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When is a spill really a spill?
FEATURES
When Is a Spill Really a Spill? Spills of hazardous materials are always a possibility in a research lab although most labs, and institutions with labs, cannot justify a full-time hazardous materials response team to respond to those spills. Labs should respond to incidental spills if it is safe, if they have training, and if they have equipment; a hazardous materials response team should respond in all other situations. The key is determining which is which. At the University of California–San Diego we have developed a flexible system that allows to respond to situations appropriately, protect the safety of our personnel and comply with applicable regulations.
By James M. Kapin
A
t the University of California, San Diego (UCSD), we maintain a hazardous materials response team to respond to routine spills and chemical emergencies and to assist outside agencies in case of a campus disaster. “Spills happen,” and it is an important part of our job to respond to these situations in an appropriate manner. Maintaining a hazardous materials response team represents a substantial expense in terms of equipment and personnel, but we think it necessary to have this particular expertise available in-house. However, we do not want to burden our personnel for minor or incidental spills. All UCSD responders have other jobs, so we need to balance these job duties with need to protect campus personnel and provide customer service. The majority of our responses are to laboratory scale spills inside a re-
Jim Kapin has worked in industrial hygiene, lab safety, and emergency response for over 10 years. He has a B.A. from UCSD, an M.P.H. from San Diego State University, and holds local and national offices in the California Campus Environmental Health and Safety Association, American Industrial Hygiene Association, and the American Chemical Society. He is also on the faculty of the San Diego Community College District. Jim can be reached at (858) 534-2823 or at [email protected]. 16
search laboratory. On the one hand, lab spills are generally no more than a few liters and laboratories themselves generally have a range of engineering controls that provide a large margin of safety to the responders and personnel in nearby areas. In addition, we generally know what material has been spilled. On the other hand, across the entire campus there is a tremendous range of materials that can be released. So when is a spill really a spill? When can labs handle the situation and when do we need to activate our team? Once activated, what role should our team play?
UNCONTROLLED RELEASES, INCIDENTAL SPILLS, AND EMERGENCY RESPONSE
According to regulations, an “Emergency Response” is “a response effort . . . to an occurrence which results in, or is likely to result in, an uncontrolled release of a hazardous substance” (29 CFR 1910.120 (a)(3)). With this in mind, the answer to the first question is simple: A spill is really a spill when it is an “uncontrolled release” where lives, the environment, or property are in immediate danger. Lab personnel are not (usually) trained to deal with these situations; however, they are clearly able to mop up small spills that occur in the course of daily activities. Labs should respond to incidental spills if it is safe, if they have training, and if they have equipment. A hazardous materials response team should respond to “nonincidental” releases, i.e., uncontrolled releases in a laboratory setting. Of
© Division of Chemical Health and Safety of the American Chemical Society Published by Elsevier Science Inc.
course, sometimes the difference between an incidental spill and an uncontrolled release is difficult to determine. Deciding how to respond to a spill, like any other decision about worker safety, needs to be made based on occupational health principles, not by regulatory compliance. In this case, however, the regulations provide us a convenient framework. Title 29 of the Code of Federal Regulations, section 1910.120 (29 CFR 1910.120), Hazardous Waste Operations and Emergency Response (HAZWOPR), tells us that an uncontrolled release requires an emergency response if it puts lives in danger. An incidental release, on the other hand, is not an emergency and so does not require an emergency response. Definitions of these terms are clarified in a variety of Standard Interpretation and Compliance letters, accessible through the OSHA Web site at www.osha.gov. ●
●
An uncontrolled release is an accidental release of a hazardous substance from its container that, if not contained or stopped, would pose a threat to personnel in the immediate area from the vapors, fire, overpressurization, etc. Such releases require an emergency response. An emergency response is required for uncontrolled releases, because they could cause high levels of exposure to toxic substances, threaten life or injury (or at least IDLH conditions), pose the threat of fire or explosion, or otherwise require immediate action. Spills or releases that do not require immediate atten-
1074-9098/01/$20.00 S1074-9098(00)00160-X
●
tion are not necessarily emergencies. An incidental release is one that does not present an immediate health or safety hazard to employees, property, or the environment. No immediate action is required and the spill does not need a response to prevent death injury or other damage. If action does not need to be taken immediately, if the health and safety of employees is not immediately threatened or there are not other safety or health hazards (even if an alarm has been sounded), then the situation is not an emergency.
