Your driver calls frantically. There's been an accident,
and your vehicle is bleeding hazardous material. Only
a
well-practiced emergency response plan can minimized
damage and liability.
By Norm Norville
Senior Associate Editor
According to U.S. Department of Transportaton statistics, there were
15,220 hazardous materials incidents in 1998. These incidents range
from minor spills to major releases involving loss of life. How well
are
you prepared to handle this complex and dangerous issue?
Hazmat emergency training must not only teach the
driver how to
react to a spill situation (see
"Containment How-To," CCJ, September ‘98), it also must instruct
the fleet manager on how to work with on-site officials who may be
hundreds or thousands of miles away. From the outset, how you
react to a hazmat spill situation will set the tone for the whole process.
An emergency response plan should identify only
one person
(possibly yourself) as the point person to deal with all emergency
hazmat spill situations. By designating more than one person, you
increase the risk of confusion, delays and miscommunication at a time
when immediate response is critical. Because this is a huge responsi-
bility, you shouldn't designate someone who already has a full work-
load. Other responsibilities must never interrupt the point person
during a hazmat incident.
Certain guidelines may allelviate the stress and
strain of a hazardous
spill emergency. First, know your drivers' capabilities and keep
records of his or her training. Second, instruct drivers to contact
the
point person as soon as possible after an emergency and provide the
drivers with the name and phone numbers(s), so there is no confusion.
Chuck Cavanaugh, vice president of purchasing for
Amtralease, an
association of North American truck leasing and rental companies
based in Orlando, Fla., says, "A driver doesn't want to be fooling
around with different phone numbers, trying to find the right one to
call for help with a spill problem."
Make sure your drivers carry reliable communication
devices such
as cell phones, so contact can be established at a moment's notice.
Remember, emotions run high, and you don't want to make your
drivers rely on finding a pay phone, maneuvering through CB radio
traffic, or asking officials at the scene for a means to call.
When the driver calls, get important information
such as:
• the extent and seriousness of the spill;
• any reported injuries;
• any immediate health or environmental dangers;
• how much of the contaminant has been released;
• what spill containment procedures have been
deployed, if any;
• the names and titles of response officials
on the scene.
Usually, when an incident occurs, an emergency response
team
arrives first on the scene. In most cases, it's the local fire department,
although some communities have hazmat response teams designated for
such situations. The response team will assess the situation and imple-
ment emergency procedures. At this time, you should take your driver
out of the scenario, and begin your responsibilities as a fleet manager
and/or hazmat point person.
When responding to the situation, inform the emergency
response
team that your fleet has a contingency plan that can handle the situation.
Let the official know your plan and the manner in which you will imple-
ment it. Remember, you must assure on-site officials that your contin-
gency plans can be implemented in a way that benefits all affected
parties.
If you have no plan or fail to execute one properly,
the local response
team will take over the situation, and you'll probably get stuck with
some
hefty bills and/or regulatory fines. According to Tom Moses, president
of The Spill Center, an environmental claims management company
in
Acton, Mass., "There is a growing concern in the transportation industry
over local ordinances that authorized reimbursement to emergency
response agencies. The ordinances are becoming overly broad, and have
few limits on the type of costs that can be charged.
That said, get the name, title, and phone number
of the on-site emer-
gency response official. Ask the official for an assessment of the
spill, and
what, if any, emergency procedures will be implemented. Record the
date, time and content of this communication for reference. Isolate
your-
self from outside distractions, speak clearly and with a level head,
and
listen to recommendations. In addition, have your hazmat registrations/
permits handy to provide any information pertaining to these documents.
If you haven't done so, you should obtain information
on state and
local regulations and reporting procedures. Although the Environmental
Protection Agency (EPA) is the final say on national regulatory laws,
state
and local municipalities can add variances to meet their particular
needs.
For instance, a more densely populated area, such as a big city, may
have more stringent regulations, and may require different procedures
because of a potential threat to public safety.
Contingency Plan
According to Kelley Coyner, administrator for the Research and Special
Programs Administration of the U.S. Department of Transportation,
"Strong safety standards are critical, but alone are not effective
if shippers
and carriers do not know how to comply with them."
In addition to driver spill containment training,
a written contingency plan
detailing how your company will respond to spill emergencies is the
best
way to ensure you are in compliance with environmental regulations.
Also,
it is just as important to communicate the plan to managers and employees.
Keep it current, adding or deleting names and phone numbers of emergency
responders. Consider all fleet activities that have the potential to
generate a
spill, and lay out the most appropriate response option for each activity.
A
one-size-fits-all response generally does not work in every instance.
Your contingency plan should list cargo, fuel and
other truck fluids that
have the potential to require an emergency response. It should also
list the
phone numbers of the regulatory agencies, as well as cleanup and disposal
services that may be needed. Because you prepared in advance, you can
respond immediately by alerting hazardous-materials emergency crews
and
filing reports to appropriate agencies. The Spill Center's Moses emphasizes
the importance of "immediately contacting governmental authorities
and
property owners, controlling and measuring the spill, and documenting
the
amount of the product released."
Reporting
The Department of Transportation (DOT) Code of Federal Regulation
(CFR) 171.15, states: "The EPA requires a carrier who transports
hazardous materials to give notice after each incident during the course
of transportation in which, as a direct result of release of such materials:
• a person is killed or injured, requiring
hospitalization;
• damage exceeds $50,000;
• evacuation of the general public lasts one
or more hours;
• one or more transportation arteries or facilities
are shut down for one
or more hours;
• the operational flight pattern or routine
of an aircraft is altered;
• fire or spillage of suspected radioactive
contamination occurs;
• fire or spillage of suspected infectious
substances occurs;
• there has been a release of a marine pollutant
exceeding 119 gal for
liquids, or 882 lb for solids."
In addition, you must report any continuing danger to life that exists
at the
scene, even though it may not meet the above criteria. Give each notice
to
DOT by telephone at 800-424-8802.
Also, each carrier must file, within 30 days of
the discovery, DOT form
F5800 (in duplicate), for each incident that occurs during the course
of
transportation (including loading, unloading, and temporary storage).
It must
include a copy of the hazardous waste manifest, an estimate of the
quantity
of the waste removed from the scene, the name and address of the facility
to which it was taken, and the manner of disposition. The form must
be sent
to the Information Systems Manager, DHM-63, Research and Special Pro-
grams Administration, Department of Transportation, Washington DC
20590-0001. The carrier must retain a copy at the principal place of
bus-
iness for a period of two years.
It is important to remember that reporting responsibility
and liability remain
with the spill generator, regardless of fault. Fleet managers also
should under-
stand state and local reporting procedures, which may vary.
If you have a documented contingency plan in place,
and you execute it
properly, you may minimize the effects of a potentially volatile situation.
It's all
about awareness, training, and the ability of the fleet manager to
deal with
problems professionally and decisively.
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