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Federal, state and local regulations require employers to
develop and implement a Hazardous Materials Release Response Policy to
provide a consistent and adequate means of handling an emergency involving
a hazardous materials. As part of Stanford's continuing commitment to
develop and implement policies and procedures consistent with these regulations,
the policy below has been established. The policy has been designed to
assure that Principal Investigators are fully informed of and included
in the response strategy.
In the case of an emergency involving a release of hazardous
materials release that is "health threatening" or "released to the environment"
as defined in Section II(A) of this policy document, the Palo Alto Fire
Department (PAFD) is to be notified immediately by calling 9-911 and/or
pulling a fire alarm if the building needs to be evacuated or if a telephone
is not available. Once involved, the PAFD is in command until the hazard
has been fully abated and they relinquish command. In the case of a release
that is "non-health threatening" and "contained" as defined, the Department
of Environmental Health and Safety (EH&S)
Emergency Response Team should be contacted immediately
and will assume command until relinquishing it to the PAFD or the hazard
has been fully abated.
As stated in the following section of this policy, the participation
of all members of the Stanford community is required for its successful
implementation. Department Chairs, Laboratory Directors, Principal Investigators,
and Supervisors have the specific responsibility to see that individuals
for whom they are responsible are trained in proper emergency response
procedures and that the work areas for which they are responsible are
posted conspicuously with emergency response procedures. (Please refer
to the Definitions section and Activating Procedures for a summary of
required responses in an emergency involving hazardous materials.)
EH&S is working with academic departments and can provide
information for a department in establishing emergency response procedures
for a specific area. An "IN CASE OF EMERGENCY" poster is available for
posting from EH&S. Please call that office (3-0448) with any questions
you may have.
Non-compliance with this policy may result in a building's
Hazardous Materials Storage Permit being revoked. Civil and criminal penalties
may also be sought by the enforcing agency.
NOTE: There is a separate policy for dealing with
emergencies involving hazardous materials in the School of Medicine. That
policy is virtually identical to that described here, with differences
related to telephone numbers, emergency contact personnel, and some procedures
for involved units. For information in the School of Medicine, contact
the Medical School Manager of Health and Safety.
A) POLICY STATEMENT
It is the policy of Stanford University to establish and
maintain emergency response procedures and capabilities to:
- respond to incidents involving hazardous materials;
- assist the Fire Department with hazardous materials expertise;
- clean up modest hazardous materials releases;
- maintain records of all hazardous materials releases and accidents;
- report incidents to outside agencies as required;
- review causes of incidents to reduce recurrence; and,
- review responses to incidents in order to improve service.
This policy and associated procedures are intended to provide
tiered response to incidents involving hazardous materials appropriate
to their magnitude and risk. If the appraisal of magnitude and risk is
uncertain, the response strategy will address the worst case scenario.
Extreme care should be taken that these procedures are followed explicitly
and consistently and that the reporting party provides accurate and complete
information to the responding entity.
The purpose of this statement is to set forth procedures
to be followed in the event of an emergency involving the accidental release
of hazardous materials, in order to:
- protect research personnel, the general public,
and the environment;
- protect property and research assets;
- comply with the regulatory response reporting, recording and abatement
requirements;
- encourage safe practices and requests for assistance when personnel
are in doubt about hazardous materials; and
- standardize response procedures throughout the University.
Refer to Section II A) "Definitions" for a summary of required
responses and actions.
Conditions and releases involving asbestos are excluded
from this policy (call 3-0486 for attention to asbestos concerns).
B) RESPONSIBILITIES
Environmental Health & Safety is responsible for:
1. maintaining a trained emergency response team
and equipment capable of addressing modest Hazardous Materials Releases;
2. maintaining working knowledge of applicable laws and regulations;
3. maintaining records of Hazardous Materials Releases and incidents;
4. informing the campus community of the Emergency and Hazardous Material
Release Response Policy.