A release is covered by the HAZWOPR standard whenever conditions create an emergency. Incidental releases cleaned up by personnel from outside the area are not necessarily emergencies.
IS IT AN EMERGENCY?
Chemical releases which do not pose a threat to the health or safety of the employees or the workers cleaning it up are considered incidental. Incidental releases are limited in quantity, exposure potential, and toxicity, and clearly present a minimal hazard to workers in the area or those assigned to clean them up. ●
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An incidental release of a hazardous substance which does not pose a significant safety or health threat to employees in the area, or to workers cleaning the spill, and which does not have the potential to be come more serious is not an emergency. Nuisance spills, minor releases that do not require immediate attention (from lack of danger to employees, property, or other factors), are not considered emergencies. An ordinary spill that can be handled by workers is not an emergency, although workers must be properly trained under Hazcom or the lab standard. Responses to releases of hazardous substances where there is no potential for health or safety hazards are also not emergencies. If the safety of employees is not immediately threatened (and no other
●
hazards are involved), there is no emergency. If action does not need to be taken immediately, there is no emergency.
If we do not need to declare the situation an emergency under HAZWOPR regulations, we have some freedom to respond in a time frame and in a manner that allows us to protect worker safety and to use our human resources sensibly.
but there is no time pressure other than from lab personnel anxious to get back to work. On the other hand, a broken vacuum line venting mercury from a diffusion pump and possibly condensing oxygen out of the atmosphere in the cold traps could easily escalate if not handled properly. Even water leaking from a refrigerator can trigger an emergency response—if the first people on the scene had no other information than several gallons of an unknown liquid spreading across a floor.
SO HOW TO RESPOND?
The potential for an emergency is determined case by case. Spill assessment is based on anticipated exposures and other consequences. It is important to consider toxicity by all routes of exposure (especially inhalation and dermal) and to look at hazard characteristics, including flammability, explosiveness, reactivity, and the surrounding environment. High vapor pressures, oxygen displacement, toxicity or explosive atmospheres, along with corrosivity and other potential for bodily impairment would contribute to the evaluation of emergency potential. Of course, physical properties alone are not going to tell the full story; large amounts of less hazardous materials can pose the same threat as small quantities of a more hazardous materials. Other factors to consider include breakdown products or incompatibility issues (such as with air- or waterreactive materials), synergistic, or additive affects. The final factor to consider is the experience of employees in the area. Workers who are familiar with a material, understand its hazards, and are trained and equipped to deal with those hazards may treat a spill as incidental that would be considered an emergency in another area. The bottom line is that emergencies require quick action—if there is any doubt about the situation, treat it as an emergency. Four liters of hydrochloric acid spilled on the floor of a lab area is probably beyond the capabilities of most labs to handle; however, once the space is evacuated and the doors are closed, this situation is stable. The HazMat team needs to be activated,
Chemical Health & Safety, January/February 2001
APPROPRIATE RESPONSE
The key to protecting campus personnel (and ourselves) without overextending our resources is to provide an appropriate response. Overresponding wastes resources and needlessly disrupts lab activities; an underresponse puts lives, the environment, or property in danger. Given the variety of materials used on campus and the even variety of knowledge, skills, and abilities among lab personnel, we have developed a system that allows us maximum flexibility. Once we are notified of a spill or a release, if we can confirm the release is only incidental, we have a “nonresponse” response. The labs will be instructed on how to clean the spill safely and we will follow up to make sure there are no problems. If we cannot confirm the spill is incidental, we will handle it as a Hazardous Material Response, activate our team, and respond appropriately. Even if the situation is an uncontrolled release, if it does not pose an immediate threat and does not need to be responded to immediately, it is still not a true “emergency response.”
