The Resource Conservation and Recovery Act (RCRA) requires large quantity generators of hazardous waste (LQGs) to have written preparedness, prevention and emergency procedures in place to minimize the possibility of fire, explosion and hazardous waste releases to the environment and to help ensure quick response if they do occur [40 CFR 262.251]. To assist outside personnel aiding in these efforts, the plan must include a Quick Reference Guide (QRG) to essential safety and response information [40 CFR 262.262].
Contingency plans describe the actions that the facility will take to minimize the harmful effects of spills, fires, explosions and other emergencies [40 CFR 262.261].
Essential planning details include:
- Response actions that facility personnel will take
- Agreements made with local fire, police, medical and other agencies
- Names and phone numbers of all emergency coordinators at the facility
- An up-to-date list of available emergency response equipment (spill control equipment, fire suppression equipment, communication systems, etc.), including the location of each item and a description of its capabilities
- An evacuation plan, if necessary
Facilities must maintain copies of the plan and its revisions at the site. They must also send copies to local emergency response agencies.
The Environmental Protection Agency (EPA), which enforces RCRA, does not set an interval for reviewing contingency plans, but the agency does need to be kept up to date. Any change at the facility should trigger a review of the site’s contingency plan to determine if changes are necessary [40 CFR 262.263]. The EPA specifically requires plans to be reviewed and amended when:
- There are changes to applicable regulations
- The plan fails in an emergency
- Emergency coordinators change
- Emergency equipment changes
- Facility changes such as:
- Anything else that increases the potential for fire, explosions or releases to the environment
Employees and the environment are safer when a facility has good systems for quick communication and mitigation of fires, spills and other emergencies. Contingency plans must list the types and locations of response equipment available at the site. Unless the LQG can prove that one of the following items is not necessary or would be unsafe, the following equipment is required [40 CFR 262.252]:
- A communication alarm system to provide immediate instructions in an emergency
- A telephone, two-way radio or other device to call local or state response agencies (police, fire, etc.)
- Portable fire extinguishers and/or fire control equipment
- Spill control equipment
- Decontamination equipment
- Sufficient water to supply fire hose systems, sprinklers, foam systems or other fire suppression equipment
Facility personnel must maintain and regularly test all response and communication equipment to help make sure that it will work appropriately during an emergency [40 CFR 262.253].
Arrangements with Local Authorities
Community emergency services often provide assistance to facilities during emergencies. Facilities must determine their need for outside services and help community responders familiarize themselves with a site’s layout, including the locations of hazardous materials and wastes, entrances, evacuation routes and the types of injuries or illnesses that might result from spills, fires or other emergencies [40 CFR 262.256].
Sharing plans and making response arrangements with these agencies before an emergency promotes safety and ongoing dialogue. Facilities must attempt to contact:
- Local police departments
- Fire departments
- Other emergency response contractors
- Equipment suppliers
- Local hospitals
- The local Emergency Planning Committee
Facilities must also maintain records to verify these contacts (or the attempts) and describe any response arrangements made with these agencies.
Quick Reference Guides
Certain LQGs must provide local emergency responders with a quick reference guide (QRG)—facilities that become LGQs after May 30, 2017, and all existing LQGs that amend their contingency plans. As mentioned above, the QRG helps outside response agencies access essential facility information without reading an entire plan.
Per 40 CFR 262.262(b), a Quick Reference Guide must include:
- The identity of hazardous wastes at the facility, their location, the maximum amount onsite at any time and a description of each waste’s hazards
- Any unique threats or special circumstances involving the wastes and any special medical treatment that might be necessary after exposure
- A site map showing the locations of hazardous wastes as well as routes to access them
- A street map of the facility, including public roads and nearby businesses, schools and residential areas
- Locations of fire hydrants and other water supplies
- Onsite notification system capabilities (alarms, speakers, etc.)
- Names and phone numbers of emergency coordinators
Naturally, facilities cannot predict releases or fires, but when they do happen, it’s essential to have a plan and the necessary equipment to quickly get the situation under control. It can mean the difference between a temporary interruption and a major catastrophe. And sharing plans and quick reference guides with local responders helps everyone address these emergencies safely, quickly and effectively.