Department Chairs, Principal Investigators, and Supervisors
are responsible for:
1. ensuring the safety of those working under their
direction;
2. assisting the Health and Safety Emergency Response Team or Palo Alto
Fire Department in any hazard evaluation in areas under their direction;
3. training those under their direction in correct emergency response
procedures;
4. ensuring that emergency response procedures are posted conspicuously
in each work area.
Faculty, Students, Staff and Visitors are responsible for:
1. following sound health and safety practices
; 2. reporting any emergency or hazardous situation immediately according
to these procedures;
3. cooperating and assisting with any emergency response personnel;
4. complying with all applicable University policies and practices.
A) DEFINITIONS
EMERGENCY:
An unforeseen event that calls for immediate action to
protect individuals, the environment, or property.
NON-EMERGENCY RELEASE:
A spill that is not the result of a container failure
and the quantity of which is less than one ounce (30 ml) and can be
cleaned up within 15 minutes. (Non-emergency releases do not require
recording or reporting, but must be cleaned up immediately. If assistance
is required, contact EH&S at 3-0448.)
HEALTH THREATENING:
An emergency in which there is a clear potential for serious
injury to a person or release of contaminants to the environment if
immediate action is not taken. (If in doubt, consider the emergency
health-threatening.)
NON-HEALTH THREATENING:
Any emergency in which there is not a clear potential
for serious injury to any person. (If unsure whether an emergency is
health- threatening or non health-threatening, assume it is health-
threatening.)
HAZARDOUS MATERIALS RELEASE:
A Health Threatening or Non-Health Threatening spill,
unauthorized or unexpected release of a hazardous material from primary
containment, as defined in any of the referenced laws or regulations.
If Health Threatening, the EH&S Emergency Response Team (ERT) will assist
the Palo Alto Fire Department or other responding agency in cleanup
and report of incident to Santa Clara County. If Non-Health Threatening,
EH&S will call the Central Communications if assistance is needed. Conditions
and releases involving asbestos are excluded from this policy (call
3-0486 for attention to asbestos concerns).
CONTAINED:
Indicates a Hazardous Material Release that is within
secondary containment, i.e. a floor, tray or engineered containment
system. (The ERT will cleanup and record the release.)
RELEASED TO THE ENVIRONMENT:
Indicates a Hazardous Material Release that is discharged
to the surface, soil, sewer, surface water or air outside of a building
at a hazardous level as defined by applicable regulations. This also
refers to a Contained Hazardous Material Release that takes more than
eight hours to clean up, as is specified in the Santa Clara County Hazardous
Material Storage Permit Ordinance. (The ERT will call Central Communications
at 9-911 and proceed to clean up the release obtaining assistance as
necessary and reporting to regulatory and other cognizant agencies as
required).
B) PROCEDURES
These procedures are intended to provide tiered response
to incidents involving hazardous materials appropriate to their magnitude
and risk. The evaluation of the hazard of what to report or record, and
of how to respond will be made by the ERT Command Staff in consultation
with the Principal Investigator (PI) or other knowledgeable or responsible
parties, and the Palo Alto Fire Department (PAFD) when they are involved.
In the event that there is no time for a full hazard evaluation,
or there are many chemicals or other complexities involved, or there is
insufficient information available about the materials or situation involved,
then precautions based on the worst case scenario for the incident will
be applied to the response to protect the ERT, the public and the environment.
These precautions will be taken by the ERT and any other agency responding
to a call for assistance.
Extreme care should be taken that these procedures are followed
explicitly and consistently and the reporting party should provide accurate
and complete information to the responding entity.
ACTIVATING PROCEDURES FOR EMERGENCY RELEASE
EXTREMELY IMPORTANT: FOLLOW THESE STEPS EXPLICITLY
In all cases, when any person becomes aware of an emergency,
regardless of its location:
- If Health Threatening, call 9-911 and/or pull
the nearest fire alarm if the building needs to be evacuated or if a telephone
is not available.
- If Non-Health Threatening, call EH&S at 3-0448.
- If involving radiation or radioactive materials, call Health Physics
at 3-3201.
- If the reporting party is unclear of the health threatening nature of
the emergency, assume it is health-threatening and proceed accordingly.