GETTING THINGS GOING
The most important step in this system is the first one. Calls can come in from the front desk or through a variety of other personnel who do not have adequate training to make a decision in this area. In these cases, a group page will go out to the hazardous materials response team and a knowledgeable member of our team will contact the lab or spill area as soon as possible to 17
gram and are certified to wear air-purifying respirators (APRs) and selfcontained breathing apparatus (SCBAs). The secondary Responders (the “Blue Team”) are used for support and decontamination duties in larger-scale events. HAZWOPR training is optional for them and they may wear a respirator, depending on their level of experience and training. All spill response materials are stored on spill response carts that can be moved to the scene of the spill. This gives us more mobility than the traditional trucks or vans that are often used on campuses. Once a response is initiated, the carts can easily be unloaded and brought to the spill location, giving us easy access to all required supplies, protective equipment, and other resources we need.
CONCLUSION
Figure 1. Spill Response Flowchart.
find out relevant information and decide what type of response to initiate. Based on information received, that person may instruct the lab to handle the spill themselves (the nonresponse response) or initiate a hazardous materials response by the HazMat team (Figure 1). If we cannot be sure the spill is only incidental, that initial contact will provide relevant information for other team member who will be calling in; if it is incidental, they will send the “all clear” page. The initial group page goes out to all the primary hazardous material responders. For large-scale situations that require
18
more personnel, we have a secondary group of responders that can be called in. Campus police can activate our response team by activating an “afterhours” call-back list. Our primary responders (the “Red Team”) are all 40-hour trained and able to act as incident commanders, operations, or HazMat leader or any other role in the incident command system. If an actual response is called for, they will make up the majority of the entry and backup teams. In addition to the HAZWOPR training and annual refresher training, they are all enrolled in a medical surveillance pro-
This flexible approach allows us to provide an appropriate response to a variety of situations with a limited commitment of personnel. By having this capability, we can coordinate with other responding agencies and minimize disruption to research and instruction. Spills are inevitable in an institution with over 200 research laboratories in over 40 buildings; although the type and variety of those spills vary greatly, we need to be able to deal with a range of events from 10 mL of HCl spilled in an instructional lab to a leaky cylinder of arsine in a pilot-scale semiconductor fabrication facility. With this in mind, our flexible, staged approach allows us to put the right people in place when the spill really is a spill, while still allowing us the flexibility to respond in an appropriate manner.
Chemical Health & Safety, January/February 2001
When Is a Spill Really a Spill? Spills of hazardous materials are always a possibility in a research lab although most labs, and institutions with labs, cannot justify a full-time hazardous materials response team to respond to those spills. Labs should respond to incidental spills if it is safe, if they have training, and if they have equipment; a hazardous materials response team should respond in all other situations. The key is determining which is which. At the University of California–San Diego we have developed a flexible system that allows to respond to situations appropriately, protect the safety of our personnel and comply with applicable regulations.
By James M. Kapin
A
t the University of California, San Diego (UCSD), we maintain a hazardous materials response team to respond to routine spills and chemical emergencies and to assist outside agencies in case of a campus disaster. “Spills happen,” and it is an important part of our job to respond to these situations in an appropriate manner. Maintaining a hazardous materials response team represents a substantial expense in terms of equipment and personnel, but we think it necessary to have this particular expertise available in-house. However, we do not want to burden our personnel for minor or incidental spills. All UCSD responders have other jobs, so we need to balance these job duties with need to protect campus personnel and provide customer service. The majority of our responses are to laboratory scale spills inside a re-
Jim Kapin has worked in industrial hygiene, lab safety, and emergency response for over 10 years. He has a B.A. from UCSD, an M.P.H. from San Diego State University, and holds local and national offices in the California Campus Environmental Health and Safety Association, American Industrial Hygiene Association, and the American Chemical Society. He is also on the faculty of the San Diego Community College District. Jim can be reached at (858) 534-2823 or at [email protected]. 16
search laboratory. On the one hand, lab spills are generally no more than a few liters and laboratories themselves generally have a range of engineering controls that provide a large margin of safety to the responders and personnel in nearby areas. In addition, we generally know what material has been spilled. On the other hand, across the entire campus there is a tremendous range of materials that can be released. So when is a spill really a spill? When can labs handle the situation and when do we need to activate our team? Once activated, what role should our team play?
