Environmental Science & Engineering - www.esemag.com - June 2003
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Spills- need to know versus nice to know

By Cliff Holland, President, Spill Management Inc.

Top management can no longer give lip service to environmental programs. In Canada, a petroleum company was found guilty of not demonstrating due diligence in protecting the environment based on the company’s level of sophistication. The Court of Appeal felt that the company had the sophistication to test and determine potential impacts to the environment rather than rely on supplied information from the material safety data sheet (MSDS) and the capability of their water treatment systems, etc.

Top management needs to know and act upon issues that increase spill prevention, level of preparedness, and response capability, as well as the scales of impact that could result in charges under the Environmental Protection Act. Business upsets or interruption and the nightmare of business recovery may expand far beyond turning on the process and getting the people back on the job. Today, shareholder and customer confidence are reaching far beyond the boundaries of the corporate doors as we are now seeing with the Severe Acute Respiratory Syndrome (SARS) in Toronto and the Mad Cow disease in Alberta.

Time critical issues Whether 10 ml of nitric acid is spilled and reacts to cause an evacuation or a fuel tank leaks into a waterway and causes an adverse effect, both events require prevention and preparedness measures to be in place to counteract the consequences of an initial release or spill.

Multi-disciplined, trained workers and an internal response team are the best defence and do more to prevent the escalation of an event in the first few minutes than any outside agency or response service can do when they arrive at the scene. Experience has shown benchmark times that demonstrate the value of in-house capability and the Time Critical Period for gaining control of a spill or release are as follows:

First 15 seconds
One to two minutes
10 to 15 minutes
One half hour to one hour
Two hours.

Companies that can gain control of a spill or release as soon as possible have a better chance of handling the event as a routine incident. Those that are still trying to gain control of an event at or beyond the two-hour mark are now facing a situation that has most likely escalated into an emergency. From the authority and accountability of top management to the responsibility and response capability of the site-specific operating teams, time critical issues should be addressed to help prevent a routine spill or release from turning into a major event that destroys a company, an industry and impacts international trade.

Who’s in charge? Depending on the nature and scale of the impact, the fire department (the lead agency) is now going to be in charge of the site, a state of emergency may be declared, evacuation of the neighbourhood could occur, various government agencies will be enforcing their concerns, contractor and specialty services will spare no effort to bring the situation to its conclusion, and the news media, internet and videographers will distribute information to all who demand it and anyone who will listen. Spills and releases that can be handled as a routine incident keep the organization in charge.

Response capability
(competency vs. confidence) Competent responders show a high level of capability based on their hands-on knowledge, experience and training. They have first-hand knowledge of the varying conditions, controls, etc., required to handle critical situations. Confident responders tend to rely on the written word to maintain control of conditions that they don’t truly understand. Each response group needs to understand that all responders will have different levels of competency depending on the situation. Internal response teams and volunteer fire departments are examples of teams made up of workers with diversified skills and backgrounds. Highly skilled and competent responders come from within their own industry, from the chemical companies, and rail companies, etc.

Industry needs to develop internal capability to handle their spills and releases. Build competency into your system and determine the need for support services of competent contractors as well as educate emergency services about what, where, when, why, and how their services may be required.

Golden rules for response a) Never assume - Responders need to clear their minds of all distractions and focus on every possible aspect that can bring an event to a safe and successful conclusion. Industry-specific and product-specific responders will most likely have the highest level of knowledge to assess the risk and hazards, as well as determine supplies, equipment and support services required at the scene to help prevent conditions from taking a turn for the worst.

b) Suit up for toxicity by protecting the entry routes of the body. Once responders have blocked out chemical or biohazard contaminates from entering the body, the focus can now switch to being mindful of physical dangers that could harm the body. These physical dangers or impacts are fire, explosion that could kill, or corrosive and biological properties that could eat through or permeate the suit, etc., and other physical dangers that could affect your safety on site.

c) Work clean to prevent chemical reactions that could result in the generation of heat, fires, explosions, toxic gases etc., that could turn a manageable situation into a disaster.

d) Do not respond into a spill area (hot zone) to patch, repair, open, transfer or handle undamaged, or damaged goods, leaking or stressed vessels, containers, tanks, packages and other spilled products without first:

Knowing, understanding and respecting the physical, chemical and biological properties of the spilled product as well as potential by-products and unwanted reactions.
Determining the integrity of containers, stability of products involved and potential for adverse conditions occurring.
Sizing-up or assessing the situation to develop Initial Entry Procedures that will provide safe entry and exit during the event and allow work to be carried out safely and systematically.

Response phases Levels of personal protection, type of response activities, safe distances will vary at spill sites. Fire departments may think that competent industrial teams look scary with the way they work and handle spills. The industrial team may think the fire department is using overkill by choosing encapsulating suits with supplied air to handle the same situation. Who’s right? Both groups may be right based on their level of first-hand knowledge, experience and training. Both groups need to communicate to find a common ground with agreed procedures.

There are three basic phases that responders need to be aware of:

Phase I - Initial Response - This is best described as a routine event where responders can perform response activities with what they are wearing or basic protective equipment. For example, for a sulphuric acid spill, responders may be able to respond with minimal protection up to one kilometre away, and build a containment area long before the acid or acid vapour affects the area.

Phase II - Initial Entry (Critical) - Responders will best identify this phase if their hearts start to beat faster, or they know from firsthand information that the situation is critical or dangerous. At this point in time all activities should be restricted to Phase I level of response. All the site safety, proper protective equipment and required support services must be in place before work begins.

Phase II requires that all duties and activities must be executed with rigid discipline. Plans must be focused on site safety, work procedures, safe distances, buddy systems, retreat routes, rescue procedures and control countermeasures. All levels of responders need to know that criteria for this phase will vary according to a response organization’s level of expertise and the competency level of individuals on the team. In one case, the risk of a hydrochloric acid tank releasing its contents could have created a need for $80,000-$100,000 of response equipment and training. The internal response team plus the staff on site developed preventative measures to handle this major event for less than $5,000.

Phase III - Site Remediation (cleanup) - This phase covers the routine clean-up of the site. Workers must be mindful that reactions may occur causing the activation of Phase I Initial Response or Phase II Initial Entry for worker safety.

Conclusion Industrial sites need to consider having trained workers and an internal response team for site-specific spills and releases. They have first-hand knowledge of the chemical solutions used on site. During an event, in-house personnel know the plant layout, danger, access points, etc., better than any responder coming to the site. Personnel at the site have a vested interest in identifying potential spills and releases that impact the organization’s ability to conduct business.

For more information, contact e-mail: spillman@on.aibn.com.

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