The Emergency Planning and Community Right-to-Know Act (EPCRA), enacted in 1986, has two major purposes: (1) to increase public knowledge of and access to information on the presence of toxic chemicals in commu- nities, releases of toxic chemicals into the environment, and waste manage- ment activities involving toxic chemicals; and (2) to encourage and support planning for responding to environmental emergencies.
OSHA standards
1. Hazardous waste operations and emergency response 1910.120 2. Hazardous waste operations and emergency response 1926.65 3. Training curriculum guidelines — non mandatory 1926.62
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Chapter four: Governmental regulations 31
As can be seen, there are a number of potentially applicable OSHA standards and EPA regulations that may be required within your overall emergency and disaster preparedness program. Safety professionals are urged to be diligent in identifying all applicable current regulations as well
4. Training curriculum guidelines — non mandatory 1910.120
5. Fire protection 1910 Subpart L
App. A
6. Means of egress 1910 Subpart E
7. Flammable and combustible liquids 1910.106 8. Existing installations — mandatory 1910.66 App. D 9. Employee emergency plans and fire prevention plans 1910.38
10. Emergency action plans 1918.100
11. Respiratory protection 1910.134
12. Emergency action plan 1917.30
13. Process safety management of highly hazardous chemicals 1910.119 14. Model emergency temporary standard 1990.152
15. Employee emergency action plans 1926.35
16. Flammable and combustible liquids 1926.152
17. Employee alarm system 1910.165
18. Fire brigades 1910.156
19. Emergency standards 1911.12
20. Portable fire extinguishers 1910.157
21. Hazardous atmospheres and substances 1917.23
22. Means of egress 1910.37
23. Emergency disclosures 71.11
24. Access to employee exposure and medical records 1910.1020
25. Signs and markings 1917.128
26. Fire detection systems 1910.164
27. Means of egress 1926.34
28. Changes to approved plans 1952.297
29. Level of federal enforcement 1952.272
30. Level of federal enforcement 1952.265
31. Description of the plan as initially approved 1952.290
32. Description of the plan 1952.270
33. Description of the plan as initially approved 1952.260 34. Description of the plan as initially approved 1952.250 35. Completion of developmental steps and certification 1952.232 36. Description of the plan as initially approved 1952.240 37. Completion of developmental steps and certification 1952.212
38. Developmental schedule 1952.211
39. Description of the plan as initially approved 1952.210 40. Description of the plan as initially approved 1952.200
41. Level of federal enforcement 1952.172
42. Description of the plan 1952.170
43. Description of the plan as initially approved 1952.150 44. Description of the plan as initially approved 1952.160 45. Power transmission and distribution (emergency lighting) 1926.950
32 Disaster management and preparedness as proposed regulations in the development of the plan. Additionally, safety professionals should ensure that each and every element within each regu- lation is appropriately addressed within the emergency and disaster pre- paredness plan. Compliance with all OSHA, EPA, and other applicable reg- ulations and standards is essential in order to avoid potential penalties and litigation as well as to ensure a complete and thorough emergency and disaster preparedness plan.
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chapter five
Structural preparedness
“Action without study is fatal. Study without action is futile.”
Mary Beard
“Unless there be correct thought, there cannot be any action, and when there is correct thought, right action will follow.”
Henry George
Once the risks and probabilities of disasters have been identified, physical facilities must be examined in detail and appropriate countermeasures implemented to prevent and minimize the impact of unwanted emergencies.
