Best Practices

Combating Chemical Disasters: Three Steps for Safety

By Chuck Haling

The recent chemical explosions at a warehouse in the Chinese port of Tianjin that killed 173 people are a sobering reminder of the severe consequences that a breakdown in chemical safety can have (Bodeen, 2015). Moreover, it is a call to action for companies to review their chemical safety plans and processes, and to ensure that they are meeting the compliance requirements set forth by the array of agencies with oversight of hazardous chemicals.

Safety directors should follow three crucial steps to help protect their companies, employees and communities from chemical disasters.

Step 1: Know What Hazardous Chemicals Are On Site, Where & In What Quantities

The company is responsible for having a comprehensive view of all hazardous chemicals present in the workplace, and to ensure that hazard information [e.g., safety data sheets (SDS)] is available and communicated to employees in a clear and easily accessible way. In the U.S., this responsibility is mandated by OSHA’s (2014a) HazCom standard.

Employees armed with the necessary chemical information and proper training are better prepared to prevent incidents from occurring, and better equipped to handle any incidents that do occur. Unfortunately, many employers overlook their HazCom obligations. OSHA’s annual list of the 10 most frequently cited standards consistently puts HazCom violations near the top, which means that workers across many industries are at risk for injury and illness from exposure to chemicals (OSHA, 2014b).

Safety professionals play a critical role in ensuring that chemical safety does not slip through the cracks and that employers meet the five key OSHA (2014a) HazCom requirements:

  1. Maintain a written plan that details all aspects of the company’s HazCom program, including how chemical information is made available to employees, how and where SDS are stored, and what training efforts are in place to ensure that employees know how to properly access and use this information.
  2. Keep an up-to-date chemical inventory list, documenting every hazardous chemical in the workplace (even if not in use), where it is located and in what quantities.
  3. Maintain SDS for every hazardous chemical on the inventory and provide employees with right-to-know access.
  4. Ensure that hazardous chemicals are labeled properly, including all key information, such as product identifiers and hazard statements.
  5. Train employees on their rights under the standard and on the specific chemical hazards to which they are exposed.

Step 2: Have a Solid Emergency Prevention & Response Plan in Place

Having a comprehensive emergency plan in place is essential for businesses, especially those that deal with hazardous chemicals. Without a solid plan in place, a disaster can devastate a business or even end it. According to Federal Emergency Management Agency (FEMA, 2014), up to 40% of businesses affected by disaster never reopen following the event.

Again, the ideal situation is to prevent chemical disasters, but these events sometimes occur. An emergency plan should not only outline prevention measures, but also include procedures to follow during and after an event. An important part of disaster planning is identifying and communicating with first responders (e.g., local and state agencies) before an incident occurs to make sure they are properly equipped with the necessary information and tools (FEMA, 2014). Without open and active dialogue with all involved parties, the plan is less likely to be executed smoothly in an emergency.

FEMA (2013) recommends the following steps to develop and maintain a business emergency plan:

  • Program management: Identify regulations that establish requirements, and develop and administer the program.
  • Plan: Assess risks, conduct a business impact analysis, and examine ways to prevent hazards and reduce risks.
  • Implementation: Write a preparedness plan that addresses areas such as emergency response, incident management and training.
  • Test and exercises: Test and evaluate the plan by developing and conducting exercises to gauge effectiveness.
  • Program improvement: Identify when the program should be reviewed, determine methods to evaluate it and use the findings to make necessary improvements.

Step 3: Be an Expert on Safety Regulations

Multiple U.S. agencies have hazardous chemical oversight, including OSHA, EPA, DOT, Department of Homeland Security (DHS) and others. Following is a brief synopsis of notable regulations from these agencies.

Emergency Planning & Community Right-to-Know Act (EPCRA)

Also known as Title III of the Superfund Amendments and Reauthorization Act, EPCRA sets requirements for local and state emergency planning as it pertains to hazardous chemicals, the public’s right to access information on chemical hazards in their community, and the reporting responsibilities for facilities that store, use and/or release hazardous chemicals.

EPCRA has four main components: Emergency planning, emergency release notification, hazardous chemical storage reporting requirements and toxic chemical release inventory. Under this regulation, facilities must immediately notify proper authorities as soon as they become aware of a reportable chemical release, in addition to submitting annual Tier II reports on chemical quantities in facilities above the thresholds set by EPA (2012).

HazCom Standard

In the U.S., HazCom is enforced by OSHA to give workers the right to know and understand the hazards of their workplaces. In 2012, OSHA aligned the HazCom standard to the UN’s Globally Harmonized System of Classification and Labeling of Chemicals, ushering in a multitude of changes, including chemical classification and the formatting of SDS and labels (OSHA, 2014a).

