The 2017 hurricane season was one of the most expensive in U.S. history. Combined, Hurricanes Harvey, Irma, Maria and Jose exceeded $200 billion in damages. In 2018, the world watched as Hurricanes Florence and Michael wreaked havoc in North Carolina and the Florida Panhandle. Hurricane Michael was recorded as the strongest storm to make landfall in the U.S. since Hurricane Andrew in 1992. So, as the 2019 hurricane season starts, operators of chemical plants should get ready.
Unfortunately, too many businesses focus more on how to address the aftermath of a hurricane — or other extreme weather, such as tornados and flooding, that also can lead to significant damage — than preparing for the next event.
Indeed, many facility operators aren’t equipped to handle weather-related emergencies. One of the most dangerous and costly mistakes chemical plant managers can make is neglecting to prepare hazardous waste for the impact of natural disasters.
To reduce the risks of injury, environmental harm or regulatory penalties, a successful response to a disaster requires extensive expertise and knowledge of hazardous materials and waste management. Often, natural disaster response involves emergency response to one or more spills, e.g., of fuels, chemicals, U.S. Department of Transportation (DOT) hazardous materials and U.S. Environmental Protection Agency (EPA) hazardous wastes. This necessitates successfully performing critical tasks such as identifying unknown substances, spill containment, proper waste handling and cleanup.
Chemical industry leaders must place utmost importance on determining how to protect hazardous materials and wastes, as well as how to clean and dispose of them following a disaster. To avoid putting facilities, inventories and profitability at risk, they must take proper precautions so that operations are resilient in the event of a disaster, especially one resulting in high winds, heavy rainfall and flooding.
The following tips will help you better prepare to protect hazardous waste in chemical facilities before and during extreme weather emergencies.
Identify Hazardous Waste
Before any action steps can take place, it’s necessary to understand what’s considered hazardous waste. The EPA defines hazardous waste as “waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment.” Once an item with hazardous properties no longer is usable, it’s deemed hazardous waste.
The EPA regulates hazardous waste under the Resource Conservation & Recovery Act (RCRA) to ensure these wastes are managed in a compliant manner. RCRA mandates that generators of hazardous waste are responsible for waste from the time of generation to its final destruction, and sees that these wastes are managed in ways that protect human health and the environment.
Hazardous waste items have ignitable, corrosive, reactive or toxic characteristics. To determine whether a product is considered hazardous waste, review its safety data sheet (SDS), manufacturer information, label and ingredients. You also can check specific guidelines provided by hazardous management service providers.
Create An Emergency Response Plan
A lack of diligent preparation can lead to increased destruction and financial loss in the aftermath of a weather-related disaster. When creating an emergency response plan for a natural disaster, you should consider several factors.
First, facilities must assess their risk for natural disaster incidents. For example, a business on the Pacific Coast has the greatest risk of being impacted by earthquakes, wildfires and mud slides. In contrast, a facility on the Atlantic Coast more likely may encounter hurricanes and flooding. By identifying the most probable hazards, sites can plan to handle hazardous waste properly.
Next, plant operators should determine emergency response roles. Consider who will make crucial decisions in the event of a disaster, who will be involved in managing hazardous waste, and who will assist in its removal.
Additionally, an appropriate emergency response plan should include proper communication protocol. One common mistake organizations make when preparing for a disaster is not putting a thorough communication plan in place. Particularly in the event of a disaster, a lack of communication or a breakdown in delivering important messages is problematic and can pose hurdles, especially after the incident reaches the public eye. Proactive planning with local emergency responders is key to obtaining the response and support needed when an emergency strikes.
Lastly, keep in mind that when an area has been hit by a major hurricane, roads and access points often are blocked from entry. So, you should identify your emergency response partner in your emergency response plan so that its staff can gain entry to the site when there are restricted access areas. An emergency response partner also can handle all contact with local law enforcement and response teams to find out when it’s safe to travel to affected facilities and begin the hazardous waste cleanup process.
Before disaster strikes, plant managers can take steps to prevent waste from releasing inside the facility and into neighboring communities. If possible, remove excess waste and hazardous materials from the facility before any inclement weather hits.
Most chemical processing facilities have an abundance of bulk waste. While larger containers often are secured and don’t migrate in the event of a disaster, smaller containers run the risk of being lifted, carried or turned over, releasing hazardous materials into local communities and waterways. There’s also a potential risk of release in storage areas with an overflow of materials. To prevent these issues, keep hazardous waste storage areas clear, and take steps to mitigate items from spreading. Containers should be closed, sealed and relocated to a reinforced area of the facility or to an off-site space. Elevating containers can help prevent a release, especially if flooding is a concern. In any case, clearly identify, segregate and don’t block off storage areas.
