Section 302, Emergency Planning Notification) specifies that all manufacturers must file reports if they have on their premises “planning threshold quantities” (defined in SARA; see sidebar on page 81) of any of the 406 (now reduced to 366) chemicals labeled “extremely hazardous” by the U.S. Environmental Protection Agency. A list of these chemicals was published in the November 17, 1986, edition of the Federal Register.
One would think that the information contained in these business plans quickly would find its way to fire department first responders—who will make use of it and for whom the data were intended in the first place. In some jurisdictions, however, the data are placed in a file or entered in a computer and used for permitor feecollection programs, regulatory enforcement, or public review. While each of these uses is important, the most critical function of the data is to inform emergency responders. In some instances where the information does reach these personnel, it is received in the original format of a business plan, the Hazardous Materials Management Plan, or the SARA Title III Tier I or Tier II reporting forms. These original documents are cumbersome, complicated, and generally unsuitable for use in emergency response situations.
In an engine and truck company first responder situation, the fire company supervisor has very little time to spend reading about the facility or facilities involved. The amount of information contained in a multipage business plan can overwhelm and confuse anyone attempting to absorb it all during the first crucial minutes of an emergency.
How helpful is it for responders in emergency circumstances to know the facility’s Standard Industrial Classification number? Its Dun & Bradstreet rating? The owner’s mailing address? The Chemical Abstract Services number of every single chemical stored on site? And who wants to be bogged down with such extraneous information when responding to an incident at three o’clock in the morning!
THE HAYWARD DEPARTMENT SOLUTION
The Hayward (CA) Fire Department serves a population of 105,000 and has a mix of residential and industrial structures in its jurisdiction. Located about halfway between San Jose and Oakland in the eastern San Francisco Bay area, Hayward is home to about 650 facilities that store, use, or otherwise handle hazardous materials; and the Hayward Fire Department serves as the administering agency for the disclosure documents required from these businesses.
To provide our responders with clear and concise information at the onset of an emergency, our Hazardous Materials Office implemented a system that makes available to the responders only the data they need w hen responding to a specific emergency.
When the required Hazardous Materials Management Plans (HMMPs) began to come in, we realized that a majority of these 650 facilities did not present a significant potential for hazardous-materials emergency situations. Many of the occupancies, for example, are service stations with underground storage of flammable materials or manufacturing facilities with aboveground storage of small quantities of mostly innocuous materials.
The hazardous classifications we considered when compiling our list were explosives, blasting agents, flammable liquids, flammable gases, strong or concentrated corrosives, flammable solids, and reactive materials. Other classes of hazardous materials w ere included if the materials were stored in quantities that presented a significant hazard potential.
We identified about 100 facilities where hazardous-materials emergencies could have a severe impact on our department’s resources and pose a major threat. We screened these facilities further to determine those that handle acutely or extremely hazardous materials, and we eliminated the manufacturers w^ho have on site quantities below the SARA-specified threshold limits. We added to the list facilities that store other types of hazardous materials in bulk and aboveground. We then distributed the list of facilities and addresses to all fire companies.
INFORMATION SHEET
Since, of course, fire companies require more than addresses when responding to emergencies, we proceeded to condense the HMMP information (a minimum of 10 pages) into a single, double-sided Target Hazard Sheet.
The format we adopted for presenting this concise body of information to our initial responders was introduced during the tenure of former Hayward Fire Chief William Neville and had been developed for structural fires (high-rises and other large structures) and wildland fires (canyons with an urban interface) in Los Angeles, where Neville formerly had served as deputy fire chief. One side of the laminated 8⅛” x 1 1″ one-page prefire data sheet presents easy-toread information, divided into 10 sections, relative to the facility and the materials on site (see sidebar on page 78).
On the other side of the Target Hazard Sheet is a map generated by the Macintosh computer and its Superpaint program. The basic information for the map is taken from the HMMPs and confirmed through actual field inspections by the firefighter developing the map.
A copy of the sheet is kept in a loose-leaf binder on each apparatus for easy access. Since the sheet is waterproof, it can be taken out of the binder and referred to throughout the incident without being damaged.
Hie information sheet is not meant to be a stand-alone document, since it does not provide all the information needed for even a moderate-size chemical facility emergency. It is intended as a tool for the first responder on the scene. It identifies the most hazardous chemicals at the facility and their locations. It provides the home phone numbers of key facility employees and lists special hazards and protection and containment features built into the facility.
An example of the sheet’s limitations is that it provides only enough space under the Hazardous Materials Storage heading to list 1 5 to 20 chemicals. even though many others may be on site. These IS to 20 entries were selected during our department’s preliminary review of the facility’s entire chemical inventory because they present the most serious major safety problems either because of their extreme toxicity or flammability reactivity or because they are present in quantities exceeding safety thresholds. Each of the chemicals on this short list is keyed to a location shown on the map on the other side of the sheet.
