Facilities Check List
Practical, step-by-step guides for the busy FM
December 2001
HAZWOPER Planning
HAZWOPER, or Hazardous Waste Operations and Emergency Response, is the more familiar name of OSHA Standard 29 CFR 1910.120, which is designed to protect employees who must respond to releases of hazardous substances. The HAZWOPER regulation requires that facilities provide training and a written emergency response plan, along with documented procedures for implementing this plan, if their employees are expected to respond to emergency incidents involving hazardous substances.
The written emergency response plan must be available for inspection by employees and must address, at a minimum, the following elements:
- Pre-emergency planning and coordination with outside agencies.
- It is a common complaint of outside emergency responders that they are called or allowed to become involved only after a situation has advanced beyond control. A facility manager must:
- Realistically determine the kinds of incident facility personnel can handle
- Realistically determine when outside emergency responders should be brought in
- Meet with outside emergency responders to discuss their roles in an emergency and what hazardous substances and processes are on site
The local fire department is usually the key organization when help from outside the facility is needed. - Personnel roles, lines of authority, training, and communication.
- The people who will participate in an emergency response must be identified
- Their roles and procedures for communication must be established
- The limitations of the various roles during an emergency must be defined
- Personnel must know when not to intervene, such as when a fire is too large to handle
- The appropriate level and method of training must be designated
- Emergency recognition and prevention.
- Emergency planning should focus on:
- Identifying types of incidents that could occur at the facility
- Ways to prevent employee exposure to hazards through engineering controls, safe work practices, and standard operating procedures
- Safe distances and places of refuge.
- Facility plans must identify:
- The areas where employees are expected to meet in an emergency
- The procedures for accounting for all employees
- Site security and control.
- An important part of implementing an emergency response is restricting unauthorized personnel from the area of the emergency. Site security personnel should:
- Assist in the evacuation of personnel
- Implement and enforce the response zones established by the person in charge of the response effort
- Evacuation routes and procedures.
- Specific plans and maps must be in place to indicate the evacuation routes and places of refuge for facility occupants during an emergency.
- All facility personnel should be trained in the proper evacuation procedures for their work locations
- Decontamination procedures.
- During an emergency response, people may get hazardous substances on their clothing or equipment. To cope:
- Facility plans must identify safe methods for disposing of contaminated clothing and equipment and/or effective methods of decontaminating such items
- Any on-site materials that require special decontamination procedures must be noted
- Appropriate procedures and equipment to handle these materials, such as U.S. Department of Transportation (DOT) waste containers or spill control materials should be in place
- Emergency medical treatment and first aid.
- Emergency responses involving hazardous chemicals can result in personal injury. Facility emergency response plans must:
- Identify potential overexposure and other hazards
- Specify appropriate first aid treatments
- Specify the location of supplies (including any antidotes or other special equipment)
- Detail relevant training
- Emergency alerting and response procedures.
- Installing equipment and developing procedures for alerting people to an emergency are important aspects of emergency planning.
- The location of all emergency alarms must be noted on the evacuation plans.
- Personnel must be trained in the types and meaning of various internal alarms.
- The employer must establish an employee alarm system that complies with OSHA standards.
- The plan must specify a system to alert all affected employees of an emergency situation.
The type of system chosen will depend on the size of the facility. For multistory buildings subdivided by interior walls, traditional alarm systems are recommended. OSHA prefers supervised telephone or manual fire-alarm pull-box stations with paging systems to transmit messages throughout the building. The alarm boxes must be located so that employees do not have to travel more than 200 feet to reach one. Workplaces with fewer than ten employees, however, may be exempt if OSHA determines that a direct verbal alert is sufficient. - Personal protective equipment (PPE) and emergency equipment.
- A very important part of planning is to identify and locate personal protective equipment and emergency equipment needed to respond to anticipated emergencies. This includes:
- Equipment for respiratory protection
- Equipment for spill control
- Decontamination equipment
- Fire fighting equipment
- Personal protective clothing
- Supplies for first aid and neutralization.
One person should be responsible for replenishing all equipment and supplies. - Medical surveillance.
- Facilities must establish a medical surveillance program that monitors workers’ health to ensure their ability to respond to an emergency and to provide emergency and other treatment for emergency response personnel.
- Site topography, layout, and prevailing weather conditions
- Facility emergency response planning must consider the site topography and layout, especially if certain areas could affect access of emergency response equipment or runoff from releases of hazardous chemicals. Prevailing weather conditions, such as wind direction and temperature, are important in planning an evacuation and establishing safe distances.
- Procedures for reporting incidents to government agencies
- Several regulations require releases of hazardous substances to be reported to designated government agencies on the federal, state, and local levels. Emergency plans should include:
- The identification of reportable incidents
- The appropriate agencies to be notified
- The senior person responsible for reporting such incidents.
- Critique of response and follow up.
- Once an emergency response action is completed, the emergency response plan must be reviewed.
- If portions of the plan or personnel training or performance were inadequate, they should be noted and appropriate changes implemented.
- Procedures that worked well and effective personnel response should also be noted.
- Revised procedures must be documented and communicated to all people involved, both on site and off site.
When a building owner or manager requires a facility’s staff to respond to emergencies, drills and exercises should be formally conducted to ensure staff response proficiency. Once the planning process is finished, facility personnel should assist in training emergency responders and, most importantly, should conduct facility tours and emergency exercises.
The plan must be reviewed periodically and amended if site conditions change or new information becomes available. The training should include regular drills in the emergency response plan. If necessary, special procedures may be necessary to ensure the safety of any handicapped employees or tenants, especially during an evacuation.
This installment of FM Check List is adapted from BOMI Institute’s Environmental Health and Safety Issues (www.bomi-edu.org/19092.html), course in BOMI Institute’s Real Property Administrator (RPA), Facilities Management Administrator (FMA) and Systems Maintenance Administrator (SMA) designation programs.