Once extreme weather has subsided, teams should check the status of the materials on-hand and decide what’s been compromised, what must be removed and what should be replaced. Pumping out sewage tanks and disposing of incomplete manufactured articles also is a good idea.
Respond To Container Leaks
In dealing with a container leak, the two most important steps are identifying the spilled material and securing the container for cleaning. For compliance and safety, you must monitor the entire process to ensure timely and accurate communication, proper documentation and appropriate procedures.
After identifying the leaking material and assessing any immediate threats to human health and the environment, expert technicians should secure both the container and the surrounding area while also ensuring that no additional material can escape. It may make sense to move the container to a secure area, with special attention paid to weather and wind direction to maximize safety. Technicians also may perform air monitoring to check oxygen levels.
Cleaning requires use of specialized equipment, which may include HEPA-filter vacuums, salvage drums and disposable cleaning products. Technicians will separate damaged or contaminated items from any items deemed safe. Upon completion, the facility operator should request a detailed action report that includes images, a call log and supporting documentation.
Implement A Post-Incident Response Process
Unfortunately, many facility managers don’t take the necessary steps for managing hazardous waste until regulatory compliance dictates otherwise. However, ignoring regulatory mandates can severely undermine the organization’s brand, the safety of its employees and the trust of the community.
A post-incident response process and plan helps ensure the facility has taken the necessary steps to reduce further risk following a natural disaster. One important aspect is minimizing personnel exposure. So, when beginning the post-incident response process, it’s important to restrict access only to key personnel.
Plant operators then must verify any impacted building’s structural integrity to prevent catastrophic failure, which can result in injuries, severe damage and even death. City or government engineers must clear individuals to enter the building. Even after being allowed to enter, proceed with caution. Waste storage areas aren’t necessarily the only problematic areas. The severe weather will have shifted many items: shelving may have collapsed; the roof may have blown off; and light fixtures may have fallen. During remedial efforts, team members will need to break down, identify and segregate all hazardous materials.
Examine all areas of the site to determine if products require replacement, to prevent chemicals from entering waterways and to dispose of incomplete articles that no longer are usable. Chemical processing facilities typically involve higher volumes of bulk waste, likely resulting in more significant damage during extreme weather.
Understand The Impact Of Non-Compliance
There are many repercussions of improperly handling hazardous waste at any given time, including in the event of a disaster. Organizations that don’t understand federal, state and local regulations face environmental, health and safety risks, as well as chemical destruction. In addition, facilities may incur significant monetary penalties. While the financial burden of non-compliance is substantial, the negative impact these public fines have on brand perception can be even more damaging.
Because the public is showing growing concern for environmental issues, local and even national news outlets are quick to pick up on any perceived offenses by corporations. In addition, the proliferation of social media means negative news about environmental fines or improper disposal of hazardous waste spreads quickly and pervasively across those channels.
Common missteps that could result in fines include:
• lack of, or improper, labeling;
• open containers of hazardous waste onsite;
• dumping hazardous waste down the drain;
• having no or inadequate hazardous waste manifests;
• failing to properly train employees in hazardous waste management, handling and emergency preparedness;
• non-compliance with hazardous waste generator regulations; and
• not having hazardous waste determinations on file.
The average cost of a proactive environmental compliance program for hazardous waste varies but, with millions of dollars in potential fines at risk for non-compliant practices and consumer loyalty at stake, organizations must be well informed about changes from the EPA and update their hazardous waste management programs accordingly.
Seek Assistance From Experts
Even with a proper emergency response plan in place and great awareness of the importance of regulatory compliance, process plants should enlist the help of hazardous waste removal experts. Professional response is essential to several high-pressure tasks, such as identifying unknown substances, managing spill containment, handling hazardous waste and overseeing cleanup.
Substance identification is one of the most important responsibilities in any emergency response. Trained experts not only can identify numerous chemicals and compounds but also can assess any potential dangers. They can quickly and accurately identify an unknown substance and provide its SDS, which informs the on-site technicians of proper handling procedures, physical data, potential health hazards and equipment requirements for storage and disposal.
Without a pre-existing agreement in place, it could take more time for you to line up a third party to access and service your facility during a hurricane or other natural disaster, as its priority will be to tend to existing customers first. Therefore, it’s important to find the best emergency response partner for your facility before a disaster rather than waiting until the damage has occurred.
In the aftermath of a natural disaster, waste and environmental concerns are only a part of a larger, complicated picture. Every hazardous waste emergency response situation must be managed with a commitment to safety and full compliance. When disaster strikes, follow all applicable regulations from the initial response to cleanup and ultimate closeout of all paperwork and reporting.
WADE SCHEEL is the director of governmental affairs for Stericycle Environmental Solutions, Lake Forest, Ill. Email him at [email protected].