The age and condition of the physical plant will determine the size and scope of this task. A new complex with all new buildings, constructed in compli- ance with the latest building code would present less of a challenge than an old facility constructed in many phases. The level of commitment, or lack of commitment, to maintaining existing facilities will become apparent as the inspectors proceed. In older buildings that have housed several tenants and many modifications, basic structural integrity may have been compro- mised. On one inspection of an older facility, the interior of a large warehouse had been renovated into two floors of office space for design and production personnel. A major structural component supporting the roof of the building had been severed to add a door, enabling the space on the other side to be accessed. The bottom chord of the roof truss had been removed without adding reinforcement. No engineering studies were conducted to determine the impact prior to construction. The fire protection system of the building had not been modified to add additional heads in this new building built inside the original one. The company maintenance manager assured me that design safety factors and the adjacent trusses would support the roof. Under normal circumstances, time was proving his point; however, severe snow load, a blocked roof drain, or strong winds could have easily collapsed the
34 Disaster management and preparedness roof with high dollar losses and the potential for death and injuries. A fire separation wall constructed at considerable cost to obtain a two or four-hour rating is easily compromised when an opening is made to allow people or vehicles access. The decision makers may not have even realized it was a rated wall. Other examples of building modifications that have the potential to increase fire spread and endanger occupants include:
• Increased travel distance to exits beyond legal limits imposed by codes
• Improper storage of materials including flammables, combustibles, and toxic materials
• Overloaded electrical circuits and/or lack of emergency lighting in renovated areas
• Absence of firewalls and/or fire partitions
• Failure to extend firewalls and/or fire partition walls beyond the underside of a ceiling
• Penetration of fire separation walls by utilities (telephone, cable, data- transmission lines)
• Fire doors compromised by physical damage or propped open with wedges
Although good housekeeping does not ensure a building’s fire safety, this author has never seen a facility with poor housekeeping that was fire safe. If you find a facility with large quantities of combustibles accumulating and in desperate need of cleaning, closer examination will probably reveal larger maintenance and fire protection deficiencies. This first step in prepar- ing the physical facilities for a disaster is to determine their structural integ- rity on a daily basis, without the addition of an emergency. Technical means alone cannot accomplish this task for you; however, you should use all means available to assist your survey. The availability of thermal imaging equip- ment is an example of a tool that can assist the inspector in finding air, steam, and water leaks as well as heat or cooling losses. Finding leaks early while they are small saves energy and reveals weak spots in the integrity of these systems that could fail under emergency conditions.
Another area frequently overlooked is fire protection system integrity.
Have the fire detection and suppression systems been inspected and main- tained according to the applicable National Fire Protection Association Stan- dards? If the occupancy use of a structure changes, the fire protection system may not be able to contain or extinguish a fire. An automatic sprinkler system designed to handle the fire load of a light hazard office occupancy probably could not handle the fire if the space was converted to records storage (large quantities of paper) or flammable liquids storage. This may seem obvious to modern safety professionals, but at some point in the past, the decision to convert the space may have been made without the advice and counsel of safety and/or fire protection personnel. Another classic example often used is a hypothetical XYZ tricycle manufacturing plant. The tricycle
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Chapter five: Structural preparedness 35 designed and manufactured during the 1940s and ’50s was mostly steel with padded seats and rubber tires. If the XYZ tricycle manufacturing plant was fortunate enough to have installed an automatic sprinkler system then, that same system would be ineffective in protecting a tricycle built by today’s standards. The tricycle manufactured today is almost entirely plastic and is even stored in corrugated cardboard boxes. The fire load imposed by the plastic and cardboard would probably be too much for the XYZ company’s sprinkler system designed for the manufacturing of the ’40s or ’50s. How old is the sprinkler system in the building(s) you protect? Has the system been upgraded to reflect increased use of plastics and/or flammable/com- bustible liquids? A thorough analysis of the condition, size of the sprinkler piping, heads, and the water supply by a sprinkler design engineer will yield a plan to restore the system’s effectiveness. In some cases, if the water supply is strong enough, the heads are located properly, and the piping is of suffi- cient size and condition, the system can be upgraded by simply replacing the sprinkler heads with larger diameter sprinkler heads.
Before leaving the subject of automatic fire protection systems, earth- quake protection, control valve supervision, and protection of systems dur- ing cold weather should all be evaluated. The National Fire Protection Asso- ciation Pamphlet 13 Standard for the Installation of Sprinkler Systems includes a seismic map in the appendix showing the potential for earthquake damage and the need for protection of the piping from earthquake damage.
