In a few weeks look for our latest EBook, “The 10 Most Common Hazardous Waste Violations & How to Avoid Them.” In the meantime, today’s post will provide a sneak peek and focus on one of the most common violations and sources of Department of Toxic Substances Control (DTSC) fines; failure to have an emergency contingency plan.
Every hazardous waste generator is required to have an emergency contingency plan. A written Hazardous Waste Contingency Plan is a program designed to minimize hazards to human health and the environment from fires, explosions or an unplanned sudden release of a hazardous waste. This program is developed by each facility owner or operator and establishes actions that must be immediately implemented during an emergency situation. Each plan lays out an organized, planned and coordinated response to an emergency. The type of contingency plan required for a facility depends on the amount and types of waste generated at the facility.
To understand your requirements, you must first understand your hazardous waste generator requirements, which are determined by the amount of hazardous waste your facility produces each month.
Creating a Contingency Plan
Contingency Plan Requirements for Small Quantity Generators (SQG’s)
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Designate an emergency coordinator and post contact information
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Post the location of emergency equipment
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Post emergency telephones
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Ensure employees are familiar with emergency procedures
Contingency Plan Requirements for Large Quantity Generators (LQG’s)
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Create a written plan on-site and make sure the it is up-to-date and reviewed frequently
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Designate an emergency coordinator(s) and post contact information
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Post the location of emergency equipment
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Post emergency telephones
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Create an emergency evacuation plan
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Ensure employees are familiar with emergency procedures
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List name, address and phone number (s) (home and office) for designated emergency coordinator
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Submit written plan to local authorities
To Whom Must the Plan be Submitted
In addition to maintaining a copy (or copies) of the contingency plan at the facility, copies must be submitted to local police departments, fire departments, hospitals, and state and local emergency response teams that may provide emergency services to the facility. Even if a facility will be providing its own responders, the contingency plan still should be sent to appropriate authorities in the local community in case of an off-site release or major emergency that requires their assistance. Individual copies of the contingency plan should be numbered. A facility should maintain a log identifying each copy and its location.
Why is this Important?
Recent tragedies such as the devastating explosion at the West Fertilizer Company in West, Texas in April of 2013, should serve as a reminder to companies to put proper controls in place to ensure that your company is in compliance with Federal and State regulations. During this catastrophe, 14 people died including 11 first responders. A proper contingency plan is one of those requirements for the safety of your employees, emergency responders and your community. It can help to save lives in the event of a catastrophe.
To determine if you are in compliance, it is good business to perform a routine facility audit to ensure that you are meeting your regulatory obligations. Consult with a licensed and experienced hazardous waste disposal company to create your hazardous waste contingency plan.
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