- If the release is in a laboratory, in addition notify the Principal
Investigator responsible for that area as soon as it is practical to do
so. If the Principal Investigator is unknown or unavailable then notify
the Department or Building Administrator, Safety Committee Chairperson,
or Department Chairperson. When possible, leave appropriate messages in
each case. (The work and home phone numbers of these people should be
posted near every room containing hazardous materials.)
When 9-911 (Central Communications) receives a report of
an emergency involving hazardous materials during working hours they will
notify EH&S immediately. During non-working hours 9-911 will notify EH&S
at 3-0448 and at all other times they will contact the ERT directly. 9-911
will notify the Health Physics Office at 3-3201 in the event of an emergency
involving radiation or radioactive materials.
General Responding Procedures (more specific actions will
be followed depending on the incident):
1) DURING WORKING HOURS:
When EH&S receives a call from the reporting party or
Central Communications the following will occur:
a) The report receiver will acquire all pertinent information regarding
the emergency (time, date, nature and location of the incident, name
and phone number of reporting party and type and quantity of hazardous
materials involved) and record that on a Request and Response (R&R)
form. If the incident is in a laboratory, obtain if possible, the name
and phone number of the PI and determine if the PI has been contacted
and record this on the R&R form. If the PI has not been contacted the
reporting party should be told to contact the PI immediately.
b) The R&R form will be given to a designated ERT Leader who will establish
the Incident Command System (ICS) to the extent necessary to respond
to the incident.
c) The ERT is in command of the affected area until further notice or
command is transferred to the PAFD.
d) The ERT will consist of a Team Leader, an Operations Staff and a
Command Staff. The Command Staff will include at minimum a Safety Officer
and if needed a Public Information Officer. The Team Leader may function
in any or all of these roles.
e) The ERT Leader will contact the reporting party to gather more information
about the incident, if necessary.
f) The ERT Leader will see that the PI (or other responsible party in
the order previously stated if PI is not available) has been called.
g) The ERT Leader will call for assistance such as the PAFD or cleanup
contractor if the release is either Health Threatening or Released to
the Environment or is otherwise necessary.
h) If the PAFD is called to the scene, Command will be transferred to
the PAFD by the ERT Leader.
i) The ERT will respond to the site of the incident.
j) The ERT Leader, in consultation with the Operations Staff, Command
Staff, the PI or other responsible party, and others if needed, should
establish the response strategy, compliant with all requirements of
the OSHA regulations in 29 CFR part 1910.120 and the Santa Clara County
Hazardous Materials Storage Ordinance (SCCHMSO) and other relevant laws
and regulations.
k) The Operations Staff will then initiate the response strategy to
abate the hazard accordingly.
2) DURING NON-WORKING HOURS:
When a reporting party calls EH&S, the following will
occur:
a) The dispatcher for Central Communications or the person at the Work
Information Center will acquire all pertinent information regarding
the emergency (time, date, nature and location of incident, name and
phone number of reporting party, and type and quantity of hazardous
materials involved) and record that information.
b) If Central Communications has been contacted they will then dispatch
the appropriate fire, police and ambulance service.
c) The PAFD is in command until further notice or command is transferred
to the ERT.
d) The Work Information Center or Central Communications will then go
down the emergency call list provided by EH&S of members of the ERT.
They will call each team member, in the order that they appear on the
list, until they reach one of them at home.
e) The Work Information Center or Central Communications will then give
the pertinent information, gathered from the reporting party to the
ERT Member. Central Communications will continue to call other team
members if requested to do so by the member contacted.
f) The first designated ERT Leader contacted will establish the Incident
Command System (ICS) to the extent necessary to respond to the incident.
g) ERT will consist of an ERT Leader, an Operations Staff and a Command
Staff. The Command Staff will include at minimum a Safety Officer and
if needed a Liaison Officer and a Public Information Officer. The Team
Leader may function in any or all of these roles.
h) The ERT Leader will contact the reporting party to gather more information
about the incident, if necessary.
i) The ERT Leader will call for assistance such as the PAFD or cleanup
contractor if the release is either Health Threatening or Released to
the Environment or if otherwise necessary.