UNCONTROLLED RELEASES, INCIDENTAL SPILLS, AND EMERGENCY RESPONSE
According to regulations, an “Emergency Response” is “a response effort . . . to an occurrence which results in, or is likely to result in, an uncontrolled release of a hazardous substance” (29 CFR 1910.120 (a)(3)). With this in mind, the answer to the first question is simple: A spill is really a spill when it is an “uncontrolled release” where lives, the environment, or property are in immediate danger. Lab personnel are not (usually) trained to deal with these situations; however, they are clearly able to mop up small spills that occur in the course of daily activities. Labs should respond to incidental spills if it is safe, if they have training, and if they have equipment. A hazardous materials response team should respond to “nonincidental” releases, i.e., uncontrolled releases in a laboratory setting. Of
© Division of Chemical Health and Safety of the American Chemical Society Published by Elsevier Science Inc.
course, sometimes the difference between an incidental spill and an uncontrolled release is difficult to determine. Deciding how to respond to a spill, like any other decision about worker safety, needs to be made based on occupational health principles, not by regulatory compliance. In this case, however, the regulations provide us a convenient framework. Title 29 of the Code of Federal Regulations, section 1910.120 (29 CFR 1910.120), Hazardous Waste Operations and Emergency Response (HAZWOPR), tells us that an uncontrolled release requires an emergency response if it puts lives in danger. An incidental release, on the other hand, is not an emergency and so does not require an emergency response. Definitions of these terms are clarified in a variety of Standard Interpretation and Compliance letters, accessible through the OSHA Web site at www.osha.gov. ●
●
An uncontrolled release is an accidental release of a hazardous substance from its container that, if not contained or stopped, would pose a threat to personnel in the immediate area from the vapors, fire, overpressurization, etc. Such releases require an emergency response. An emergency response is required for uncontrolled releases, because they could cause high levels of exposure to toxic substances, threaten life or injury (or at least IDLH conditions), pose the threat of fire or explosion, or otherwise require immediate action. Spills or releases that do not require immediate atten-
1074-9098/01/$20.00 S1074-9098(00)00160-X
●
tion are not necessarily emergencies. An incidental release is one that does not present an immediate health or safety hazard to employees, property, or the environment. No immediate action is required and the spill does not need a response to prevent death injury or other damage. If action does not need to be taken immediately, if the health and safety of employees is not immediately threatened or there are not other safety or health hazards (even if an alarm has been sounded), then the situation is not an emergency.
A release is covered by the HAZWOPR standard whenever conditions create an emergency. Incidental releases cleaned up by personnel from outside the area are not necessarily emergencies.
IS IT AN EMERGENCY?
Chemical releases which do not pose a threat to the health or safety of the employees or the workers cleaning it up are considered incidental. Incidental releases are limited in quantity, exposure potential, and toxicity, and clearly present a minimal hazard to workers in the area or those assigned to clean them up. ●
●
●
●
●
An incidental release of a hazardous substance which does not pose a significant safety or health threat to employees in the area, or to workers cleaning the spill, and which does not have the potential to be come more serious is not an emergency. Nuisance spills, minor releases that do not require immediate attention (from lack of danger to employees, property, or other factors), are not considered emergencies. An ordinary spill that can be handled by workers is not an emergency, although workers must be properly trained under Hazcom or the lab standard. Responses to releases of hazardous substances where there is no potential for health or safety hazards are also not emergencies. If the safety of employees is not immediately threatened (and no other
●
hazards are involved), there is no emergency. If action does not need to be taken immediately, there is no emergency.
If we do not need to declare the situation an emergency under HAZWOPR regulations, we have some freedom to respond in a time frame and in a manner that allows us to protect worker safety and to use our human resources sensibly.
but there is no time pressure other than from lab personnel anxious to get back to work. On the other hand, a broken vacuum line venting mercury from a diffusion pump and possibly condensing oxygen out of the atmosphere in the cold traps could easily escalate if not handled properly. Even water leaking from a refrigerator can trigger an emergency response—if the first people on the scene had no other information than several gallons of an unknown liquid spreading across a floor.
SO HOW TO RESPOND?