The sheets and maps are updated annually according to facility reports mandated by city ordinance. Facilities are instructed to notify our department immediately if there are significant changes in the storage, location, and use of chemicals or if there is any other change that could have implications for the fire department. Each facility is given a copy of its Target Hazard Sheet to use as a guide should interim revisions become necessary.
The information sheets were designed for use with the Department of ‘Transportation’s Emergency Response Guidetxxik (ERG). like the Target Hazard Sheet, the ERG is simple to use. It provides quick and basic information. it is easily portable, and it is not intended as a stand-alone reference source. The information sheets provide the ERG page number for each chemical listed. Our first responders are trained to use the information sheet with the ERG.
The information sheet and the ERG contain basic but vital information needed during the first 15 minutes or so of an emergency involving hazardous materials. If the incident is a serious one; is one of long duration; or involves a large, complex facility, the industrial and business communities help responders to cope with the incident. We work within the local Community Awareness Emergency Response (CAER) organization to identify the facilities that have the greatest potential for major haz-mat incidents.
LOCK BOX
We asked each of the target facilities to keep on site —ideally in a strategic location that is upwind and easily accessible to the fire department—a lock box large enough to hold a binder with comprehensive information specific to the facility and its chemicals.
The binder in the lock box contains an area map showing all businesses within a quarter-mile of the facility and their phone numbers. This map is a valuable tool for evacuation or shelter-in-place notification to nearby businesses and other structures.
In addition to an area map, we require comprehensive facility maps identical to, although much larger in scale and much more detailed than, the first responder information sheet maps, which have to be fairly small in scale so that they easily can be carried in a turnout coat pocket. Designed as a resource to be used in the command post, the foldout facility map identifies general haz-mat storage areas. Individual storage areas (tank farms, process areas, drum-storage areas, w arehouses, etc.) are detailed on individual pages. Each detailed map of an individual storage area includes the names and quantities of the chemicals therein and a description of their storage containers. It also details information specific to that storage area relative to sprinklers, secondary containment, piping, valve locations, etc.
One advantage of developing a detailed map system that can be taken from a lock box to a command post location is that the incident commander, his staff, and the facility’s employees can use the maps to help identify existing and potential areas of involvement as well as applicable methods of control.
The dual-map system (first responder sheets and comprehensive binder) also allows entry teams to communicate with the command post from other site locations. We make sure that the comprehensive facility map and the first responder map are identical except for their scale and level of detail so that personnel using the map at separate locations can use it as a common frame of reference while communicating.
The comprehensive response binder, designed as a resource for use in the command post, is also very valuable for in-plant emergency response teams. It includes the material safety data sheet (MSDS) for each chemical stored at the facility. The MSDS provides the command post staff with the necessary’ information to manage and control containment, neutralization, and cleanup operations for chemical accidents on site.
Another source of facility information that will be available to our responders in September is a Macintosh SE 30 that utilizes Computer Aided Management of Emergency Operations (CAMEO) software. Hayward and the cities of San Leandro and Union City have established an advanced hazardous-materials response team and jointly have purchased a custom-built large hazardous-material apparatus and a smaller standard flatbed truck with aluminum box and lift gate to transport bulkier items that overload the typical haz-mat apparatus. Each department w ill respond in these vehicles on an alternating monthly schedule at first —to provide all team members w ith the same opportunity to become proficient in their operation —and then on a quarterly schedule. Each of the three departments has purchased a mobile air compressor. The team responds to every call with a minimum of six personnel and an average of 10 to 12 technicians and has the capability to call out up to 50 technicians.
Within the year, the large haz-mat apparatus will have stored in its computer data on fixed hazardous-materials storage facilities in all three cities. Eventually, the hard copy used to produce the first responder Target Hazard Sheet maps will be stored in CAMEO, as will the detailed comprehensive binder maps. The computerized data will allow the responding haz-mat team to review detailed facility information en route to the incident without the need to carry hundreds of comprehensive facility binders on the apparatus. The CAMEO software also is able to run gas/vapor dispersion models based on facility and site information already in the computer as well as on additional data pertaining to prevailing conditions at the emergency scene.
Regardless of where in the United States your department is located, an administering agency in your area should be receiving community rightto-know information as mandated by SARA Title III; it is a federal law. As emergency response personnel, you have the right to any information that can help you when responding to hazardous-materials incidents. Insist that you get whatever information is submitted by the facilities in your area.
If your fire department’s administrative division, fire prevention bureau, or hazardous-materials office is receiving the information, make it your business to get it if you don’t have it already. If an outside agency is receiving the initial information and your department has not yet received it, insist that arrangements be made to get the data to you. It makes no sense to keep that information in office files. You must bring it to the emergency scene in a usable format so that the objective of this data-gathering process—to safeguard your health and safety—can be realized.
