outlook
Prepare Proactively for Environmental Incidents
W
hen releases of chemicals or wastes occur, how a plant and its employees respond often deter- mines how big the problem becomes. Prepara-
tion is the key to responding appropriately to an environmen- tal accident.
The laws and regulations applicable to a specifi c environ- mental emergency depend on the substance released (e.g., petroleum products, hazardous wastes, listed chemicals, etc.), the environmental media affected by the release (i.e., air, land, surface water, groundwater), the people potentially exposed to the released substance (employees or the general public), and whether the combination of these factors impli- cates a regulatory program administered by federal, state or local governments. Understanding the requirements before an environmental emergency happens can help prevent an ineffective response and reporting delays. While there are many potentially applicable require- ments, general concepts are consistent throughout the laws and regulations.
Defi ne Responsibilities Responsibility for environmental matters at a manufac- turing facility can be assigned in different ways, but for an organization to address an emergency successfully, responsi- bilities must be clearly defi ned and integrated into a response plan before an emergency occurs.
Facilities should have a clear chain of command. Vari- ous laws and regulations require designating an emergency response coordinator and training of employees about how to respond to an environmental emergency. Response tasks, including internal and external reporting, should be assigned to specifi c employees before an emergency, and the coordi- nator should confi rm such tasks have been completed.
Addressing the Emergency The appropriate measures to take during an environmental emergency vary widely depending on the event. Safety of
John W. Dawson IV
Bass, Berry & Sims PLC (Nashville, TN)
employees, fi rst responders and the general public should be the fi rst concern. When it is safe, steps should be taken to stop the release and contain released materials. Proper safety and response equipment should be available and used. If possible, fl oor drains, storm drains, drainage ditches, pipes, air ducts and other pathways to the environment should be closed.
Response tasks, including internal and external reporting, should be assigned to specifi c employees before an emergency.
For things to go as smoothly as possible during an emer-
gency, the response equipment, alarms and communication systems must be in good working order. This requires peri- odic inspections. Likewise, employees must know and have practiced their responsibilities prior to the emergency.
Reporting a Release During an environmental emergency, reporting to regula- tors often gets overlooked or delayed. Several laws and regulations require immediate reporting to the National Response Center and/or state and local offi cials. Under various enforcement policies, US EPA interprets “immedi- ate” as within 15 minutes of knowledge of the release. This reporting allows a designated offi cial to quickly arrive at the scene and provide expertise that can help reduce the impacts of an environmental release. Follow-up reporting at a later date is also required in some situations. It is critical that the personnel responsible for external reporting under- stand the requirements before the emergency. The best way to handle an environmental emergency is
to be prepared. Preparation can prevent the impacts of the release from becoming worse and reduce the risk of penalties for failure to follow applicable legal requirements.
27 — Motorized Vehicle Manufacturing 2017
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