j) If the PAFD is called to the scene, Command will be transferred to
the PAFD by the ERT Leader.
k) The ERT Leader will see that the PI or other responsible department
member has been called.
l) The ERT will respond to the ESF to pick up the ER vehicle.
m) At ESF the Team Leader will begin an R&R form on the incident.
n) The ERT will then respond to the site of the incident.
o) The ERT Leader, in consultation with the Operations Staff, Command
Staff, the PI or other responsible party, and others if needed, will
establish a response strategy that complies with all requirements of
the OSHA regulations in 29 CFR part 1910.120 and the Santa Clara County
Hazardous Materials Storage Ordinance (SCCHMSO) and other relevant laws
and regulations.
p) The Operations Staff will then initiate the response strategy to
abate the hazard accordingly.
3) For a Non-Health Threatening, Contained incident (the
PAFD or other agencies are not present) the following procedures apply:
a) On arrival at the site the ERT will conduct an initial hazard evaluation
of the incident.
b) If the ERT Leader determines that the incident is either Health Threatening
or Released to the Environment, then the ERT will call for additional
assistance from the PAFD and transfer Command to the PAFD at that time.
If time permits this should be done after consulting with the PI or
other responsible party and the Director, Associate Director, Fire Marshall,
or other designated Command Staff members of the Health and Safety ERT.
c) A full hazard evaluation should then be conducted if time permits.
d) Under the command of the PAFD, the ERT Leader, in consultation with
the Operations Staff, Command Staff, the PI or other responsible party,
and others if needed, will establish the response strategy that complies
with all requirements of the OSHA regulations in 29 CFR part 1910.120
and the SCCHMSO and other relevant laws and regulations.
e) The Operations Staff will then initiate the response strategy to
abate the hazard accordingly.
4) Whenever the PAFD or Police arrive, they designate
an Incident Commander and establish their own ICS. The ERT Leader will
then render any assistance that the Incident Commander may need.
5) All Emergency Hazardous Material Releases will be reported
to EH&S and recorded on an R&R. All spills due to container failure
must be reported to EH&S. Non-container spills greater than one ounce
(30 ml) that can not be cleaned up within 15 minutes must also be reported
to EH&S. For any Health Threatening Hazardous Material Release to the
Environment, Central Communications will be notified immediately to
assist in the response and the Santa Clara County Health Department
will also be notified immediately at (408) 299-6930.
C) REFERENCES
Santa Clara County Hazardous Materials Storage Ordinance
(SCCHMSO) (SCC Ord. NS517.31 Sec. B11-306.01):
Specifies Hazardous Materials release recording
and reporting requirements and that an emergency and spill response plan
be developed and implemented.
Chapter 6.6 of the Health and Safety Code
(Safe Drinking Water and Toxic Enforcement Act):
Contains requirements for the reporting of hazardous
materials releases. They do not apply, however, until a particular chemical
has been listed by the Governor for more than 12 months. Even then the
requirements will only apply to those chemicals that are listed.
Chapter 6.95 of the Health and Safety Code (H&SC)
(Hazardous Material Release Response Plans and Inventories,
H&SC sec. 25359.4):
Refer to spill reporting requirements. Title 19
California Administrative Code Sections 2701 et sec.
California Occupational Safety and Health Administration
regulations:
Require reporting industrial injury as defined
on OSHA form 5020.
Cal/OSHA (Hazardous Materials Information and Training Act):
See OSHA 29 CFR.
Superfund Amendments and Reauthorization Act of Environmental
Protection Agency (EPA) part 1910.1200 Title III CERCLA Amendments:
Community right to know, reporting and cleanup
of releases to the environment.
Resource Conservation and Recovery Act of Environmental
Protection Agency (EPA):
Defines illegal disposal
OSHA 29 CFR part 1910.120:
Regulates emergency response teams.
Proposed OSHA 29 CFR 1910.1450:
Regulates emergency response teams.
OSHA 29 CFR 1910.1200:
Hazard Communications Standard, emergency information
and training.
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