Risk Management Plan Rule

Enforced by EPA, the risk management plan rule focuses on the effects of chemical incidents on the community near a facility. Companies with more than a threshold quantity of a regulated substance must complete a hazard assessment detailing the potential effects of an accidental release, an accident history covering the past 5 years, and an evaluation of worst-case and alternative accidental releases. Companies must also implement a prevention program that details safety precautions, maintenance, monitoring and employee training, in addition to an emergency response program, so that they are prepared in the event of an emergency (EPA, 2015).

Process Safety Management Standard

Process Safety Management is an OSHA (2009) regulation concerned with the safety of a company’s employees and local first responders. It requires that employers undergo a process hazard analysis that identifies chemical incidents that could occur based on the specific chemicals in a facility, and reviews what safeguards are in place to keep disasters from happening.

Chemical Facility Antiterrorism Standards

DHS (2015) enforces chemical facility antiterrorism standards, which address disaster safety from a national security perspective. Companies identified as high risk must register with DHS and maintain performance-based security standards to protect facilities from potential terrorist attacks.

Executive Order 13650

A recent action closely related to the regulations outlined here was the signing of Executive Order (EO) 13650 (OSHA, 2015). U.S. President Barack Obama signed the EO in 2013 following a major explosion of a fertilizer plant in West, TX, to launch a review the state of hazardous chemical safety in the country and to determine areas for improvement. The order formed a working group of U.S. agencies, led by OSHA, EPA and DHS, and tasked them with creating actionable steps the agencies could take to identify facilities at risk for chemical emergencies, improve communication throughout the chemical supply chain, increase communication with emergency responders and improve safety for all stakeholders.

So far the EO has resulted in the cross-training of inspectors from various agencies to better and more quickly identify facilities that are out of compliance with various standards. The group is working to consolidate disparate facility and chemical data to identify companies that are registered and reporting with one agency, but not others. Often, these outliers have requirements with several agencies, as the chemicals and reporting thresholds between regulations are similar, although not identical. A major finding of the EO working group is that better communication is needed between local first responders and chemical facilities.

No Need to Go It Alone

While these points are essential to remember, there is always more for safety professionals to learn and apply as regulations and policies evolve. Fortunately, safety directors are not alone; help is available.

The most recent EO report suggests that agencies and companies should look to new technologies for solving some of the communication gaps (OSHA, 2015). To that end, several OSH software solutions can help companies collect hazard information and disseminate it to stakeholders. These solutions facilitate tracking and reporting on chemical and safety processes across a company, and provide better visibility to exposure risks so that management can implement corrective measures and track progress.

It is not possible to predict when disasters will strike, but steps can be taken now to prevent them or greatly soften the blow when they do happen.

References

Bodeen, C. (2015, Sept. 11). Final death toll set at 173 in China warehouse explosion. Associated Press. Retrieved from http://bigstory.ap.org/article/e2fb632be4eb42a0a3b7003bfbedc623/final-death-toll-set
-173-china-warehouse-explosion

Department of Homeland Security (DHS). (2015). Chemical Facility Anti-Terrorism Standards (CFATS). Retrieved from www.dhs.gov/chemical-facility-anti-terrorism-standards
EPA. (2012). EPCRA overview fact sheet. Retrieved from www2.epa.gov/sites/production/files/2015-05/documents/epcra_fact_sheet.pdf
EPA. (2015). Risk Management Plan (RMP) rule overview. Retrieved from www2.epa.gov/rmp/risk-management-plan-rmp-rule-overview
Federal Emergency Management Agency (FEMA). (2013). Preparedness planning for your business. Retrieved from www.ready.gov/business
FEMA. (2014). Preparedness in America: Research insights to increase individual, organizational and community action. Retrieved from www.fema.gov/media-library-data/1409000888026-1e8abc820153a6c8cde24ce42c16e857/20140825_Preparedness%20in%20America_August%202014%20Update_508.pdf
OSHA. (2009). OSHA QuickCard: Process safety management depends on you! Retrieved from www.osha.gov/Publications/process-safety-card.pdf
OSHA. (2014a). OSHA fact sheet: Steps to an effective hazard communication program for employers that use hazardous chemicals. Retrieved from www.osha.gov/Publications/OSHA3696.pdf
OSHA. (2014b). Top 10 most frequently cited standards. Retrieved from www.osha.gov/Top_Ten_Standards.html
OSHA. (2015). OSHA fact sheet: Actions to improve chemical facility safety and security. Retrieved from www.osha.gov/chemicalexecutiveorder/EO13650FS-ImprovingChemicalFacilitySafety.pdf

Chuck Haling is vice president of sales at VelocityEHS.

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