The potential for an emergency is determined case by case. Spill assessment is based on anticipated exposures and other consequences. It is important to consider toxicity by all routes of exposure (especially inhalation and dermal) and to look at hazard characteristics, including flammability, explosiveness, reactivity, and the surrounding environment. High vapor pressures, oxygen displacement, toxicity or explosive atmospheres, along with corrosivity and other potential for bodily impairment would contribute to the evaluation of emergency potential. Of course, physical properties alone are not going to tell the full story; large amounts of less hazardous materials can pose the same threat as small quantities of a more hazardous materials. Other factors to consider include breakdown products or incompatibility issues (such as with air- or waterreactive materials), synergistic, or additive affects. The final factor to consider is the experience of employees in the area. Workers who are familiar with a material, understand its hazards, and are trained and equipped to deal with those hazards may treat a spill as incidental that would be considered an emergency in another area. The bottom line is that emergencies require quick action—if there is any doubt about the situation, treat it as an emergency. Four liters of hydrochloric acid spilled on the floor of a lab area is probably beyond the capabilities of most labs to handle; however, once the space is evacuated and the doors are closed, this situation is stable. The HazMat team needs to be activated,
Chemical Health & Safety, January/February 2001
APPROPRIATE RESPONSE
The key to protecting campus personnel (and ourselves) without overextending our resources is to provide an appropriate response. Overresponding wastes resources and needlessly disrupts lab activities; an underresponse puts lives, the environment, or property in danger. Given the variety of materials used on campus and the even variety of knowledge, skills, and abilities among lab personnel, we have developed a system that allows us maximum flexibility. Once we are notified of a spill or a release, if we can confirm the release is only incidental, we have a “nonresponse” response. The labs will be instructed on how to clean the spill safely and we will follow up to make sure there are no problems. If we cannot confirm the spill is incidental, we will handle it as a Hazardous Material Response, activate our team, and respond appropriately. Even if the situation is an uncontrolled release, if it does not pose an immediate threat and does not need to be responded to immediately, it is still not a true “emergency response.”
GETTING THINGS GOING
The most important step in this system is the first one. Calls can come in from the front desk or through a variety of other personnel who do not have adequate training to make a decision in this area. In these cases, a group page will go out to the hazardous materials response team and a knowledgeable member of our team will contact the lab or spill area as soon as possible to 17
gram and are certified to wear air-purifying respirators (APRs) and selfcontained breathing apparatus (SCBAs). The secondary Responders (the “Blue Team”) are used for support and decontamination duties in larger-scale events. HAZWOPR training is optional for them and they may wear a respirator, depending on their level of experience and training. All spill response materials are stored on spill response carts that can be moved to the scene of the spill. This gives us more mobility than the traditional trucks or vans that are often used on campuses. Once a response is initiated, the carts can easily be unloaded and brought to the spill location, giving us easy access to all required supplies, protective equipment, and other resources we need.
CONCLUSION
Figure 1. Spill Response Flowchart.
find out relevant information and decide what type of response to initiate. Based on information received, that person may instruct the lab to handle the spill themselves (the nonresponse response) or initiate a hazardous materials response by the HazMat team (Figure 1). If we cannot be sure the spill is only incidental, that initial contact will provide relevant information for other team member who will be calling in; if it is incidental, they will send the “all clear” page. The initial group page goes out to all the primary hazardous material responders. For large-scale situations that require
18
more personnel, we have a secondary group of responders that can be called in. Campus police can activate our response team by activating an “afterhours” call-back list. Our primary responders (the “Red Team”) are all 40-hour trained and able to act as incident commanders, operations, or HazMat leader or any other role in the incident command system. If an actual response is called for, they will make up the majority of the entry and backup teams. In addition to the HAZWOPR training and annual refresher training, they are all enrolled in a medical surveillance pro-
This flexible approach allows us to provide an appropriate response to a variety of situations with a limited commitment of personnel. By having this capability, we can coordinate with other responding agencies and minimize disruption to research and instruction. Spills are inevitable in an institution with over 200 research laboratories in over 40 buildings; although the type and variety of those spills vary greatly, we need to be able to deal with a range of events from 10 mL of HCl spilled in an instructional lab to a leaky cylinder of arsine in a pilot-scale semiconductor fabrication facility. With this in mind, our flexible, staged approach allows us to put the right people in place when the spill really is a spill, while still allowing us the flexibility to respond in an appropriate manner.
Chemical Health & Safety, January/February 2001