When your 3,000-gal. holding tank ruptures, it's way too late to start developing an emergency response plan. Controlling a spill requires immediate action and having a plan as well as trained workers to carry it out.
A strong plan minimizes environmental harm and facility downtime. Although container, vessel and piping manufacturers strive to ensure the physical integrity of their products, and the odds of rupture may seem remote, the fact remains that even the best-designed containment system can leak. Drums and totes can be damaged in transit. Forklift drivers can stab a drum. Vandals can open a block valve. It's essential to foresee problems and develop a plan so that everyone knows what to do when a problem occurs.
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Assess the potential
Before starting a plan, determine which materials are on-site and where they're stored. Consider every chemical, from bulk materials for processes to liquid floor wax for an entranceway. Determine where each chemical goes once it arrives at the dock. Find out whether it's used immediately or stored. Don't neglect cleaning chemicals stored in remote areas, waste containers that are stored before shipment, or areas where forklift batteries are recharged and refilled.
Using a plant layout drawing as a guide, walk through the facility and map potential spill hazards. Mark areas where chemicals are stored or used. Note the names of the chemicals and container volumes. Also consider outdoor tanks both above and underground. Mark the location and routing of piping from tanks or totes, which can leak or rupture. Locate floor drains that lead to public sewer systems or bodies of water that may need to be guarded to prevent environmental harm in the event of a spill.
Purchasing agents and receiving clerks can be good sources of information about chemicals in the plant. Compare findings from your walkthrough with lists of materials that were purchased or received. Investigate any discrepancy between the lists and reality.
Determine the hazard
Determine the potential for harm using relevant Material Safety Data Sheets (MSDS) or other safety information to identify corrosives and flammable materials. Check the data sheets to determine if any of the chemicals are incompatible if mixed.
The data sheets usually provide general spill-response and safety information. If the information isn't clear, or if a specific question arises, consult the chemical's manufacturer, whose phone number should be listed in Section One of the data sheet.
Even if the material itself is not inherently hazardous, spills can still pose problems. For example, a 300-gal. tote of corn syrup isn't corrosive, nor is it a fire risk. It will, however, produce a large, sticky mess if a valve breaks or a seam ruptures. If left unattended, it also attracts insects and animals.
Acknowledge that hazards may be different throughout the facility, and separate planning elements may be needed for each area. For example, flammable liquids may be stored in one area, bulk powders in another. Each area is hazardousthe first faces flammability issues, the second, engulfment hazards (materials that may break loose and engulf and suffocate a worker). Clearly, different spill-response plans will be needed for these areas.
In addition to the hazard created by the sheer presence of a spill, look for potential danger to employees or the community. Determine if employees will need to evacuate, and identify the precautions they have to take. Establish exit routes for quick, safe evacuation. Consult with local fire departments or hazardous-materials response teams when developing your plan since they will be needed to assist if an accident occurs and public evacuation is necessary.
Look for safety materials and resources already on-site. Ensure that the maintenance department has necessary absorbents on hand. Make vacuums available. Find out who has already received spill-response training.
Determine what spill response equipment would be needed and where it should be stored. If spills are likely to occur at the receiving dock, be sure to store a spill-response kit there. If totes are stored in an area near floor drains, have drain covers nearby. If it's not practical to absorb an entire spill, determine what equipment (dikes, bulldozers, industrial-sized vacuums) will be needed and where it can be stored.
Assemble a cross-disciplinary team of workers and managers from various areas. Discuss findings with them and enlist their help in designing a spill response plan. Because these people work in different areas and have different process knowledge, they will be able to add insight regarding potential problems that may have been overlooked in the initial walkthrough.