Some older systems may not be designed to withstand an earthquake and could leave the facility vulnerable at a time when post quake fires are common. All fire control valves must be of the indicating type and must be locked in the open position and/or electronically supervised. Most insurance companies have programs designed to minimize the time fire control valves are closed and ensure systems are promptly restored to operation after any maintenance or sprinkler operation. The level and temperature of water in storage tanks and the status of fire pumps must also be monitored to ensure their operation if needed. Buildings with sprinkler systems have burned to the ground simply because a valve was accidentally or intentionally closed.
Cold weather poses challenges to improperly designed or maintained sprinkler systems. Wet pipe systems should not be installed on loading docks, in freezers, or anywhere temperatures may drop below 40°F. Each fall, all low point drains on dry pipe systems must be checked for accumu- lation of water. Antifreeze based sprinkler systems must also be checked each fall before freezing weather to ensure the solution will protect against the lowest expected temperature.
Structural security from flash floods, mudslides, and high water of any type should be assessed and appropriate intervention methods developed long before the need for those plans arises. What utilities might be compro- mised? Are there any critical components such as pumps, transformers, raw materials, or finished goods that should be relocated permanently to prevent losses, or do you have sufficient resources to move and/or protect those
36 Disaster management and preparedness items should the situation dictate it? One industrial plant located on a small island lost its only evacuation route when a toxic chemical release enveloped the only bridge linking the island with the mainland. Contingency plans now include boats to egress people and bring in emergency response per- sonnel and assistance.
Building security must also be evaluated and the risk and probability of disasters from attacks by external or internal sources must be assessed. This should include threats to any and all of the company resources including:
• Property
• Employees
• Equipment
• Inventory
• Data
• Trade secrets
• Manufacturing methods and procedures
• Company image, reputation, and consumer confidence
The loss of consumer confidence after the Tylenol product container tampering served as a wake up call for many companies. Most companies responded quickly, and today most products have packaging seals to warn the consumer of product tampering. At times prudent security measures seem to run counter to fire and emergency evacuation procedures. Computer integrated access control systems are being viewed as a valuable tool in this battle. Photograph identification badges with cameras at all entrance/exit points limit unauthorized personnel from company property. Access control locks operated by the same badges limit access to those areas each employee should enter. The computer integration of the locks also maintains a record, including dates and times, of all employees entering and leaving various areas. This same type of system is very helpful for accountability of employ- ees when an evacuation is necessary. The computer can instantly generate a list of all employees who have not reported to an evacuation checkpoint.
Workplace violence remains a threat to the personnel and success of businesses worldwide. A domestic dispute in a factory in Kentucky ended with a high speed vehicle crash through the main employee entrance. The car crashed completely through a cafeteria that only minutes earlier had been filled with employees. Every facility must have a workplace violence plan. Some companies choose to make it part of the emergency action plan and others choose to make it a separate plan. In either case, it should focus on preventing and settling disputes while they are manageable and protect- ing the employees in the event a violent act does occur. Physical barriers that prevent vehicles from being driven into selected areas can be incorpo- rated into the design of parking areas. Advances in closed circuit video camera technology continue to increase this tool as an effective means to deter unwanted persons from company property.
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Chapter five: Structural preparedness 37 The role that safety and/or security forces must play in emergency response to fires, medical emergencies, hazardous material incidents, confined space rescue, and bomb threats should be based upon careful analysis of:
1. The proximity of well-trained, well-equipped external assistance 2. The level of automatic protection available
3. The potential for loss if external assistance is insufficient
4. Management commitment to training and equipping an internal team Well intentioned people frequently say things like “I would never have fire brigades. They are too expensive.” If your facility is located in a part of rural America with little or no organized emergency response near the plant, how will you prevent the plant from burning down if you don’t have a functional fire brigade? Another common response is “We don’t have a fire brigade.
We have a hazardous response team.” The bottom line is the mission state- ment for your team (whatever you choose to call them) should describe in detail the duties they should and should not perform. If their duties include the use of any fire protection equipment, then they must receive the training and protective equipment consistent with that level of response regardless of the name given the team. The nature of emergency response lends itself to having a multi-purpose team. A medical screening team ensures the employees are physically fit to wear respirators, have incident command and respirator training, and understand the chemistry of fire.
