Emergency Planning: Protecting the Community and Your Employees

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Emergency PlanningProtecting the Community and
Your Employees

• Operation Partnership Emergency Network Meeting
• December 4, 2009

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Agenda

• Discuss the history of the Emergency Planning and
  Community Right-to-Know Laws
• What are you required to do
• How can it help?
• Your business
• Emergency responders
• The community

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Emergency Planning and Community Right-to-Know

• A Short History

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Bhopal India

• December 3, 1984
• Union Carbide Pesticide Plant
• Release of 42 Tonnes of Methyl Isocyanate Gas
• 500,000 exposed
• 2,259 died immediately
• Estimated 25,000 ultimate deaths
• Frequently cited as the world's worst industrial
  disaster

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Bhopal India

• Little was known about plant operations
• Onsite data was non-accessible
• Chemical/process information non-existent
• Workers, equipment, and safety regulations
• Warnings and previous accidents ignored
• Little accountability
• Pollution and economic legacy still evident

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USA

• Emergency Planning and Community Right to Know
  Act
• Protecting the Community
• Protecting Responders
• Hazard Communication Act
• Protecting the Employee

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Emergency Planning and Community Right to Know Act

• Establishes requirements for reporting on
  hazardous and toxic chemicals.  
• Helps increase the public's knowledge and access
  to information on
• Chemicals at individual facilities,
• Their uses, and
• Releases into the environment
• States and communities, working with facilities,
  can use the information to improve chemical
  safety and protect public health and the
  environment.
• Local Emergency Planning Committee (LEPC)

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Emergency Planning and Community Right to Know Act

• Texas Tier Two Report
• Must be completed by owner or operator
• Annual hazardous chemical inventory
• Provides detailed information on chemicals
• Extremely Hazardous Substances - 500 pounds or
  the Threshold Planning Quantity, whichever amount
  is less
• More than 10,000 pounds of a "generally hazardous
  chemical" (products which require a Material
  Safety Data Sheet MSDS)
• How Much is 10,000 Pounds of a substance?
• 1,250 of gasoline or diesel fuel
• 200 bags of de-icing agent

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Emergency Planning and Community Right to Know Act

• The Texas Tier Two Report includes
• Facility tracking information
• Information on the hazardous chemicals being
  reported
• Common and chemical names of products
• Hazard classifications
• Reporting ranges
• Days on site
• Container types
• Storage locations

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Emergency Planning and Community Right to Know Act

• Submitted annually in an electronic format
• Texas Department of State Health Services
• http//www.dshs.state.tx.us/tiertwo/publications.s
  htmnewprocedures
• Local Fire Department
• City of Fort Worth, Emergency Management Office
• Local Emergency Planning Committee
• City of Fort Worth, Emergency Management Office
• OEM_at_fortworthgov.org

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What do I need to do?

• Step 1
• Gather the information
• Who
• What
• When
• Where
• Why
• Workplace Chemical List

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(No Transcript)
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Material Safety Data Sheet
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Material Safety Data Sheet
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Material Safety Data Sheet

• Where do I find the MSDS?
• From the Manufacturer
• Require they supply at the time of delivery or
  refuse shipment
• What form do they come in?
• Paper
• Electronic
• PDF
• Scan
• Managed by a private third party
• More about the MSDS to come later!

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What Do I Need to Do?

• Step 2
• Input the information into the State Electronic
  Reporting System
• http//www.dshs.state.tx.us/tiertwo/default.shtm
• Step 3
• Email resulting files to the State, Fire
  Department, and LEPC
• T2Sdatafiles_at_dshs.state.tx.us
• OEM_at_fortworthgov.org
• Step 4
• Send in the state fee (50-500 depending on
  Facility type and number of chemicals reported)

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Things to Remember

• Report is for last calendar year
• January 1 - December 31st
• Must file report by March 31st
• 90 days to complete the paperwork
• If you are below the thresholds, you do not have
  to file
• Still required to show, if asked, how you
  determined that you were exempt from reporting
• Fire at facility
• Major Spill

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Links

• EPCRA
• http//www.epa.gov/oem/content/lawsregs/epcraover.
  htm
• Tier II Reporting
• http//www.dshs.state.tx.us/tiertwo/default.shtm
• Extremely Hazardous Substance List
• http//tier2.azserc.org/LinkClick.aspx?fileticket
  lRi92yplKjA3Dtabid36mid382
• LEPC
• http//www.tarrantcountylepc.com

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Worker Right to Know

• AKA
• Hazard Communication Standard
• HazCom
• Occupational Health and Safety Standard
• 29CFR1910.1200
• Purpose
• To ensure workers are aware of the hazards that
  they may encounter in the workplace
• To train employees

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Worker Right to Know

• Required compliance elements
• Chemical Inventory
• Workplace Chemical List
• Written Plan
• Labeling
• MSDS
• Training

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Chemical Inventory

• Workplace Chemical List
• No need to do extra work
• Detailed

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The Written Plan

• Who is responsible for the various aspects of the
  program in your facility
• A list of hazardous chemicals in the workplace
  (hazard inventory)
• How the requirements will be met
• For labels and other forms of warning
• Materials safety data sheets
• Employee information
• Training

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The Written Plan

• Does not need to be anything elaborate
• Many fill-in-the-blank models online
• Need to customize
• Facility
• Organization
• In English
• Required by law
• May need to be translated for employees

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Labeling
Manufacturer info
Legible permanent Cannot be removed or defaced
Hazards
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Labeling

• All Containers must be labeled
• Exception
• Small amounts in temporary containers used on a
  daily basis
• The paint pot

Better
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Material Safety Data Sheet
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Material Safety Data Sheet
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Material Safety Data Sheet

• Where do I find the MSDS?
• From the Manufacturer
• Require they supply at the time of delivery or
  refuse shipment
• What form do they come in
• Paper
• Electronic
• PDF
• Scan
• Managed by a private third party
• Must be accessible to employees

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Material Safety Data Sheet
Stored on a shared file
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Material Safety Data Sheet
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Material Safety Data Sheet
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Training

• Trained prior to working with hazardous materials
• In person
• Online
• The HazCom Standard
• What it is
• Where to get the information
• WCL
• MSDS
• How to protect yourself
• Hazard detection
• PPE
• The Written Plan

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Training

• Everyone is trained to their level of potential
  exposure
• Use a sign in sheet
• Keep it on file
• Retrain as assignments change

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Exercise the Plan

• Spot Check
• Hold everyone accountable
• Invest in compliance or in Workers Comp Claims
• Make it a priority from the Top

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Links

• OSHA Hazard Communication Standard
• www.osha.gov/pls/oshaweb/owadisp.show_document?p_t
  ablestandardsp_id10099

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Questions and Discussion