The adage “Knowledge is power” applies not only to life in general, but also to the discipline of hazmat response.
GLENN CLAPP CSP, EFO, CHMM, CFPS
The quantity and quality of intelligence we gather, both prior to and during a hazmat incident, is a great predictor of our success in bringing the incident to an efficient and effective positive outcome. Such intelligence assists us in determining the product or products we are dealing with, their relative hazards and the overall details of the situation at hand.
Successful intelligence gathering in relation to hazmat incidents should begin well before an incident occurs. Fire service personnel are very well acquainted with the pre-planning of commercial occupancies to enable us to be familiar with their layout, construction, and fire protection systems so that our fire suppression efforts can be maximized. In fact, the Insurance Services Office values pre-planning efforts so highly that in their Public Protection Classification (PPC) Rating that rates the fire suppression capabilities of a department, the maximum number of points that can be awarded in one section is gained by performing a minimum of one pre-planning activity per year with each commercial, industrial, institutional, or similar occupancy in their territory.
This emphasis on pre-planning activities should also be carried over into the field of hazardous materials response. Hazardous materials facilities are often more than willing to welcome hazmat response personnel into their facilities, as it benefits both emergency response and facility personnel.
Hazmat pre-planning efforts not only allow response personnel to familiarize themselves with the facility itself and the hazardous materials therein, but also allow the emergency responders and facility personnel to become acquainted with one another and each other’s response capabilities, equipment and response methodologies. As we oftentimes state, the time and place to get to know one another is not on the incident scene. Although pre-planning activities place an added load on our already full “plates,” the time spent on those activities pays off huge dividends when an incident actually occurs. A pre-plan visit can also be an opportune time to inquire about the existence and content of an Emergency Response Plan (ERP) as required by OSHA in 29 CFR 1910.120 (the HAZWOPER Standard). The ERP is required by OSHA to contain information on pre-emergency planning and coordination with outside parties, evacuation routes and procedures; and PPE and emergency equipment utilized at the facility — just to name a few of the required items. The effective transfer of pertinent intelligence and information can also be assisted through the participation of hazmat response personnel in joint training and exercise (both table-top and full scale in nature) activities. The relationship between public and private sector personnel is only enhanced by such events, which can serve as valuable preludes to the “real thing” in terms of an incident.
Hazmat response personnel should also become familiar with and obtain intelligence from required chemical reporting data. Title III of the Superfund Amendments and Reauthorization Act (also known as the Emergency Planning and Community Right-to-Know Act [EPCRA]) requires that Tier II Chemical Reports be filed by facilities meeting certain criteria on or before the first day of March of every year. Tier II Reports reference the hazardous chemicals on site during the preceding calendar year and contain data such as facility contact information, the hazardous chemicals present at the facility, their locations, and quantities of same reported in ranges.
The normal thresholds observed for Tier II reporting are 10,000 pounds for non-extremely hazardous substances and 500 pounds for extremely hazardous substances (EHSs). Local Emergency Planning Committees (LEPCs), however, can choose to adopt more stringent thresholds. As a case in point, the Wake County, North Carolina LEPC has set Tier II reporting thresholds at 55 gallons/500 pounds or the Threshold Planning Quantity of an extremely hazardous substance (the lesser of the three). In North Carolina, Tier II Reports are filed using the E-Plan online filing system and are automatically disseminated to state and local emergency management agencies, and the local fire department having jurisdiction.
Section 303 of EPCRA requires that facilities possessing quantities of extremely hazardous substances (EHSs) more than their Threshold Planning Quantities (TPQs) provide specified information to their LEPC. Wake County, North Carolina for example requires that such facilities submit the information in the form of a Site Specific Plan (SSP) that can best be described as a more detailed and thorough Tier II Report. The SSP template is available online and is completed by the facility and the information is then disseminated to the appropriate emergency response agencies. Such SSPs can be a valuable asset in pre-planning efforts as they provide a detailed look into the facility, the chemicals present and the response procedures utilized by facility personnel and responding agencies.
Let us now turn our discussion from intelligence gathering efforts conducted prior to the occurrence of an incident to those utilized once we respond to the scene of a hazmat incident.
As we should have become familiar with key facility personnel during our pre-planning activities, we should know who the best facility contact is to obtain accurate information from regarding the nature and extent of the incident. There may even be certain personnel that serve as the best source of information for certain areas of or process lines at the facility. Knowing the appropriate contact or contacts helps us to reduce the likelihood of having to progress through multiple personnel to find the most accurate and pertinent information. While many hazmat response personnel prefer to speak to chemical engineers or management personnel at a fixed facility to gather intelligence, responders should not discount the institutional knowledge of process operators and other similar personnel with many years of experience working with specific processes and chemicals. Such personnel can oftentimes quickly tell you in no uncertain terms what the hazards and idiosyncrasies of specific chemicals they work with are.
As gatherers of intelligence at hazmat incidents, hazmat response personnel should also strive to develop a group of personnel that can competently utilize research sources to verify the intelligence gathered at the incident scene. This Research Group as it is termed in Incident Command System (ICS) parlance should be allowed to work in an unobstructed and uninterrupted manner to determine exactly what hazardous materials the hazmat team is dealing with and the hazards therein so that responders can “trust but verify” the intelligence being gathered from facility personnel, chemical reporting and other resources. The Research Group can be one of the busiest entities on scene in the initial stages of a hazmat incident, and I have always said that one of the best items ever placed on a hazmat unit is the lock on the door of the research area, as it allows the Research Group to perform their work in an unimpeded manner on the incident scene.
As we have discussed above, the gathering of intelligence prior to and during a hazmat incident often sets the tone of the success of our actions on scene. Intelligence gathering can be thought of as solving the puzzle of what product or products we are dealing with, their hazards and situationally specific details of the incident itself. The greater the quantity and accuracy of the intelligence and information we gather, the safer and more effective our on-scene actions will be. As always, stay safe out there and be sure to visit the North Carolina Association of Hazardous Materials Responders website at www.nchazmat.com.
Glenn Clapp is a past president of the North Carolina Association of Hazardous Materials Responders and has over 24 years of fire service and emergency management experience. He is currently an Improvement Specialist with the Industry Expansion Solutions Division of North Carolina State University and is a volunteer firefighter with the Fairview Fire Department. He is also a Technician-Level Hazmat Instructor, an Executive Fire Officer, a Certified Hazardous Materials Manager and a Certified Fire Protection Specialist.