Investing company time and money in training a single team to deal with all emergencies makes good sense. Most plants also have civic minded employees who already serve on local fire departments and/or rescue squads. These people have experience, may be willing to serve on your team, and may already have some of the required training. Often these people have the unique skills and leadership qualities to organize, train, and serve as officers of industrial emergency response teams. Any additional training you provide them benefits your facility and the community at large. For those who choose to evacuate only and wait for the insurance money to rebuild the facility, ask yourself this question: Can other divisions of the company satisfy our customers’ needs until the plant is rebuilt or will the customers use another supplier until and when our facility is rebuilt?
The level of emergency response could range from a small group of main- tenance personnel trained to use fire extinguishers and provide information to assist the local fire department to a full interior structural attack brigade trained and equipped equal to their municipal counterparts. The decision should be based upon an analysis of the risks and potential consequences.
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39
chapter six
Coordinating with local assets
“No matter how much work a man can do, no matter how engaging his personality may be, he will not ad- vance in business if he cannot work through others.”
John Craig
“Coming together is a beginning, keeping together is progress; working together is success.”
Henry Ford
The ability to communicate, coordinate, and work effectively as a team can be a major factor in the success of your emergency plan. In a large-scale disaster, more and more resources will be needed. The ability of those responding agencies to understand the scope and size of the problem and their ability to communicate among themselves will also influence the suc- cess of the operation. The more familiar they are with your facility and the more they have worked together, the more effectively they will be the day you need them most. Many of the agencies you will work with exist to serve the community. Law enforcement, firefighters, paramedics, and other public safety personnel want to protect the community they serve and to protect the property, jobs, and taxes the company generates. Their level of prepared- ness to help you will vary from community to community. It is your job to assess their capabilities and provide them with the training and special equipment they need to succeed in protecting your assets. It may take some selling on your part to convince them your facility has unique challenges and merits special attention on their part. Meet with the local fire chief and discuss your desire to involve his department in the planning process. The same invitation should be extended to the police chief and the directors of the local emergency medical service agency. If your facility or the surrounding
40 Disaster management and preparedness area must be evacuated quickly, you may also want to involve a local trans- portation agency or the school board to provide bus transportation. As you prepare the emergency response plan, you may discover the need for spe- cialty equipment such as sand or sand bags, dump trucks, specialty law enforcement teams such as SWAT, or bomb technician units. Some of the agencies you contact may feel they are already adequately trained and equipped to handle emergencies at your facility. It is your job to show them their need to walk your facility and study the activities and processes and then decide if they are properly trained and equipped to respond effectively.
Because many fire and EMS personnel work a three platoon system you may have to conduct several tours to enable all the agency personnel to partici- pate. You may be fortunate enough to work with responding agencies who are well read and may know as much or more about the historical nature of emergencies in facilities like yours than you. You could also encounter responding agency personnel with good intentions but little knowledge of the potential for death, injuries, environmental impact, or economic losses at your plant. You must play with the hand you have been dealt. Seek out those individuals who have the best grasp of the situation and enlist their help in educating the others. Do not be afraid to describe the negative impacts on their agencies and the community if emergency response is not effective.
The LEPC (Local Emergency Planning Committee) will be another asset you should draw upon in the creation of your emergency response plan, and the SERC (State Emergency Response Commission) will want to evaluate your plan. Depending upon the nature of your business and the quantity of various regulated hazardous materials at your facility, you may be regulated by the Process Safety Management Standard.
Once you have enlisted the help of a team with representatives from these responding agencies, begin to work through all of the potential emer- gencies your risk analysis identified. Conduct a resource list based upon the answer to a question repeated over and over: If this happens, then what will I need? As you identify each of these resources needed, have someone contact the appropriate business or agency and negotiate until the resource is avail- able. Among those on this resource contact list you may find:
• Emergency sheltering facilities
• Hotels
• Motels
• School gymnasiums
• National Guard Armories
• Public arenas
• Community outreach groups
• American Red Cross
• Salvation Army
• Heavy construction equipment companies
• Trucks
• Cranes
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